At Smilecloud, we deeply value your privacy and prioritize the protection of your personal data in all our operations. We have designed this policy to inform you about how we process your personal data–which includes operations such as collection, storage, use, disclosure, sharing, or erasure. Also, you will find valuable insights regarding your rights concerning such data.
This policy forms part of the Contract between you and us. Terms that are capitalized but not defined here carry the meanings provided in our General Terms.
By using our Services, you acknowledge that you have read and understood this Privacy Policy. For any inquiries or concerns about our privacy practices, feel free to reach out to us through the contact information provided below.
We're including these "Simply put" sections to make our legal documents more approachable and easier to understand. These summaries give you a quick and plain-language overview of the more detailed legal terms–they are not legally binding.
This Privacy Policy applies to every service provided by Smilecloud, which includes our website, applications, and any other form of interaction you might have with us, such as when responding to feedback forms or participating in our online or physical events. However, please note that our services may contain links to services or applications offered by third parties, which our privacy practices do not cover.
Smilecloud as a data controller. This Privacy Policy is applicable solely to the personal data processed by Smilecloud in our capacity as a data controller. We undertake this role when we determine the purpose and means of processing your personal data collected as a result of various scenarios, such as during your interactions with our Services as an End User or Customer representative (like billing or other account contacts), website visits, participation in both online and physical events, engagement with our advertisements, communication via emails and other forms.
Smilecloud as a data processor. It's important to note that this Privacy Policy does not apply when we process personal data on behalf of our Customers, acting in the role of a data processor. In such circumstances, we operate under the instructions of our Customers who serve as the data controllers. Any processing of personal data on behalf of Customers is subject to the terms outlined in our Data Processing Addendum. Therefore, any inquiries or requests concerning the processing of personal data as part of our client services should be directed to the relevant Customer, who acts as the data controller for such data.
Smilecloud as a joint controller. When you purchase a subscription to use our Services from one of our partners, Smilecloud may act as a joint controller along with that partner. In such situations, both Smilecloud and the partner are jointly responsible for determining the purpose and means of the personal data processing. The identity of the joint controllers and their respective contact information can be found below. For further clarity or to address specific questions regarding joint data processing activities, or if you wish to exercise your rights with respect to data processed under this joint controllership, please contact either Smilecloud or our partner directly. Notably, our partnerships do not affect our roles as a sole controller or processor in other contexts, as outlined above in this Privacy Policy.
For a more detailed understanding of the concepts of controller and processor, we recommend you refer to this European Commission guide.
Simply put:
This Privacy Policy covers all your interactions with Smilecloud, whether browsing our website, using our app, or joining our events. It applies when we manage your personal data for our own purposes (as a 'data controller'). When we're processing personal data under our customers' instructions, we have a different role (called a 'data processor'), and this Privacy Policy does not apply. Plus, in cases where you join us via a partner, both of us (Smilecloud and the partner) jointly handle your personal data.
In this Privacy Policy, the terms "personal data", "data", "personal information" and "information" are used interchangeably and refer to any information relating to an identified or identifiable natural person.
In the following sections, we provide a detailed account of the various types of information we collect, which may include:
name, address, email, telephone number, profile image
the type of device, unique device identifying numbers, operating systems, browsers, your internet service provider or mobile network, IP address, location
employer name, job title, work address, work email, qualifications, skills
bank account details
details about the products or services provided
purchases, customer service interactions
In various instances, you directly provide us with your personal data. You are under no obligation to provide us with any personal data. However, in the absence of some data, we may not be able to provide you with our full range of services. For instance, without a valid email address, we would be unable to set up an account for you. There is also optional information that, while not necessary, enhances the quality of your experience while interacting with our Services. The following sections provide more details about the nature of the data you may provide to us.
Account and payment. Some of our Services, such as Smilecloud Biometrics and Smilecloud Passport, require an account or payment. When you sign-up or update your account, you provide us with certain information, which may include your name, email address, and other personal details. Depending on your sign-up method, you may also be asked to create a username and password that will be associated with your account. In the case of paid services, we process the data you provide to issue your invoice, and our payment processor processes your payment instrument information.
Feedback and support. We provide customer support for some of our Services and we welcome your feedback regarding all our offerings. As available, you may contact our customer support or provide your feedback through email, chat, phone calls, or other means which will dictate the information we collect and how we process it. This information usually includes your contact details and any other personal data you share that are relevant to your query or feedback.
Website and social media. We collect information that you provide to us when interacting with our websites or social media pages. For instance, when you post comments, contribute to discussions, or share content on these platforms. Please be aware that any information you post publicly may be visible to others.
Surveys, promotions, and events. If you choose to participate in our surveys, promotions, contests, webinars, or other events, we will collect the information you provide in the context of these activities. This can include your contact details, your responses to survey questions, and any other information you submit.
Please note that the information you provide to us must be accurate, complete, and up-to-date. If there are any changes to your personal data, please inform us promptly.
As you navigate and interact with our Services, it's important to know that Smilecloud automatically gathers certain types of information - most of which do not directly identify you. This process is conducted through various digital tools and analytics platforms, which gather information about your device, usage patterns, and interaction with our Services. The following sections outline in greater detail the specific types of information we collect automatically and the reasons why we do so.
Usage Data. We collect data about how you interact with our services to improve functionality, understand user behavior, and optimize our Services. This information helps us develop and improve features and manage performance for a better user experience. This includes information about how you use our services, such as the features you use, the actions you take, and the time, frequency, and duration of your activities.
Device and Technical Data. We gather data from the device you use to interact with our services for security purposes and to ensure our services function correctly and optimally on different devices and platforms. This information also helps us to diagnose and resolve technical issues and understand trends in device usage. Depending on the type and settings of your device, this could include information about the device you're using, including the type, operating system, device settings, IP address, and crash data.
Cookies and Similar Technologies. We use these technologies to recognize you when you visit our services, remember your preferences, and provide a personalized experience that's consistent with your settings and overall makes your interactions faster and more secure. You can find more information regarding our use of cookies in our dedicated Cookie Policy.
Location Data. We collect your location data to provide localized services, such as setting your language preference and providing content relevant to your geographical location. This enhances the user experience and allows us to comply with regional legal and regulatory requirements. This could involve information about your geographical location derived from your IP address or other location-based data.
As detailed below, Smilecloud obtains certain information from third-party sources as part of providing our Services. This data acquisition is predicated on the understanding that you have already established an agreement with these third parties that allows for the lawful transfer of data. To ensure this, we regularly assess and verify that any data we receive from third parties has been lawfully obtained and transmitted in compliance with applicable data protection laws and best practices. Please note that it remains your responsibility to check and understand the privacy practices of these third parties before sharing your data with them or granting them consent to share your data with us. If you have concerns about how data has been collected or shared, we recommend reaching out directly to the third-party service in question.
Third-Party Services and partners. We may receive data about you from Third-Party Services you link or integrate with our Services or from partners who help us deliver and improve our Services. For example, if you choose to log in to your Smilecloud account with third-party services such as Google or Apple, we may receive information about you from these services.
Our Customers and other individuals that interact with our Services. We may receive data about you directly from our Customers or other individuals who use our Services. For example, when a Customer provides your contact information for setting up a new account or when your Team Members or Collaborators share data that involves you. This information allows us to provide relevant Services, foster collaboration, and facilitate better communication within our Services.
Social networks. When you engage or interact with Smilecloud profiles on social media, we may receive information related to these interactions, which can help us better understand your interests and preferences.
Payment processors. When you make a purchase or transaction, our payment processors may provide us with information related to the transaction to facilitate it and for record-keeping purposes.
Marketing and analytics partners. We work with various partners who help us market our services and analyze the data we collect, including data we collect using cookies and similar technologies. These partners may provide us with information about your activities across different websites or online services.
Publicly available sources. We may obtain information about you from publicly available sources such as news articles, public databases, and open government registries.
Business partners and affiliates. We may receive your data from our affiliated companies or business partners who work with us in connection with our Services or in the context of a business transaction, like a merger or acquisition.
We want to clarify that Smilecloud does not process sensitive data, including health-related information, in our capacity as a data controller. It's our customers who decide the type of data they wish to process using our services.
Should our customers choose to use Smilecloud for the processing of sensitive data, such as health-related information, we act strictly as a data processor. In these instances, the processing is governed by our Data Processing Agreement (DPA), and we adhere to its stipulations, as well as all applicable laws and regulations, to ensure the utmost level of confidentiality and integrity for your sensitive data.
It's vital for customers to understand their obligations when handling health-related or other categories of sensitive data, as they bear the primary responsibility for compliance with relevant data protection laws.
Simply put:
This Privacy Policy explains what personal data Smilecloud collects when you interact with us, including your name, contact info, device details, and more. Some services might only be available if you provide certain info. We also collect data automatically, like how you use our services and your device info, to improve our services and your experience. Plus, we get data from third parties, like social networks or our partners, based on agreements you have with them. And to be clear, we don't process sensitive data like health info as a data controller; that's on our customers if they choose to use our services for such data.
Applicable privacy laws require us to ensure that we have legal grounds for processing your personal data. As a data controller, we must constantly assess the appropriateness of the chosen legal grounds for the corresponding data processing activity. As detailed in the following section (What are the purposes for which we process your data?) and depending on the type of data being processed and the context, we rely on the following legal grounds for data processing:
Consent: In some instances, we may process your personal data based on the explicit consent you provide. This is often the case for certain types of direct marketing or if we collect sensitive personal data about you. When we rely on your consent, you will be informed at that moment and have the right to withdraw your consent at any time.
Performance: We process your personal data as necessary to enter into or carry out the performance of the Contract, as well as other agreements that we may have with you. This includes processing your personal data for contract management, customer service, account setup, transaction completion, billing, and service delivery.
Legal obligations: There may be situations where we must process personal data to comply with a legal obligation—for instance, maintaining records for tax purposes or providing information to a public body or law enforcement agency.
Legitimate interests: Sometimes, we process personal data to fulfill our legitimate business interests while always ensuring we balance these interests against your rights and freedoms. Examples of our legitimate interests include data processing activities for internal administrative purposes, enhancing our Services, ensuring network and information security, and marketing purposes.
For more details and various examples that might help clarify the concept of "legal grounds for processing personal data" further, we encourage you to visit the European Commission's webpage on this topic here.
Simply put:
We handle your personal data based on specific legal grounds: when you explicitly consent (especially for certain marketing activities), to perform our contractual obligations (like delivering our services), to comply with legal obligations (like tax laws), and to pursue our legitimate interests (such as enhancing our services and maintaining security) — all while carefully considering and respecting your privacy rights.
It's important to understand that, as a data controller, we don't use your data arbitrarily. Instead, we process your data for specific purposes, all aligned with providing a safe, efficient, and customized experience when using our Services. In this section, we've outlined the various purposes that guide our data processing activities while also providing their corresponding legal grounds for processing.
Provision of the Services. We process your data to establish a contractual relationship or be able to comply with our contractual obligations related to delivering you our Services. This includes processing for identity verification, billing, account management, service-related notices, and communication. (Legal grounds: Performance of a contract)
Service development, security, and analysis. We process your data to understand how you use our Services and the features you use most often. We may use this data along with anonymized and aggregated data (so that you are not identified) to benefit our systems' integrity and security, support research, analyze and improve the Services, and develop new products, services, or features. (Legal grounds: Legitimate Interest)
Customer support and other communication. When you reach out to us with a support query, provide us with feedback, or other forms of communication (regardless of the medium of exchange), we process your data to effectively respond and resolve your issues, as well as improve our processes. (Legal grounds: Legitimate Interest)
Marketing, promotion, and personalization. Data processing for this purpose may involve the communication of commercial offers and information related to products or services offered by us or our partners. You can always adjust your preferences regarding such communication by accessing the appropriate links in all promotional messages. (Legal grounds: Consent) We may also process data to personalize communications to be more relevant and of interest to you, analyze marketing campaigns to measure the effectiveness of our efforts, and provide you with relevant information and request opinions or reviews concerning our Services. (Legal grounds: Legitimate Interest)
Legal compliance and promotion of rights. We process certain data to comply with our legal obligations and regulatory requirements, such as maintaining records for tax and other administrative purposes, as well as to be able to defend or file a complaint or legal action. (Legal grounds: Legal obligations)
For an in-depth analysis of the principle of "purpose limitation", you may read the Working Party Opinion 03/2013, available for download here.
Simply put:
Our use of your data has clear purposes: to manage our services and our relationship with you (like verifying your identity and managing billing), to improve and secure our services, to help you when you contact us, for marketing and personalizing your experience with us (you can always opt-out of these), and to meet legal requirements. We always align our data use with the legal grounds required under privacy laws.
At Smilecloud, we never sell your personal data to anyone. While we sometimes share this information with third parties, we ensure it's done responsibly, securely, and in line with applicable laws. This section details the circumstances under which and the entities with whom we might share your personal data.
Within our Services. We may share your information with others within our Services to facilitate communication, collaboration, and access to certain features. For example, our Services, like Smilecloud Biometrics, allow you to share content that may contain personally identifiable information or display your public information to others.
Our Customers. We may disclose personal data to our Customers to facilitate service delivery, support, and billing and to improve service experiences. Please be aware that when using an email address assigned by your employer or organization to access our Services, that entity may be able to oversee and manage your usage. This could include their capacity to view or limit your access to certain features or data within the Services.
Third-Party Services, applications, and websites. If you or your Admin enable integrations with Third-Party Services, apps, or websites, we may share certain relevant data with these providers, usually based on your express consent. This data sharing allows us to offer more comprehensive and integrated services. We encourage you to review the terms of service and privacy policies of any Third-Party Services before you enable integrations.
Service providers (Subprocessors). We engage with trusted third-party providers to perform specific tasks on our behalf, including hosting services, analytics, payment processing, and other operational tasks. These service providers are engaged on a contractual basis and only have access to the personal data necessary for performing their services. They are not permitted to share or use the information for other purposes. We constantly assess whether these third parties have implemented and maintain adequate technical and organizational measures regarding data security and privacy. You can find the complete list and the role of each of them on our Subprocessors page.
External partners. We share personal data and anonymized business data with our trusted external partners, who aid us in running our business effectively while adhering to legal requirements. These partners include our accounting and legal teams, our sales and distribution partners, and those ensuring our services' security. Our accounting partners, for instance, may require access to your billing information for auditing purposes. Our legal partners may need access to your data to address potential legal claims or disputes. Our sales and distribution partners may require insights into user engagement to improve distribution strategies or service deployment. Similarly, our security partners, who work diligently to protect the integrity of our Services, may also require specific user data to identify and mitigate threats or unauthorized activities. Sharing such data is integral to maintaining our service's safety, ensuring compliance with applicable laws, and streamlining our operations. We always ensure that these partners adhere to strict confidentiality and data protection obligations, safeguarding your privacy rights.
Affiliates and business transitions. We may share your personal data internally within our family of companies—those we own and control. This sharing facilitates a cohesive service experience and allows us to improve our products and services. In addition, in case of a merger, acquisition, reorganization, sale of assets, or the unlikely event of bankruptcy or insolvency, we may transfer your personal data to the relevant third parties involved while ensuring that your privacy rights are not compromised.
Compliance with legal obligations and protection of rights. We may share personal data in response to legally justified requests from public authorities, such as court orders, subpoenas, or other legal procedures. Situations might also arise where we are required to share your data with law enforcement authorities. This could aid in fraud detection, mitigation, or response to unauthorized Services use or policy violations. Such measures are taken to ensure the safety of our Services and protect our rights, and yours as well as others. In cases where account termination occurs due to a violation of our terms or policies, we may still retain your data as necessary to prevent and mitigate the risks of recurrent or new violations.
Explicit consent for additional data-sharing scenarios. With your explicit consent, we may share your data beyond the scenarios outlined in this policy. In such instances, we will provide you with a comprehensive explanation of what data we propose to share, the purpose for doing so, and the recipient's identity. Your participation shall be completely voluntary, and we will always give you the opportunity to opt-out or withdraw your consent at any time.
Simply put:
We only share your data responsibly: within our services for functionality, with our customers for support and billing, and with trusted third parties like service providers and external partners for operational needs. We also share data for legal reasons or with your explicit consent.
At Smilecloud, we operate on a global scale. This means that your personal data may be transferred and processed outside the country where you reside, including outside the European Economic Area and countries not subject to the General Data Protection Regulation (GDPR).
We ensure that all such transfers comply with applicable data protection laws and are carried out in keeping with recognized safeguards. When data is transferred to countries that may not offer the same level of data protection as that in the EEA, we rely on various legal mechanisms to ensure your rights and protections travel with your data. These include the adequacy decisions made by the European Commission, Standard Contractual Clauses (SCCs), and, where necessary, your explicit informed consent.
Regardless of where your personal data is processed, we apply the same protections described in this policy and adhere to the principles set out in the GDPR. We also comply with additional local law requirements and work diligently to ensure all our subprocessors do the same.
For more in-depth information about data transfer mechanisms, refer to the European Commission webpage here.
Simply put:
We're a worldwide operation allowing you to connect globally, so your data might cross borders. Rest assured, we handle such transfers with care, using legally sanctioned frameworks to keep your data safe no matter where it goes.
As an individual whose personal data is processed by Smilecloud, you possess several rights under the General Data Protection Regulation (GDPR), as outlined below:
This policy is intended to inform you about how we process your data. You can also ask us questions about the processing of your data at any time.
You may request access to the personal data that we process about you.
If you believe the personal data we hold about you is inaccurate or incomplete, you can request that this information be corrected or completed.
In certain circumstances, you have the right to request the deletion or removal of your personal data from our systems.
You may ask us to suspend the processing of your personal data in certain circumstances.
This allows you to request the transfer of your personal data and send it to another party in a structured and machine-readable format.
You have the right to object to the processing of your personal data under certain conditions, including for direct marketing purposes.
If we are processing your personal data based on your consent, you can withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
This right allows you to object to decisions being made about you based solely on automated processing of your personal data, including profiling, if such processing produces legal effects concerning you or similarly significantly affects you. This means you have the right to demand human intervention in the decision-making process or contest the decision.
To exercise your rights, you're invited to get in touch with us using the contact information provided below. For the security of your data, we may need to verify your identity before acting on your request. Our responses may have certain information redacted, particularly when they involve the personal data of other individuals, confidential information, or other business-specific details.
For some of your rights, the action can be taken directly within our Services – for instance, modifying your profile details or erasing certain data you've previously uploaded. In these situations, we might guide you to take those actions yourself.
If your account is under the administration of another party, like your employer, you may need to approach them for assistance in exercising your rights. In scenarios where your request pertains to the processing of your data by us acting as a data processor on behalf of our Customers, we ask that you direct your request to the respective Customer. We're committed to aiding our Customers in responding to such requests as part of our responsibilities as a data processor.
For more information about your rights as a data subject, refer to the European Commission webpage here.
Simply put:
You've got a suite of privacy rights regarding your personal data with Smilecloud. You can ask about your data, access it, correct it, or even have it deleted in some cases. If you're not happy with how we're using your data, you can say so or withdraw any consent you've given. You can use some of these rights directly via our services, or you can always reach out to us. We can verify who you are to keep your data safe, and sometimes, you will need to talk to your employer or whoever manages your account. If you're asking about data we handle for a Customer, please contact them directly; we're here to help them respond.
At Smilecloud, we prioritize the security of your personal data. Recognizing that the technological landscape is in constant evolution and inherently susceptible to vulnerabilities, we remain vigilant and proactive in our efforts to protect your information. We have established comprehensive technical and organizational measures (TOMs), aimed at safeguarding your data against unauthorized access, modification, or deletion. These TOMs encompass aspects such as secure storage, transfer, and processing of your personal data. However, no security system is impenetrable, and while we strive to continually update our security practices to tackle emerging threats and vulnerabilities, we cannot guarantee absolute security. We encourage you to also play an active role in protecting your data. For further details on our data security efforts, please visit our Security Page.
Your personal data is processed and stored in various locations where Smilecloud and our Subprocessors have operations. These locations could be within or outside your country of residence or the European Economic Area (EEA). Rest assured that we only engage with Subprocessors that commit to upholding stringent data protection standards. For a comprehensive list of our Subprocessors and their locations, please refer to our Subprocessors Page.
In determining the appropriate retention period for personal data, we evaluate the amount, nature, and sensitivity of the data. We assess the potential risk of harm from the unauthorized use or disclosure of your personal data. We consider the purposes for processing your personal data and any applicable legal requirements. We commit to securely deleting or anonymizing your personal data when it is no longer needed for its collected purposes or when you request its deletion, provided that we are not legally required or permitted to continue to keep such data.
Account information. We retain the information associated with your account for the duration of the Contract term, which may be until your account deletion date, and for a reasonable period afterward. This is necessary to complete final transactions, resolve outstanding issues, or fulfill recordkeeping obligations. For instance, if you've made a purchase, we may need to keep certain transactional information to comply with financial reporting requirements. Or, if there's an unresolved issue relating to your account, we might need to retain the relevant information until the issue is resolved.
Information shared within the Services. As part of the interactive and collaborative nature of our Services, certain information you share, such as messages, comments, or postings, may persist even after you've closed your account. For instance, if you've participated in a group project or discussion, your contributions may remain part of the project's history or conversation thread. This allows for a continuous understanding and a cohesive user experience for the remaining participants.
Information in managed accounts. For accounts that are administered through an organization, such as your workplace, the duration of your information's retention is determined by the account administrator. This means, for instance, if you are using our Services through a corporate email address provided by your employer, your employer, as the account administrator, may dictate the data retention terms. Your information could be retained for as long as the employer requires, perhaps even beyond your employment period, for reasons like record-keeping, compliance with company policies, or legal obligations.
Marketing information. If you have chosen to receive marketing communications from us, we securely maintain information concerning your marketing choices. Such data is held until you decide to change your marketing preferences.
Financial information. We retain your financial data in line with our legal, tax, and regulatory responsibilities. This can encompass details like transaction records, invoices, or payment history, which are fundamental to ensure accurate bookkeeping and auditing. Such information is retained for as long as required by the relevant laws and regulations governing financial record-keeping.
Simply put:
We keep your personal data only as long as necessary: your account info stays with us until your account is closed and a little after to resolve any pending matters; the content you share in our services remains to maintain context for others even after you leave; if your account is through your employer, they decide the retention period; your marketing preferences are remembered until you change them; and financial data is kept as per legal requirements for things like audits and taxes.
Smilecloud is committed to adhering to data protection regulations not just within our home base in the EU, but across all the territories we operate. While the GDPR sets the foundation of our privacy practices, this section outlines our practices in compliance with various international data privacy laws and provides specific details for those in regions with distinct legal requirements.
If you are located in Brazil, this section provides additional disclosures required by the Lei Geral de Proteção de Dados (LGPD).
Legal Basis for Processing Personal Data. As per LGPD Article 7, we process your personal data based on the following legal bases: with your consent, for the fulfillment of legal or regulatory obligations, when necessary for the performance of a contract or preliminary procedures related to the contract, and when necessary to meet our legitimate interests or a third party.
Data Subject Rights. Under the LGPD, you have specific rights regarding your personal data, similar to those under GDPR. These include the right to confirm the existence of processing, access data, correct incomplete, inaccurate, or outdated data, anonymize, block, or delete unnecessary or excessive data, portability, deletion of personal data processed with consent, and the right to information about public and private entities with which we share data. You also have the right not to give your consent and revoke any consent you have already given. In such cases, we will inform you regarding the consequences of such refusal of revocation, which may include our inability to provide the Services.
Please refer to the “Exercising your rights” section above for the procedures to exercise these rights.
Data Protection Officer. We have appointed a Data Protection Officer as required by LGPD. For any concerns or inquiries regarding the processing of your personal data, please contact our DPO at dpo@smilecloud.com
Data Transfer. In cases where personal data is transferred outside Brazil, such transfer is conducted in compliance with LGPD requirements. Please refer to the “International Transfers” section for more information.
If you are located in Canada, please know that our Privacy Policy is designed in strict accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA), guided by the 10 Fair Information Principles set out by the Office of the Privacy Commissioner of Canada. These principles shape our approach to accountability, transparency, consent, data collection and use, accuracy, access, and security. Our commitments include:
If you have concerns about our data handling practices and are not satisfied with our response, you may contact the Office of the Information and Privacy Commissioner of Canada for further assistance.
If you are located in the United States, please be aware that Smilecloud as a “business” does not generally fall under U.S. privacy regulations such as the California Consumer Privacy Act (CCPA) due to our operations not meeting the thresholds of these regulations.
Please see our Data Processing Addendum regarding our “service provider” status.
Smilecloud is committed to aligning with US privacy regulations' principles and best practices. Our approach includes:
No Sale of Personal Data. Importantly, we do not engage in the sale of our users' personal data. Respecting user privacy is a core value of our business, and we are committed to protecting personal information from unauthorized access or disclosure.
Modifications of the Privacy Policy. We may update our Privacy Policy from time to time, in accordance with the Contract provisions. Any changes we make will become effective upon publication. The "Last Updated" date below will tell you when this policy was last modified. By continuing to use the Service following such changes, you will be deemed to have acknowledged such changes. Your rights under this Privacy Policy will not be diminished without your consent.
How to contact Smilecloud. The controller of your personal data is Smilecloud SRL. If you have any questions or comments about this Privacy Policy, or if you would like to exercise your rights regarding your personal data, please contact us by email at contact@smilecloud.com. You may also write to us at:
Smilecloud SRL
2 Martin Luther Street
Timișoara, Timiș County
Romania
You may also contact our Data Protection Officer here.
If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.
How to contact our joint controllers. If you have questions or concerns related to data processing and would like to contact our joint controllers, please reach out to them through the following details:
Institut Straumann AG
Peter Merian-Weg 12
CH-4052 Basel
Switzerland
Email: privacy.group@straumann.com
Last updated: 18.12.2023
