This website https://smartan.ai/ (“Website”) and the Smartan.ai Services (“Services”) are operated by Baro Labs SRL. Services offer online publishers (“Publishers,” or “Publisher”) behavioral analytics of the users (“Users,” or “User”) of Publishers’ websites and/or mobile applications.
Data collected in the Smartan.ai Dashboard may include personal information about Dashboard Operators like their name, account name and password, job title and employer name, phone number, email, IP address, information about the device used to access the Services, and it’s method of connecting to the Services.
We use this data to provide the Services to the Publisher and operate our business, to improve the quality of the Website and the Services, for fraud detection and prevention, for security, safety and dispute resolution, for communication and marketing purposes, and for research purposes.
Data collected by the Services may include information about Users and their behavior on the Publisher’s website and/or mobile application where the Services are used. Depending on the configuration of the Services by Publisher, we may or may not collect information relating to identifiable persons like Users’ IP addresses, and utilize 3rd party cookies that allow us to gather data about a User’s behavior across several domain names.
We use this data to provide the Services to the Publisher and operate our business, to improve the quality of the Website and the Services, for security and fraud detection and prevention, and for research purposes.
Additionally, we may collect data elements that do not relate to identified or identifiable persons, such as information received from the User’s web browser, operating system, or device, including limited information about the browser type, version and settings, browser language preference, limited information about the operating system, the referring web page, device information (including the type of device), screen size and resolution, date and time of the User’s request, the name or type of mobile application, including the name, type and version of the Publisher’s mobile application the User is using, and other similar information.
We may also collect non-precise information about the geographic location of the device not more detailed than the city that the User is accessing the Publisher’s website or mobile application from.
When a User visits and navigates the Publisher’s website and/or mobile application, the Services also collect information about the User’s behavior on the website or mobile application including, but not limited to, the headlines that the User sees and/or clicks on, how long the User spends on each story page, what percentage of the page is visible to the User, as well as actions the user takes on the story page, including liking/disliking the story and sharing it via email or social networks (we don’t collect any information about recipients of the shared story).
Some information may be received directly from the Publisher, like the User’s subscription status and other non-personally identifiable information provided to us voluntarily by the Publisher to improve the quality of the analytics insights in the Smartan.ai Dashboard.
We use this data that does not relate to identified or identifiable persons to provide the Services to the Publisher and operate our business, to derive insights about Users’ interests, conduct research and test new features, gain understanding about the demographics of Publisher’s website and/or mobile application, and analyze trends, perform aggregate analysis, monitor aggregate usage by Users, customize and target content to show Users more relevant and engaging content, share data with Publishers, to improve the quality of the Website and the Services, as well as for internal reporting and marketing purposes.
Whether you are a Visitor of the Website or visiting our Website on behalf of the Publisher to use the Smartan.ai Dashboard, we may collect and store information including your IP address, browser, device type, access times, the web pages you view on our Website, and your non-precise geo-location not more detailed than the city that you are accessing the Website from.
We use such information to administer and improve the Website, to operate our business, to help us understand and analyze how it is being used, to track aggregate Website usage, for security and fraud detection and prevention, for research purposes, as well as to improve our marketing channels and materials.
We may collect data that by itself directly identifies individuals when it is submitted to us voluntarily, for example when individuals send us emails or otherwise communicate with us via the Website.
We may use such data to contact the individual in accordance with the individual’s stated preferences, respond to their requests, and resolve problems, to improve the quality of the Website and Services, operate our business and market our Services.
Baro Labs may use a variety of commonly-used technologies such as cookies, pixel tags, web beacons, and/or other similar technologies (collectively “Cookies”) to assign a unique identifier to each User, Visitor and Dashboard Operator to identify the individual across multiple usage sessions. This unique identifier is then used to identify sessions belonging to the same individual, for the purposes of collecting data identified in the previous sections of the policy.
We honor the Do Not Track browser option to give Users control over how their behavior on the web is used to personalize their experiences. If Users prefer that we not aggregate information collected about their usage in different sessions and on different websites for the purpose of providing analytics and behavioral insights to Publishers, Users can turn this feature off for a given browser using the Do Not Track browser setting. Users may also opt out of Baro Labs having access to mobile device identifiers (such as the IDFA or the Android Ad ID) through their device settings.
If Users do not want us to track their online behavior for the purpose of providing analytics and behavioral insights to Publishers, they can opt out by visiting the page smartan.ai/optout and selecting that option there. This will place an opt-out cookie on their browser. If Users delete, block, or otherwise restrict cookies, clear their cookie cache, update their browser, override their device settings or switch devices, they will need to renew their opt-out choices. If Users opt out, data may still be collected about Users’ web browsing activities, but separate page requests will not be identified as belonging to the same user.
The data we collect is stored and protected using generally accepted industry security standards. Once collected, the data may be retained by us in non-aggregated form for as long as necessary to provide the Services to our partners, to comply with our legal obligations, resolve disputes, prevent fraud, enforce our agreements, for record keeping and compliance purposes, or as long as we have a legitimate business need.
Once a Publisher expressly cancels the Services, we remove, anonymize, or aggregate data about Users and Dashboard Operators within 1 year, unless otherwise agreed in writing.
We may also anonymize the data derived from the Publishers’ Users’ data by removing identifying characteristics and aggregating it with the information of others so that it becomes anonymous and does not identify or trace to a specific Publisher or any of Publisher’s Users (“Aggregated Data”). We may use Aggregated Data without restriction and store it indefinitely.
Baro Labs only shares Collected Data with third parties in the following scenarios:
We may share Aggregated Data without restriction.
Our Services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information. If you become aware that your child has provided us with personal information without your consent, please contact us at email@example.com.
The following provisions apply to you only if you are located in the European Economic Area (“EEA”).
You acknowledge and agree that your personal information may be processed by us or on our behalf in the country where it was collected as well as other countries, including the United States, where laws regarding processing of personal information may offer less protection of your personal information than in your country.
Any Personal Data, as defined in the EU General Data Protection Regulation (“GDPR”), provided to Baro Labs by Publisher or on Publisher’s behalf (“Publisher Personal Data”), if any, and the processing thereof, shall be governed under the terms and conditions set forth in the Smartan.ai Data Processing Addendum (“DPA”) if (a) the processing is in the context of the activities of an establishment of Publisher in the EEA; and/or (b) Personal Data relates to data subjects who are in the EEA and the processing relates to the offering to them of goods or services or the monitoring of their behavior in the EEA.
Baro Labs and its sub processors may process Publisher Personal Data outside of the jurisdiction of Publisher. Publisher acknowledges and agrees that, in connection with the performance of the Services under the Agreement, Publisher Personal Data will be transferred to Baro Labs to the United States. For transfers of Publisher Personal Data to Baro Labs for processing by Baro Labs in a jurisdiction other than a jurisdiction in the EU, the EEA, or the European Commission-approved countries providing ‘adequate’ data protection, Baro Labs agrees it will use the form of the Standard Contractual Clauses to enable the lawful transfer of Publisher Personal Data or an alternative transfer solution in accordance with Article 45 or 46 of the GDPR.
Publisher shall not provide to Baro Labs any Personal Data regarding children below the age of 16 years, or any health, financial, or insurance data or other sensitive data subject to specific regulatory or statutory protection regimes, except as may otherwise be expressly agreed in writing between the parties and in accordance with applicable law. In the event that Publisher provides such data to Baro Labs, solely Publisher (and not Baro Labs) shall be liable for any such data which is provided or otherwise made available to Baro Labs or anyone on its behalf.
The legal basis for us processing your Personal Data will typically be because:
In some cases, we use legitimate interest as a legal basis for processing Personal Data in order to provide our Services. A legitimate interest we rely on, for instance, is the tailoring of promotional communications to users of our Services, deriving insights about Users’ behavior and interests as part of providing Services, responding to individuals’ inquiries concerning our Services.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
We also rely on legitimate interest when we use Personal Data to maintain the security of our Services, such as to detect fraud or to ensure that bugs are detected and fixed.
If the processing of personal data is necessary and there is no contract or other lawful basis for such processing, we will generally ensure that consent has been obtained from you. You have the right to withdraw your consent to processing of personal data at any time.
The GDPR provides EEA residents with certain rights in respect of Personal Data that data controllers hold about them, including certain rights to request access to Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, to object to our processing of your Personal Data, to exercise the right to data portability, and to withdraw consent you’ve given to processing of your Personal Data at any time. You also have a right to lodge a complaint with a supervisory authority.
If you have questions or concerns about data processing or wish to exercise your rights under the GDPR regarding Personal Data we process as a data controller, you may contact our Data Protection Officer at firstname.lastname@example.org.
Effective: May 21, 2018