SMARTIST PRIVACY POLICY
This Privacy Policy is effective October 1, 2023. Please note that this Privacy Policy will be updated regularly to reflect any changes in how we process your personal data or any changes in applicable law.

Unless otherwise stated, this Privacy Policy (Policy) applies to all external Smartist applications, services, tools, websites and other data processing activities for which Smartist acts as a data controller (or any local equivalent).
On this page you will find what you need to know about how Smartist LLP (“Smartist”; “we”) protects the personal data we process and control about you (“your personal data”; “your data”) and what rights you have in relation to the processing of your personal data.

1. How does Smartist protect your personal information?

Your confidence that when you work with Smartist, your personal data is in good hands is important to us.
Smartist protects your personal data in accordance with applicable law and our data privacy policy. In addition, Smartist takes appropriate technical and organizational measures to protect your personal data from unauthorized or unlawful processing and/or from accidental loss, alteration, disclosure or access, as well as from accidental or unlawful destruction or damage.

Data we collect
We collect personal information from our employees, potential employees, clients and their current/former/potential employees/directors, suppliers, business contacts, shareholders and website users. If the information we collect is not described in this privacy policy, we will provide individuals (if required by law) with appropriate notice of what other information will be collected and how it will be used.
Below is a description of the categories of personal information we collect:
Personal details, contact details and identifiers:
Name, pronoun, all types of identifiers and contact information (e.g. email address, telephone numbers, physical address) and sometimes, when necessary for specific purposes, gender, date of birth, age, place of birth.

Commercial information:
History and records of products and services you received from Smartist. Correspondence between you and us when sent to a dedicated mailbox or through other means of electronic communication (including communication channels supported by artificial intelligence, which, for example, generates content to assist our staff in interacting with you), for the purpose of processing receivables, payments and commercial support.

Marketing and research information:
  • Identifiers - IP address, social media handles or other online identifiers of a person, email address/mobile number if used for direct marketing, and name and address
  • Demographic information - e.g. income, marital status, age group, gender, interests, pets, home ownership, health, current service providers
  • Browser/web history data and preferences expressed through selection/viewing/purchasing of products, services and content, information about your mobile device, including (if available) device type, device identification number, mobile operating system
  • Social media content - blogs, publications and everything that is published by a person on the Internet or in which that person is mentioned/linked
  • Analytics and profiles of people based on the data collected about them
  • Voice services (speech-to-text systems for search queries) without recording or storing on a mobile device.

Audiovisual materials, including transcriptions:
Photographs and images/videos taken/recorded by CCTV or other audio, video and related security/monitoring systems or taken during marketing/publicity shoots/events/sessions (including recordings of virtual or live seminars or similar events/sessions) and/or audio-video recording and transcription during meetings.

Information about the position and professional or work activity:
Professional or employment-related information such as current job description, job title, employer, location and Smartist contacts.

Access data to the system and applications, as well as information about activity on the Internet and electronic networks:
If you are granted access to Smartist systems, Smartist may collect information necessary to access such Smartist systems and applications, such as system ID, local network ID, email account, instant messaging account, mainframe ID, system passwords , as well as the Internet or other electronic means. information about network activity, including access logs, activity logs and electronic content created using Smartist systems.

Except for certain information that is required by law or Smartist policy, your decision to provide us with any personal information is voluntary. This way, you will not be adversely affected if you do not choose to provide us with your personal data. Please note, however, that if you do not provide certain information, we may not be able to achieve some or all of the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems that require the use of such personal information.

If you provide us with the personal information of another person (for example, a potential employee/referrer), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that that person has given you their consent to share the information with us Smartist.

For what purposes do we use your personal data?
Smartist uses your personal data only in cases where it is necessary for specific purposes:
  • managing our contractual relationship with you. This is necessary for the performance of a contract to which you are a party
  • facilitating communication with you to ensure proper communication
  • conducting and managing our business operations, including providing or forming part of our services to our clients and their employees/contractors and their clients, for example when collecting their data for surveys/assessments/psychometrics, data analytics, market research or other purposes - to ensure the proper functioning of our business operations
  • compliance with legal requirements is to comply with legal obligations to which we are subject
  • monitoring your use of our systems (including monitoring the use of our website and any applications and tools you use) - to avoid non-compliance and protect our reputation
  • improving the security and operation of our website, networks and information is based on our legitimate interests in providing you with an excellent user experience and the security of our networks and information
  • performing data analytics, which is the application of analytics to business operations and data to describe, predict, and improve business performance in Smartist and/or to provide a better user experience, including the use of artificial intelligence (e.g., machine learning). This includes marketing and event/meeting analytics to ensure the proper functioning of our business operations
  • advertising our products and services to you - to enable us to operate and expand our business
  • audio, video and transcription taken during live/recorded events and meetings (including virtual events/webinars) to inform interested parties about the content of such events/meetings (including online publication of recordings for marketing purposes) is based on your informed consent obtained before the event.

We will process your personal information for the purposes mentioned above based on your prior consent to the extent such consent is required by applicable law.
If you are asked to click/check “I Accept”, “I Agree” or similar buttons/checkboxes/features in relation to a privacy statement, this will be deemed to provide your consent to the processing of your personal information only where such consent is required by mandatory law.
We will not use your personal information for purposes incompatible with those of which you have been informed, unless required or permitted by law or unless it is in your own vital interests (for example, in a medical emergency).

Will we share your personal data with third parties?
We may share personal data with our service providers and professional advisors, government and government agencies, Smartist companies/affiliates or third parties in connection with the conduct of Smartist's business, including any (potential) corporate or commercial transactions, including clients where the data has been processed to provide customer services. Such third parties may be located in other countries. Before we do so, we will take reasonable steps to ensure that your personal data is adequately protected as required by applicable data privacy laws and Smartist's internal policies.
For example, we may disclose personal information to third parties for other business purposes as follows:
  • we share your information with third party service providers who provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, account maintenance or servicing, processing or fulfilling orders and transactions, verification customer information, research, data hosting, auditing and data processing
  • to protect the legal rights, safety and security of Smartist, our affiliates, users or the public, including protection from fraud and malicious activity; and
  • for other business purposes described in this privacy statement or for any other purposes disclosed to you at the time the information is collected or as permitted by your consent.

We may also share your information in connection with a significant corporate transaction, such as the sale of a website, merger, consolidation, sale of assets, or, in the unlikely event, bankruptcy.
Unless you are notified otherwise, any transfer of your personal data from the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or subject to standard contractual clauses (a copy of which can be obtained through the contact information provided below). Any other transfer of your personal data outside the EEA will be in accordance with relevant international data transfer mechanisms and standards.

About confidential data
We do not seek to collect sensitive data as defined in the second section of this Policy (also known as special categories in the EEA), through this site or otherwise. In the limited cases where we seek to collect such data, we will do so in accordance with the requirements of data privacy law and/or seek your consent.
The term "sensitive data" refers to various categories of personal data, such as racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, trade union membership, physical or mental health, biometric or genetic data, sexuality or orientation, and criminal convictions and offenses (including information about suspected criminal activity).

Data Security
We take market-leading security measures to protect your personal data. This includes (without limitation):

We are ISO27001 certified, indicating that we adhere to the highest and most stringent information security standards. This certification is the only auditable international standard that defines information security management system (“ISMS”) requirements and confirms that Smartist's security processes and controls provide an effective framework for protecting our customers' information and our own information.

Sources of information
Unless we receive your personal information directly from you, we may obtain it from the following sources: publicly available sources (registries or the Internet), Smartist employees, contractors, (potential) board members, shareholders, Smartist affiliates, employers of our contractors, our customers, government agencies, publicly accessible websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).

Personal data storage period
We will only store your personal data for as long as necessary, as set out below:

  • we retain your data for as long as we have an ongoing relationship with you (in particular if you have an account with us)
  • we will only store data for as long as your account is active or as necessary to provide services to you
  • we retain your data for as long as necessary to comply with our global legal and contractual obligations.

Your rights
You have the right (subject to the circumstances and conditions, and subject to any exceptions provided by applicable law):

Request access to the personal data we process about you: This right gives you the right to know whether we hold your personal data and, if we do, to receive information and a copy of that personal data.
Request correction of your personal data: This right gives you the right to have your personal data corrected if it is inaccurate or incomplete.
Object to the processing of your personal data: This right gives you the right to request that Smartist no longer process your personal data.
Request erasure of your personal data: This right gives you the right to request erasure of your personal data, including where such personal data will no longer be necessary to fulfill the purposes.
Request restriction of processing of your personal data: This right gives you the right to request that Smartist process your personal data only in limited circumstances, including with your consent.
Request portability of your personal data: This right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of the personal data you have provided to Smartist, or to request that Smartist transfer such personal data to another data controller.

If the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting a Smartist employee by email. Please note that this will not affect Smartist's right to process personal data obtained before your consent was withdrawn, or its right to continue some of the processing on legal grounds other than your consent.
If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome people to first contact Smartist to resolve any complaint.

2. How do we use personal information when you visit the Smartist website?

In addition to the information set out above, the following paragraphs describe how we use personal information when you visit the Smartist website:

What personal data do we collect?
Smartist collects personal information on its websites in two ways: (1) directly (for example, when you provide personal information to complete an application with the company). If you contact us, we may keep a record of that correspondence.
And (2) indirectly (for example, through our website technology).
Our website or mobile applications may collect personal information about your computer or mobile device, including (if available) your IP address, operating system, device type, device identification number, mobile operating system and browser type, for system administration and filtering purposes . traffic, to search for custom domains and compile statistical reports.

Do we include (links to) third party websites and programs?
Our websites may include:
Links to the sites of our partners, client companies and their branches.
Certain programs (widgets and applications) of third parties. In this case, please note that such third parties may process your personal data collected through such programs for their own purposes.
We do not accept any responsibility for the sites or programs of such third parties. Please review the terms of use and privacy statements of such third parties before using or providing any information to such third party sites or programs.

How do we use the personal information we collect on our websites?
We use personal data for the purposes described in Section 1 “For what purposes do we use your personal data” above, and to provide you with information you request, process online job applications and for other purposes that we describe to you at the time collection. We analyze your IP address and browser information to determine what works best on our website and to help us identify ways to improve it and make it more effective.

3. Contact us
Please contact us by email if:
You have a general question about Smartist protects your personal information how.
You wish to exercise your rights in relation to your personal data rights as set out in the sections of this Privacy Policy or you wish to make a complaint about Smartist's use of your data.
You can also contact us by letter to the address of the company's location.
hello@smartist.dev
050008 Abaya Avenue -115 Almaty, Kazakhstan