1. INTRODUCTION
Welcome to "SMARTPLAYER" LLP ("Company", "we", "our", "us"), located at the address: 167 Brusilovsky Street, Almaty, Almali district, Republic of Kazakhstan, BIN: 220940047618. We are committed to protecting your personal data and respecting your privacy.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our website, platform, or any other digital services (collectively referred to as the "Services").
This Policy applies to all personal data collected and processed through any of our digital platforms, including but not limited to:
- Website: Access to informational pages, online forms, and account management portals.
- Platform: Use of our integrated digital solutions designed for personalized user experiences and secure data management.
We are fully compliant with the General Data Protection Regulation (GDPR) and the Brazilian General Data Protection Law (LGPD), ensuring transparency, accountability, and security in handling your personal data. By accessing or using our Services, you acknowledge and agree to this Privacy Policy.
Our commitment includes:
- Safeguarding your data through robust technical and organizational measures.
- Providing clarity on your rights regarding personal data and how to exercise them.
- Ensuring that any processing of your data is lawful, fair, and transparent.
If you do not agree with the terms of this Privacy Policy, please refrain from accessing or using our Services. Should you have any questions or require clarification, you may contact us using the details provided in the "Contact Us" section.
2. DEFINITIONS
- Personal Data: Any information relating to an identified or identifiable natural person.
- Processing: Any operation performed on personal data, such as collection, storage, use, disclosure, and deletion.
- Data Subject: An individual whose personal data is processed.
- Controller: The entity that determines the purposes and means of processing personal data.
- Processor: The entity that processes personal data on behalf of the controller.
- Data transfer: any provision, disclosure, sending, access or other transfer of personal data to a third party or to another jurisdiction, including cases of cross-border movement, carried out in accordance with applicable data protection laws.
3. DATA COLLECTION
We collect and process personal data to provide and improve our Services, comply with legal requirements, and meet our legitimate business interests. This includes information you provide directly, data collected automatically, and information obtained from third parties. Below, we outline the types of data we collect and the methods used:
Categories of Personal Data We Collect:- Identification Data: Name, email address, phone number, postal address, and other identifiers necessary to provide our Services.
- Technical Data: IP address, browser type, device information, operating system details, and other diagnostic data.
- Usage Data: Information on how you interact with our Services, including pages visited, time spent, navigation paths, and actions taken.
- Communication Data: Messages sent through contact forms, email, or other communication channels.
- Payment Data (if applicable): Billing address, payment method details, and transaction history.
- Location Data: Precise or approximate location data collected via GPS or other geolocation services, where applicable.
- Behavioral Data: Information gathered from cookies, web beacons, and similar technologies to understand user preferences and improve user experience.
How We Collect Data:- Direct Input: When you provide information during account registration, form submissions, or customer support inquiries.
- Automated Technologies: Through cookies, server logs, tracking pixels, and analytics tools when you use our website or applications. We automatically collect and store certain types of information about your use of Our Services, including information about your interaction with products, content, and services available through Our Services. Like many websites, we use "cookies" and other unique identifiers, and we obtain certain types of information when your web browser or device accesses Our Services and other content served by or on behalf of on other websites. Our physical stores may use cameras, computer vision, sensors, and other technology to gather information about your activity in the store, such as the products and services you interact with. Click here to see examples of what we collect.
- Third Parties: From affiliates, service providers, or publicly available sources, including social media platforms, to enhance our understanding of user needs.
Collection Through Digital Platforms:- Website: We collect interaction and preference data when you browse or log in.
- Platform: Detailed user activity logs, including file uploads, preferences, and custom settings.
Use of Cookies and Similar Technologies:We use cookies, pixel tags, and local storage to:
- Recognize returning users and personalize their experience.
- Analyse website performance and improve our Services.
- Deliver targeted advertisements and measure their effectiveness.
For more information about cookies, please refer to our Cookie Policy –
https://smartplayer.org/legal/cookie-policy.
Special Categories of DataWe do not intentionally collect sensitive personal data, such as health information, unless explicitly required and with your consent.
4. LEGAL BASES FOR PROCESSING
We process your personal data based on the following legal grounds:
- Consent: consent is made on the basis of acceptance, expressed in registration on the site and the creation of an account.
- Contractual Necessity: To fulfill a contract with you or to take steps at your request before entering into a contract.
- Legal Obligation: To comply with a legal obligation.
Legitimate Interests: For our legitimate interests, provided your rights and interests do not override those interests.
5. PURPOSES OF PROCESSING
We use your personal data for the following purposes:
- To provide and maintain our services.
- To manage your account and provide customer support.
- To communicate with you, including responding to inquiries.
- To analyze usage and improve our website and services.
- To comply with legal obligations and protect our rights
6. DATA SHARING AND INTERNATIONAL TRANSFERS
As part of providing our Services, your personal data may be transferred to, stored, and processed in countries outside the European Economic Area (EEA) or Brazil. These countries may have data protection laws that differ from those in your jurisdiction. However, we are committed to ensuring that your personal data remains secure and is handled in accordance with this Privacy Policy and applicable data protection regulations.
Circumstances of International Transfers:- Service Providers: We may engage third-party service providers located in different countries to perform tasks such as hosting, analytics, payment processing, or customer support.
- Affiliates and Partners: Personal data may be shared with our global subsidiaries, affiliates, or trusted partners to support our business operations.
- Legal Obligations: In certain cases, we may be required to transfer data to comply with legal or regulatory requirements in other jurisdictions.
Safeguards for Data Transfers:To ensure adequate protection of your personal data during international transfers, we implement the following safeguards:
Adequacy Decisions: Transfers to countries recognized by the European Commission as providing an adequate level of data protection.
Other Measures: Encryption, pseudonymization, and strict contractual obligations with third parties to guarantee data security.
Transparency on Data Locations:Your personal data may be processed in the following regions:
- United States: Hosting and analytics services provided by leading technology companies.
- The Republic of Kazakhstan: We guarantee that such processing complies with applicable data protection standards, such as the Law of the Republic of Kazakhstan “On Personal Data Protection”.
- EEA Member States: Data processing for users within the EEA.
- Other Regions: Specific cases involving support services or global partnerships.
Your Rights and Choices:If your data is transferred internationally, you retain all rights under GDPR and LGPD. You may request information about:
- The location of your data.
- The specific safeguards applied during the transfer.
- Copies of relevant contractual agreements (subject to confidentiality obligations).
We continuously review and update our data transfer practices to ensure compliance with evolving legal requirements and industry standards. For further details, please contact us at (Contact Information).
If your personal data is transferred outside the European Economic Area (EEA) or Brazil, we ensure appropriate safeguards are in place.
7. DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.
8. DATA SUBJECT RIGHTS
Under GDPR and LGPD, you have the following rights:
- Right to Access: Obtain confirmation of whether your personal data is being processed and access your data.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your personal data under certain conditions.
- Right to Restriction: Request restriction of processing under certain circumstances.
- Right to Data Portability: Receive your personal data in a structured, commonly used format and transfer it to another controller.
- Right to Object: Object to processing based on legitimate interests or for direct marketing purposes.
- Right to Withdraw Consent: Withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
To exercise these rights, please contact us at Republic of Kazakhstan, Almaty, Almali district, Brusilovsky street, house 167, office 777.
e-mail address: support@smartplayer.org.
9. DATA SECURITY
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction.
10. COOKIES AND TRACKING TECHNOLOGIES
We use cookies and similar tracking technologies to enhance your experience on our website. For detailed information, please refer to our Cookie Policy –
https://smartplayer.org/legal/cookie-policy.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
12. CONTACT US
If you have any questions or concerns about this Privacy Policy or our data processing practices, please contact us:
- Email: support@smartplayer.org.
- Mailing Address: Republic of Kazakhstan, Almaty, Almali district, Brusilovsky street, house 167