Privacy Policy

With this privacy policy we inform you about the scope of the processing of your personal data (hereinafter “data”) when you are using our website www.smartdaddy.app and web application https://smartdaddy-app.web.app. This privacy policy does not apply to linked website that are not owned and controlled by SmartDaddy. If you are using the mobile version of our Services, please refer to our Privacy Policy posted in the iOS and Android App respectively.

The SmartDaddy Service is a parental control service. Whilst accessing the web application and registering for the services, we are the Controller of the personal data you supply to us when registering for the services. However, whilst you are using our services and the features of the services (including but not limited to SMS tracking, call tracking, contacts, web history, apps history, screen time, screen capture, SOS functions) you are the Data Controller and we become the Data Processor. For further details, please refer to our Processing Agreement and direct any questions you may have us using support@smartdaddy.app.

In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the General Data Protection Regulation (“GDPR”).

Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website. However, we reserve the right to put this data to additional uses to the extent permitted or required by law or necessary to support legal or criminal investigations. In this case, we will inform you again about this further data processing to the extent required by law and obtain your consent.

SmartDaddy LLP
NOORAYINGANAKATH, 25/9 8, FIRDOUS MANZILPUNNATHIRUTHI, THRIKKAVU,
PONNANI MALAPPURAM, KERALA,
INDIA -679577

E-mail address: support@smartdaddy.app
Web: www.smartdaddy.app

In the course of our business and website and web-application operations, we process data. This also includes disclosure by transmission to third parties and, where applicable, to so-called third countries outside the EU and the EEA. Where we transfer data outside the EU or EEA, we have highlighted this accordingly below.

The individual data concerned, processing purposes, legal bases, recipients and, where applicable, transfers to third countries are listed below:

a) Log file during website visit
We log your website visit. In doing so, we process:

• Name(s) of our accessed web site(s),
• date and time of the access,
• the amount of data transferred,
• the browser type and version,
• the operating system you use,
• the referrer URL (the previously visited web site),
• your IP address,
• the requesting provider.

The legal basis for data processing is our legitimate interest in the ongoing provision and security of our web site in accordance with Art. 6 (1) f GDPR.

The log file is deleted after seven days, unless it is needed to prove or clarify specific legal violations that have become known within the retention period.

b) Contacting us
If you contact us per e-mail or our contact form, we process the following data from you for the purpose of processing and handling your enquiry: Name, contact details -if provided by you- and your message.

If you are using our send message feature, anonymised data is collected and stored using technologies provided by tawk.to, Inc, for the purpose of web analytics and to operate the send message feature used to respond to requests. Usage profiles can be created from this anonymised data under a pseudonym. Insofar as the information collected in this way has a personal reference, the processing is carried out in accordance with our legitimate interest in effective customer service and the statistical analysis of user behaviour for optimisation purposes.

We also offer visitors to contact us via the messaging service WhatsApp of WhatsApp LLC. If you contact us via WhatsApp, we process the mobile phone number you use on WhatsApp and – if provided – your first and last name.

The legal basis of the data processing is our obligation to fulfil the contract and/or to fulfil our pre-contractual obligations in accordance with Art. 6 (1) b) GDPR and/or our legitimate interest in processing your enquiry in accordance with Art. 6 (1) f) GDPR.

c) When you watch our explainer videos
We have integrated videos from the YouTube portal of YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, USA (“YouTube”). Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”) is responsible for data processing at YouTube. When playing the videos, however, log data is transmitted to YouTube’s servers in the USA.

The legal basis for the data processing is our legitimate interest in the optimal marketing of our online offer in accordance with Art. 6 (1) f) GDPR.

d) Comment function on our blog
For our blog, we use the services of medium.com provided by Medium Inc, Whilst we have no control or influence over how Medium process your personal data we would like to highlight that it’s your choice whether to include sensitive information in your comment and to make that sensitive information public. Please do not post or add personal data in your comment that you would not want to be available.

d) Registration
If you register for our services through the web application, we will request personal and, where applicable, non- personal data in accordance with our registration form this may include your email address and name. The entry of your data is encrypted so that third parties cannot read your data when it is entered.

The basis for this storage is our legitimate interest in communicating with interested users according to Art. 6 para. 1 lit. f GDPR and, in the case of contracts, also the storage of contract data according to Art. 6 para. 1 lit. b GDPR.

Your data will remain stored for as long as the registration lasts, in particular the storage is still necessary for the fulfilment/execution of the contract, for legal prosecution by us or for our other legitimate interests or we are required by law to retain your data (e.g., within the framework of tax retention periods).

e) Contract fulfilment and data management in the context of service provision
We process various data within the framework of the provision of our services and for the initiation and processing of the existing contractual relationship between you and us.

If you have commissioned us to provide a service, we process your data (if provided: Name, contact details, address, bank details, Child’s Name, DOB (optional) and gender (optional) and all information that is necessary in the context of fulfilling the services, exclusively for the purpose of processing and handling the contractual relationship. This includes in particular our appropriate advice and support, correspondence with you, invoicing, fulfilment of our accounting and tax obligations.

Accordingly, the data is processed on the basis of Art. 6 (1) b) GDPR as well as to fulfil our legal obligations pursuant to Art. 6 (1) c) GDPR.

For further details on processing whilst you are using our services and the features of the services (including but not limited to SMS tracking, call tracking, contacts, web history, apps history, screen time, screen capture, SOS functions), please refer to our Processing Agreement and direct any questions you may have us using support@smartdaddy.app.

f) Stripe
Payment by credit card and debit card is made via the payment service provider Stripe to which we pass on your mandatory details (e-mail address) provided during the checkout, for payment processing. Your data will only be passed on for the purpose of payment processing with the payment service provider Stripe and only insofar as it is necessary for this purpose. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.

g) Use of cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent in accordance with Art. 6 para. 1 a) GDPR as well as our legitimate interest in accordance with Art. 6 para. 1 f) GDPR.

We only store personal data for as long as it is necessary for the purposes for which it is processed or for as long as any consent you have given us has been revoked by you. Insofar as statutory retention obligations must be observed, the storage period for certain data may be up to 6 years, irrespective of the processing purposes.

SmartDaddy will not disclose or otherwise distribute your personal data to third parties unless this is necessary for the performance of our services (legal basis for processing: Art. 6 para. 1 lit. b) GDPR), you have consented to the disclosure (legal basis for processing: Art. 6 para. 1 lit. a) GDPR) or the disclosure of data is permitted by relevant legal provisions.

SmartDaddy is entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors for SmartDaddy pursuant to Art. 4 No. 8 GDPR within the framework of the data protection provisions. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations.

The service providers commissioned by SmartDaddy process your data exclusively in accordance with our instructions. SmartDaddy remains responsible for the protection of your data, which is ensured by strict contractual regulations, technical and organisational measures and additional controls by us.

Please note that this does not apply to any data provided by you or your child when using Parental Control services. For further details, please refer to our Processing Agreement and direct any questions you may have us using support@smartdaddy.app.

Personal data may also be disclosed to third parties if we are legally obliged to do so e.g., by court order (legal basis for processing: Art. 6 (1) (c) GDPR) or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil SmartDaddy’ legitimate interests (legal basis for processing: Art. 6 (1) (f) GDPR).

Automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR does not take place on the part of SmartDaddy.

We use the data you provide to fulfil and process our contract and to respond to your enquiries in accordance with Art. 6 (1) (b) GDPR or on the basis of your consent in accordance with Art. 6 (1) (a) GDPR. Insofar as you have also given us your separate consent to process your data for consulting, marketing and advertising purposes, SmartDaddy is entitled to contact you for these purposes via the communication channels you have given your consent to.

a) Information
Upon request, we will provide you at any time and free of charge with information about all personal data that we have stored about you.

b) Correction, deletion, restriction of processing (blocking), objection
If you no longer agree with the storage of your personal data or if this data has become incorrect, we will arrange for the deletion or blocking of your data or make the necessary corrections (insofar as this is possible according to the applicable law) on the basis of a corresponding instruction. The same applies if we are only to process data in a restrictive manner in the future. You have the right to object in particular in cases where your data is required for the performance of a task that is in the public interest or in our legitimate interest, as well as profiling based on this. You also have such a right of objection in the event of data processing for the purpose of direct advertising.

c) Right to revoke consent with effect for the future
You may revoke your consent at any time with effect for the future. Your revocation will not affect the lawfulness of the processing up to the time of revocation.

d) Data portability
If data is processed on the basis of a contract, pre-contractual negotiations, consent or with the help of automated procedures, you have the right to data portability. Upon request, we will provide you with your data in a common, structured and machine-readable format so that you can transfer the data to another data controller if you wish.

f) Exercise of your data subject rights and right of appeal
To assert these rights, please contact us. The same applies if you have questions about data processing in our company. You also have the right to lodge a complaint with a data protection supervisory authority. The Information Commissioner`s Office (ICO) is the for SmartDaddy Ltd relevant authority in matters of data protection. You have the right to make a complaint at any time to the ICO (www.ico.org.EU). We would, however, appreciate the chance to deal with your concerns before you approach the ICO in the first instance.

State-of-the-art internet technologies are used to ensure the security of your data. During the online enquiry process, your details are secured with SSL encryption. For secure storage of your data, the systems are protected by firewalls that prevent unauthorised access from outside. In addition, technical and organisational security measures are used to protect the personal data you have provided against accidental or intentional manipulation, loss, destruction or access by unauthorised persons.

We are present in various “social media” platforms in order to communicate with our customers, interested parties and users registered there and to be able to inform them about our offers there. We would like to point out that you use these platforms and their functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g., commenting, sharing, rating).

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behaviour and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. Cookies are usually stored on your computer for this purpose. Independently of this, data that is not directly collected from your devices may also be stored in the usage profiles (especially if you are a member of the respective platforms and are logged in to them).

We, as the provider of this information service, do not collect and process any data from your use of our service beyond this.

The processing of users’ personal data is based on our legitimate interests in providing users with effective information and communicating with users pursuant to Art. 6 para. 1 p.1 lit. f. GDPR. If you are asked by the respective providers for consent to data processing, the legal basis for processing is Art. 6 para. 1 sentence 1 lit. a., Art. 7 GDPR.

If you are a member of a social network and do not want the network to collect data about you via our website and link it to your stored membership data with the respective network, you must

• log out of the respective network before visiting our website,
• delete the cookies on your device and
• close and restart your browser.

After logging in again, however, you will once more be recognisable to the network as a specific user. In the case of requests for information and the assertion of user rights, we would also like to point out that these can most effectively be asserted with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so within your account or contact us. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

Our website also contains – clearly recognisable – links to the websites of other companies. Insofar as there are links to websites of other providers, we have no influence on their contents. Therefore, no guarantee or liability can be assumed for these contents. The respective provider or operator of the pages is always responsible for the content of these pages.

The linked pages were checked for possible legal violations and recognisable infringements at the time of linking. Illegal contents were not recognisable at the time of linking. However, permanent monitoring of the content of the linked pages is not reasonable without concrete indications of a legal violation. Such links will be removed immediately if infringements of the law become known.

Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal information from minors under the age of 18 without first obtaining consent from a legal guardian through direct contact.

We kindly ask you to regularly inform yourself about the content of our privacy policy. We will amend the privacy policy as soon as changes to the information processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g., consent) or other individual notification.

If you have any concerns about a possible compromise of your privacy or misuse of your personal information on our part, or any other questions or comments, you can contact us.