SMT Privacy Policy & Compliance

Last Modified: December 19, 2019

At SmartMedia Technologies, Inc. (‘SMT’) we take consumer privacy seriously. This Privacy Policy describes how we collect and use information, and explains how you can protect your privacy.

We specialize in creating personalized advertisements. We work with online partners to build advertisements for users who visit their website or mobile applications and with publishers to display personalized advertisements. Providing an overall better web experience for users, so that they are only seeing ads that interest them.

This Privacy Policy explains:

Information we collect

We collect information in order to provide better and more relevant advertising to consumers. We may collect this information in the following ways:

Information you give us. 

For example, from time to time we offer brand recognition surveys on behalf of advertisers. If you participate in these surveys, we will have access to your survey responses. We do not collect personal information through these surveys.

Personal information is information about a person whose identity can reasonably be determined from the information. Examples are a person's name, telephone number, or e-mail address.

Information we get from your use of our services. 

We may collect information about the services that you use and how you use them, like when you visit a website that uses our advertising services or you view and interact with our ads and content. This information includes:

Cookies

We may send cookies to your browser in order to support behavioral targeted advertising. Through it, we may collect data about websites visited, content viewed, searches on other websites, ad interaction, interaction with advertiser websites and other click and browsing behavior. None of our cookies contain personal information and we do not collect personal information with these cookies.

Advertising identifiers

To support behavioral targeted advertising on devices where cookies are not available (such as some mobile phone and smart televisions), we may use identifiers such as Apple's Identifier for Advertising (IDFA) and Google's Advertising ID. These advertising identifiers do not constitute personal information.

Browser information

To support behavioral targeting advertising in situations where cookies are unreliable, we may collect information to identify your web browser. We may collect:

a portion of the IP address,
certain HTTP header fields,
cached anonymous identifiers and/or
browser characteristics measurable through JavaScript.

The information collected may vary based on where you are physically located in order to comply with local law. The browser information does not constitute personal information.

Mobile App Data 

To support behavioral advertising, we may collect data from mobile apps, such as the content of the apps and event information shared by the apps.

Contextual Data 

To support contextual advertising, we may collect data about web pages, including page content and page URLs.

IP addresses 

To support targeted advertising campaigns, outside the EU, we may collect your IP address. We also store IP addresses in server logs for anti-fraud and security reasons.

Tracking Pixels

To determine whether you have opened or clicked on an advertisement, we include a unique identifier in our marketing e-mails called a web beacon or pixel.

Hashed email addresses 

If an Advertiser allows, we may collect hashed versions of the emails that are entered on that Advertiser’s site. These hashed emails are used as an additional identifier to help us better target ads for Advertisers, including across multiple devices or browsers.

Information we get from third parties

We may collect personal information and non-personal information about you from third parties. This information may include name, address, e-mail address, IP address, categorical attributes and demographic information. This information may be licensed or purchased and the use of the information complies with the privacy policy pursuant to which the data was originally collected, as well as local law.

We may also show ads based on the content of the webpage you are visiting, if the publisher of that webpage has provided it to us for contextual analysis.

How we use information we collect

We use the information we collect to serve advertisements to you and to target and analyze consumer behavior. Our goals are to provide better and more relevant advertising to you and provide useful aggregated analytics to our customers.

While we target advertising for common everyday health topics such as colds, coughs and heartburn, we do not collect or use information about past, present or potential future medical conditions or treatments or sex life.

We do not create, collect or use data in order to specifically target children aged 12 or under. Nor do we collect behavioral data when we run advertising on websites or online services where we have actual knowledge that the websites or online services are directed towards children aged 12 or under.

We do not combine personal information with online behavioral information. We sometimes support our online behavioral advertising with demographic, categorical or performance information (such as the types of e-mails that users have opened or clicked on in the past) extracted from our e-mail lists, however we always first remove or anonymize all personal information.

We retain information that is collected and used for online behavioral advertising only as long as necessary to fulfill a legitimate business need, or as required by law.

Transparency and choice

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:

OPT OUT of our web-based online behavioral advertising by clicking on the button below:

OPT IN to our web-based online behavioral advertising by clicking on the button below:

You can opt out of our in-app mobile online behavioral advertising by changing the settings on your mobile device. On Apple devices, the setting may be under Settings-Privacy-Advertising-Limit Ad Tracking. On Android devices, the setting may be under Settings-Account & Sync-Google-Ads-Opt Out of Interest-Based Ads.

All of these are separate. We do not have personal information in our cookies, for example, so you cannot opt out of online behavioral advertising by e-mailing us. Similarly, the big red button requires cookies to work (it sets an "opt-out" cookie), and since cookies do not work in mobile apps, it will not opt you out of in-app online behavioral advertising. If you set your browser to block our cookies, or if your browser does not support our cookies, the big red button will not work and you may still receive online behavioral advertising.You will still receive online ads even if you opt out of online behavioral advertising (with the big red button or through your mobile device settings); however, the ads will be less relevant to you.

Advertisers and third-party ad networks may also participate in our ad network and may also utilize cookies to deliver advertisements and monitor the performance of such advertisements. Many third-party ad networks have agreed to provide an "opt out" mechanism for their ad cookies. The collection of information through cookies by such third parties will be governed by their own privacy policies and practices, over which SMT has no control.

Some web browsers include a "Do Not Track" request in the HTTP header. At this time, we do not alter our behavior or change our web services upon receiving a "Do Not Track" request.

How we share information

We do not share personal information with companies, organizations and individuals outside of SMT unless one of the following circumstances applies:

For legal reasons. 

We will share personal information with companies, organizations or individuals outside of SMT if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

·      meet any applicable law, regulation, legal process or enforceable governmental request;
·      detect, prevent, or otherwise address fraud, security or technical issues; or
·      protect against harm to the rights, reputation, property or safety of SMT, our clients, our consumers or the public as required or permitted by law.

In connection with a merger or sale. 

If we enter into discussions to sell, merge or otherwise reorganize our business, we reserve the right to transfer and disclose all data (including personal and non-personal user information) to prospective and/or actual purchasers or investors. We will require that such purchasers/investors treat the transferred data as described in the Privacy Policy that exists prior to the change unless and until you consent to a new Privacy Policy.

We may share non-personal information (in aggregated and/or non-aggregated form) publicly and/or with our partners, like publishers, advertisers or connected sites. For example, we may share information about campaign performance with advertisers.

Information security

We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. Please be advised that, although we take reasonable technological precautions to protect your data, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, we cannot and do not warrant that your information will be absolutely secure. Any transmission of data at or through our website is at your own risk.

CCPA Compliance

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this section.

Our service collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our service has collected the following categories of personal information from its consumers within the last twelve (12) months: 

Category

Examples

Collected

A. Identifiers

A unique personal identifier, online identifier, Internet Protocol address, email address or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, telephone number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

NO

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial Information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifiers or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronics, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behaviors, attitudes, intelligence, abilities, and aptitudes.

NO



Personal information does not include:


Publicly available information from government records.
De-identified or aggregated consumer information.
Information excluded from the CCPA's scope.

We obtain the categories of personal information listed above from the following categories of sources:


Directly from you. For example, from forms you complete or products and services you use.
Indirectly from you. For example, from observing your interactions with our service as well as on websites where we have our tracking pixels.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. 

To provide, support, personalize, and develop our, products, services and our clients’ advertising efforts.To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To personalize your experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our service , third-party sites, and via email or text message (with your consent, where required by law).

To help maintain the safety, security, and integrity of our, products and services, databases and other technology assets, and business.For testing, research, analysis, and product development, including to develop and improve our, products and services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.As described to you when collecting your personal information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our users is among the assets transferred.


We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties: service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose: 

Category A: Identifiers.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties: service providers.

Your Rights and Choices The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.Access to Specific Information and Data Portability RightsYou have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

The categories of personal information we collected about you.The categories of sources for the personal information we collected about you.Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and 
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.


Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.


Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Visiting smartmediatech.io/privacypolicy.
Sending an email to privacy@smartmediatech.io.


Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. We cooperate with our service providers and clients in responding to your consumer requests and in confirming your identity. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Changes

We reserve the right to change our Privacy Policy at any time without notice. However, these changes will not reduce your privacy on a retrospective basis. We will post any Privacy Policy changes on this page and it is your responsibility to check this page for updates.

Contact

If you have questions or complaints relating to this Privacy Policy, please contact us at privacy@smartmediatech.IO.