Last Update: September 14, 2012
Smartt considers User privacy and data integrity to be of great importance. The following Agreement demonstrates our firm commitment to data integrity and User privacy and outlines our policies and procedures in relation to all data collected. By using Smartt services and products, all Users agree to be bound by this Agreement. It is the responsibility of all Users to comply and stay up to date with changes made to this Agreement. For the purposes of this Agreement, the term “User” includes, but is not limited to, any visitor to the smartt.com, or similarly Smartt owned high level domain or sub-domain websites, Users engaging in any content sharing, discussion boards, e-mailing or other social media activity on Smartt platforms, forums and other similarly administered sites, and Customers engaging in any communication or activity using Smartt Services whereupon data is transmitted to, from, or through Smartt owned or leased network and computer equipment.
Types of Data Collected
During the course of business, Smartt or its agents may collect data related to Users through the following methods:
- Automated means such as communication protocols and Cookies
- Online web based registration and online sign-up forms
- Sales inquiries, invoicing and transactions
- Online User communications including e-mail, social media, forums and other mediums
- Offline communications and interactions including in-person, telephone communication or by regular postal service
- Third party sources of information
Depending upon the method of collection and purpose of the data collected, the data collected may include information about the User such as name, title, address, company, phone number and e-mail address, or financial and transaction information such as credit card, CVV or CVC numbers, expiry dates or bank account details and payment information, or information about use of Smartt web sites such as electronic communications protocols, web pages visited, and Cookies and User preferences and privileges.
Electronic Communication and Cookies
For the purposes of quality control and to better facilitate customer support and employee training, Smartt may randomly record telephone conversations in whole or part and store this information on internal company equipment and servers. Such data storage will be executed with the same level of security as other equally sensitive data storage of customer information. Smartt may associate such random recordings with specific case or trouble ticket numbers, which may in turn be associated with a User or Customer profile and used as reference to assist in future troubleshooting, user experience improvement and Service delivery improvement.
Managed Online Profiles
As part of the delivery of certain Services, Smartt may, with the permission and authorization of Customer, manage online profiles for certain Customers. Online profile management may result in the Customer providing Smartt with proprietary, copyrighted, trademarked or other Customer and User specific information including Customer generated content, media and press information and instructions for how to delivery, display and otherwise relay such information, to the best of Smartt's ability, to the general public as part of an online marketing effort or targeted campaign. Such information may then be displayed on third party sites.
How Smartt Uses Collected Data
Smartt collects data from Users for the following purposes:
- To engage in transactions for service. Name, address, circuit numbers, telephone numbers, email, purchase details, and credit card/payment information may be collected and stored as part of the transaction history. The majority of the data collected under this category is contact information. Smartt may need to share some of this data (address, payment) with credit card clearing houses, banking institutions, and other similarly situated third parties that are required to accomplish the transaction.
- To provide future service or support. Information collected for this purpose is both contact data and information related to products and service/support requested. This information can include address details, circuit numbers, telephone numbers and other physical location details. This information is used to provide service, product updates, notices or migration support.
- To select content. Data may be collected to help create web site content and navigation that is most relevant and User friendly. This includes data collected as a result of site navigation as well as data provided in forms.
- To respond to User inquiries and requests for information. This data includes registrations for online newsletters, opt-in mailing lists and specific requests for further information.
- To provide various Smartt communities, such as resellers, with relevant product alerts and updates. These updates are related to product releases, pricing, terms, special offers and associated campaigns. This data is sent out as part of the program signing up for the relevant program or online account.
- To better tailor marketing to User needs. We may use information from purchases and requirements to provide User with timely and pertinent notices of product releases and service developments that address User needs and requirements.
- To better respond to requests for service or quotes for product and equipment purchase. Smartt will pass contact information to the appropriate Smartt sales person, reseller for follow-up related to Smartt products or services.
- To provision services. Some services require that we share non-financial information with third party telecommunications companies. This data usually relates to physical location and contact information and does not contain financial information.
If a User elects to use our Spread TheSmartt or similar referral or reseller program for informing partners, associates, resellers or Users about our site, products and services, we may request specific information such as name, email address, mailing address or other contact information to be collected. Smartt will use this information only for the purposes of contacting the User for administrative, provisioning or other processes required to provide Services or verify interest in the appropriate program. Smartt may also use this information for tracking the success of our referral programs. There are parts of the web site that permit Users to participate in interactive static and live discussions. Some of these are moderated; all are subject to access for technical reasons. Smartt does not control the content that Users post and some may serve as public discussion forums, frequently asked questions databases and other venues for common discourse. As in any interactive forum open to many Users, individual Users should carefully consider what data is shared or made public. Smartt reserves the right to remove offensive, derogatory, racist, sexually suggestive, oppressive or otherwise inappropriate material.
User Portal, User Customization, Preferences and Opt-Out
Smartt maintains, updates, removes and adds to many User portals. Different Users gain access to different portals including, but not limited to, the Smartt Webmail Portal, User Statistics Portal, Smartt Trouble Ticketing Portal, Domain Registration and Domain Management Portal. New Users are automatically registered for access for various Portals. The various Portals allow Users the ability to create Users, add/delete Users, add/delete User privileges and opt in (or out) of services and mailing lists. The Portals provide Users with control over their preferences for electronic information delivery. Smartt also creates a main Super User and assigns such a User with the ability to manage accounts or profiles. Smartt maintains the data and allows Super Users to update such data at any time. To change this information, a Super User must be a current User and login with a User ID and password and follow the prompts to make various modifications. All Users are responsible for the safe keeping of various passwords, usernames, private information and other User specific data. Super Users become the main contact for account modification requests made by individual Users. Smartt continues to expand the portfolio of services and information that Users may access, update and opt out of. Some communications are not subject to general opt-out. These include communications about sales transactions; information about critical updates and services notifications, Smartt operational changes; disclosures to comply with legal requirements; and network upgrades or other related service maintenance which materially affect the delivery of various services.
Smartt is concerned with the security of the data collected and has in place commercially reasonable measures to prevent unauthorized access to such information. These measures include network security, policies, procedures, employee training, physical access and technical elements relating to data access controls. In addition, Smartt uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as bank details and credit card information. In the event that individual personal data is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Smartt will notify the affected individual of the breach in writing by electronic mail. Notice will be given promptly, unless cooperation to delay is required by law or as part of a criminal investigation. All reasonable efforts will be made to determine the scope of the breach and to assure or restore the integrity of the system or data breach.
Third Party Policies
Smartt sites may contain hyperlinks, electronic mailing links or references to third party sites and information. Such information may be posted by Smartt staff or authorized agents or may be a result of a forum or other social media posting. Smartt is not responsible for the accuracy or safety of such information and provides links to such third party content for reference and educational purposes only. Smartt may not necessarily condone the views and information presented on such third party content and is not liable for any harmful effects the viewing or availability of such content may incur on the User.
During the normal course of business, Smartt may update and modify this Agreement. It is the responsibility of the User to review this site continuously and diligently monitor changes accordingly. In the event that Smartt uses User data in a manner different from that stated at the time of collection, the User will be notified via the electronic mail address on file. In the event of any material change to this Agreement, Smartt will notify the User by electronic mail or post a prominent notice on this web site notifying Users of the change. In some cases where we post the notice we will also email Users who have opted to receive communications from us, notifying them of the changes in our privacy practices.
Smartt monitors all traffic on its network in order to assess accurately User and Customer usage statistics. This information is safeguarded according to internal company policies and guidelines. Smartt may use this information for billing purposes, assess overuse charges for various Services, provide network details including usage trends and analyze User responses to website changes. Users are able to access total data usage using the Smartt data statistics portal using the appropriate login. This portal can be found on the Smartt website. Administrators, officers, directors and other duly appointed representatives of a company may also request specific usage information from Smartt in order to comply with legal requirements or internal company audits. Such usage data will be released only to authorized personnel on file and at the discretion of Smartt. Smartt will not release communal or shared log files, only those which contain the data files of the Customer in question. Log files are available for the previous nine (9) calendar months. Each log file request results in a $125 administrative fee charged to the Customer. The administrative fee must be paid prior to log file tabulation and release to Customer.