Last Updated: January 6th, 2023
You understand and agree that SME may store and process your personal information on computers located outside of the European Union, including, but not limited to, in the United States. By using the Services, you agree to the collection and processing of your personal or personally identifiable information outside of the European Union.
By providing SME with your personal or personally identifiable data and using the Services, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use the SME Services and please do not provide personal information to us.
- Personal Information Collected.
When you use the Services, we may collect personal or personally identifiable information from you (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data.
We may collect and process the following categories of PII about you:
- Communication Data. Communication data includes any communication that you may send to us through the Services, email, or social media. We process this data to communicate with you, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. SME’s lawful ground for processing this communication data is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.
- User Data. User data includes data about how you use the Services and any data that you post to or authorize through the Services. This includes data stored in persistent cookies when you login to the Services and analytics data that is collected when you use the Services. We collect and process this data to operate the Services, to authenticate you as a user of the Services, to ensure that timely and relevant content is provided to you, to secure the Services, to ensure that the Services operates in a fast and efficient manner, and to maintain backups of the Services. SME’s lawful ground for processing this user data is its legitimate business interests in administering and offering the Services.
- Technical Data. Technical data includes data about your use of the Services, such as your IP address, your login data, your phone number, your mobile device model, your operating system, your geolocation, and your time zone. SME may collect this data from your use of the Services and from advertising IDs. SME processes this data to analyze your use of the Services, to route Services traffic, to administer and secure the Services, to provide location-relevant content, and to troubleshoot problems with the Services. SME’s lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy.
- Marketing Data. Marketing data includes data about your preferences in receiving and interacting with SME’s advertisements or content on the Services. SME collects this data from your use of the Services and from advertising IDs created through advertising programs, such as Google Advertising IDs, TikTok Advertising IDs, and Apple Advertising IDs. SME does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. SME’s lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Services and to grow its business and marketing strategy by providing advertisements, including remarketing advertisements, to you.
- Financial Information. If you decide to link financial accounts that you hold with a financial institution (“Financial Account”) to your User Account, we will collect certain information from you about your Financial Account, such as your online login credentials, your transaction information, amount of funds, and other information about you and your Financial Account (“Financial Information”). SME will use your Financial Information to provide you the Services. SME’s lawful ground for collecting Financial Information is your consent, which is given when you link your Financial Accounts to your SME User Accounts.
- Personally Sensitive Data. Personally sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, or information about your health. SME does not collect or use personally sensitive data through the Services.
SME will only use your PII for the purpose for which it was collected. In the event that SME needs to use your PII for an unrelated new purpose, SME will provide you with notice of this new use and will explain the lawful ground for such processing. SME may process your PII without your knowledge or consent where required or permitted by law.
SME does not use your PII to automatically make any decisions or to create an automated profile about you.
- Collection of Data From Third Parties.
SME may collect data about you through cookies and other technologies. This helps SME understand how you use the Services and to understand any patterns that may be associated with your use of the Services. This aids SME in developing or improving its Services in response to your needs or wants.
SME may use session or persistent cookies. Session cookies are only stored on your computer or mobile device during your use of the Services and are automatically deleted when you close your web browser. Session cookies may be used to direct internet traffic to a server that is closer to you or to allow us to identify you as you move between pages of the Services. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the Services that created the cookie when you revisit it again. SME may use persistent cookies to authenticate you when you return to the Services so that you do not have to login again or when it utilizes Google Analytics or other analytics providers, which is intended to track the origin and behavior of traffic to the Services. SME may use the following analytics providers, and you are directed to review their cookie policies:
Google Ads: https://policies.google.com/technologies/ads
SME may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, TikTok, or Apple. These third parties may be based outside of the European Union.
- Marketing Communications.
As stated above, SME’s lawful ground for sending you marketing communications is either consent or its legitimate business interests, such as to grow its business by advertising products to you. SME may send you marketing communications if you have asked for information concerning its goods or services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask SME to stop sending you marketing messages at any time by logging into the Services to adjust your marketing preferences within your User Account or by following the opt-out link in any marketing message sent to you. If you opt-out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.
- Disclosure of Personal Information.
SME may share your PII with the following parties:
- Service providers that provide SME with information technology or other administrative services;
- SME’s accountants, auditors, insurers, or attorneys;
- Law enforcement agencies upon the receipt of a subpoena or court order or where necessary to protect SME’s personnel or property; and
- Government bodies that require SME to report its processing activities.
SME may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.
- Data Security.
SME has put into place data security measures to protect your PII. SME allows access to your PII only by employees and service providers who have a need to know or on SME’ instructions. However, no security measures are impenetrable and there are always security risks. SME will notify you and any regulatory body of any breach of your PII or SME’s security measures if it is legally required to do so.
- Retention of Data.
- Right to Access, Rectification, Correction, Erasure, Transfer, and Withdrawal.
We do not charge a fee for accessing your PII or exercising your rights. However, we may charge a reasonable fee if your request is unreasonable or excessive.
To ensure the security of your PII, we may need to request specific information from you to confirm your request. We strive to respond to any verifiable consumer request within forty-five (45) days of receipt.
If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Our response will also explain the reasons we cannot comply with a request, if applicable.
In the case of data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information.
If we modify or delete some or all of your personal information, we will retain your personal data if reasonably necessary to fulfill any other requests from you (for example, to opt-out of further messages or for a copy of your data).
- California Privacy Rights.
|A. Identifiers||Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))||Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.||YES|
|D. Commercial||Records of products purchased.||YES|
|F. Internet or other similar network activity||Browsing history, search history, information on a consumer’s interaction with a Services, application, or advertisement.||YES|
We obtain these categories of PII directly from California residents when they complete forms through our Services or provide it to us as a part of a transaction or inquiry concerning our products. We also obtain these categories of PII indirectly from California residents while observing their actions on our Services and from third parties or service providers that they have authorized to receive and share PII.
California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you.
Even though SME does not sell your personal information, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.
To submit a request for a list of the categories of personal information collected from you or to request that SME delete your personal information, please email us at:
To verify your request, we may request certain information from you to confirm that you are a SME user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to SME to disclose or delete your personal information. To do so, you must provide SME with proof that the individual or business has been appointed as your agent, such by providing a signed power of attorney form, and provide accurate responses to any information requested by SME that may be necessary to confirm that you are a SME user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by SME for their exercise of these rights conferred under California law.
- Third Party Links.
SME’ Services may include links to third-party websites and applications. By clicking on third-party links, you may allow third parties to collect or share data about you. SME does not control these third-party links and you are advised to review their respective privacy policies.
- Responding to Do Not Track Signals.
You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI wesbite and DAA website. The SME Website is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.
- Nevada Residents.
If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may send us an email [email protected] with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.
- Children’s Privacy.
We do not direct the Services to anyone under the age of 13 and we do not knowingly collect PII from anyone under the age of 13. If you are a parent or guardian of an individual under the age of 13 and believe that we may have collected PII from your child, please contact us at [email protected].
- Notification of Changes.
- Contact Us.