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Smart Start® EU Privacy Policy

Smart Start, LLC values you as a customer and respects your right to privacy. We know that you purchase our products and services because you trust that we will stand behind our promises. We pledge our commitment to treat your information responsibly. We created this Privacy Policy to show you that we are working hard to protect your privacy.

Smart Start, LLC acknowledges concerns about the collection and transmission of personal information over the Internet and other Web-based applications. Thus, we have established standards and procedures regarding the collection and use of customer information. We have also taken steps to protect the information you provide from unauthorized use or disclosure.

Smart Start, LLC (“us”, “we”, or “our”) operates the http://www.smartstartinc.com website, provides monitoring services to monitoring authorities in various municipalities all over the world, as well as provide hosted services for distributors in countries inside and outside of the U.S. (the “Service”).

This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.

We will not use or share your information with anyone except as described in this Privacy Policy.

We use your Personal Information for providing and improving the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

EU-US Privacy Shield

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “EU-US Privacy Shield”). The EEA also has recognized the EU-US Privacy Shield as providing adequate data protection (Directive 95/46/EC). Consistent with our commitment to protect personal privacy, Smart Start, LLC certifies that it complies with the principles of the EU-US Privacy Shield as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Smart Start, LLC is subject to the investigatory and enforcement policies of the Federal Trade Commission.  To learn more about the EU-US Privacy Shield program, and to view Smart Start, LLC’s certification, please visit https://www.privacyshield.gov.

If you are a European Data Subject with an unresolved complaint or dispute arising under the requirements of the Framework, we agree to refer your complaint under the Framework to an independent dispute resolution mechanism. That independent dispute resolution mechanism is JAMS alternative dispute resolution (ADR) provider. For more information and to file a complaint, you may contact JAMS at https://www.jamsadr.com. In addition, under certain conditions, more fully described on the Privacy Shield website, EU data subjects may invoke binding arbitration for non-monetary issues when other dispute resolution procedures have been exhausted.

Scope

This EU-US Privacy Shield Privacy Policy applies to all personal information received by Smart Start, LLC in the United States from the EEA, in any format, including electronic, paper or verbal. We are committed to subjecting such EU Personal Data to the Framework, including its Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability.

Information Collection and Use

Smart Start, LLC may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personal information will only be collected from the forms that you voluntarily submit to us through the survey process and other transactions you may initiate through this website, mobile app, phone calls, and in-person verbal communication. Personally identifiable information may include, but is not limited to, your email address, name, phone number, postal address, other information (“Personal Information”).

We collect this information for the purpose of providing the Service, identifying and communicating with you, responding to your requests/inquiries, and improving our services.  We may also use the information provided to make available special offers.

In some instances, Smart Start, LLC may provide software hosting services to Independent Distributors who may themselves collect personal information directly from individuals in the EEA. Where Smart Start, LLC receives, stores, or processes personal information from our Distributors in the EEA, we will use and disclose such information in accordance with the notices provided by our Distributors, only if consistent with the EU-US Privacy Shield Principles, and the choices made by the individuals to whom such personal information relates. We will endeavor, as much as is practicable, to enable our Distributors to publish and follow the EU Data Protection Directive on their websites and in all contact with their clients to whom they provide Services.

SHARING OF PERSONAL DATA – ONWARD TRANSFERS

Smart Start, LLC does not transfer data collected or maintained by or for EU clients to third parties outside of its Distributors and Affiliates. All Distributors and Affiliates enter into a contract with Smart Start, LLC which requires them to safeguard personal information consistent with this Policy, and at least the same level of protection as is required by the relevant EU-US Privacy Shield Principles being subject to EU Directive 95/46/EC (the EU Data Protection Directive), EU-US Privacy Shield certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada).  In the event that Smart Start, LLC becomes aware that a Distributor or Affiliate is using or disclosing personal information in a manner contrary to this Policy or the EU-US Privacy Shield Principles, Smart Start, LLC will take reasonable steps to prevent or stop the use or disclosure.  Smart Start, LLC complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions, and is liable for appropriate onward transfers of personal data to third parties.

INTERNATIONAL TRANSFER

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we may transfer the information, including Personal Information, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. These servers are subject to the same security standards as those used to store the information in the EU.   Access to the data stored on these servers is limited to the same Smart Start, LLC employees and its distributors.

Log Data

We may also collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information to increase our Service’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and transferred to your device. We use cookies to collect information to improve our services for you.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provides information on how to accept cookies, disable cookies or to notify you when receiving a new cookie.

If you do not accept cookies, you may not be able to use some features of our Service. Therefore, we recommend that you leave them turned on.

Service Providers

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services and/or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.

Compliance with Laws

We will disclose your Personal Information where required to do so by law, subpoena, if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement, or to protect the security or integrity of our Service.

Access

Personal information is limited to Smart Start, LLC employees and approved distributors, and third parties where required for the operation of business duties. Note that these authorized personnel accessing information are required to sign a confidentiality agreement and privacy agreement. As stated in these agreements, Smart Start, LLC employees, its distributors, and approved third parties will not collect, use, disclose, alter, retain or destroy personal information except in accordance with Smart Start, LLC, its distributors, relevant government bodies, approved third parties, the courts, or law enforcement agencies.

Personal information, including monitoring data and other related information, will be shared with the relevant government bodies and third party assessment agencies where required by contract and law. Additionally, monitoring data may be shared with other third parties if permission has been given for such an arrangement.

Smart Start, LLC will not intentionally disclose the information collected from you via this website, mobile app, phone calls, and in-person verbal communication to any person or entity outside of Smart Start, LLC and its affiliates without your permission unless disclosure is: a) necessary for us to conduct the business of; b) required or permitted by law; and c) to research, actuarial, or other organizations for the purposes of conducting studies.

On request, Smart Start, LLC will take reasonable steps to let the client know, generally, what sort of personal information we hold about them, for what purposes, and how we collect, hold, use and disclose such information.

Quality

Smart Start, LLC takes reasonable steps to make sure that the personal information we collect, use, and disclose is accurate, complete, and up-to-date. Individuals may also contact Smart Start to have their information updated.

Smart Start, LLC’s hosted services provide several methods to ensure correct information is collected, including data masks, input data validation routines, and several data integrity reports to alert distributors of possible data entry errors or omissions.

Security

The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store in order to protect it from unauthorized access, destruction, use, modification, or disclosure.  Smart Start, LLC will take reasonable precautions to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Smart Start, LLC endeavors to limit access to Personal Data to our personnel that have the specific business purpose of maintaining and processing such Personal Data. Smart Start, LLC´s personnel who have been granted access to Personal Data are aware of their responsibilities to protect the security, confidentiality and integrity of such information. Smart Start, LLC has also put in place appropriate procedures to safeguard and secure the information. These methods of storing the information are in place to help safeguard the information you provide to us. However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.  Please note that e-mail communications sent over the Internet may be subject to viewing, alteration or copying by other parties. Smart Start, LLC is not responsible for the security of communications sent to us via the Internet and e-mail. If you wish to communicate sensitive information to us regarding your business, please feel free to contact us via the telephone or the postal service to ensure confidentiality and security of your correspondence.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Choice and Updating Your Information and Preferences

On your request, we will grant you reasonable access to your Personal Information that we hold, as well as such other related rights as are provided by applicable law. In addition, we will take reasonable steps to permit you to correct, amend or delete your Personal Information that you demonstrate to be inaccurate or incomplete. However, in accordance with applicable law, we may limit or deny access to your Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the legitimate rights of persons other than you would be violated. We reserve the right to take reasonable steps to authenticate the identity of any individual seeking access to Personal Information.

We may provide web pages or other mechanisms on our Sites through which you can correct or update your Personal Information, or elect to change your preferences regarding our future use or sharing of your Personal Information with third parties for marketing purposes. You can also contact us to update your Personal Information or change your preferences via phone or by email.

If you receive a marketing communication from us by email, you may also opt out of receiving future email marketing communications by following the opt-out instructions provided in that email. Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Sites, or other business matters, and that these communications may be unaffected if you choose to opt-out from marketing communications.

In accordance with our routine record keeping and applicable law, we may delete certain records that contain your Personal Information. We are under no obligation to store such information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of that information. In addition, you should be aware that it is not always possible to completely remove or delete all your information from our databases without some residual data because of backups and other reasons.

Children’s Privacy

Only persons age 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”).

We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a child under age 13 without verification of parental consent, we take steps to remove that information from our servers.

Contact Information

Questions or comments regarding this Policy should be submitted to Smart Start, LLC at:

Smart Start, LLC
500 E. Dallas Rd, Suite 100
Grapevine, TX  76051
United States
Phone: 1-800-880-3394

Notice of Changes or Revisions

This Privacy Policy is effective as of June 15, 2017 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

EU Privacy Policy for www.smartstartinc.com

Updated on: June 15, 2017