describes our policy regarding the privacy of Personal Information for the online platform
“Smart Sender” (hereinafter referred to as the “Platform”).
References to the words “we”, “our” or “us” (or similar words within the meaning)
means the Smart Sender Platform.
References to the words “you,” or “your” (or similar words within the meaning)
That is, an individual whose Personal Information we collect, use and process.
store and process on the Platform server, as well as our principles
for processing Personal Information.
store and process on the Platform server, as well as our principles
for processing Personal Information.
or through channels other than this Platform.
The Client registers on the Platform website and has the right to connect Chatbots.
For example: Telegram, Viber, VKontakte, Facebook Messenger, Skype, WhatsApp.
The Client has the right to register on the Smart Sender Platform by filling out
the form or using the quick registration via social networks: Facebook, Twitter, Google.
The Client may transfer the Personal Information of his active Subscribers from any other
platform to the Smart Sender Platform, keeping the entire base of Subscribers,
if such a transfer is technically possible to carry out from such another platform.
With the help of the Chatbot, Client may automate his support and his actions
depending on the Subscriber's response, create an online store and increase
the number of goods and/or services he sells.
When collecting, processing, storing Personal Information, Smart Sender makes every
effort to adhere to the rules and requirements that are provided for by the
General Data Protection Regulation (Regulation (EU) 2016/679 of April 27, 2016), known as “GDPR".
We are grateful to you for using the Smart Sender Platform.
Definitions and Terms
Smart Sender Platform - means a website to increase sales and clients
loyalty that uses chatbots and Messengers offline mode.
GDPR (General Data Protection Regulation) - means the regulation
within the framework of European Union legislation on the protection of personal data
of all natural persons who are citizens of the European Union.
Owner of the Smart Sender Platform or the Owner - means
SMARTSENDER INTERNATIONAL LLC, a legal entity registered in accordance with the laws
of Ukraine, location: Ukraine, 02105, Kyiv, Sobornosti Avenue, Building 4, Apartment 76,
represented by the director Oleksandr Serdiuk
(hereinafter referred to as the "Owner");
Client - means an individual who registers on the Platform
and is a user of Smart Sender services.
Subscriber - means an individual who registers on the Platform
(using a pop-up window or by sending a message to the Chatbot) and with whom
the Client contacts, or will contact in the future using the Smart Sender services.
User - means the common name of Clients and Subscribers of the Platform.
Controller - means any natural or legal person, government authority,
institution or other body that independently determines the purposes and means
of processing Personal Information.
Processor - means an individual or legal entity, government agency,
institution or other subjects that processes Personal Information on behalf
of and on behalf of the Controller.
Third party - means a natural or legal person, public authority,
institution or subject other than the data subject, controller, processor and persons
who are authorized by the controller or processor under their direct supervision
to process Personal Information.
User's Consent - means a voluntary, specific, informed and unambiguous
expression of will, in which the User, by means of a statement or a clear affirmative action,
consents to the processing of his Personal Information.
Social network - means an online platform that is used by the User
for communication, dating, creating social relations between people who have similar
interests or offline connections, as well as for entertainment (music, films) and work.
Double Opt-In - means a type of subscription that implies additional
confirmation of your email address directly from the email. For example: The User, when
registering on the Platform server, received an e-mail to his e-mail, which indicates
that to confirm the registration, the User needs to follow the link. Also, the Subscriber
can start interacting with the Platform by writing a relevant command in his Messenger.
Single Opt-in - means a one-step confirmation of the subscription,
when the User just needs to enter his email and click the "Subscribe" button.
Pop-up - means a floating window that opens on the computer screen
to confirm an action.
Chatbot - means a program that simulates real communication with the User.
Services - means the tools and materials developed and provided
by Smart Sender to manage and increase the number of your Subscribers and the goods and / or
services sold; for integration with various types of services. For example: save Personal
Information of Clients from Smart Sender to Google Sheets.
Cookies - means small text files that store information about your
previous activities on the Platform. For example: the date and time of the site visit,
clicks and transitions, your preferences.
Personal Information - means any information that directly or
indirectly allows you to identify you or your Subscriber. For example: your name,
surname, phone number.
Payment system - means a payment organization, members of a payment
system and a set of relations that arise between them during the funds’ transactions.
Address Book - means a list of contacts and information about
the Client's Subscribers, for example: email address, name, birthday.
and basic provisions for using the Platform. For example: tariffs,
client support functions, integration with other services.
Web beacon - means an electronic image called one-pixel (1x1)
or blank GIF images. Web beacons are capable of recognizing certain types
of information on your computer, such as cookies, the time and date
the page was viewed, and the description of the page where the
web beacon is located.
Messenger - means instant messaging system.
For example: Telegram, Viber,
Smart Pixel is intended for the interaction of the User
with the functionality of the Platform Services.
Account - means a body of data that stores a collection of data
about the User in a computer system.
Service - means the provision of services to the Clients of the Platform.
Data protection officer - an individual who is appointed
by the Controller and Processor to protect Personal Information.
Checkbox - means an element of the User's graphical interface,
which allows the User to confirm his consent. For example: when registering on
the Platform Server, when expressing consent to the processing of Personal Information.
You can familiarize yourself with the services and rules of the Platform
the Platform User provides in various ways.
of Personal Information obtained when using the Platform, as well as when interacting
through Messengers or Payment systems.
When interacting (providing services, exchanging data, maintaining statistics) of the Platform
with Messengers, the User's Personal Information is processed, provided, stored and protected
the Viber Messenger, all Personal Information you provide will be subject
When interacting (providing services, exchanging Personal Information, maintaining statistics)
of the Platform with Google services, the User's Personal Information is processed, provided,
When interacting (providing services, exchanging data, maintaining statistics) of the Platform
with the services of Facebook - the User's Personal Information is processed, provided,
The Owner is not responsible for the processing, transfer, safety and protection of the User's
Personal Information while interacting with other services and / or Messengers. For example:
When using the Viber Messenger, the owner of this Messenger (Viber) will be responsible
for the processing, transfer, safety and protection of the User's Personal Information.
The Owner has the right to access the Personal Information of the Client's Payment Systems.
We use various types of Payment systems to carry out mutual settlements with our Users.
For example: Stripe,
PayPal. You can
Payment systems by clicking on the links above.
When the Platform performs transactions with the Client's funds, the Client's Personal
Information is processed, provided, stored and protected in accordance with the privacy
policy of the relevant Payment System. For example: When using the PayPal payment system,
the owner of this payment system (PayPal) will be responsible for the processing,
transfer, safety and protection of the User's Personal Information.
with the GDPR (General Data Protection Regulation). The purpose of the audit: compliance
with the provisions and compliance with the GDPR rules.
The audit is carried out in the following cases:
At the beginning and at the end of the reorganization of the company's
activities in accordance with the GDPR;
According to the schedule every 6-12 months;
Before starting work with new contractors;
Before conducting risky transactions with Personal Information;
After revealing the fact of violation of the security of Personal Information.
The Owner has the right to conduct the following types of audit:
- Internal audit. Carried out by the company independently;
- Sanctioned audit. It is carried out by regulatory bodies authorized to conduct
investigations and inspections for the proper processing of the Personal Information
of the Platform and its counterparties;
- External audit. It is carried out by an independent expert
in the protection of Personal Information.
The Personal Data Protection Officer is appointed by the Controller or Processor
in any of the cases provided for in Article 37 of
the General Data Protection Regulation (GDPR).
We are not responsible for the actions of other companies
that are not controlled by the Platform.
To provide a high-quality service, we have the right to receive, process, store
and transfer the Personal Information of Users from messenger websites,
social networks. For example: Google, Facebook.
The User's Personal Information received from other websites
Using the Platform, we do not collect or process intentionally any Personal Information
about persons under the age of sixteen. If you have not reached the age of sixteen, do not
use the services of the Platform. In the event that we become aware of the use of
the Platform by such a person, we will delete the collected information about it.
If you have information that such a fact took place, please contact the support
service by sending an email to firstname.lastname@example.org.
We distinguish the following categories of Personal Information:
Sensitive information - means information, unauthorized disclosure,
modification or concealment of which may lead to tangible loss or material damage.
For example: race, religious and political beliefs, income information, gender - anything that,
if disclosed, could violate privacy and cause moral harm to an individual.
Statistical information - means information that rarely changes
over time or is not subject to change. For example: phone number, email,
IP, passport data, cookie.
Biometric information - means unique biological and
physiological characteristics that allow you to identify a person.
For example: fingerprint, face, voice, iris, palm and finger veins.
The Platform stores Personal Information about Clients:
the language that the Client uses to work on the services of the Platform;
Platform entry time;
browser, operating system;
subscription to email notifications from the Platform;
a key to confirm 2-factor authorization, if an account login was added;
social network user ID (if logged in using any of the available methods: Twitter, Facebook, Google);
information about the Subscribers who were invited to the Platform;
payment information to pay for the services of the Platform through the Payment system;
information about payments that pass through Payment systems within the framework of projects created by the Client;
history of using promotional codes from events and / or advertising;
information about Messengers.
The Platform stores Personal Information about Subscribers:
status (signed, not signed);
date of the first communication;
Subscriber identifier in the Messenger (through which communication with the Client goes);
clicks on links sent in Messengers;
following links in the Messenger dialogue;
chat history (messages, button clicks, status delivered, read status, message sent status);
advertising identifiers for further advertising purposes;
Subscriber transition of labels from advertising;
context variables, for example, User ID in their system, additional information;
information about the Subscriber's purchases
(first and last 4 digits of the card, card type, token for debiting in one click);
general purchase history of the Subscriber (payment statuses, quantity);
Subscriber identifiers in other analytics systems: ROISTAT, Google Analytics,
Facebook, Yandex Metrica;
the Subscriber's interest in other objects, goods;
internal contact notes;
arbitrary recurrent subscriptions created by the Subscriber;
all arbitrary information that the Subscriber left on the Platform.
For example: step, Subscriber requests.
The Owner has the right to collect any other Personal Information about his Users.
For example: Profession, preference, address.
Users voluntarily provide us with Personal Information using the services of the Platform,
consulting with support staff, sending us email messages, integrating our service
with another site or service, or cooperating with us in any other way.
During your interaction with the Platform, we automatically receive and record
Personal Information about your actions. For example: the history of the
pages viewed, the time and date of the visit, the browser used.
The collection of Personal Information is carried out using
log files, cookies and other tracking technologies.
The Platform may use Personal Information to tailor it to your preferences
and improve the navigation of the Platform and the services it provides.
of the Platform, partner companies, Messengers, display targeted advertisements,
and also to collect demographic information about the User. For example, if the login
to the site is carried out using a cookie, then, after the User enters his data
on the login page, the cookie allows the server to remember that the User
has already been identified and is allowed access to the corresponding services and operations.
storing personal preferences and settings of the User;
tracking the User's access session;
storing statistics about the User.
The Owner, when providing services, uses the following types of cookies:
Session cookies, also known as transient cookies, exist only
in temporary memory while the User is on a website page. Browsers usually
delete session cookies after the User closes the browser window.
Persistent cookies are deleted on a certain date or after
a certain period of time. This means that information about the cookie will
be transmitted to the server every time the User visits the website
to which these cookies belong. For example, they can be used to avoid re-entering
data each time you visit the Platform.
Third-party cookies are a type of files that appear when web
pages contain content from external websites, such as links to other websites. For example,
they can be used to track the history of visits by the User to other websites.
Web analytics cookies are used to analyze the behavior of the
User when browsing various pages of the website. One of these is Google Analytics,
a web analytics service provided by Google Inc. ("Google"). The use of the above
cookies is based on Art. 6 of the General Data Protection Regulation (GDPR).
Information generated in relation to your use of our Platform may include:
browser type / version;
operating system used;
Referring domain url (pre-visited website);
hostname of the computer from which the access is being made (IP address);
server request time.
The Owner, when providing the Services, uses the following types of cookie:
locale - used to define preferences in the language, storage for unauthorized users;
accounts:sid - session using accounts.smartsender.com;
console:sid - session using console.smartsender.com;
messenger:sid - session using messenger.smartsender.com;
customer:sid - session using customer.smartsender.eu
direct:sid - session using direct.smartsender.com;
support:sid - session using support.smartsender.com;
ref - saved referral token, if an individual was invited by another individual within the referral program;
id_token - JWT authorization between microservices, protected by base64 + a secret key to verify it;
home:sid - session using smartsender.com;
ssid - user identifier on the Smart Sender Platform for communication via Smart Pixel.
and we are not responsible for the provisions of their privacy policies.
The Platform may use web beacons to determine the User's activity,
for example, the User clicks on the links of other sites.
Using web beacons, we determine the effectiveness of the provision
of our services and improve the quality and stability of our Service.
We have the right to receive information about Clients and Subscribers
from third-party sources, for example: social networks, databases of
third-party data providers and partners. The collection of such information
is carried out exclusively by legal means. We also use Personal Information
to supplement information about our Users.
We have the right to create anonymous records
from Personal Information, without identifying the User.
The Platform contains links to third party sites or social networks whose privacy
policies may differ from ours. Recommendation: check and read
he privacy policies of all websites you visit.
Use of Personal Information
We have the right to process Personal Information for the following purposes:
registration on the Smart Sender Platform;
sending information and advertising content according to your preferences;
invoicing for which Users are paid for Smart Sender services;
sending system notifications;
providing support to Users;
ensuring compliance with the provisions described
ensuring the safety and protection of the rights of our Users,
third parties and the Platform;
compliance with legal requirements and implementation
of court orders, inquiries and other legal processes;
providing information to representatives and advisers of the Platform, including
lawyers and accountants, who help us with legal compliance,
accounting and security requirements;
filing claims and protecting interests in litigation, dispute and other legal disputes;
responding to requests from government agencies, including for national
security purposes and compliance with law enforcement requirements;
providing, maintaining and improving the offered services;
formation of relevant offers to Users.
Employees of the Owner have the right of limited access to Personal Information of Users
on the Platform's services, for example: lawyers when protecting the Owner's rights,
developers when making changes to the Platform's software, an accountant
when making settlements with the Client and / or keeping records.
The Controller and / or Processor have the right of limited access to
the Users' Personal Information on the Platform services,
in the performance of their direct duties.
The right of limited access (if there is a request on behalf of the User) to
the Personal information of Users on the services of the Platform
has the support service of the Platform.
We have the right to process the User's Personal Information based on the User's
consent received, as provided for in Art. 4 GDPR: “any freely given, specific,
informed and unambiguous indication of the data subject’s wishes by which
he or she, by a statement or by a clear affirmative action, signifies agreement
to the processing of personal data relating to him or her;”
Disclosure of Personal Information to third parties
We have the right to disclose Personal Information in the following cases:
Service providers. We use the services of third parties
(services, social networks) to provide our services or to perform certain activities
on our behalf related to the processing of your Personal Information.
For example: collecting Personal Information from social network accounts.
Third parties. (in case of control change)
The Owner has the right to sell, disclose or transfer information about Users as part
of a corporate business transaction such as an acquisition or merger,
financing, corporate reorganization, joint venture, including
the sale of company assets, or in the event of bankruptcy,
bankruptcy or insolvency, in which such the information
can be disclosed to any third parties as a business asset
in a transaction. For example, in the event of a merger
of the Platform with another similar service, your
Personal Information may be transferred to such a service.
Third parties. (in case of protection of our rights)
The Owner has the right to disclose your Personal Information if he believes
that this is necessary to protect his legal rights and interests.
For example: In the case of protecting your rights in court,
in disputes with third parties.
For courts, law enforcement and government agencies.
The Owner has the right to transfer Personal Information in case of fulfilling any
legal obligations (including in connection with a court order). For example:
Court order, request from the government and/or law enforcement agencies.
For partners. The Platform may disclose statistical
Personal Information to its partners, for example: Personal Information of Users,
information about the structure of traffic sales with our partners.
For the other third parties. With the written or online consent
of the User, Platform may disclose Personal Information to third parties.
For example: e-mail from the User, check-box confirmation.
CMS systems, CRM and other websites. We have the right to
transfer Users' Personal Information to systems and websites that integrate with
our service at your request, in accordance with the provisions described above.
All third parties with whom the Platform exchanges Personal Information are obliged
The Owner never transfering the Messenger ID to third parties.
An individual is registered as a Subscriber of the Platform by sending a message
to the Platform's chatbot using the Messenger. Depending on the type of Messenger,
the commands for registering as a Subscriber of the Platform may differ.
For example: to start interacting with the Platform using the Telegram messenger,
press the START button in the dialog box. In order for Facebook to start interacting
with the Platform using the Facebook Messenger, you need to click the button with
the name “BEGIN” in the language that the Subscriber has set on his device.
Subscriber registration methods may change over time due to innovations in the
functionality of such Messengers.
We reserve the right to obtain the consent of an individual to register on the Platform's
services using the Pop-up. The pop-up window may contain a consent form in the
form of a checkbox. For example: An individual who confirms such a checkbox
is automatically registered on the Platform server as a Subscriber.
The Client has the right to import Personal Information about his Subscribers
to the Platform Servers. The Client is responsible for the availability
of the appropriate permission (explicit consent).
The Client must provide explicit consent to the transfer of the Subscribers’
Personal Information to the Platform service in one of the following ways:
Explicit consent requirement:
Consent must be consistent with the specific processing purposes of the Client;
Silence, pre-ticked checkboxes, or inaction do not constitute consent;
The Client is obliged to obtain an unambiguous consent from the Subscriber
to import Personal Information;
The Client is obliged to make sure that it keeps proper records
and stores the consents of its Subscribers.
Address Book is created by the Client.
Address Books are stored on a secure server of the Platform.
We under no circumstances transfer the Client's Address Books to third parties.
Only authorized employees have access to the Address Books.
For example: controller, support employee.
If the User contacts the Platform support service, our specialists will answer him.
We have the right to transfer Personal Information only
Personal Information. The user can contact us directly to request access to the
Personal Information that we hold about him, as well as to any information
in accordance with Art. 15 General Data Protection Regulation.
Exercise of the right to access: To gain access to his Personal Information,
which is stored on the Platform server, the User must write a request to
the Platform support service.
The right to be forgotten. The User has the right to delete
Personal Information about himself or his account, after considering the User's
request sent to the support service or through a special section of the Platform.
Personal Information and / or account, in this case, will be permanently deleted.
The Client can remove individual Subscribers at their request, at any time,
in accordance with Art. 17 General Data Protection Regulation.
Exercise of the right to access: To delete your Personal Information or account that is stored
on the Platform Server, the User must go to a special section of his personal account and
take the appropriate action or contact the support service by e-mail: email@example.com.
Right to rectification. The User has access to Personal Information
that needs to be updated, corrected, supplemented at any time. The user can also contact
the support of the Platform in order to access his information in order to correct,
change or delete it, in accordance with Art. 16 General Data Protection Regulation.
Exercise of the right to access: To make corrections to his Personal Information,
which is stored on the Platform server, the User needs to write a request to
the Platform support service.
The right to transfer data. We can transfer the User's Personal
Information to third-party organizations, at any time and at the request of the User,
in accordance with Art. 20 General Data Protection Regulation.
Exercise of the right to access: To carry out the transfer of his Personal Information,
which is stored on the Platform server, the User needs to write a request to the
Platform support service.
The Subscriber has the right to unsubscribe from interaction with
the Platform service by writing a “stop” command in the Messenger.
In order to delete Personal Information, the Subscriber must request a list
of Personal Information using the Messenger. To do this, he needs to register
the command profile in the dialogue with the Chatbot in his Messenger. Or send
an email to the Platform support service at firstname.lastname@example.org.
The Subscriber has the right to delete and / or upload the Personal Information collected
by him using the Platform service by writing an email to the Platform support service
at email@example.com, or register the profile command in the dialogue with the
Chatbot in his Messenger.
Storage, accuracy and safety of Personal Information
Personal information stored on the Platform's server
is tied to the User's name and password of his account.
Client's Personal Information is stored on the Platform
website until it is deleted by the Client.
The Subscriber's Personal Information is stored on the Platform website until it
is deleted by the Client or the Subscriber refuses to subscribe, but no
longer than the period for which we may need such information. Unnecessary
information is deleted automatically or after a decision to delete it.
We retain Personal Information for as long as is necessary to provide services or
comply with our legal obligations, resolve disputes, prevent misuse, and
enforce our agreements. For example: If the User stops using our services,
his Personal Information is deleted from the Platform's website.
Personal Information that is stored on the Platform server
is considered the property of the User.
We have the right to use and disclose the User's Personal Information only for
In the event of a change in Personal Information, the User is responsible for
notifying the Platform of such changes. For example: The User has changed
the Personal Information (e-mail, phone number, passport data), which is
necessary for the correct provision of services, and has not notified
the Smart Sender Platform support service about this fact.
At the request of the User, we provide information about the fact of processing
of Personal Information by third parties. For example: the use of Personal
Information by Social networks, mobile services.
We make every effort to ensure that Personal Information is accurate and up-to-date, to the extent possible,
in accordance with General Data Protection Regulation.
Smart Sender notifies the User that his Personal Information can be used by
the Platform to provide services, and in case of disagreement,
the User must leave the Platform website.
Smart Sender has the right to collect Personal Information of Users in order
to obtain marketing and statistical information.
Protection of Personal Information
We take all reasonable and appropriate measures to protect Personal Information from loss,
misuse and unauthorized access and disclosure, modification and deletion, taking into
account the risks associated with the processing and specifics of Personal Information.
The Platform Servers is located in Estonia, and the User's
Personal Information may be transferred to this country.
Although laws to protect the rights and privacy of Personal Information may differ from
those in your country, we do our best to provide adequate measures
to protect your Personal Information.
We use the following methods to protect Personal Information, in accordance
with Art. 32 General Data Protection Regulation:
pseudo anonymization and encryption of Personal Information;
the ability to ensure the continued confidentiality,
integrity, availability and resilience of processing systems and services;
regular testing, assessment and measurement of the effectiveness of technical
and organizational measures to ensure the security of the processing
of Personal Information.
By putting a check in the blank field of the checkbox, you agree to the rules for the collection,
storage, processing and transfer of your Personal Information to third parties to whom we may
Smart Sender makes every effort to ensure that any actions related
to Personal Information fully comply with the provisions
of the General Data Protection Regulation.
of personal data and compliance with legal requirements.
We notify the User of such changes by posting news on the website,
sending an e-mail newsletter, or using other means.
In the event that the User has unsubscribed from emails in which we inform about all changes
in the legal documentation, the User is still responsible for reading them.
at the time of your visit to the Platform.
If you would like to ask questions, provide feedback, update Personal Information stored
on the Smart Sender Platform please contact support at: firstname.lastname@example.org.
You can also contact us at the following mailing address: Ukraine, 02105, Kyiv, Sobornosti Avenue, Building 4, Apartment 76.