LAST UPDATED JUNE 13TH, 2023

Introduction

This page (“Privacy Policy” or “Policy”) provides our policies and procedures for collecting, using and disclosing your information and outlines the security measures we’ve put in place to protect the information that you store using SME Advantage SA, LLC.'s ("SME Advantage SA") services, including the services made available through this web site, and any other software or services offered by SME Advantage SA in connection with such services (the “Services”). By using these Services, you consent to the collection, transfer, processing, storage, disclosure and other uses of your information described in this Privacy Policy.

What information does SME Advantage SA collect and store?

Personal Information

When expressing an interest in obtaining additional information about the Services or registering to use the Services, SME Advantage SA requires you to provide your personal contact information, such as your name, company name, address, phone number, and email address (these are referred to below as your “Personal Contact Information”). When purchasing the Services, SME Advantage SA also requires you to provide financial and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”).

Data, Diagnostic & Login Information

Using SME Advantage SA’s Services, you will be able to create, upload, store and share information such as company description, email ID, logo, photos, custom emails, user email IDs, etc. (this is collectively referred to below as “Data”). This information will be stored and maintained on SME Advantage SA’s web site. If you run into technical errors in the course of using the Services, SME Advantage SA may request your permission to obtain a crash report along with certain logging information from your system documenting the error (“Diagnostic Information”). Such information may contain information regarding your Operating System version, hardware, browser version (and .NET version information in case of Windows systems), and your email address, if provided. Additionally, certain login information is maintained in a cookie stored locally on your computer (i.e. not on a server) in order to streamline the login process (“Login Information”).

Analytics Information

As you navigate SME Advantage SAs website and use our Services, SME Advantage SA may also collect information through the use of frequently used information-gathering tools, such as cookies and Web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on SME Advantage SA’s website (such as web pages viewed and links clicked). Collectively, this information is referred to as “Analytics Information.”

Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to your website or other websites.

Google's use of advertising cookies enables it and its partners to serve ads to your users based on their visit to your sites and/or other sites on the Internet.

Users may opt out of personalized advertising by visiting Ads Settings or by visiting www.aboutads.info.

Geo-Location Information

SME Advantage SA does not collect any information regarding your real-time geo-location while using the Services; however, it may do so at some point in the future. We will request your permission before collecting such information.

What does SME Advantage SA do with the information it collects?

SME Advantage SA uses the information it collects in the following ways:

Personal Contact Information – We use this information primarily to administer our Services to you and provide you with updates and product announcements. Per the Privacy and Conditions, we may use some of your information for marketing purposes, as explained below.

Billing Information – SME Advantage SA does not store any Billing Information on its servers. Instead, we use a payment provider, Stripe (www.stripe.com), to store and process all payment related transactions. Find information regarding Stripe’s privacy policy here.

Data, Diagnostic Information and Login Information – We use this information solely for the purpose of administering and improving our Services to you.

Analytics Information – SME Advantage SA may use your Analytics Information in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality and user-friendliness, and to verify users have the authorization required for the Services to process their requests.

Sharing & Disclosure of Private Information

Third Party Applications and Your Use

SME Advantage SA provides users with the ability to link to their Data on third party sites such as Facebook, Twitter and LinkedIn. Such linking is at the complete discretion of users. Because of this, SME Advantage SA cannot be held responsible or liable for the linking of user’s Data to such third party sites, nor for how these third party sites use such links.

Marketing and Publicity

Per our Privacy and Conditions, you agree to permit SME Advantage SA to identify you as a customer and to use your name and/or logo in SME Advantage SA’s website and marketing materials.

Sale of Personal Information

SME Advantage SA does not sell, rent, or trade your private information to any third parties in any way.

Service Providers and Business Partners

SME Advantage SA may use certain trusted third party companies and individuals to help us provide, analyze, and improve the Services (including, but not limited to, data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Services’ features). These third parties may have access to your information strictly for the purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.

Non-Private or Non-Personal Information

We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of our Services, in our discretion.

Our Use And Disclosure of Information

SME Advantage SA will not disclose any personally identifiable information about any individual except as set forth in this Privacy Policy. This applies to information about our customers and information our customers provide to us about their customers. We are not limited in any way in our use of non-personal information that does not permit direct association with any specific individual or non-identifiable aggregate information about our users (such as the number of customers who use our services, the geographic distribution of our users, the amount of information located and/or removed, etc.).

Internal Uses of Your Personally Identifiable Information

We collect, store and process your personally identifiable information on servers located in the United States. Due to the unpredictable nature of Internet routing, your information may pass through other countries while in transit to our servers. We use the information we collect about you in order to:

• Develop and deliver our services

• Process your transactions

• Provide customer service and manage your account

• Improve our products, services and marketing.

We provide access to personally identifiable information about our users only to those who require it for the above purposes.

SME Advantage SA will not sell or rent any of your personally identifiable information to third parties. SME Advantage SA will not share any of your personally identifiable information with third parties except in the limited circumstances described below.

We share information with service providers under contract who help with our business operations such as payment and order processing, fraud investigation, bill collection, and information management and analytics. If content generation is included in your services, we may share information with service providers under contract to create, edit and/or publish such content. These third parties are obligated to protect your information and are contractually prohibited from using your personally identifiable information for any other purpose. They are never permitted to share your information with any third parties. They are authorized to use your personal information only as necessary to provide these services to SME Advantage SA.

We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, to conduct investigations of violations of our Privacy of Use and/or to protect our right, protect your safety and the safety of others. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we reserve the right to provide that person or entity’s contact information (but not bank account or credit card information) to victims who request it.

We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified subscriber or limited group of subscribers, we will make reasonable business efforts to contact the subscriber(s) before providing information to the party that requests it. We cannot guarantee that we will be able to do so in all cases, whether due to a time limit, court order, inability to effectively contact a subscriber, or other circumstances.

When a user signs up for a co-branded version of our service through links to SME Advantage SA.com from our co-branded partner’s website, SME Advantage SA will share with the co-branded partner that user’s name, e-mail address and physical address in order to provide enhanced integration between SME Advantage SA’s services and the services of our co-branded partner. If you do not want your information shared with SME Advantage SA’s co-branded partner, sign up for SME Advantage SA directly through SME Advantage SA.com and other sub-domains and not through a link from our partner’s website.

We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, services and advertising. It will not be shared with third parties for their marketing purposes. These third parties are contractually obligated to protect your information and are prohibited from using your personally identifiable information for any other purpose.

As with any other business, it is possible that in the future, SME Advantage SA could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by SME Advantage SA, including customer account information, but would continue to be bound by this Privacy Policy until it is amended.

We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

The implementation of our Services, by its very nature, may require using your personally identifiable information to locate other information about you. Such use may include, but not be limited to, using your information to search the publicly accessible Internet sites as well as searching private information databases and sites.

The implementation of our Services, by its very nature, may require revealing your personally identifiable information in order to effect removal of Internet content about you. For example, we may have to disclose your name to a website in order to notify them to remove Internet content about you. This occurs with your express permission for a specific, given purpose.

Internal Uses of Your Personally Identifiable Information

We will retain your information for as long as your account is active or as needed to provide you the Services. If you wish to cancel your account or request that we no longer use your information to provide you the Services, you may delete your account (this will be done by SME Advantage SA’s customer care team). If you delete your account, your Data will no longer be stored in our servers. While we try to delete your Data from our servers as quickly as possible, please be aware that there may be a delay from the time you delete your account to the time that your Data is removed, and that some of your Data may continue to exist for a period in backup copies.

Changes To Privacy Policy

If we decide to make material changes to our Privacy Policy, we will notify you by e-mail through the primary e-mail address specified in your account and/or post those changes to this Privacy Policy on the Website homepage prior to the changes taking effect. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you.

You are also responsible for regularly reviewing the Privacy Policy and related documents. We reserve the right to modify this Privacy Policy at any time. No amendment to or modification of this Policy will be binding unless in writing and signed by a duly authorized representative of SME Advantage SA, or posted to the Site by a duly authorized representative of SME Advantage SA.

In the event that SME Advantage SA goes through a business transition, such as a merger, an acquisition by another company, or a sale of a portion of its assets, users' personally identifiable information will, in most instances, be part of the assets transferred. Users will be notified via prominent notice on the site for 30 days after a change of ownership or control of their personally identifiable information. If, as a result of the business transition, a user’s personally identifiable information will be used in a manner different from that stated at the time of collection, users will be given a choice consistent with our notification of changes section.

Internal Uses of Your Personally Identifiable Information

If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your personally identifiable information (otherwise known as Personal Data). These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland. “Personal Data” is any data that relates to an identified or identifiable natural person. Examples of Personal Data include identifiers such as name, location data, and unique online identifiers.

In addition to the principles, practices and policies set forth above in this Privacy Policy, SME Advantage SA has adopted the following principles to govern its collection and processing of Personal Data:

Personal Data shall be processed lawfully, fairly, and in a transparent manner.

The Personal Data collected will only be those specifically required to fulfill SME Advantage SA’s obligations to deliver the SME Advantage SA service.

Personal Data shall only be retained for as long as it is required to fulfill contractual requirements.

Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.

The data subject has the right to request from SME Advantage SA access to and rectification or erasure of their Personal Data, to object to or request restriction of processing concerning the data, or to the right to data portability. In each case such a request must be put in writing to SME Advantage SA.

About the California Consumer Privacy Act (CCPA)

Effective on January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents to obtain certain information collected by the business with whom they have established business relationships.

If you are a California resident, you may exercise certain rights to access, restrict, or delete your personal information by submitting a request through this link.

Community

Our Services may include publicly accessible community services such as blogs, forums, and wikis. Please be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts on these communities may remain even after you cancel your account.

Questions, Complaints and Contacts

If you have any questions regarding this Privacy Policy, please contact us at [email protected], or by U.S. mail at the address below:

SME Advantage SA, LLC.

Attn: Privacy Officer

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