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. Information We Collect.
The Personal Information that we may collect broadly falls into the following categories:(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service or communicate with us in any other way.We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in privacy policy.This information may include:Registration information: You need a Google account to use the Services as a Member. When you register for an account, you will be asked to provide certain basic information, such as your name, email address, username, password.Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your credit card details and billing address. Smartsub will also maintain a record of your billing transactions and purchases, and any communications and responses.Information we process on your behalf: In order to connect and manage Google Ads and/or Analytics, you need to give access of that functions to Smartsub. We use and process this information to provide the Services in accordance with your instructions.(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement here.This information may include:Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.(iii) Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and services.Device information: We may collect information about the type of device and operating system you use. We do not ask for, access, or track any location-based information from your mobile device at any time while downloading or using our mobile apps or Services.B. Use of Personal Information
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see the "Our Security" section of this privacy policy.
To send you system alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.
To communicate with you about your account and provide customer support. To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations. To improve that process, we have software that helps us find email campaigns that may violate our Terms of Use.
To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
To prosecute and defend a court, arbitration, or similar legal proceeding.
To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
To provide, support and improve the Services. For example, this may include sharing your or your Contacts' information with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws.
Combined information. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.
To enable your use of the integrations and plugins you choose to connect to your Smartsub account. For instance, if you choose to connect a Google integration to your Smartsub account, we'll ask you to grant us permission to view and/or download, as applicable, your Google Sheets, Google Contacts, Google Analytics and Google Drive. This allows us to configure your integration(s) in accordance with your preferences.
Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
C. Cookies and Tracking Technologies
We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.
6. 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.
7. 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.
8. Contacts.
If you have any questions, comments or requests regarding the Privacy Policy, please contact us at hello@smartsub.co.
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