Smarter Cards
The Smarter Way to Expand your Network

My Internet Support, LLC. (MIS) and Smarter Card Privacy Policy

Effective May 1, 2020

Privacy is an extremely important topic, and we want you to know that at My Internet Support, LLC. (MIS) and Smarter Card, we take it very seriously. We are committed to protecting the privacy and security of your personal data. If you have questions, please contact the privacy team at  privacy@myinternetsupport.com or the support team at support@smarter.cards

Smarter Card Privacy Policy

Smarter is committed to protecting your privacy and ensuring you have a positive experience when using the services we provide, which we generally refer to as Smarter Card, or when visiting our promotional or marketing website smarter.cards.

This policy explains how we handle data, including what we collect and how we obtain it, how we use it, when and if we disclose it, and some of your options for managing your data with Smarter Card. It applies worldwide to all our subsidiaries and covers all data that you provide to us, as we describe below.

Information that can be used to identify or be reasonably associated with a specific person is “personal data”. Where the data described in this policy is personal data, we only disclose it in the ways we have stated.
This policy applies to information we collect:
  • On the website.

  • Within the apps.

  • ​In email text, and other electronic messages between you and this service.

It does not apply to information collected by:
  • Us offline or through any other means us offline or through any other means, including on any other website operated by company or any third party (including our affiliates and subsidiaries); or 
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the service.
please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our service. by accessing or using this service, you agree to this privacy policy. this policy may change from time to time. Your continued use of this service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our service is not intended for children under 13 years of age. no one under age 13 may provide any information to or on the service. we do not knowingly collect personal information from children under 13. if you are under 13, do not use or provide any information on this service or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. if you believe we might have any information from or about a child under 13, please contact us at support@smarter.cards.

Information We Collect About You And How We Collect It

We collect several types of information from and about users of our service, including information:

By which you may be personally identified, such as name, mailing address, e-mail address, telephone number, or social media screen names, any other identifier by which you may be contacted online or offline (“personal information“);

That is about you but individually does not identify you; and/or

About your internet connection, the equipment you use to access our service and usage details.
We collect this information:
  • Directly from you when you provide it to us.

  • Automatically as you navigate through the service. Information collected automatically may include usage details, ip addresses, and information collected through cookies, web beacons, gps location, and other tracking technologies.​
  • ​From third parties, for example, other social media providers and/or our business partners.
  • ​Information you provide to us. the information we collect on or through our service may include:
  • Information that you provide by filling in forms on our service. This includes information provided at the time of registering to use our service and/or posting material. we may also ask you for information when you report a problem with our service.
  • records and copies of your correspondence (including email addresses), if you contact us.
  • Your search queries within the service.
  • You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the service including our ‘blog-site’, or transmitted to other users of the service or third parties (collectively, “user contributions“). your user contributions are posted on and transmitted to others at your own risk. although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the service with whom you may choose to share your user contributions. therefore, we cannot and do not guarantee that your user contributions will not be viewed by unauthorized persons.
  • Information we collect through automatic data collection technologies. as you navigate through and interact with our service, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
  • Details of your visits to our service, including traffic data, location data, logs, and other communication data and the resources that you access and use on the service.
  • Information about your computer and internet connection, including your ip address, operating system, and browser type.
  • We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. it helps us to improve our service and to deliver a better and more personalized service, including by enabling us to:
  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our service according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our service.
  • The technologies we use for this automatic data collection may include:
  • Cookies (or browser cookies). a cookie is a small file placed in users’ browsers to store their preference. you may refuse to accept browser cookies by activating the appropriate setting on your browser. however, if you select this setting you may be unable to access certain parts of our website or service. unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. by using an app, you authorize us to gather and retain data related to your use of the service.
  • Flash cookies. certain features of our website may use local stored objects (or flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web beacons. pages of our website, our apps, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-party Use Of Cookies [And Other Tracking Technologies]

Some content or applications, including advertisements, on the service are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. these third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our service. the information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. they may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:
  • To present our service and its content to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our service or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our service.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
We will only ever share your personal information with third parties after having obtained your express consent to do so. you may ask us to stop using your personal information for this purpose at any point by changing the setting authorizing the third party disclosure.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure Of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
  • ​To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • ​To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of follow-mee, inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by follow-mee about our service users is among the assets transferred.
  • ​To third parties to market their products or services to you if you have not opted out of these disclosures. 
  • ​To fulfill the purpose for which you provide it. for example, if you give us an email address to use the “email a friend” feature of our service, we will transmit the contents of that email and your email address to the recipients, or if you enable interaction with other social media networks with our service, we will transmit the information you provide to those other social networks.
  • ​For any other purpose disclosed by us when you provide the information.
  • With your consent.
We may also disclose your personal information:
  • ​To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of follow-mee, inc., our customers, or others. 

Choices About How We Use And Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. we have created mechanisms to provide you with the following control over your information:

Tracking technologies and advertising. you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. to learn how you can manage your flash cookie settings, visit the flash player settings page on adobe’s website. if you disable or refuse cookies, please note that some parts of this service may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. however these third parties may provide you with ways to choose not to have your information collected or used in this way. you can opt out of receiving targeted ads from members of the network advertising initiative (“nai“) on the nai’s website.

Accessing And Correcting Your Information

You can review and change your personal information by logging into the service and visiting your account profile page.
If you delete your user contributions from the website, copies of your user contributions may remain viewable in cached and archived pages, or might have been copied or stored by other service users. proper access and use of information provided on the service, including user contributions, is governed by our terms of use.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. where we have given you (or where you have chosen) a password for access to certain parts of our service, you are responsible for keeping this password confidential. we ask you not to share your password with anyone. we urge you to be careful about giving out information in public areas of the service. the information you share in public areas may be viewed by any user of the service.

Unfortunately, the transmission of information via the internet is not completely secure. although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our service. any transmission of personal information is at your own risk. we are not responsible for circumvention of any privacy settings or security measures contained in the service.

Changes To Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice provided within the service. The date the privacy policy was last revised is identified at the top of the page. you are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our service and this privacy policy to check for any changes.

Information We Collect

We collect 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 consumer, household, or device (“personal information“). personal information does not include:
  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • Health or medical information covered by the health insurance portability and accountability act of 1996 (HIPAA) and the california Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months: 

Category Examples Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

B. personal information categories listed in the California Customer Records Statute (cal. civ. code § 1798.80(e)).

A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Bio metric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face-prints, and voice-prints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

G. Geo location data.

Physical location or movements.

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

I. professional or employment-related information.

Current or past job history or performance evaluations.

J. Non-public education information (per the family educational rights and privacy act (20 u.s.c. section 1232g, 34 c.f.r. part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

K. inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the categories of personal information listed above from the following categories of sources:
  • Directly from you. for example, from forms you complete when downloading the app or when obtaining other products and services you purchase.
  • Indirectly from you. For example, from observing your actions on our website.

Use Of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes: 
  • To fulfill or meet the reason you provided the information. for example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. we may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our website and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your services experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our services, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the ccpa.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our services is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. when we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may share your personal information with the following categories of third parties: 
  • Service providers.
  • Our advertising vendors for our products and services disclosures of personal information for a business purpose
In the preceding twelve (12) months, company has not disclosed personal information for a business purpose/has disclosed the following categories of personal information for a business purpose:
  • Category A: Identifiers.
  • Category F: Internet or other similar network activity.
We disclose your personal information for a business purpose to the following categories of third parties:
  • Service providers.
  • Our advertising vendors for our products and services.
  • Sales of personal information
In the preceding twelve (12) months, the Company had not sold personal information. 

Your Rights And Choices 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your ccpa rights and explains how to exercise those rights.

Access To Specific Information And Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. once we receive and confirm your verifiable consumer request (see exercising access, data portability, and deletion 0), we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • Sales, identifying the personal information categories that each category of recipient purchased; and
  • Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
  • We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see exercising access, data portability, and deletion 0), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (cal. penal code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, And Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
  • You may be able to login to our app and request that we delete your personal information. if this functionality is not available then please email us at: support@smarter.cards.
  • Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent you must require that your authorized agent be verified by us through your designation of such individual with sufficient information to identify that person including at least their full name, business address and telephone number.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. the verifiable consumer request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: Your full name, e-mail address, primary telephone number and home ZIP code 
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  

Response Timing And Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For 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 from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
  • However, we may offer you certain financial incentives permitted by the ccpa that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes To Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the website and update the notice’s effective date. your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Changes To The Privacy Policy And Your Duty To Inform Us Of Changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. please keep us informed if your personal data changes during your relationship with us.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. clicking on those links or enabling those connections may allow third parties to collect or share data about you. we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. it does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 
  • Identity data includes first name, last name, username or similar identifier.
  • Contact data includes billing address, delivery address, email address and telephone numbers.
  • Financial data includes payment card details (though this information is provided directly to our payment processors and we do not have access to this information although we remain the controller for this data).
  • Transaction data includes details about payments to and from you and other details of products and services you have purchased from us (though this information is provided directly to our payment processors and we do not have access to this information although we remain the controller for this data).
  • Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses and anything you post on our blog site.
  • Usage data includes information about how you use our application, website, products and services.
  • Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • We also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. however, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and bio-metric data). nor do we collect any information about criminal convictions and offences.

If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). in this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. 

How Is Your Personal Data Collected?

We use different methods to collect data from and about you including through:
  • Direct interactions. you may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. this includes personal data you provide when you:
  • Apply for our products or services or download our app;
  • Create an account on our website or app;
  • Subscribe to our service or publications;
  • Request marketing to be sent to you;
  • Enter a competition, promotion or survey;
  • Use or contribute to our blog site; or
  • Give us feedback or contact us.
  • Automated technologies or interactions. as you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. we may also receive technical data about you if you visit other websites employing our cookies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical data from the following parties:
  • Analytics providers such as google based outside the EU;
  • Advertising networks such as google adwords based outside the EU; and
  • Search information providers such as google based inside or outside the EU.
  • Contact, financial and transaction data from providers of technical, payment and delivery services based outside the EU.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. most commonly, we will use your personal data in the following circumstances:
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.
  • Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. we will give you notice if we begin using an advertiser and allow you to opt-out of such marketing either by clicking ‘unsubscribe’ in an email or other manner as designated by us.

Promotional Offers From Us 

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-Party Marketing 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. 

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the app and checking or unchecking relevant boxes to adjust your marketing preferences.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions or information relayed to you through our blog site.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. if you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. for more information about the cookies we use, please see our primary privacy policy.

Change Of Purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. if you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
  • Disclosures of your personal data
  • We may share your personal data with the parties set out below for the purposes set out in the table above.
  • Internal third parties that perform maintenance or our contractors agents that are necessary for the services.
  • External third party contractors and agents as necessary to perform our services or provide our products to you.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. alternatively, we may seek to acquire other businesses or merge with them. if a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

We share your personal data within our company, which is located in the United States. This will involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

Many of our external third parties are based outside the eea so their processing of your personal data will involve a transfer of data outside the eea.

Whenever we transfer your personal data out of the eea, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European commission.

Where we use certain service providers, we may use specific contracts approved by the European commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the privacy shield which requires them to provide similar protection to personal data shared between Europe and the us. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the eea.

data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. they will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.  

Collection and Use of Data

To make a request, please contact our Privacy Team at privacy@myinternetsupport.com.

If you have a password protected Smarter Card account, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

Additional Information About Specific Regulations 

Residents of the European Union (EU), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland 

If you reside in the European Union (EU), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have legal rights with respect to your personal data, including those set forth under the EU’s General Data Protection Regulation (GDPR).

GDPR requires that we have a “basis” for processing your data. We process your personal data (i) with your consent (where applicable), (ii) to perform a contract with a customer, and (iii) for other legitimate interests and business purposes.

Residents of the State of California 

If you reside in California, you may have legal rights with respect to your personal data, including those set forth under the California Consumer Privacy Act (CCPA). If you are a California resident, you can request information about both the categories and specific pieces of data we have collected about you in the previous twelve months, the reason we collected it, the category of entities with whom we have shared it and the reason for any disclosure. Smarter Card is prohibited from discriminating against California consumers that choose to exercise their privacy-related rights under the CCPA.

Contact Us

If you have any privacy-related questions or comments related to this privacy policy, please send an email to privacy@myinternetsupport.com
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