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Smilur Privacy Policies


As the processor of your data, Smilur, Inc. hereinafter referred to as Smilur complies with Data Protection laws in the United States and the EU General Data Protection Regulation (GDPR). This Privacy Policy details how Smilur processes your personal data.
 

The personal data we collect about you


Personal data collected, used, stored and transferred by us may include:
 

  • Identity Data including first name, last name
     

  • Contact Data including home address, email address and telephone numbers
     

  • Financial Data is never stored by Smilur and is always processed through third parties: Stripe, and Quickbooks Online.
     

  • Location Data including details of interaction, meetings
     

  • Transaction Data including payments made for products and services you have purchased from us, minutes of meetings
     

  • Photographic Data including CCTV and images captured from our photo technologies
     

  • Technical Data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access the Smilur website. Information accessed via VNC/SSH during support sessions
     

  • Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services
     

  • Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences
     

How do we collect your personal data?


Personal data is collected by us using the following methods:
 

  • Direct interactions with employees and/or authorized representatives of Smilur, by mail, phone, email, social media or otherwise when inquiring about a product or service offered by Smilur.
     

  • Automated technologies or interactions with our website, by using the web inquiry form or any other automated means.
     

  • Third parties or publicly available sources such as: Social Media, Blogs, Internet Searches, Online Advertising, CRM Systems, Suppliers and support ticket platforms.
     

How do we use your personal data?


We use your personal data in the following circumstances and relying on the following lawful basis for processing:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Change of Purpose


We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. Please contact us for an explanation as to how any new processing compatible with the original purpose.
 

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
 

Changes to our Privacy Notice


We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on October, 29th 2018.
 

Marketing Communications


You will have the choice to opt-in to receiving other related marketing information and related products and services.
 

You can opt-out of receiving these types of communications at any time by contacting our Compliance team at info@smilur.com or by clicking on the relevant link in email communications you receive from us.
 

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We also limit access to your personal data to only those Smilur staff, appointed representatives, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
 

Cookies

When using Smilur websites, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
 

Cookies Policy

Smilur, Inc (“us”, “we”, or “our”) uses cookies on the https://www.smilur.com, and https://app.smilur.com websites (the “Services”). By using the Services, you consent to the use of cookies.

 

What are cookies?


Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Services or a third-party to recognize you and make your next visit easier and the Services more useful to you.
 

Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
 

How Smilur Inc. uses cookies


When you use and access the Services, we may place a number of cookies files in your web browser.


We use cookies for the following purposes:
 

  • To enable certain functions of the Services
     

  • To provide analytics
     

We use both session and persistent cookies on the Services and we use different types of cookies to run the Services:
 

  • Essential cookies. We may use cookies to remember information that changes the way the Services behave or look, such as a user’s language preference on the Services.
     

  • Analytics cookies. We may use analytics cookies to track information how the Services are used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Services to see how our users react to them.
     

Third-Party Cookies


In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Services, deliver advertisements on and through the Services, and so on.
 

What are your choices regarding cookies


If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
 

Where can you find more information about cookies

You can learn more about cookies and the following third-party websites:
 

Website Third-Party Links


Smilur’s websites may include 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
 

Who we disclose personal data to?


Your personal data may be shared with third parties for the following purposes:


External Suppliers & Contractors - Specialist IT system providers to facilitate the customer relationship management, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal; information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Smilur.
 

Outsourced Support Provider - In order to provide out of hours technical support services in relation to our products and services we use third party suppliers and your data may be transferred to them for this purpose.
 

Regulators - Sharing information may be necessary to fulfill our legal obligations as a regulated profession and otherwise cooperate with law enforcement, legal proceedings and regulatory authorities.
 

Others - Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
 

How long is your personal data retained?

 

We only retain your personal data for as long as necessary. The table below outlines how long data is retained, and depends on the reason the personal data is used for:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


Any categories of personal data not referenced specifically above, will be retained for as long as necessary taking into account the lawful basis for collecting the personal data initially, any ongoing obligations imposed on Smilur and the fundamental rights and freedoms of the data subject.
 

You have the right to:
 

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you.
     

  • Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
     

  • Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You
    can also to ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

     

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
     

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
     

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
     

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
     

Questions


If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact Smilur by emailing support@smilur.com or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.

 

Additional Events Specific Privacy Policy


When guests share their media from Smilur software, what data do we collect for each direct sharing option?

  • E-mail – E-mail Address and File Names
     

  • Text – Phone Number and File Names
     

  • Facebook -Username, File Names, Number of Friends, Name, Email Address, Gender, Age Range, Locale, Timezone (depending on profile settings)
     

  • Twitter – Username, Number of Followers, File Names (depending on profile settings)
     

  • Instagram – File Names, Username, Number of Followers (depending on profile settings)

     

Does Smilur collect the names of my Facebook friends or Instagram or Twitter followers?
 

No. Smilur does not collect the names or data of your Facebook friends or Instagram or Twitter Followers.
 

What other data does Smilur Collect or Retain?
 

Some events include surveys of guests. For these events, the survey data will be collected, stored, and shared in accordance with other guest data from that event.


How is this data used?
 

  • This data is accessed by our technical support team to help provide support.
     

  • The data may be sent to the event coordinator or sponsors in individual or aggregate form.
     

  • The data is aggregated for statistical reporting purposes.
     


What 3rd party services we use and what data they have access to.

Texts are sent through Twilio:

 

    Twilio Privacy Policy: https://www.twilio.com/legal/privacy
 

E-mails are sent through AWS:


    AWS Privacy Policy: https://aws.amazon.com/privacy/
 

Unique URL data and media are stored and hosted on Amazon Web Services:
 

    AWS Privacy Policy: https://aws.amazon.com/privacy/
 

Photos are stored on Cloudinary's servers:


    Cloudinary Privacy Policy: https://cloudinary.com/privacy

 

Do we share this data with 3rd parties:
 

  • The data from each event is available to the event coordinator for that individual event.
     

  • The data from each event may be made available to sponsors of the event.
     

  • Anonymous aggregate data may be shared publicly or with any 3rd party.
     

  • Smilur will not use any data collected from event guests for any direct marketing purposes.
     

  • Smilur will not sell any data collected from event guests to anyone other than the above mentioned parties.

     

Where are guests photos stored?
 

  • Photos are stored and saved to a local hard drive when they are originally taken. They are deleted from this local storage within 1 week of the end of the event.
     

  • Photos are saved to an online server hosted by Cloudinary and uploaded to AWS cloud storage.  The photos will be shared with the event guests and also shared with the event coordinator and sometimes event sponsors, unless otherwise specified.
     

  • Photos for Unique URLs are stored on our Amazon Web Services indefinitely.

     

Can I limit storage and data collection or sharing?
 

The event coordinator can decide to limit data collection and storage for a particular event.
 

Can I find out what data Smilur has stored on me?
 

You can request data Smilur might have pertaining to you. Email support@smilur.com.
 

Can I delete data that Smilur has stored on me?
 

You can anonymize data that Smilur has stored pertaining to you. Email support@smilur.com.
 

Smilur archives all photos from Smilur events using Cloudinary and AWS – Clients can request their photos to be removed or password protected at any time.


Smilur reserves the right to use images (including but not limited to photos, GIFs and/or videos) from events for display, advertising, Smilur’s website and social media platforms, third party websites, magazine submissions and any other means of online or print marketing and promotion of Smilur’s business.  In connection with the marketing and promotion of the images, Smilur may place its logo and/or trademarks on the images. Clients can request that media from their event not be used by Smilur for marketing purposes.  Please submit your request in writing to support@smilur.com.

 

Additional Software Specific Privacy Policy


What personal information does Smilur collect when I book Services?
 

Name, Address, E-mail Address


What is this information used for?
 

Name and Address are used for billing. E-mail Address is used to send information about service updates and new products.
 

Stripe and Quickbooks are our billing processors.
 

Can I unsubscribe from these E-mails?
 

Yes. By clicking the unsubscribe link in the e-mails.


What personal information from the guests at my event is available to Smilur? How is this information used?
 

Smilur has access to the same sharing data available to you. This can include:
 

For each direct sharing option:

  • E-mail – E-mail Address and File Names
     

  • Text – Phone Number and File Names
     

  • Facebook -Username, File Names, Number of Friends, Name, Email Address, Gender, Age Range, Locale, Timezone
     

  • Twitter – Username, Number of Followers, File Names
     

  • Instagram – File Names, Username, Number of Followers

     

The collected data is used to deliver media to end users the aggregate data is used for statistical purposes.
 


 

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