SmartRM® Privacy Policies


GENERAL

These Privacy Policies describe how SmartRM, Inc., a company incorporated under the Laws of Delaware, with registered office in VDC Center U, Mass Boston W, 100 Morrissey Boulevard, Boston, MA 02125, United States of America (hereinafter “SmartRM” or “We”, such definition including any affiliate or sister company owned by, or owning itself, SmartRM) collects your personal information when you visit SmartRM pages (www.smartrm.com, hereinafter the “Website”) and when you use SmartRM product and services, including the Software (as defined in our Software License Agreement).

SmartRM Website, products and services including SmartRM Software are intended for adult audiences only: SmartRM acts accordingly and does not intentionally collect personal information from anyone under 18 years of age.

As a visitor to the Website, you can merely act as visitor without any need or obligation to proactively submit your personal information. Nevertheless, in connection with other activities, such as downloading hosted SmartRM products and services, including the Software, SmartRM may ask you to provide some of your personal information by submitting a form. It is optional for you to engage in the activities offered by SmartRM, therefore it is also optional to complete such form and provide SmartRM with your personal data. Nevertheless, if you decide to abort your sign up process and you decline to provide us with your data, We may not be able to provide you any of our product or services. Please note that some of the data required within the form will be considered mandatory (and will be identified trough the symbol “*”) to proceed: mandatory data may be your first name, last name, company name and email address. Similarly, if you decide to withdraw your consent and delete the mandatory information once you have signed, you may not be able to engage in our products and services any longer.

SmartRM uses your information for the following general purposes: provide you any SmartRM products and services you decide to download; improve our services; identify bugs or mistakes; give instructions to you on the correct use of our products and services; record and track your use of our products and services; provide technical support and customer care services to our clients; respond to competent Authorities’ requests. SmartRM may also use aggregate, non-identifying or encrypted data for statistical analysis purposes. We also wish to make you aware of the fact that We may determine whether the systems you use meet the minimum requirements to use our products, and in relation to that We reserve the right to deliver information to you concerning compatibility and interoperability.

Should We cease from delivering SmartRM products and services for free, We may then use your data for billing and invoicing purposes.

SmartRM may also send you updates, official communications, notice of marketing initiatives, commercial offers, provided you released your consent to this extent in compliance with applicable laws.

DATA SHARING

SmartRM hereby declares that your data shall not be sold or shared with third parties without your previous consent, according to applicable laws. In particular, SmartRM represents that your data may be subject to disclosure under the following circumstances:

COOKIES

As is happens on most Websites, We may collect certain information and save it in log files. Those information may be comprehensive of Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP) and running operating system. While you surf on the Website, SmartRM may set and install session and permanent cookies on your computer. Use of cookies is necessary to enhance users’ experience and facilitate your surfing activity on the Website. A “cookie” can be defined as a little set of data, a “pixel” that is installed on your browser by a Web server and can only be read by the same server from which it has been originated. Cookies work as to recognize you when you surf on the Website and move from page to page on it. You can disable cookies by changing your browser options or delete them in the relevant folder of your computer.

SECURITY

SmartRM has built security systems, including administrative, technical and physical measures, to protect your personal information (including those processed within the Contents you share trough the Software) while you surf on the Website, use the Software or any other SmartRM products and services.  SmartRM shall use any reasonable efforts to ensure that only relevant and authorized employees and contractors will have access to your data, exclusively for purposes relating to their role within our company and the provision of our products and services. In any case, you are also required to contribute to your own safety by periodically changing you password, ensuring your data are accurate, true and correct, updating your personal information when necessary, running antivirus on your computer on a regular basis, making sure you use safe and protected browsers.

CHANGES TO THIS PRIVACY POLICY

SmartRM may update this policy from time to time to respond to legislative change or variations to the relevant characteristics of SmartRM products or services. The binding version of this privacy policy shall then be the one available on the Website at the URL: www.smartrm.com/privacy and not the one proposed to you at the time you sign up for any of the SmartRM product or services, including the Software. We will notify you about significant changes in the way We collect, manage and process personal data by publishing a note on the Website, sending you a notice of update on the email address you released at the time of sign up for a SmartRM product or service, or by linking these privacy policies from the Website homepage.

THIRD PARTIES’ DATA

SmartRM Software enables you to share Contents (as defined in our Software License Agreement) with third parties, including family members, friends or colleagues according to your choice. To fulfil your use of the Software, SmartRM may require you to release and disclose personal information about the persons to whom you are sending the Contents such as their name, physical address, email address, and so on. The personal information you provide about any person is used only for the purpose for which it is collected. SmartRM will not use any of those information to target the intended recipients of your Contents for commercial or marketing purposes.

INTERNATIONAL USERS

Please consider that, especially if you reside within the EU, your data may be processed jointly by SmartRM and SmartRM S.r.l., a company incorporated under the laws of Italy whose registered offices are in Torino, Corso Corso Castelfidardo 30a, c/o I3P: your personal data that you decide to submit in the registration form, as well as any third parties’ data (subject to restriction under the previous paragraph) will be then collected, stored and processed on our proprietary servers in our server farm located therein.  The personal information practices set out in this privacy policy apply each and every SmartRM users worldwide regardless their respective native or residence Country.

COMPLAINTS – QUESTIONS

We hereby wish to inform you that our Software, as Well as any other SmartRM products and services, should be considered in to be a test phase. Therefore, We may not always be able to prevent or identify an unintended privacy issue, despite our efforts to do so. SmartRM is not in the position of providing a full guarantee on an error-free performance under this privacy policy. We will use any reasonable efforts to comply with this privacy policy and the applicable regulation on data protection; We are also keen to react to any breach of this privacy policy should We be notified of any failure to act accordingly. SmartRM shall not be considered liable for any incidental, consequential or punitive damages relating to this privacy policy,  governed by the laws of the United States. For any questions, concerns or notification regarding your privacy please feel free to email SmartRM at [email protected].

You can also send us questions trough ordinary mail at the following address:

SmartRM, Inc.
VDC Center U, Mass Boston W,
100 Morrissey Boulevard,
Boston, MA 02125

Or at

SmartRM S.r.l.,
Corso Corso Castelfidardo 30/a, c/o I3P
10129 Torino