The present legal notices are intended to define the terms and conditions of use of the Smart Global Privacy Solutions website and to define the role and obligations of each user.
I. PERSONAL DATA
You can visit the Smart Global Privacy Solutions website without revealing any personal information. You are not obligated to send this information to Smart Global Privacy Solutions.
However, in case of refusal, you may not benefit from certain information or services that you wish to access, or these could be degraded. Therefore, Smart Global Privacy Solutions will propose the collection of certain information (hereinafter your “Personal Information”) to respond to your requests. By providing this information, you expressly agree that it be processed by Smart Global Privacy Solutions, for the purposes indicated in point 2 below and for the purposes stated at the end of each form found on the website.
In accordance with the General Data Protection Regulation adopted by the European Parliament on April 14th, 2016 and law 1,165 on ‘computing and freedom’ voted in Monaco, Smart Global Privacy Solutions informs you of the following points:
• 1. Identity of the Controller
The Controller is Smart Global Privacy Solutions, headquartered at 1 rue du Gabian 98000 MONACO and registered under the number 17S07390 in the directory of trade and industry of Monaco.
• 2. Purpose of data processing
Smart Global Privacy Solutions may process your Personal Information:
– for the purpose of giving you access to the information or services you have requested;
– for the purpose of collecting information that could enable us to improve our Site, our products and services (in particular by means of cookies); and/or
– for the purpose of contacting you regarding various events related to Smart Global Privacy Solutions, either through our forms or through our online chat facility.
• 3. Recipients
Only Smart Global Privacy Solutions is the recipient of your Personal Information. This Personal Information, whether in individual or aggregated form, is never transmitted to a third party, with the exception of the processors to whom Smart Global Privacy Solutions can contact (you will find more information about them in section 7 below). Neither Smart Global Privacy Solutions, nor any of its processors, sells the personal data of visitors and users of its site.
• 4. Storage period
Your Personal Information is stored by Smart Global Privacy Solutions only for the time corresponding to the purpose of the collection, as indicated in section 2 above, which can not in any case exceed 18 months. This maximum shelf life is indicated at each moment that we collect data on our site and is specified in a clear and explicit way.
• 5. Privacy rights
Regarding your Personal Information, you have the following rights, which you can exercise by writing to us at the postal address mentioned in section 1 or by contacting us via our contact form.
Management of requests for access to personal data, requests of right to erasure, to rectification, to portability of personal data, as well as requests for restriction and objection to the processing of personal data;
You have the right of access to the Personal Information that concerns you. However, because of the obligation of security and privacy in the processing of personal data by Smart Global Privacy Solutions, you are informed that your request will be processed provided that you supply proof of your identity.
Smart Global Privacy Solutions informs that it will be entitled, if necessary, to oppose manifestly unfair requests (by their number, their repetitive or systematic nature).
Also, you can set general and specific guidelines regarding the fate of personal data after your death. In this case, the heirs of a deceased person may request to consider the death of their relative and / or to make the necessary updates.
• 6. Response time
Smart Global Privacy Solutions undertakes to respond to your request for access, rectification or objection or any other additional request for information within a period that should not exceed 1 month from the date of receipt of your request.
• 7. EuropéenneAuthorised service providers and transfer to a country within or outside of the European Union
Smart Global Privacy Solutions informs you that it uses authorised service providers to facilitate the collection and processing of the data that you have communicated to us. These providers could be located outside the European Union even if Smart Global Privacy Solutions carries out regular checks and strives to work only with processors located only within the European Union. Smart Global Privacy Solutions has previously ensured the implementation by its providers of adequate safeguards and compliance with strict conditions of confidentiality, use and protection of data. Vigilance was focused on the existence of a legal basis for any data transfer to a country outside the EU, should such a transfer be made.
Processors concerned :
- Microsoft Azure (FR): for site hosting and data management
- GoogleAdwords(USA): for marketing campaign management
• 8. Complaints to the supervisory authority
If you consider that Smart Global Privacy Solutions does not comply with its obligations regarding your Personal Information, you will be entitled to make a complaint or request to the supervisory authority of your jurisdiction or country.
II. POLICY ON COOKIES
When you first log in to the Smart Global Privacy Solutions website, you are informed that information about your browsing could be stored in files called “cookies”.
• 1. General information about cookies on the Smart Global Privacy Solutions website
Smart Global Privacy Solutions, as publisher of this website, will be able to implement a cookie on the hard drive of your terminal (computer, tablet, mobile etc.) to ensure smooth and optimal navigation. “Cookies” are small text files of limited size that recognise your computer, tablet or mobile to customise the services we offer.
The information collected through cookies does not allow you to be identified by name. It is used solely to improve the interactivity and performance of our website and to offer content tailored to your interests.
This information is not disclosed to third parties, except when Smart Global Privacy Solutions has obtained your consent in advance or when the law requires the sending of such information, by order of a court or any administrative or judicial authority.
To better inform you about the information that cookies identify, you will find below a table listing the different types of cookies that may be used on the website of Smart Global Privacy, their names, purposes and their retention period.
• 2. Configure your cookie preferences
You can accept or refuse the deposit of cookies at any time.When you first log in to the Smart Global Privacy website, a banner briefly outlining information about cookies and similar technologies will appear on your screen.
This banner informs you that by continuing your navigation on the website of Smart Global Privacy Solutions (by loading a new page or by clicking on various elements of the site for example), you accept the deposit of cookies on your terminal. You are also deemed to have consented to the deposit of cookies by clicking on the “X” icon to the right of the banner on your screen.
Depending on the type of cookie involved, collecting your consent to deposit and read cookies on your device may be imperative.
Cookies consent exemption
In accordance with the recommendations of the control authorities of the European Union, some cookies are exempt from obtaining prior consent. They are exempt in those cases where they are strictly necessary for the proper functioning of the website or when they have the ultimate objective of enabling or facilitating electronic communication. These include cookies for session ID, authentication, load balancing session cookies as well as cookies for customising your interface. These cookies are fully subject to this policy insofar as they are issued and managed by Smart Global Privacy.
Cookies requiring the prior collection of your consent
This requirement applies to third-party cookies that are described as “persistent” because they remain in your device until they are deleted or expire.
Because these cookies are issued by third parties, their use and deposit are subject to their own privacy policies, which you will find below. This cookie family includes audience measurement cookies (including Google Analytics), advertising cookies (which Smart Global Privacy Solutions does not use) and social sharing cookies (including YouTube, Twitter and LinkedIn).
Audience measurement cookies provide statistics on the frequency of use and the use of various elements of the website (such as the content / pages you visited). This data contributes to improving the ergonomics of the Smart Global Privacy Solutions website. An audience measurement tool is used on this website.
The social network sharing cookies are issued and managed by the social network publisher.
Subject to your consent, these cookies allow you to easily share part of the content published on the Smart Global Privacy Solutions site, especially through a “button” to share applications according to the corresponding social network.
There are four types of social media exchange cookies available on the Smart Global Privacy Solutions website :
– Twitter, which you will find the options dedicated to the control or the restriction of the use of the cookies as well as the policy of use of the cookies : https://support.twitter.com/articles/20170518#
–YouTube, which you will find help to delete cookies from the Google Chrome browser by clicking on the following link : https://support.google.com/youtube/answer/32050?hl=en and also the policy complete cookie information from the following link:https://www.google.fr/intl/en/policies/technologies/cookies/
Configuration of cookies
Most Internet browsers are configured by default to allow cookies. Your browser allows you to modify these standard configurations so that all cookies are rejected systematically or so that only part of the cookies is accepted or refused according to the issuer.
PLEASE NOTE: The rejection of the deposit of cookies in your terminal could alter your experience as a user and your access to certain services of this website. In this case, Smart Global Privacy Solutions is not responsible for the consequences related to the degradation of navigation conditions that may arise due to your choice to reject, delete or block the cookies necessary for the proper functioning of the website. These consequences could not constitute damage and there can be no claim for any compensation for this fact. Your browser also allows you to delete existing cookies on your device or notify you in the event that new cookies are deposited on your device. This configuration does not affect your browsing, but you lose all the benefit of the cookie.
Take note below of the many tools available to set cookies on your device.
Settings in your internet browser
Each Internet browser has its own cookie management settings. To know how to change your cookie preferences, below are the links you need to access the browser menu provided for this purpose:
For further information on the tools for controlling cookies, you can consult the ICO website: https://ico.org.uk/media/1545/cookies_guidance.pdf
Configuration of the cookies management tool.
The deactivation of cookies can also be made directly through the online tool configured on the Smart Global Privacy Solutions website. Interactively, it will allow you to manage your cookies through a banner available in the bottom right of the displayed page (“Service Management” button) and list all active cookies.
To deactivate a cookie, simply click on the cross next to the proposed service. If all cookies are disabled, the banner dedicated to collecting the user’s consent will reappear when the page is updated.
III. CONDITIONS AND LEGAL INFORMATION
Smart Global Privacy Solutions hereinafter “the Site” is published by SMART GLOBAL PRIVACY SARL, Limited Liability Company, with a capital of 15,000 euros, registered under No. 17S07390 in the Trade and Industry Directory since April 30, 2017 Regarding the processing of personal data, Smart Global Privacy Solutions has made a simplified declaration to the Commission for the Control of Normative Information (CCIN) under the numbers No. 2017.05065 and No. 2017.05093.
Smart Global Privacy Solutions has been granted principled government authorisation by the Minister of State on February 22, 2017.
The head office is located 1 rue du Gabian 98000 MONACO – Principality of Monaco
The director is Mr. Guignard.
Any user of the Smart Global Privacy Solutions website expressly agrees:
-not to use the Smart Global Privacy Solutions website to spread and promote computer viruses, Trojan horses or any other similar programme, to damage computer systems or to disrupt the general good functioning of sites.
-to assume any direct or indirect material or bodily harm caused and to resolve any dispute that may occur.
-to relieve Smart Global Privacy Solutions of any responsibility in this regard.
The personal data collected and processed by Smart Global Privacy Solutions is that which the USER of the Smart Global Privacy Solutions Service voluntarily transmits, including via registration or contact forms, namely:
– Technical data: type of browser, IP connection, reference and pages viewed.
– Personal data: Surname, first name, email, phone number, company name, role.
The USER of the Smart Global Privacy Solutions Service undertakes to provide accurate and up-to-date information and to promptly notify any changes to this information by e-mail to firstname.lastname@example.org , in order for all the corresponding modifications to be made.
The nominative files have been the subject of a simplified declaration to the CCIN No. 2017.05065 and No. 2017.05093 in accordance with the law relating to data and privacy.
In accordance with the aforementioned law, the user who has completed an online registration form has the right to information, to objection, and to access and rectification of data. These rights can be exercised by sending a letter to the address of the head office indicated in the heading, indicating surname, first name, date and place of birth, postal address and email.
AMENDMENT OF GENERAL CONDITIONS OF USE OF THE PLATFORM
Smart Global Privacy Solutions reserves the right to modify this legal notice. Given the possible extensions and improvements to the functioning of the site, Smart Global Privacy Solutions reserves the right to unilaterally modify the present legal notices at any time, without prior notice.
In particular, the visitor must consult and accept the legal notice of the website. Each use of the same implies the acceptance of the latest version of these legal notices.
In the event of a significant change in these legal notices, the new legal notices will become effective the day after their publication on the website of Smart Global Privacy.
The content of the site can not be modified, copied, distributed, framed or reproduced without the agreement of Smart Global Privacy Solutions.
Smart Global Privacy Solutions is a registered trademark of Smart Global Privacy Solutions SARL. Copyright Protection © 2017-2087 Smart Global Privacy Solutions
USPTO Patent pending No. 62592565
APPLICABLE LAW AND JURSDICTION
It is expressly stipulated that these legal notices are governed by the Monegasque law. Any dispute that arises during the execution of this contract will be submitted to the competent courts of Monaco.