Privacy Policy

Last updated: January 01, 2024

We believe in the importance of being able to control who gets what information. This not only means you want your coworker to have your work email, and your friend to have your personal phone number, but it also means there are people who shouldn’t have any of your information.

We’ve made several choices in how Smart Connections is built to ensure only the people you choose to share with get the details you choose to share.

This Privacy Policy sets forth Smart Connections’ (“Smart Connections”, “we”, “us”, or “our”) privacy practices in connection with Smart Connections’s website located at www.smartconnections.be (the “Site”) and the Smart Connections mobile applications (collectively, the “Service”). This Privacy Policy applies only to information collected by Smart Connections from users of our Services and visitors of our websites. Access to the Services is provided pursuant to the Terms & Conditions. Capitalized terms used but not defined in this Privacy Policy, shall have the meaning set forth in the Terms & Condtions.

Please read the following carefully to understand how we will collect, use, and maintain your personal information. It also describes your choices regarding the use, access, and correction of your personal information.

The Smart Connections Service

Smart Connections organizes and provides efficient means to access and receive updates regarding your contacts, and to share your own information with your contacts. The Smart Connections Service may additionally connect with third party software platforms which you have authorized to connect with Smart Connections (“Third Party Platforms”).
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What Is Personal Information?

“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, address, telephone number, mobile number or e-mail address, an identification number, location information, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

“Sensitive Personal Information” means racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union members, the processing of genetic, biometric data for purposes of uniquely identifying a natural person, and information concerning an individual’s health, sex life, or sexual orientation. We treat your Personal Information and Sensitive Personal Information as confidential.

“Other Information” is any information that is not Personal Information or Sensitive Personal Information. Personal Information does not include anonymized or “aggregate” information, or publicly available information that has not been combined with Personal Information or Sensitive Personal Information.

What Information Do We Collect And When Do We Collect It?

We may collect your Personal Information in the following circumstances:

• When you voluntarily provide it to us, such as when you register for an account with your email and password, or by using a social login (“Smart Connections Login Credentials”), send us an email or post information or other content to our Site or Service;
• When you connect a Third Party Platform with your Smart Connections account we will receive information from that service (such as your username, basic profile information) via the authorization procedures used by that service. Any additional information we receive depends on which services you authorize and any options that are available;
• If you purchase a subscription to the Service requiring billing or payment information, we require that you provide certain additional Personal Information, including your address, phone number, and credit card number (“Payment Information”). This information is necessary to process your requests and to contact you; and
• When you accept another user’s invitation to connect on the Service.

When you utilize the Service, we also receive certain Other Information about you or your use of the Service. Such Other Information may be collected using various technologies, including:

• Logs: We track the data you see in Smart Connections and how you interact with it by automatically collecting certain information such as, the pages you visit or features you use within the Service, the date and time of your activities on the Service, the URLs from the websites you visit before and after navigating to the Service, your software and hardware attributes (including operating system type and version, App version, device type, and device identifiers, including IDFA and/or Advertising IDs), your browser type and version, and your general geographic location derived through your IP address (e.g., your city, state, or metropolitan region). To obtain such information, we may use web logs or applications that recognize your device and gather information about its online activity. We treat this information as confidential if we combine it with or link it to any of your Personal Information. We use tracking data about individuals to inform us about how Smart Connections is being used to help us provide a better user experience.
• Cookies: Like almost all websites today, Smart Connections uses cookies to determine whether you are logged in on your device and to recognize repeat visitors. We send cookies to your device in order to uniquely identify your browser and improve the quality of our Service. Cookies are small pieces of information that a website sends to your device’s hard drive while you are viewing a site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). If you wish to restrict or block the cookies which are set by Smart Connections, or by any other website, you can do this through your browser settings. Please note, if you choose to disable cookies, some of our Service may not work properly or at all.
• Web beacons: The Service or the emails that you receive from us may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email.
• Local storage: We may collect and store information (including Personal Information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

Smart Connections keeps Personal Information contained in your cookies and obtained through the other tracking technologies confidential. We do not set any cookies outside of the smartconnections.be domain.

We also may partner with certain third parties to collect, analyze, and use some of the Personal and Other Information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Service or in email communications from Smart Connections. This information may be used for a variety of purposes, including analytics.

How Do We Use the Information We Collect?

We use your Personal Information and Other Information collected through our Service for the following purposes:

• to enable you to share Personal Information and connect to and communicate with other users;
• to provide our Service or information you request, and to process and complete any transactions;
• to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
• to monitor and analyze usage of the Service and trends, and to personalize and improve our Service and our users’ experiences on our Service, such as content, or features that match their profiles or interests, and to increase the functionality and user friendliness of our Service;
• to send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, our Service;
• to contact you about the Service in which you have expressed interest or that might be of interest to you; and
• for any other purpose for which the information was collected.

What Information Do We Share With Third Parties?

Smart Connections exists to make your professional network more actionable, not to sell your data. However, we share personal information as follows:

• Other users you connect with on the Service:  The core functionality of the Smart Connections Service allows you to share your Personal Information with other users, and to receive the Personal Information of those other users.  When you invite another user to connect with you, either via the interface of the Service, or by sharing a QR code, link or other personal identifier generated by the Service, your Personal Information will be provided to people who view or access such code, link or identifier.  You can control which information you share via the settings provided within the Service.

• With Your Consent: We may share your Personal Information when you give us your consent to do so, including if we notify you on our Service that the information you provide will be shared in a particular manner and you provide such information.
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• Service Providers, Agents and Related Third Parties: We sometimes hire other companies to help us provide the Service to you. Examples include third-party payment processors, companies who send emails on our behalf, cloud-hosting providers and other service providers who work with us in connection with the operation of our Service. Such service providers are only provided with the information they need to perform their specific function, will only use your Personal Information to perform the services requested by us, and we make efforts to ensure they are subject to confidentiality restrictions consistent with this Privacy Policy.
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• Legal Processes: We may also disclose your Personal Information if required to do so by law or when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders; when we believe that disclosure is necessary to protect our rights or the rights, property or safety of others; to enforce or apply our Privacy Policy, our Terms of Service or our other policies or agreements.
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• Business Transfers: We might sell or buy business assets. We may share your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where Personal Information may be disclosed or transferred as one of our business assets.
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• Analytics: We partner with certain third parties to collect the Other Information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies or use similar tracking technologies on your computer or other device.
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• Google API usage: Smart Connections Automated Email Signatures use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirement.

• Aggregated information: We may share aggregated demographic information about our user base with our partners. Such aggregated information does not identify individual users. We do not link this aggregate user data with personal information. Our Privacy Policy does not restrict or limit our collection and use of aggregate user data.

User Communications

You may choose to provide us with another person’s email address so that person may be invited to create an account on our Service. By providing us with another person’s email address, you represent to us that you have obtained the consent of the person concerned as regards such disclosure to us of that email address. We may disclose such information if required to do so in order to comply with legal process, as described above.

Links to Other Sites

Our Service may contain links to other sites. Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from our Service.

What Steps Do We Take To Protect Your Information?

We use reasonable physical, technical, and administrative security measures to protect your Personal Information in an effort to prevent loss, misuse and unauthorized access, disclosure, alteration and destruction. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

What Choices Do You Have Regarding the Use of Your Information?

You may withdraw your consent to process your Personal Information at any time by providing written notice to us at hello@smartconnections.be. If you do so, you will be unable to use the Service.

You may “opt out” of receiving marketing or promotional communications from us by following the instructions in those communications or by emailing us at hello@smartconnections.be. If you opt out, we may still send you non-promotional emails, such as emails about your Smart Connections account or our ongoing business relations.

Your Rights: Reviewing, Changing or Deleting Your Information

You may review, update, correct or delete the Personal Information in your account from within the Service itself or by contacting us at hello@smartconnections.be. You also authorize us, on your behalf, and in accordance with your account preferences to delete information when not reasonably needed for the Service. If you have shared your Personal or Other Information with others and they have not deleted it, or it was copied or stored by other users, Smart Connections will not be obligated to delete such information.

Retention of Your Information

We retain information for as long as reasonably necessary to deliver our Service to you or to fulfill the purposes described in this Policy. You may delete the Personal Information in your account as described above. Please note that, in limited circumstances, we may retain information for a longer period of time as required by law.

Lawful Bases for Processing

We will only collect and process Personal Information about you where we have lawful bases. Our lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, such as when you purchase a subscription to the Service) and our legitimate interests (such as to comply with applicable laws and enable or administer our business).

Minors

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us at hello@smartconnections.be. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information from our files.

Changes to our Privacy Policy

Smart Connections may update this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page with an “effective date” indicating when the changes will take effect. We encourage you to review this Privacy Policy periodically. If you have questions or concerns regarding our Privacy Policy, please contact us at: hello@smartconnections.be.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in Belgium is the Data Protection Authority who may be contacted through this link, per email at contact@apd-gba.be or telephone: +32 (0)2 274 48 00.

Any more questions?

Please contact us at hello@smartconnections.be if you have any questions about our Privacy Policy.