Privacy Policy for SmartyDesk Software

Effective Date: 12/07/2023

Effective: 5th July 2023

This Privacy Policy describes how SmartyDesk collects, uses and discloses information associated with an identified or identifiable individual (referred to in this Privacy Policy as ‘Personal Data’) and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us.

When we refer to ‘SmartyDesk’, we mean SmartyDesk LLC or SmartyDesk limited liability company, as explained in more detail in the ‘Identifying the data controller and processor’ section below.

Table of contents:

Applicability of this Privacy Policy

This Privacy Policy applies to SmartyDesk’s online workplace productivity tools and platform, including the associated SmartyDesk mobile and desktop applications (collectively, the ‘Services’), SmartyDesk.com and other SmartyDesk websites (collectively, the ‘Websites’) and other interactions (e.g. customer service enquiries, user conferences, etc.) that you may have with SmartyDesk. If you do not agree with this Privacy Policy, then do not access or use the Services, Websites or any other aspect of SmartyDesk’s business. For the avoidance of doubt, this is the only privacy policy that applies to SmartyDesk.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the SmartyDesk platform (‘Third-Party Services’), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy. In addition, a separate agreement governs delivery, access and use of the Services (the ‘Customer Agreement’), including the processing of data such as messages, files or other content submitted through Services accounts (collectively, ‘Customer Data’). The organisation (e.g. your employer or another entity or person) that entered into the Customer Agreement (the ‘Customer’) controls its instance of the Services (its ‘Workspace’) and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have an account, you can check https://SmartyDesk.com/account/team for the contact information of your workspace owner(s) and administrator(s). If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.

California notice of collection of personal information: We collect the information described below under ‘Information we collect and receive’ for the business and commercial purposes described below under ‘Information use’. To learn more about exercising your California privacy rights, please review the ‘California privacy rights’ section below.

Information we collect and receive

SmartyDesk will collect and receive information through operating the Services and Websites, and through other interactions with SmartyDesk. Such information will include Customer Data and other information and data (‘Other Information’) in a variety of ways:

Customer Data. Customers or individuals granted access to a Workspace by a Customer (‘Authorised Users’) routinely submit Customer Data (such as messages, files or other content submitted through Services accounts) to SmartyDesk when using the Services.
Other Information. SmartyDesk also collects, generates and/or receives the following categories of Other Information:

Workspace and account information: To create or update a Workspace account, you or our Customer (e.g. your employer) supply SmartyDesk with an email address, phone number, password, domain and/or other account set-up details (for more detail on Workspace creation, click here. In addition, Customers that purchase a paid version of the Services provide SmartyDesk (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
Usage information:

Services metadata. When an Authorised User interacts with the Services, metadata is generated that provides additional context about the way that an Authorised User uses the Services. For example, SmartyDesk logs the Workspaces, channels, people, features, content and links that you view or interact with, the types of files shared and what Third-Party Services are used (if any).
Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page that you visited before using the Website or Services, browser type and settings, the date and time that the Services were used, information about browser configuration and plugins, and your language preferences.
Device information. SmartyDesk collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
Location information. We receive information from you, our Customers and other third parties that helps us to approximate your location. We may, for example, use a business address submitted by your employer (who is our Customer) or an IP address received from your browser or device to determine approximate location to assist with localisation or for security purposes.

Cookie information: SmartyDesk uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information. For more details about how we use these technologies, and your opt-out controls and other options, please visit our Cookie policy.
Third-Party Services information: A Customer can choose to permit or restrict Third-Party Services for its Workspace and SmartyDesk can receive personal data from such Third-Party Services. Typically, Third-Party Services are software that integrate with our Services, and a Customer can permit its Authorised Users to enable and disable these integrations for its Workspace (for more details on third-party application management, settings and permissions, click here). SmartyDesk may also develop and offer SmartyDesk applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with SmartyDesk. For example, if a cloud storage application that you are using is enabled to permit files to be imported to a Workspace, we may receive the user name and email address of Authorised Users, along with additional information that the application makes available to SmartyDesk to facilitate the integration. Authorised Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to SmartyDesk. When a Third-Party Service is enabled, SmartyDesk is authorised to connect and access Other Information made available to SmartyDesk in accordance with our agreement with the provider of the Third-Party Service and any permission(s) granted by our Customer (including by its Authorised User(s)). Examples of information which SmartyDesk may receive in this manner include whether you successfully created a new account or interacted with a third-party application in a way that is attributable to SmartyDesk usage activity. We do not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services. For more information on SmartyDesk’s interaction with Third-Party Services, click here.
Contact information: In accordance with the consent process provided by your device or other third-party API, any contact information that an Authorised User chooses to import (such as importing an address book to find colleagues and SmartyDesk Connect contacts or calendar from a device or API), forward or upload to the Services (for example, when sending emails to the Services) is collected when using the Services.
Third-party data: SmartyDesk may receive data about organisations, industries, lists of companies that are customers, website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information that we collect and might include aggregate-level data, such as which IP addresses correspond to postcodes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
Audio and video metadata: SmartyDesk may receive, capture and store metadata derived from your use of features such as SmartyDesk huddles or clips, and additional related data such as data regarding the date and time of your SmartyDesk huddle and the Authorised User that you connected with.
Additional information provided to SmartyDesk: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions that you provide if you participate in a focus group, contest, activity or event, feedback that you provide about our products or services, information that you provide if you apply for a job with SmartyDesk, enrol in a certification programme or other educational programme hosted by SmartyDesk or a vendor, request support, interact with our social media accounts or otherwise communicate with SmartyDesk.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively “Information”). However, certain Information is collected automatically and if some Information, such as Workspace setup details, is not provided, we may be unable to provide the Services.

How we process your information and our legal bases for doing so

Customer Data will be used by SmartyDesk in accordance with a Customer’s instructions, including to provide the Services, any applicable terms in the Customer Agreement, a Customer’s use of Services functionality and as required by applicable law. SmartyDesk is a processor of Customer Data and the Customer is the controller. The Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data, and otherwise apply its policies to the Services.

SmartyDesk uses Other Information to operate our Services, Websites and business. More specifically, SmartyDesk uses Other Information for the following purposes:

Compliance with a legal obligation:
SmartyDesk processes Other Information when we comply with a legal obligation including, for example, to access, preserve or disclose certain information if there is a valid legal request from a regulator, law enforcement or others. For example, a search warrant or production order from law enforcement to provide information in relation to an investigation, such as your profile picture or IP address.

We use Workspace and account information, usage information, cookie information, Third-Party Services information, contact information, third-party data, audio and video metadata, and additional information provided to SmartyDesk for compliance with a legal obligation.

Legitimate interests:
We rely on our legitimate interests or the legitimate interests of a third party where they are not outweighed by your interests or fundamental rights and freedoms (‘legitimate interests’).

To provide, update, maintain and protect our Services, Websites and business.
This includes the use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities, or at an Authorised User’s request.

It is in our and your interests to provide, update, maintain and protect our Services, Websites and business.

To develop and provide search, learning and productivity tools and additional features.
SmartyDesk tries to make the Services as useful as possible for specific Workspaces and Authorised Users. For example, we may:

improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorised User;
make Services or Third-Party Service suggestions based on historical use and predictive models;
identify organisational trends and insights;
customise a Services experience; or
create new productivity features and products.

It is in our interest and in the interest of Customers and Authorised Users to continuously improve and develop the customer support that we provide.

To investigate and help prevent security issues and abuse.
We may use a variety of tools such as device fingerprinting to prevent issues and abuse. We may process, including in an automated fashion, Other Information to better understand how SmartyDesk is used or to prevent spam or abuse.

It is in our interest to keep the Services secure and to detect, prevent and address abuse (such as spam) and to investigate and take action in respect of suspicious activity on the Services.

To aggregate or de-identify information.
In some cases, we aggregate or de-identify information that we have associated with you and use the resulting information, for example, to improve the Services.

It is in our interest to research and improve the Services;
It is in the interests of Customers and Authorised Users to practice data minimisation and privacy by design in respect of their information.

Share information with others, including law enforcement, and to respond to legal requests.

It is in our interest and the interest of the general public to prevent and address fraud, unauthorised use of SmartyDesk, violations of our terms or other harmful or illegal activity; to protect ourselves, our users or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm.

Transfer, store or process your information outside the European Economic Area.
As the Websites and Services operate globally, with Customers around the world, we need to share information that we collect globally. We carry out necessary transfers outside the European Economic Area, including to Australia, Canada, Japan, India, South Korea and the United States, to provide, update, maintain and protect our Services, Websites and business.
For more information, review the ‘International data transfers’ section below.

It is in our and your interests to provide, update, maintain and protect our Services, Websites and business.

We use Workspace and account information, Third-Party Services information, third-party data and additional information provided to SmartyDesk for the following legitimate interests:

To communicate with you by responding to your requests, comments and questions.
If you contact us, we may use your Other Information to respond.

It is in our, our Customers’ and Authorised Users’ interests to facilitate communication (for example to answer questions from Customers).

To send service emails and other communications.
For example, we may:

send you service, technical and other administrative emails, messages and other types of communications; or
contact you to inform you about changes in our Services, our Services offerings and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services, and you may not opt out of them. It is in our Customers’ and Authorised Users’ interests to address service-related issues.

We use Workspace and account information and usage information for the following legitimate interests:

For billing, account management and other administrative matters.
SmartyDesk may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.

It is in our interest to facilitate the effective provision and administration of the Websites and Services.

We use Workspace and account information, usage information, cookie information, Third-Party Services information, third-party data and additional information provided to SmartyDesk for the following legitimate interests:

To send marketing emails and other communications.
We sometimes send emails about new product features, promotional communications or other news about SmartyDesk. These are marketing messages, so you can control whether you receive them. If you have additional questions about a message that you have received from SmartyDesk, please get in touch through the contact mechanisms described below.

It is in our interest to promote the Websites and Services and send our direct marketing.

How we share and disclose information

This section describes how SmartyDesk may share and disclose Information, as described in the section entitled ‘Information we collect and receive’ above. Customers determine their own policies and practices for the sharing and disclosure of Information to third parties. SmartyDesk does not control how a Customer or any third party chooses to share or disclose Information.

The Customer’s instructions. SmartyDesk may share and disclose Information in accordance with a Customer’s instructions and with appropriate consent, including any applicable terms in the Customer Agreement and the Customer’s use of Services functionality and in compliance with applicable law and legal process. Some sharing at a Customer’s request may incur additional fees.

To enable SmartyDesk to follow our Customers’ instructions, SmartyDesk provides several administrator controls to allow Customers to manage their Workspaces. For example, we follow our Customers’ instructions to enable or disable Authorised Users’ use of various features of the Services, such as clips or SmartyDesk huddles, channel posting permissions, the sharing and visibility of direct messages including files, or whether and how Authorised Users can connect with other organisations’ Workspaces through SmartyDesk Connect.
We also follow Customer and Authorised User instructions on how an Authorised User’s profile may be displayed within a Customer’s Workspace or when shared through SmartyDesk Connect or other features.
Customers may also provide their Authorised Users with the ability to adjust the audience and visibility of certain Customer Data. To learn more, visit our Help Centre to understand what choices and settings are available.

Displaying the Services. When an Authorised User submits Information, it may be displayed or discoverable to other Authorised Users in the same or connected Workspaces or SmartyDesk Connect instances. For example, an Authorised User’s email address may be displayed with their Workspace profile, or other profile and organisational information may be displayed to Authorised Users. Please consult the Help Centre for more information on Services functionality.
Collaborating with others. The Services provide different ways for Authorised Users working in independent Workspaces to collaborate, such as SmartyDesk Connect or email interoperability. Information, such as an Authorised User’s profile and organisational information, may be shared, subject to the policies and practices of the Workspace(s) that you use. For example, depending on the settings of your Workspace, to enable connections with other Authorised Users, your profile may be shared or searchable or discoverable by Authorised Users or other users outside of the Workspace(s) that you belong to, or shared via email when you invite an Authorised User or other user to collaborate via SmartyDesk Connect. In many instances, SmartyDesk includes either administrator controls or user controls, depending on the use case, with respect to external collaboration. Authorised Users may also decide to expand the visibility of certain content and Customer Data, such as files.
Customer access. Owners, administrators, Authorised Users and other Customer representatives and personnel may be able to access, modify or restrict access to Information. This may include, for example, your employer using features of the Services to access or modify your profile details, or to export logs of Workspace activity. For information about your Workspace settings, please visit https://SmartyDesk.com/account/settings.
Third-party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist SmartyDesk with verifying Owners and Customers, or we may share business information to develop strategic partnerships with Third-Party Service providers to support our common customers. In this respect, depending on the Third-Party Service provided, SmartyDesk may share your Information. Additional information about the subprocessors that we use to support delivery of our Services is set forth at SmartyDesk subprocessors.
Third-Party Services. A Customer may enable, or permit Authorised Users to enable, Third-Party Services. We require each Third-Party Service provider to disclose all permissions for information accessible through the Services, but we do not guarantee that they do so. When Third-Party Services are enabled by a Customer or an Authorised User, SmartyDesk may share Information with Third-Party Services. Third-Party Services are not owned or controlled by SmartyDesk and third parties that have been granted access to Information may have their own policies and practices for its collection, use and sharing. Please check the permissions, privacy settings and notices for these Third-Party Services, or contact the provider if you have any questions.
Forums. The Information that you choose to provide in a community forum, including personal data, will be publicly available.
Organisers and sponsors of events/webinars. If you attend an event or webinar organised by SmartyDesk, we may share your profile and organisational information with the event or webinar sponsors when you register, have your badge scanned or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.
Professional advisers. We may share your Information with professional advisers acting as service providers, processors, controllers or joint controllers – including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
Corporate affiliates. SmartyDesk may share Information with our corporate affiliates, parents and/or subsidiaries.
During a change to SmartyDesk’s business. If SmartyDesk engages in a merger, acquisition, bankruptcy, dissolution, reorganisation, sale of some or all of SmartyDesk’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information we collect and receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated or deidentified Data. We may disclose or use aggregated or de-identified Information for any purpose. For example, we may share aggregated or de-identified Information with prospects or partners for business or research.
Law enforcement and regulators. If we receive a request for information, we may disclose Other Information if we reasonably believe that disclosure is in accordance with or required by any applicable law, regulation or legal process. Please review the Data request policy, Data request overview and Transparency report to understand how SmartyDesk responds to requests to disclose data from government agencies, law enforcement entities and other sources. This may at times include information that SmartyDesk Technologies, LLC processes on behalf of SmartyDesk Technologies Limited in its role as a subprocessor, including as pursuant to the terms of any data protection agreement between SmartyDesk and its Customers.
To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property or safety of SmartyDesk, its users or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud or security issues, including to prevent death or imminent bodily harm.
With consent. SmartyDesk may share Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. For Workspaces registered to corporate entities, SmartyDesk may share Information with consent of the Workspace primary owner or authorised corporate officer, or their designee. For workplaces created without a formal affiliation, SmartyDesk may require user consent.

Data retention

SmartyDesk will retain Customer Data in accordance with a Customer’s instructions (including to perform any applicable terms in the Customer Agreement and through the Customer’s use of Services functionality) and as required by applicable law. The Customer may customise its retention settings and, depending on the Services subscription, apply those customised settings at the Workspace level, channel level or other level. The Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please review the Help Centre or contact the Customer.

SmartyDesk may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features that you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for SmartyDesk to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

Security

SmartyDesk takes security of data very seriously. SmartyDesk works hard to protect Information that you provide from loss, misuse and unauthorised access or disclosure. These steps take into account the sensitivity of the Information that we collect, process and store, and the current state of technology. SmartyDesk has received internationally recognised security certifications. To learn more about current practices and policies regarding security and confidentiality of the Services, please visit our Security practices. Given the nature of communications and information processing technology, SmartyDesk cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site, and we don’t control or endorse what is on third-party sites.

Age limitations

SmartyDesk does not allow use of our Services and Websites by anyone younger than 16 years old, to the extent prohibited by applicable law. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Changes to this Privacy Policy

SmartyDesk may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, SmartyDesk will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

International data transfers

SmartyDesk may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, SmartyDesk will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with SmartyDesk’s obligations.

In particular, we offer the following safeguards if SmartyDesk transfers Personal Data from jurisdictions with differing data protection laws:

European Commission’s Standard Contractual Clauses. SmartyDesk uses Standard Contractual Clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) for transfers to, among others, Australia, Canada, India, Japan, South Korea and the United States. SmartyDesk will transfer your Personal Data to facilitate the provision of the Services. A copy of our standard data processing addendum, incorporating the Standard Contractual Clauses, is available here, and a copy of the executed version of the Standard Contractual Clauses may be obtained by contacting us as described in the ‘Contacting SmartyDesk’ section below.
Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System and Privacy Recognition For Processors. SmartyDesk’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (‘APEC’) Cross Border Privacy Rules (‘CBPR’) system and the Privacy Recognition for Processors (‘PRP’). The APEC CBPR system provides a framework for organisations to ensure protection of personal data transferred among participating APEC economies, and the PRP demonstrates an organisation’s ability to provide effective implementation of a personal data controller’s privacy obligations related to the processing of personal information. More information about the APEC framework can be found here. If you have an unresolved privacy or data use concern related to our APEC, CBPR or PRP certifications that we have not addressed satisfactorily, you may contact our third-party dispute resolution provider.

Data Protection Officer

To communicate with our Data Protection Officer, please email dpo@SmartyDesk.com.

Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the ‘controller’ and ‘processor’ of information. In general, the Customer is the controller of Customer Data. In general, SmartyDesk is the processor of Customer Data and the controller of Other Information. Different SmartyDesk entities provide the Services in different parts of the world.

SmartyDesk Technologies Limited, an Irish company based in Dublin, Ireland, is the controller of Other Information and a processor of Customer Data relating to Authorised Users who use Workspaces established for Customers outside of the US and Canada.
SmartyDesk Technologies, LLC, a US company based in San Francisco, California, is the controller of Other Information and a processor of Customer Data relating to Authorised Users who use Workspaces established for Customers in the US and Canada.

Your rights

Individuals in the European Economic Area, the United Kingdom, Brazil and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete or correct this information. You can do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact the Customer who controls your workspace for additional access and assistance. Please check https://SmartyDesk.com/account/settings for Customer contact information.

To the extent that SmartyDesk’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), SmartyDesk primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us as described in the ‘Contacting SmartyDesk’ section below. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. SmartyDesk may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to SmartyDesk’s use of your Personal Data for this purpose at any time.

Your California privacy rights

This section provides additional details about the personal information that we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or ‘CCPA’, as amended by the California Privacy Rights Act or ‘CPRA’.

California law requires that we detail the categories of personal information that we collect and disclose for certain ‘business purposes’, such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in earlier sections of this Privacy Policy. In addition to the information provided above in the ‘Information we collect and receive’ section, we collect the following categories of personal information from you, your employer, data analytics providers, data brokers and Third-Party Services for our business purposes:

Identifiers/contact information;
Commercial information;
Internet or electronic network activity information;
Financial information;
Geolocation information;
Professional or employment-related information;
Audio and visual data;
In limited circumstances where allowed by law, information that may be protected under California or United States law; and
Inferences drawn from any of the above categories.

We collect this information for the business and commercial purposes described in the ‘How we process your information and our legal bases for doing so’ section above. We share this information as described in the ‘How we share and disclose information’ section above. SmartyDesk does not sell (as such term is defined in the CCPA or otherwise) the personal information that we collect (and will not sell it without providing a right to opt out). We may also share personal information (in the form of identifiers and Internet activity information) with third-party advertisers for the purposes of targeting advertisements on non-SmartyDesk websites, applications and services. In addition, we may allow third parties to collect personal information from our sites or services if those third parties are authorised service providers who have agreed to our contractual limitations as to their retention, use and disclosure of such personal information, or if you use our sites or services to interact with third parties or direct us to disclose your personal information to third parties.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information that we collect (including how we use, disclose or may sell this information), to delete their personal information, to opt out of any ‘sales’, to know and opt out of sharing of personal information for delivering advertisements on non-SmartyDesk websites, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@SmartyDesk.com or by filling in this form. We will verify your request using the information associated with your account, including the email address. Government identification may be required. Consumers can also designate an authorised agent to exercise these rights on their behalf. Authorised agents must submit proof of authorisation.

If you would like to opt out of sharing activity based on your cookie identifiers, turn on a Global Privacy Control in your web browser or browser extension. Please see the California Privacy Protection Agency’s website at https://oag.ca.gov/privacy/ccpa for more information on valid Global Privacy Controls. If you would like to opt out of sharing activity based on other identifiers (such as email address or phone number), contact us in accordance with the ‘Contacting SmartyDesk’ section below.

For more information on SmartyDesk’s role and obligations under the CCPA, please visit SmartyDesk’s California Consumer Privacy Act (CCPA) FAQ.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict SmartyDesk’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority on the following website. If you are a resident of the United Kingdom you may contact the UK supervisory authority, the Information Commissioner’s Office.

Contacting SmartyDesk

Please also feel free to contact SmartyDesk if you have any questions about this Privacy Policy or SmartyDesk’s practices or if you are seeking to exercise any of your statutory rights. SmartyDesk will respond within a reasonable timeframe. You can contact us at privacy@SmartyDesk.com or at our postal address below:

For Customers and Authorised Users who use Workspaces established for Customers in the US and Canada:

SmartyDesk LLC
254 Chapman Rd,

Ste 208 #13503,

Newark, Delaware 19702 United States

For Customers and Authorised Users who use Workspaces established for Customers outside the US and Canada:

SmartyDesk

Level 3 63 330 Wattle Street

Ultimo, NSW, 2007