Privacy Policy

1. Introduction

SMETSOMAPP LTD ("we", "us", "our", or the "Company") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website, use our mobile applications, or interact with our services.

This policy applies to all information collected through our website, mobile applications developed or acquired by SMETSOMAPP LTD, and any related services, sales, marketing, or events (collectively, the "Services").

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use our Services.

2. Information We Collect

2.1 Personal Data You Provide to Us

We may collect personal data that you voluntarily provide when you:

• Contact us via email, contact forms, or other communication channels
• Submit an inquiry about our services or app acquisition process
• Register for an account in any of our mobile applications
• Subscribe to our newsletter or marketing communications
• Submit an application to sell your mobile application to us
• Enter into a business relationship or contract with us

This data may include:

• Name and surname
• Email address
• Phone number
• Company name and job title
• Postal address
• Payment and billing information
• Any other information you choose to provide

2.2 Information Collected Automatically

When you access our website or use our mobile applications, we may automatically collect certain information, including:

• Device Information: device type, operating system, unique device identifiers, browser type and version, screen resolution, and language preferences
• Usage Data: pages visited, time spent on pages, click patterns, features used within our applications, and navigation paths
• Log Data: IP address, access times, referring URLs, and system activity logs
• Location Data: approximate geographic location based on IP address (we do not collect precise GPS location without your explicit consent)

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Analytics providers (such as Google Analytics)
• Advertising networks
• App store platforms (Apple App Store, Google Play Store)
• Business partners and service providers

3. How We Use Your Information

We use the personal data we collect for the following purposes:

• To provide and maintain our Services: including operating our website and mobile applications, processing transactions, and delivering requested services
• To communicate with you: responding to your inquiries, sending service-related notifications, and providing customer support
• To improve our Services: analysing usage patterns and trends to enhance functionality, user experience, and performance of our applications
• To process app acquisition inquiries: evaluating submitted applications and conducting due diligence as part of our acquisition process
• To send marketing communications: with your consent, sending promotional materials, newsletters, and information about new services or features
• To comply with legal obligations: fulfilling our regulatory requirements, enforcing our terms and conditions, and protecting our legal rights
• To ensure security: detecting, preventing, and addressing technical issues, fraud, and other harmful activities

4. Legal Basis for Processing (UK GDPR)

Under the UK General Data Protection Regulation (UK GDPR), we process your personal data based on the following lawful grounds:

• Consent: where you have given us explicit consent to process your personal data for a specific purpose (e.g., receiving marketing emails)
• Performance of a Contract: where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract
• Legitimate Interests: where processing is necessary for our legitimate business interests, provided these are not overridden by your rights and freedoms (e.g., improving our services, business analytics)
• Legal Obligation: where processing is necessary for compliance with a legal obligation to which we are subject

5. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our website and store certain information. These technologies may include:

• Essential Cookies: necessary for the website to function properly and cannot be switched off
• Analytics Cookies: help us understand how visitors interact with our website by collecting and reporting information anonymously
• Functional Cookies: enable enhanced functionality and personalisation, such as remembering your preferences
• Marketing Cookies: used to deliver advertisements relevant to your interests and to measure the effectiveness of advertising campaigns

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

6. Data Sharing and Disclosure

We do not sell your personal data to third parties. We may share your information in the following circumstances:

• Service Providers: we may share your data with trusted third-party companies that perform services on our behalf, such as hosting, analytics, payment processing, email delivery, and customer support. These providers are contractually obligated to protect your data and use it only as directed by us.
• Business Transfers: in the event of a merger, acquisition, reorganisation, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you before your data is transferred and becomes subject to a different privacy policy.
• Legal Requirements: we may disclose your information if required to do so by law, or in response to valid requests by public authorities (e.g., a court order or government agency).
• Protection of Rights: we may disclose information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, or situations involving potential threats to the safety of any person.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the United Kingdom. In such cases, we will ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection legislation, including:

• Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO)
• Transfers to countries deemed to have adequate data protection by the UK government
• Other legally recognised transfer mechanisms

8. Data Retention

We retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide Services to you
• Whether there is a legal obligation to which we are subject (e.g., certain laws require us to keep records of transactions for a specific period)
• Whether retention is advisable in light of our legal position (e.g., regarding applicable statutes of limitations, litigation, or regulatory investigations)

When we no longer need your personal data, we will securely delete or anonymise it.

9. Your Rights

Under the UK GDPR, you have the following rights regarding your personal data:

• Right of Access: you have the right to request a copy of the personal data we hold about you
• Right to Rectification: you have the right to request correction of any inaccurate or incomplete personal data
• Right to Erasure: you have the right to request deletion of your personal data in certain circumstances (also known as the "right to be forgotten")
• Right to Restriction of Processing: you have the right to request that we restrict the processing of your personal data in certain circumstances
• Right to Data Portability: you have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller
• Right to Object: you have the right to object to the processing of your personal data where we are relying on legitimate interests as the legal basis
• Right to Withdraw Consent: where we rely on your consent to process personal data, you have the right to withdraw that consent at any time
• Right Not to be Subject to Automated Decision-Making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you

To exercise any of these rights, please contact us at support@smetsomapp.com. We will respond to your request within one month.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and vulnerability testing
• Access controls and authentication mechanisms
• Employee training on data protection and security practices
• Incident response procedures

While we strive to protect your personal data, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.

11. Children's Privacy

Our Services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to delete that information promptly. If you believe that we may have collected information from a child under 16, please contact us at support@smetsomapp.com.

12. Third-Party Links

Our website and applications may contain links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

14. Complaints

If you have any concerns about our use of your personal data, you have the right to lodge a complaint with the UK's supervisory authority:

We would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us first.

15. Contact Us

If you have any questions about this Privacy Policy, or if you wish to exercise any of your rights, please contact us: