Privacy Policy

Effective as of October 14, 2019
This Privacy Policy is expressly incorporated into the Smartsub Terms of Service and is an essential part of the Agreement to which you are bound if you access or use the Smartsub web application, the www.smartsub.co website ("Website") and service (together, the "Smartsub Service"). Terms used but not otherwise defined in this Privacy Policy have the definitions included in the Smartsub Terms of Service. This Privacy Policy describes how we collect and use the information you may provide or may be accessible to us when using the Smartsub Services.

Please read the entire Agreement, including this Privacy Policy, carefully before accessing or using the Smartsub Service. Your accessing or using any part of the Smartsub Service evidences your agreement to be bound by the terms and conditions of the Agreement, including this Privacy Policy. If you do not agree to all the terms and conditions of the Agreement, including this Privacy Policy, then you may not access or use the Smartsub Service.

1. Collection of Information.
The Smartsub Service allows you to build a Google Ads campaign. Through your use of the Smartsub Service, we may have accessto and/or collect various types of information:

a) Personal Information. When you use the Smartsub Services, you may provide us with your personally identifiable information either directly or through third party data sources you connect to the Smartsub Services ("Personal Information"). This Personal Information may include your e-mail and credit card number when you pay for the services via PayPal or any other trustful acquiring system. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in thee-mail, so that we may send you a reply.

b) Confidential Information. When you use the Smartsub Services, in addition to Personal Information, you may provide us with information that we should reasonably know is confidential and that you expect to be treated as confidential either directly or through third party data sources you connect to the Smartsub Services ("Confidential Information"). This Confidential information may include link to your website address, geolocation,text of advertising, list of search keywords and number of phone calls and/orrequests from the website.

c) Web-Browser Cookies. The Smartsub Services may use "cookies" to enhance your user experience. Your web browser may place cookies on their hard drive for record-keeping purposes and sometimes to track information about them. You may choose to set your web browser to reject cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of the Website may not function properly. Please also note that"cookies" are used to collect general usage and volume statistical information that does not include personal information.

d) Web Beacons. Our Website may also contain electronic images known as Web beacons (sometimes called single-pixel gifs) that are set by our service providers or business partners. Web beacons are used along with cookies enabling us and/or our partners to compile aggregated statistics and analyze how our Website is used. We may use a third party service provider or our business partners to gather information about how you and others use our Website. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Website is used.

e) Links to Other Web Sites. Our Website may include links to other web pages whose privacy practices may differ from ours. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

f) Computer Information. Like most websites, we automatically gather information about your computer such as your IPaddress, browser type, referring/exit pages, and operating system.

2. Use of Information.
Our primary goals in collecting information are to provide and improve the Smartsub Services, to administer your use of the Smartsub Services and to enable you to use and easily navigate the Smartsub Services. We may use your Personal Information or Confidential Information to let you know about products or services which may be of interest to you or to personalize the Smartsub Service to meet your needs or preferences. This may involve sharing certain Personal Information or Confidential Information, with affiliated companies or third parties.

We may use your Personal Information or Confidential information to improve the Smartsub Services, and to deliver the Smartsub functionality to you and your team and to improve the performance of our proprietary prediction and estimation models.

We may share your Personal Information or Confidential information with our service providers, business partners, subsidiaries and affiliates and if we do, we will require those third parties to protect your Personal Information and Confidential Information in compliance with the terms of this Privacy Policy. We do not sell, lease or transfer your Personal Information or Confidential information to third parties, but we may and sometimes shall disclose your Personal Information or Confidential information if any one of the following circumstances occur:

— as required by law such as to comply with a subpoena, or similar legal process;

— when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

— if we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;

— to any other third party with your priorconsent to do so.

We also may anonymize or aggregate Personal Information or Confidential Information with the Personal Information or Confidential information of other users (e.g. average performance indicators) so that the information does not identify you and does not identify you as a source of data. Such anonymized or aggregated information does not constitute Personal Information or Confidential Information and we reserve theright to sell, lease or transfer that information now or in the future.

3. Public Information.
If you are a user of Smartsub Services, we may ask you publicly to present your case on our Website. We will not publicly present your personal information like first and last name, photo or avatar in messenger, website address and direct massages you provide to Smartsub, but may show results from your Ads campaign with graphs and numbers.
4. Information Security.
These curity of your Personal Information and Confidential Information is important to us. We follow generally accepted industry standards to protect your Personal Information, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100%secure, however. As a result, we cannot guarantee its security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of information at any time. If you have any questions about security in using the Smartsub Service, please contact us at hello@smartsub.co.
5. Updates to Information.
If you would like to review or update your Personal Information, please contact us at hello@smartsub.co. If you ever decide to delete your account, you may do so by emailing hello@smartsub.co or deleting the conversation in messenger. If you terminate your account, any specialist between your account and information we store will no longer be accessible through your account. However, given thenature of sharing on the Smartsub Services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
6. Changes to Privacy Policy.
We may update and amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we amend this Privacy Policy, we will notify you byposting an announcement on the Website. If we make any material changes to this Privacy Policy, we may also choose at our discretion to notify you through the Smartsub Services and/or by sending you an email. You are bound by any update and amendment to the Privacy Policy when you keep using our Website and the Smartsub Services after such update or amendment has been first posted on the Website. We encourage you to periodically review this page for the latest information onour privacy practices.
7. Contacts.
If you have any questions, comments or requests regarding the Privacy Policy, please contact us at hello@smartsub.co.
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