Privacy Policy

1. Information you provide to us through the services

1. We collect and process information you provide directly to us via the Services. Personal data submitted through the Services include the details you submit when you create an account, participate in any interactive features of the Services, fill out a form, pay for subscriptions, apply for a job, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include your name, email address, company name, postal address, phone number and any other information you choose to provide. To the extent you provide credit card information through the Services, that information is collected and processed by our third-party payment processor pursuant to their Privacy Policy and practices.

2. Information we collect automatically when you use the services

When you access or use the Services we automatically collect information about you, including: Log Files: We gather certain information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to the Services, and store it in log files. We do not monitor or log data collected from your servers when using the Services, but we may log or monitor information about your access to our Services. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons.

3. Information we collect from other sources

We may also obtain information from other sources and combine that with information we collect through our Services for purposes of advertising and user authentication. For example, if you create or log into your SmileSIM account using your Google Apps credentials via single sign-on, we will have access to certain information such as your name and email address as authorized in your Google Apps profile settings.

4. Use of information

1. Enable you to have full access to the Services;
2. Provide, maintain and improve the Services;
3. Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices,;
4. Send you technical notices, updates, security alerts, and support and administrative messages;
5. Respond to your comments, questions and requests, and provide customer support;
6. Create your SmileSIM account and identify you when you sign-in to your account in accordance with your agreement with us;
7. Communicate with you about products, services, offers, promotions, rewards, and events offered by SmileSIM and others, and provide news and information we think will be of interest to you;
8. Monitor and analyze trends, usage and activities in connection with the Services;
9. Detect, investigate and prevent fraud and other illegal activities and protect the rights and property of SmileSIM and others;
10. Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
11. Notify you about important changes to the Services, including changes or updates to this Privacy Policy;
12. Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
13. Link or combine with information we get from others to help understand your needs and provide you with better service;
14. Consider you for possible employment at SmileSIM in connection with an application that you submit; and
15. Carry out any other purpose described to you at the time the information was collected.

5. Sharing of information

1. With vendors, consultants and other service providers we have vetted and approved who need access to such information to carry out work on our behalf only to the extent necessary for the performance of any contract we enter into with you. This includes companies providing the following services for our Website and/or Platform: hosting services, authentication services, cyber security and anti-fraud services, and advertising;
2. In response to a request for information if we believe disclosure is permitted by, in accordance with, or required by, any applicable law, regulation or legal process such as to comply with a subpoena or applicable court order;
3. With any person to whom disclosure is necessary to enable us to enforce our rights under this Privacy Policy or under any agreement we enter into with you or to protect the rights, property and safety of SmileSIM or third parties;
4. In connection with, or during negotiations of, any merger, sale of SmileSIM assets, financing or acquisition of all or a portion of our business by another company;
5. Between and among SmileSIM and all companies affiliated with SmileSIM who may act for us for any of the purposes set out in this Privacy Policy, including our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;
6. with analytics and search engine providers that assist us in the improvement and optimization of our Website, subject to our Cookies Policy; and
7. With your consent or at your direction.
8. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

6. Lawful basis for processing your information

1. We are required to state the lawful basis under which we process the personal data of our users from the European Union. Accordingly, the lawful bases upon which we process your personal information are as follows:
2. Where it is necessary to obtain your prior consent to the processing concerned in order for us to be allowed to do it, for instance in relation to direct marketing, we will obtain and rely on your consent in relation to the processing concerned.
3. Otherwise, we will process your personal data only where the processing is necessary for compliance with a legal obligation to which we are a subject; or
4. For the purposes of the legitimate interests pursued by us in promoting our business, providing the Platform to our business customers pursuant to or legal agreements with them, and in ensuring the security, accessibility and improvement of our Website and Platform and the development of new technology and services.

7. Your Rights according to GDPR

1. Right to access data. You have the right to gain access to the data about you that we process or control or to copies thereof; you also have the right to obtain from us information about the nature, processing and disclosure of this data.
2. Right to rectification . You have the right to obtain rectification of inaccuracies in the data about you.
3. Right to be forgotten/Right to erasure. You have the right to obtain from us the deletion of data about you.
4. Right to restrict processing. You have the right to restrict the processing of data about you.
5. Right to object. You have the right to object to the processing of data concerning you by us or on our behalf.
6. Right to data portability.You have the right to obtain the transfer to another operator of the data concerning you that we process or control.
7. Right to withdraw consent. In situations where we process data about you on the basis of your consent, you have the right to withdraw your consent; you can do this at any time, at least as easily as you initially gave us your consent; the withdrawal of consent will not affect the lawfulness of the processing of data concerning you that we have carried out before the withdrawal.
8. Right to submit a complaint to the supervisory authority. You have the right to submit a complaint to the personal data processing supervisory authority regarding the processing of your data by us or on our behalf. In Romania, this authority is the National Authority for the Supervision of Personal Data Processing (ANSPDCP).

8. External links

The Website may, from time to time, contain links to external sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. We are not responsible for the privacy policies or the content of such sites.

9. Social sharing features

The Website may offer social sharing features and other integrated tools (such as the Twitter logo (Larry the Bird)), which lets you share information you find on our website with other media, and vice versa. The Twitter plugin is identifiable by the Twitter (Larry the Bird) logo on our Website. When you visit one of our pages the plugin establishes a direct connection between your browser and the Twitter server. Thus, Twitter receives information from your browser as set out in Twitter’s privacy policy (see below). Please note that we, as provider of the pages, have no knowledge as to the contents of the submitted data or its use by Twitter. For further information please see Twitter’s privacy policy at https://twitter.com/en/privacy#update. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

10. Log-in features

We may allow you to sign up and log in using your Google account. If you sign up using your Google email account, Google will ask your permission to share certain information from your Google account with us. This may include your first name, last name, gender, general location, your timezone and birthday. This information is collected by Google and is provided to us under the terms of Google’s privacy policy which you can find here: https://www.google.co.uk/intl/en/policies/privacy/. You can control the information that we receive from Google using the privacy settings in your Google account.

11. Advertising and analytics services provided by others

We allow the following companies to serve advertisements on our behalf across the Internet and in applications: Google AdWords, Google analytics, Marketo, Twitter, Facebook, Adroll, Quora, Bing ads, Linkedin, Terminus, Demand base, Instagram, and Reddit using email address and cookies that are collected. These entities use technologies including cookies, web beacons, device identifiers and other tools to collect information about your use of the Services and other websites and applications, including your IP address, web browser, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by SmileSIM and SmileSIM service providers to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.

12. Marketing

1. Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing and to provide you with promotional update communications by email about our products/services. You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional electronic communications to you, or by contacting us using the contact details set out at in the Contact section of this Privacy Policy.
2. As part of the registration process for events hosted by SmileSIM which you register to attend, we may request personal data such as: your name, address, email address and telephone number, and details relevant to your occupation or employer. This information is required to process your registration for the event and to provide you with relevant event materials. This data may be shared with third party service providers engaged by us as more fully explained in the Sharing of Information section of this Privacy Policy. If you show an interest in an exhibitor at an event hosted by SmileSIM, such as by consenting to have your attendee badge scanned, we will provide your data to such exhibitors who may contact you for their own direct advertising and marketing purposes. In that case, the exhibitors’ use of your information would be subject the exhibitors’ privacy policies. For events sponsored by SmileSIM, the event host may provide your personal data to SmileSIM, subject to your consent. SmileSIM will use the data as set forth in the Use of Information section of this Privacy Policy.

13. Security

1. We take reasonable steps, including physical, technical and organisational measures, to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information submitted to us.
2. Your personal information will be retained by SmileSIM for the duration of your account and may be retained for a period after this time as necessary and relevant to our legitimate interests, our terms of agreement with you and in accordance with applicable legal obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of agreement or to identify, issue or resolve legal proceedings.
3. We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.

14. Contact

Please contact SmileSIM at contact@smilesim.com with any questions regarding this Privacy Policy.