Privacy Policy (WEBSITE)
smartproject.com
Effective date: 10.07.2026
This Privacy Policy applies to the Smart Project GmbH website located at smartproject.com, including its About, Games Catalog, Careers, Publishing, Submit Your Game, Blog and Contact pages (collectively, the “Website”). We respect the privacy of everyone who visits the Website and recognize the importance of protecting the information we collect. This Privacy Policy may be periodically updated by publishing a new version, so please make sure you rely on the most current version.
This Privacy Policy informs you how we collect, use, and process personal data in connection with the Website. We process personal data only where we have a lawful basis to do so, including where processing is necessary to respond to your request, take steps before entering into a contract, comply with legal obligations, pursue our legitimate interests, or where you have given consent and consent is required by applicable law. Where required by applicable law, such collection, use, and processing is carried out on the basis of your appropriate consent.
Please note that we do not sell your personal data or any other personal information.
If you are a California resident, please see ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS below. Residents of other jurisdictions with region-specific rights (the EEA, the UK, Switzerland, Canada, Brazil, Australia and Ukraine) should see ADDITIONAL INFORMATION FOR OTHER JURISDICTIONS below.
Please read the following to learn more about how we use your personal data.
For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”), Smart Project GmbH (“Smart Project GmbH”, “we”, “us”, or “our”) is the data controller responsible for any personal data we process through the Website.
The data controller: Smart Project GmbH
Email: support@smartproject.com
Address: Albitweg 11, 3095 Spiegel b. Bern, Switzerland
You can also find details about the data controller responsible for your information in the section “CONTACTS” below.
SCOPE OF THIS POLICY
This Policy governs the Website only. It does not govern the mobile games listed in our Games Catalog. Each published game is covered by its own, separate privacy policy addressing in-game data collection, advertising SDKs, in-app purchases, and platform-specific disclosures (Apple App Privacy “Nutrition Labels” and the Google Play Data Safety section). Clicking through from the Website to a game’s store listing takes you outside this Policy.
With respect to the Website and the processing of personal data through the Website, this Policy prevails over any other documents, unless a separate document expressly states that it applies to a specific Website feature or form and prevails over this Policy for that specific matter.
DEFINITIONS
“Website” means smartproject.com, as scoped in “SCOPE OF THIS POLICY” above – it does not include the games listed in our Games Catalog, which are covered by their own separate privacy policies.
“Personal Data” means any information relating to an identified or identifiable individual, including but not limited to your name, email address, CV contents, company name, and any other information described in “INFORMATION WE PROCESS” below.
“Smart Project GmbH” (also “we”, “us”, or “our”) means the Swiss company identified as the data controller above, together with any group entity acting on its behalf in connection with the Website.
“User” means anyone browsing the Website.
“Applicant” means anyone submitting a job application, a publishing proposal, or a game through the Website.
“Referrer” means anyone submitting another person’s contact details through our candidate-referral form.
To the extent that the California Consumer Privacy Act (“CCPA”) applies to you, the definitions in this Privacy Policy are to be read as follows: “personal data” includes “personal information”; “data subject” includes “consumer”; “controller” includes “business”; “processor” includes “service provider”, all as defined under the CCPA. For more information about the CCPA, please see ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS below.
We may apply additional standards to you as required by local law. Smart Project GmbH strives to make sure that our processing of personal data is done in accordance with applicable legislation.
If you have any questions or concerns about this Privacy Policy, including those related to exercising any of your rights, please contact us as described in “CONTACTS” below.
INFORMATION WE PROCESS
When you use the Website, we collect information about your visit – such as the pages you view and how you interact with the Website – to help us operate and improve it. Some pages also ask you to provide information directly, for specific purposes described below.
Careers page. If you apply for a role, we collect your name, email address, your uploaded CV, and anything else you choose to include in it (which may incidentally contain your phone number, photo, nationality, education, or work history).
“Know a star?” referral form. If you refer someone for a role, we collect the referred person’s name and contact details, together with your own name and email.
Contact form. We collect your name, email address, the category of your inquiry, your message, and any file you choose to attach.
Publishing proposal page. This page directs you to a Google Form, where we collect your contact name, email, company name, game title, and links or files relating to your proposal. See INTERNATIONAL DATA TRANSFERS AND THIRD-PARTY FORMS below for an important note about how Google is involved in this process.
Submit Your Game form. We collect your name, email address, company name, a link to your game, and your confirmation that you agree to this Policy.
We do not require you to submit more personal data than is reasonably necessary for the purpose you are contacting us for.
SOURCES OF PERSONAL DATA
We may obtain personal data from the following sources:
a) directly from you, when you browse the Website, contact us, submit a job application, send a publishing proposal, submit your game, ask a question, or complete any other form available on or through the Website;
b) from third-party forms or tools used in connection with the Website, including Google Forms or similar services, where you submit information through those tools and the information is then made available to us;
c) from another person who provides your contact details in a professional context, including where someone refers you for a role, cooperation opportunity, publishing opportunity, or other business-related purpose;
d) from publicly available professional sources, such as LinkedIn, company websites, professional directories, event pages, business publications, or other sources where professional contact information has been made available in a business or professional context.
Where we obtain your personal data from a source other than you directly, we use it only where we consider that we have a lawful basis to do so, taking into account the context in which the data was made available, your reasonable expectations, the nature of our communication, and your rights and interests.
INFORMATION THIRD PARTIES PROVIDE US
If another person provides us with your contact details, for example through our “Know a star?” referral form or in connection with a potential role, publishing opportunity, cooperation proposal, or other professional opportunity, we may receive your name, contact details, professional profile, and any additional information provided by that person.
We use this information only for the relevant professional purpose, such as assessing whether the opportunity may be relevant to you, contacting you about it, responding to the referral, or maintaining appropriate records. If you would like to know more about the source of your data, object to further communication, or ask us to delete your information, please contact us as described in “CONTACTS” below.
WHY DO WE PROCESS YOUR DATA
We process personal data for the following purposes:
a) to operate, maintain, secure, and improve the Website;
b) to respond to your inquiries, messages, questions, and requests;
c) to evaluate job applications, referrals, CVs, and potential recruitment opportunities;
d) to evaluate publishing proposals, game submissions, partnership requests, and other business-development opportunities;
e) to communicate with you in connection with an existing or potential professional, recruitment, publishing, partnership, or business relationship;
f) to send relevant professional communications, such as company updates, information about roles that may be relevant to your professional profile, cooperation opportunities, product or service updates, and occasional relationship messages, including holiday greetings;
g) to keep appropriate business records, protect our rights, comply with legal obligations, and establish, exercise, or defend legal claims.
Our lawful basis for processing depends on the context.
Where you contact us, submit a form, apply for a role, send a publishing proposal, or submit your game, we may process your personal data because this is necessary to take steps at your request before entering into a contract or because we have a legitimate interest in reviewing and responding to your request.
Where someone refers you or where we contact you based on publicly available professional information, we may rely on our legitimate interests in recruitment, business development, professional networking, responding to referrals, identifying relevant professional opportunities, and maintaining business relationships.
Where we send marketing or promotional electronic communications, we do so only where permitted by applicable law. If applicable law requires your prior consent for a particular type of electronic communication, we will send such communication only if we have obtained that consent.
Where we ask for your separate consent, for example to keep your CV on file for future roles or to send newsletter-style marketing communications, our lawful basis is that consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
You may object at any time to our processing of your personal data for direct marketing or further professional communications by contacting us as described in “CONTACTS” below or by using the unsubscribe or opt-out mechanism provided in our message, where available.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We retain your personal data only for as long as necessary to fulfil the purpose for which it was collected, applying the following criteria to each category of data:
Job applications and CVs (Careers page). We process and retain your application and CV for the duration of the relevant recruitment process because this is necessary to take steps at your request prior to entering into a potential employment contract with us. We retain this data until the process is closed, plus a reasonable period thereafter to handle any related follow-up, query, or dispute.
Where we wish to keep your CV on file after the process closes, to consider you for future roles, we do so on the basis of our legitimate interest in recruitment and talent management. You may object to this further retention at any time.
Where applicable law requires your prior consent for us to retain your CV for future roles, we will only do so on the basis of that consent, and you may withdraw it at any time without affecting the lawfulness of retention carried out before withdrawal.
“Know a star?” referrals. We process the referred person’s and the referrer’s data for as long as necessary to assess whether the relevant opportunity may be suitable for the referred person, on the basis of our legitimate interest in recruitment, business development, and responding to referrals made to us. We retain this data until the relevant opportunity has been assessed and closed, or until the referred person objects to further contact, whichever occurs first.
We also process the referrer’s own name and email address, separately from the referred person’s data, for as long as necessary to acknowledge and respond to the referral, associate it with the correct referrer for our internal records, and, where applicable, administer any referral-related recognition or process on our side. We retain the referrer’s data until the referral process is closed, plus a reasonable period thereafter for record-keeping purposes, on the basis of our legitimate interest in maintaining accurate business and recruitment records.
Both the referred person and the referrer may object to this processing or request deletion of their respective data at any time by contacting us as described in “CONTACTS” below.
Publishing proposals and game submissions. We process this data for the duration of our evaluation because this is necessary to take steps at your request prior to entering into a potential publishing, cooperation, or partnership agreement with us. We retain this data until we have completed our evaluation and communicated our decision, plus a reasonable period thereafter to preserve records of the evaluation and, where relevant, of any resulting business relationship. You may object to this further retention at any time.
Where we wish to keep your proposal or submission on file beyond that point, to consider it for future opportunities, we do so on the basis of our legitimate interest in business development, unless applicable law requires your prior consent, in which case we rely on that consent instead.
Contact form inquiries. We process and retain this data for as long as necessary to respond to your inquiry, on the basis of our legitimate interest in operating the Website and addressing questions and requests made to us. We retain this data until your inquiry has been resolved, plus a reasonable period thereafter in case of follow-up.
Website usage and cookie data. We retain this data in accordance with the retention periods set out in our Cookie Policy.
In every case, we do not keep personal data for longer than is necessary for the purpose for which it was collected, taking into account our legal, accounting, and business-record obligations. We delete or anonymize the data once none of these purposes continue to apply, unless a shorter period is required by applicable law or you ask us to delete it sooner.
If you object to further communication, we may retain limited information necessary to record and respect that objection, so that we do not contact you again for the same purpose.
You may request deletion of your personal data at any time, as described in “YOUR RIGHTS AND OPTIONS” below.
HOW WE USE THE PROVIDED INFORMATION
We use personal data only for the purposes described in this Policy or for purposes that are compatible with the context in which the data was provided or obtained.
For example, we may use your information to assess your application, evaluate your proposal, respond to your message, handle your game submission, contact you about a referral or professional opportunity, maintain our relationship with you, keep appropriate business records, and keep the Website safe and secure.
We do not use personal data obtained through Website forms to send unrelated marketing communications unless we have a lawful basis to do so and, where required by applicable law, your consent.
We do not provide your personal data to third parties except as described in this Policy.
SERVICE PROVIDERS AND CATEGORIES OF RECIPIENTS
We may share personal data with trusted service providers that help us operate the Website, process forms and requests, communicate with you, manage recruitment and referrals, review submissions, maintain business records, and support our internal workflows.
These providers may include providers of email communication and mailing tools, online forms and survey tools, cloud storage, email and productivity tools, document management tools, recruitment and HR management platforms, hosting, website maintenance, analytics, security, and IT support services.
These service providers process personal data only for the purposes described in this Privacy Policy and, where applicable, under appropriate data processing terms required by data protection laws.
We do not sell your personal data.
You may contact us to request more detailed information about the recipients or categories of recipients of your personal data, including specific service providers involved in the processing of your personal data, where required by applicable law.
INTERNATIONAL DATA TRANSFERS
Our Service is global by nature, and your personal data may be transferred to, stored in, or otherwise processed in countries other than the country in which you are located or in which the data was originally collected. These countries may have data protection laws that differ from the laws of your country.
Where we transfer personal data internationally, we do so in accordance with applicable data protection laws and rely on appropriate transfer mechanisms and safeguards. These may include adequacy decisions, standard contractual clauses, transfer impact assessments, supplementary technical, contractual and organisational measures, or other lawful mechanisms available under applicable law.
A note: Some pages or features of the Website may redirect you to, or make available, third-party forms or tools, including forms built on Google Forms or similar third-party services.
When you complete such a form, you may be entering data directly into infrastructure operated by the relevant third-party provider. The collection, transmission, hosting, security, and international transfer of data within that third-party environment may be subject to that provider’s own privacy policy, terms, and technical measures.
After you submit the form, we may receive the information you provided and process it for the purposes described in this Policy, including to review, respond to, evaluate, document, or otherwise handle your inquiry, application, publishing proposal, game submission, or other request.
We do not control the independent security practices, infrastructure, cookies, tracking technologies, international transfers, or other data processing activities of third-party form providers to the extent such activities are carried out by those providers for their own purposes or within their own environment.
CROSS BORDER TRANSFERS AND EU-US AND SWISS-US
For transfers of personal data from the European Economic Area, we may rely on an adequacy decision adopted by the European Commission, including the EU-U.S. Data Privacy Framework where the recipient in the United States is duly certified and the certification covers the relevant data and processing activities. Where no adequacy decision or applicable certification mechanism is available, we may rely on the European Commission’s Standard Contractual Clauses, together with a transfer impact assessment and any supplementary safeguards required under applicable law.
For transfers of personal data from Switzerland, we may rely on an applicable adequacy decision, including the Swiss-U.S. Data Privacy Framework where the recipient in the United States is duly certified and the certification covers the relevant data and processing activities. Where no adequacy decision or applicable certification mechanism is available, we may rely on appropriate safeguards recognised under the Swiss Federal Act on Data Protection, including standard contractual clauses adapted as necessary for Swiss law.
If the EU-U.S. or Swiss-U.S. Data Privacy Framework ceases to be a valid transfer mechanism, we will rely on Standard Contractual Clauses and other lawful safeguards described in this section without undue delay.
TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
For transfers of personal data from the United Kingdom, we may rely on the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, a UK adequacy regulation, or another lawful transfer mechanism recognised under UK data protection law, as applicable.
For transfers of personal data from Brazil, we may rely on transfer mechanisms recognised under the Brazilian General Data Protection Law and applicable regulations issued by the Brazilian Data Protection Authority, including adequacy decisions, standard contractual clauses approved by the Brazilian Data Protection Authority, specific contractual clauses, binding corporate rules or other lawful mechanisms, as applicable.
We may share personal data with our affiliates, vendors, service providers, suppliers, advisers, consultants, law enforcement authorities, courts, tribunals, tax and social security authorities, and other public authorities where this is necessary for the purposes described in this Policy and permitted by applicable law.
Where we engage vendors or service providers to process personal data on our behalf, we require them to process such data only in accordance with our instructions, to protect its confidentiality and integrity, and to apply appropriate security and data protection safeguards. All these recipients are themselves responsible to comply with the EU data protection rules. Where these vendors are located within the EU, we ensure that they are contractually obligated to comply with the EU data protection rules. We also ensure in our contracts with these organizations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
Where personal data is transferred outside the EU/EEA and the transfer is not covered by an adequacy decision adopted by the European Commission, we rely on lawful safeguards under Article 46 GDPR. These may include the European Commission’s Standard Contractual Clauses, transfer impact assessments, additional contractual safeguards, and supplementary technical and organisational measures, such as encryption, pseudonymisation or other appropriate security measures, where required or appropriate.
You may request a copy of these agreements by contacting us using the email address in the Contact section below.
Please feel free to contact us for additional information on third country data transfers as well as our safeguards and supplementary security measures.
You may request a copy of the relevant transfer safeguards by contacting us as described in “CONTACTS” below.
WHO CAN SEE YOUR DATA
Apart from Smart Project GmbH, your data may be seen by the service providers who help us run the Website and process your submissions (including Google, as described above), and, where necessary, by public authorities responding to a lawful request. We do not make any Website submission publicly visible to other visitors.
WHO DO WE SHARE YOUR PERSONAL DATA WITH
We may disclose information about you to organizations that provide a service to us, and/or otherwise collect, use, disclose, store, or process information on our behalf for the purposes described in this Privacy Policy (for example, to process purchases, perform data analytics, support marketing and advertising, host websites, and provide technical support), ensuring that they are contractually obligated to keep your personal data confidential and will comply with the GDPR and other relevant data protection laws.
We may share your information with the following types of service providers:
a) technical support providers who assist with our website and IT infrastructure,
b) software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;
c) professional advisers such as solicitors, accountants, tax advisors, auditors, and insurance brokers;
d) providers that help us generate and collate reviews in relation to our goods and services;
e) our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise our own products or services that may be of interest to you; and/or
f) service providers that assist us in providing our services;
g) law enforcement or government bodies.
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.
Notwithstanding the foregoing, Smart Project GmbH may share or disclose information that does not identify you (including information that has been aggregated and de-identified) with other parties, except where prohibited by applicable law.
We do not sell your personal data, and we do not share it for cross-context behavioral advertising.
YOUR RIGHTS AND OPTIONS
You have the following rights in relation to your personal data, to the extent such rights are provided by the data protection law applicable to our processing of your data: to receive information about how we collect, use, disclose, store, transfer and protect your personal data; to obtain confirmation as to whether we process personal data about you; to access certain personal data that we process; to have us correct, complete or update inaccurate or incomplete personal data; to have certain personal data erased; to have us temporarily restrict our processing of certain data; to have your personal data exported in a structured, commonly used and machine-readable format where the right to data portability applies; to object to our processing of your personal data where we rely on legitimate interests or another legal basis allowing objection; to object to direct marketing; to withdraw any previously provided consent without affecting the lawfulness of processing carried out before such withdrawal; to opt out of certain processing activities, including targeted advertising, sale or sharing of personal data, where such rights apply under local law; to request information about the categories of personal data collected, the sources of such data, the purposes of processing, the categories of recipients, applicable retention periods and international transfers; not to be discriminated against for exercising your privacy rights where such protection is provided by applicable law; and to lodge a complaint with the appropriate data protection or supervisory authority.
If the GDPR or UK GDPR applies to our processing of your personal data, you also have the right to receive the information required under Articles 13 and 14 GDPR / UK GDPR and to exercise the rights available to data subjects under Articles 15-22 GDPR / UK GDPR, including the rights of access, rectification, erasure, restriction of processing, data portability, objection, withdrawal of consent where processing is based on consent, and rights relating to automated individual decision-making. We do not carry out any decision-making based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.
To exercise any of these rights, please contact us as described in the “CONTACTS” section below. Your request should be made in writing and should include enough information to allow us to understand your request, locate the relevant personal data and verify your identity, for example, the email address you used to submit a form to us. If you make a request on behalf of another person, we may ask you to confirm your authority to act on that person’s behalf. We may decline requests that are unfounded, excessive, or not required under local law.
We will respond within the timeframe required by applicable law. Where permitted by applicable law, we may extend the response period if your request is complex or if we receive a large number of requests, and we will inform you of such extension. We may decline, limit or refuse requests that are unfounded, excessive, repetitive, technically impossible, not required under local law, conflict with our legal obligations, affect the rights and freedoms of others, or relate to personal data that we are required or permitted to retain for legal, security, fraud prevention, compliance, dispute resolution, record-keeping or the establishment, exercise or defence of legal claims. If we decline, limit, or refuse your request, you may appeal our decision by contacting us as described in “CONTACTS” below; we will respond to your appeal within the timeframe required by applicable law and, where required, will inform you of any further right to lodge a complaint with your state attorney general, data protection authority, or other applicable regulator.
COOKIES AND SIMILAR TECHNOLOGIES
Like most websites, we and our partners may use cookies and similar technologies on the Website to make it function, to understand how it is used, and – where enabled – to personalize content. You can disable cookies in your browser settings, but some parts of the Website may then not function properly.
Full details of the categories of cookies we use, their purpose, how long they last, and how to manage your preferences are set out in our separate
Cookie Policy, which forms part of, and should be read together with, this Privacy Policy.
Non-essential cookies are only set after you provide consent through our cookie banner, and you can withdraw that consent at any time using the cookie settings link on the Website.
Where required by applicable law, we recognize and honor opt-out preference signals, such as the Global Privacy Control, as a valid method of exercising applicable opt-out rights.
SECURITY
Smart Project GmbH takes appropriate steps to protect your information from unauthorized use, sharing, loss, or theft, and we review our security measures to make sure they remain effective and appropriate. Our employees who have access to your information are made aware of the importance of keeping it secure and confidential, and we use contracts with our service providers to maintain the confidentiality and security of your information.
Personal data provided to Smart Project GmbH through the Website is controlled by Smart Project GmbH and is collected, processed, and stored in Switzerland and, where applicable, in the European Union.
ADDITIONAL INFORMATION FOR OTHER JURISDICTIONS
Switzerland. As Smart Project GmbH is established in Switzerland, your data is also processed in accordance with the Swiss Federal Act on Data Protection (FADP). You may exercise rights of access, rectification, erasure, and objection broadly consistent with those described above, and may lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC).
United Kingdom. If you are in the UK, you have rights under the UK GDPR broadly equivalent to those described above, and may complain to the Information Commissioner’s Office (ICO).
EU/UK representative. EU/UK representative. Smart Project GmbH is established outside the EEA and the United Kingdom. At the date of this Privacy Policy, we do not appoint a representative in the EU or in the UK, as we consider that the requirement to appoint such a representative does not apply to our current processing activities or that an applicable exemption is available.
If our processing activities change in a way that makes the appointment of an EU and/or UK representative legally required, Smart Project GmbH will appoint such representative and update this Privacy Policy accordingly.
Canada. If you are in Canada, we process your personal data in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). You may access and request correction of your information and withdraw your consent, subject to legal or contractual restrictions.
If you are a resident of Quebec, additional obligations apply to us under Quebec’s Act Respecting the Protection of Personal Information in the Private Sector (Law 25), including with respect to privacy impact assessments and incident notification.
Brazil. If you are in Brazil, we process your personal data under the legal bases set out in the Lei Geral de Proteção de Dados (LGPD), principally consent and legitimate interest. You have the rights set out in Art. 18 LGPD, including confirmation of processing, access, correction, anonymization, portability, and deletion.
You may also lodge a complaint with Brazil’s National Data Protection Authority (ANPD).
Our designated person in charge of the processing of personal data (encarregado) for LGPD purposes can be contacted at support@smartproject.com. This function may be carried out by the same personnel responsible for handling privacy inquiries and data protection matters generally under this Policy.
Australia. If you are in Australia, we aim to handle your personal information in accordance with the Australian Privacy Principles. You may request access to and correction of your personal information, and may complain to us in the first instance and, if unresolved, to the Office of the Australian Information Commissioner (OAIC).
Ukraine. Processing of personal data of applicants and visitors in Ukraine is also subject to the Law of Ukraine “On Personal Data Protection” (No. 2297-VI), under which you may exercise rights of access, correction, and objection consistent with those described above.
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
In this section, we provide additional information about how we handle personal data about California residents as required under the California Consumer Privacy Act (“CCPA”). This section does not address publicly available information lawfully made available by government records or information exempt under the CCPA.
We do not use personal data relating to a minor for targeted advertising or sale, regardless of any consent that may otherwise apply.
We do not knowingly collect sensitive personal information as defined by the CCPA for the purpose of inferring characteristics about you, and we do not use any incidentally-collected sensitive personal information (such as information that may appear in a submitted CV) for any purpose beyond evaluating your application or submission. To the extent applicable, you have the right to limit our use of sensitive personal information.
We do not sell your personal data. The table below identifies the categories of personal data we have collected about you through the Website, and the categories of recipients we have disclosed it to for a business purpose:
California residents have the right to: opt out of any sale or sharing of personal information (we do not sell or share your data as those terms are defined under the CCPA); request deletion of your personal data, subject to certain exceptions; request that we disclose the categories and specific pieces of personal data we have collected about you, and the purposes for collecting it; correct inaccurate personal data; and not be discriminated against for exercising any of these rights.
You may submit a CCPA request by contacting us as set forth in “CONTACTS” below. We will take reasonable steps to verify your request before responding, and may ask for additional information to do so.
CHANGES
We may update this Privacy Policy from time to time. Any changes take effect immediately upon posting the updated Policy. We will indicate that an update has occurred by updating the date at the top of this page, and, for material changes, will provide additional notice, such as a banner on the Website. We encourage you to review this Policy periodically.
CONTACTS
We appoint a data protection officer when required by Article 37 GDPR. For any questions relating to this Privacy Policy, to exercise any of the rights described above, or to contact our data protection officer (where appointed), please write to us at:
Email: personal data related: support@smartproject.com
careers-related requests: job@smartproject.ua
common information: info@smartproject.com
Address: Smart Project GmbH, Albitweg 11, 3095 Spiegel b. Bern, Switzerland