Smaaart Spot Privacy Policy

Last Modified: April, 14th 2016

Smaaart Spot Privacy Policy

Please read this Privacy Policy carefully to understand how Smaaart Spot, its subsidiary and

affiliate corporations, successors, and assigns (collectively referred to as “Smaaart Spot”) uses

and protects the information you provide. This privacy policy (the “Privacy Policy”) applies to this

website and any variations or successors to this website (,,, the “Smaaart Spot Site”), any Smaaart Spot computer software

downloadable or otherwise available from the Smaaart Spot Site (“Smaaart Spot Software”) and

any Smaaart Spot services purchased or otherwise made available from the Smaaart Spot Site

(“Smaaart Spot Services”) (collectively, the “Smaaart Spot Properties”). This Privacy Policy

(“Privacy Policy”) applies to all Users (“Users”) of the Smaaart Spot Properties.



Smaaart Spot may collect two (2) types of information about you: Personal and Non­Personal.

1. “Personal Information.” Personal Information refers to information that lets Smaaart Spot

know the specifics of who you are and which may be used to identify, contact or locate you (e.g.

name, mailing address, telephone number and e­mail address). Smaaart Spot may collect

Personal Information when you use the Smaaart Spot Properties including, without limitation,

setting up account information, filling out surveys, corresponding with Smaaart Spot, or

otherwise volunteering information about yourself.

2. “Non­Personal Information.” Non­Personal Information refers to information that, by itself,

does not identify you as a specific individual (e.g. demographic information or website

visitations). Smaaart Spot may collect Non­Personal Information through any of the methods

discussed above as well as automatically through use of industry standard technologies

described further below.



The Personal Information practices set forth apply to all Smaaart Spots’ customers worldwide.

1. Registration. Prior to using one or more of the Smaaart Spot Properties, Smaaart Spot may

require certain Personal Information and Non­Personal Information to create an individual

account (“Account”) or to enable features or functionality of the Smaaart Spot Properties.

Failure to provide all information required by Smaaart Spot may prevent access to any or all

Smaaart Spot Properties, and failure to maintain accurate information may result in suspension

or termination of access to any or all Smaaart Spot Properties.

2. Information Collected Through Technology. While you are able to visit the Smaaart Spot Site

and remain anonymous, Smaaart Spot or its third party service providers may still collect Non-
Personal Information about your use of the Smaaart Spot Properties (e.g. your Internet browser,

operating system, IP address, connection speed, and the domain name of your Internet service

provider). Such information may be gathered by the following methods:

(a) Cookies. Cookies, including local shared objects, are small pieces of information that are

stored by your browser on your computer’s hard drive which work by assigning to your computer

a unique number that has no meaning outside of the Smaaart Spot Site. Cookies do not

generally contain any Personal Information. Most web browsers automatically accept cookies,

but you can usually configure your browser to prevent this. Not accepting cookies may make

certain features of the Smaaart Spot Properties unavailable to you.

(b) IP Address. You may visit many areas of the Smaaart Spot Site anonymously without the

need to become a registered User. Even in such cases, Smaaart Spot may collect IP addresses

automatically. An IP address is a number that is automatically assigned to your computer

whenever you begin Services with an Internet services provider. Each time you access the

Smaaart Spot Site and each time you request one of Smaaart Spot’s pages, the server logs

your IP address.

(c) Web Beacons. Web beacons are small pieces of data that are embedded in web pages and

e­mails. Smaaart Spot may use these technical methods in HTML e­mails that Smaaart Spot

sends to Users to determine whether they have opened those e­mails and/or clicked on links in

those e­mails. The information from use of these technical methods may be collected in a form

that is Personal Information.

(d) Tracking Content Usage. If you use the Smaaart Spot Services and you post audio visual

materials including, without limitation, text, logos, artwork, graphics, pictures, videos,

advertisements, sound and other related intellectual property contained in such materials

(collectively, “Content”) to your website or to a third party website, Smaaart Spot tracks and

captures Non­Personal Information associated with User accounts and the use of Content.



1. System Administration. Smaaart Spot may use Non­Personal Information for the purposes of

system administration, assisting in diagnosing problems with Smaaart Spot servers, monitoring

Smaaart Spot’s system performance and traffic on the Smaaart Spot Properties and to gather

broad demographic information about Smaaart Spot’s customers.

2. Personalization. Smaaart Spot uses Cookies and IP Addresses to track features such as

delivering Content specific to your interests and informing you of new, relevant services or

certain third party offerings.

3. Notices to Registered Users. If you have registered for an Account, Smaaart Spot may use

your Personal Information to send e­mails regarding your registration, including confirmation to

verify the accuracy of any information you have provided, and instructions on how to post

Content. Smaaart Spot may also send you e­mails to verify your identity or to notify you if

Smaaart Spot believes your use of Smaaart Spot Properties violates any applicable agreement

for the use of the Smaaart Spot Properties.

4. Advertising. Smaaart Spot may use Non­Personal Information to assist in optimizing the

delivery of advertisements to viewers of your Content.

5. Promotional E­mails. Smaaart Spot may use your Personal Information to send you e­mails

periodically listing promotions or events relating to the Smaaart Spot Properties or from Smaaart

Spot’s marketing partners or sponsors. You have the choice to opt­out of receiving such

promotional e­mails by sending an e­mail to and/or following the

instructions in such correspondence. Once Smaaart Spot has processed your opt­out request,

Smaaart Spot will not send you promotional e­mails unless you opt back in to receiving such


6. Contact Information. If you contact Smaaart Spot by telephone, e­mail or letter, Smaaart Spot

may keep a record of your contact information and correspondence. If you report a problem with

the Smaaart Spot Properties, Smaaart Spot may collect this information in a file specific to you.

You may contact Smaaart Spot at to request the removal of this

information from Smaaart Spot’s database.



Upon request, Smaaart Spot shall allow Users to update or correct Personal Information

previously submitted, but only to the extent such activities will not compromise privacy or

security interests. Additionally, upon request, Smaaart Spot shall delete Personal Information

from the database where such information is stored; however, it may be impossible to entirely

delete a User’s entry without some residual information being retained due to the manner in

which data backups are maintained. Requests to delete Personal Information shall be submitted




Without your affirmative consent (and on a case­by­case basis), Smaaart Spot does not sell,

trade or rent Personal Information collected through the Smaaart Spot Properties to any third

party. Notwithstanding the foregoing, Smaaart Spot shall: (1) fully cooperate with law

enforcement agencies; and (2) may be required to disclose Personal Information upon receipt of

a court order, subpoena, or to cooperate with a law enforcement investigation.

You should understand that information you provide through the registration process or post to

the public areas of the Smaaart Spot Properties, including your “User Profile” or generally

through the use of Smaaart Spot Properties (including your name (if provided) and location

information) may be accessible by and made public through syndication programs and by

search engines, metasearch tools, crawlers, metacrawlers and other similar programs, and may

be searchable by other users of the Smaaart Spot Properties.



1. Security Measures. Smaaart Spot takes appropriate security measures to protect against

unauthorized access, alteration, disclosure or destruction of Personal Information. These

include, but are not limited to, internal reviews of: (a) Smaaart Spot’s data collection; (b) storage

and processing practices; (c) electronic security measures; and (d) physical security measures

to guard against unauthorized access to systems where Smaaart Spot stores Personal

Information. All Smaaart Spot employees, contractors and agents who access Personal

Information are bound by confidentiality obligations and may be subject to discipline, including

termination and criminal prosecution or unauthorized use or disclosure of Personal Information.

2. Third Party Links. The Smaaart Spot Properties may contain links to third parties who may

collect Personal Information and Non­Personal Information directly from you. Additionally,

Smaaart Spot may use third parties to provide components of the Smaaart Spot Properties. In

either case, such third parties may have separate privacy policies and data collection practices,

independent of Smaaart Spot. Smaaart Spot: (a) has no responsibility or liability for these

independent policies or actions; (b) is not responsible for the privacy practices or the content of

such websites; and (c) does not make any warranties or representations about the contents,

products or services offered on such websites or the security of any information you provide to




If you are located outside of the United States, please note that this site is hosted on our

computer servers in the United States. Therefore, your information may be processed and

stored in the United States. As a result, United States federal and state governments, courts, or

law enforcement or regulatory agencies may be able to obtain disclosure of your information

through laws applicable in the United States. Your use of the Smaaart Spot Properties or your

submission of any Personally Identifiable Information to us will constitute your consent to the

transfer of your Personally Identifiable Information outside of your home country, including the

United States, which may provide for different data protection rules than in your country.

Furthermore, your information may be transferred to, and maintained on, computers located

outside of your state, province, country or other governmental jurisdiction where the privacy

laws may not be as protective as those within your jurisdiction. If you are located outside of the

United States and choose to provide information to us, Smaaart Spot Properties transfers

Personally Identifiable Information and processes it there. Your consent to this Privacy Policy

followed by your submission of such information represents your agreement to that transfer. If

you do not agree to this transfer, do not use the Smaaart Spot Properties.



Smaaart Spot may sell, divest, transfer, assign, share or otherwise engage in a transaction that

involves, some or all of our assets, including any or all of the information described in this

Policy, in the course of a corporate divestiture, merger, acquisition, joint venture, bankruptcy,

dissolution, reorganization, or any other similar transaction or proceeding.



Smaaart Spot continually strives to implement new technologies and processes to better protect

you, your privacy and your use of the Smaaart Spot Properties. As a result, changes to this

Privacy Policy may be made by Smaaart Spot from time to time. In no event will these changes

result in the degradation of any of the security measures designed to protect you from

unauthorized disclosure, as such measures are described in this Privacy Policy.