Privacy Statement

1. Data Controller

Smart Code provides Services to users throughout the world. However, Smart Code processes personal data inside of the United States only. Smart Code does not transfer data of its users outside of the United States.

Smart Code's data controller is:

Questions, comments and complaints about Smart Code's data practices can be submitted to Smart Code at [email protected].

2. The Data We Collect From You

For users accessing our independent technical publication at smartcode.news, the Platform operates on a strict zero-data profile. We do not require user registration, profile creation, or form submissions to access our core technical journalism. We do not harvest, compile, or store personal identifiers for readers accessing these public media services.

In order for you to utilize our Services, including but not limited to, scheduling a meeting via our Calendly link or submitting an inquiry, we collect the following data from you:

Data You Provide

• Inquiry and Scheduling Information: When you schedule a meeting or contact us through our website, we collect information necessary to facilitate that communication and provide the requested services. This includes your name, email address, phone number, and any other information you choose to provide in your message or during the scheduling process.
• Correspondence with Smart Code: Smart Code may collect personal data from you if you contact us. The purpose of collecting this data is for us to better help us assist you in resolving any issues or answering any questions you may have. This may include information such as your email address or contact number for follow-up conversations.

In order to collect this data automatically, we use certain analytics tools incorporating tracking technologies that recognize your device and compiles data about you. One example includes the use of cookies. For more information, please see the section titled Policy on Cookies and Similar Technologies.

3. How We Use Your Data

We collect, store and use the data you provide to us for the following purposes:

1. Company Communications

We will contact you through email, phone, or other means to facilitate scheduled meetings, respond to your inquiries, and provide information related to our Services. We will send you messages about the availability of our Services, security, or other service-related issues. You may change your communication preferences at any time.

2. Development of the Services

We use the private data we receive, including feedback, to: (i) monitor and analyze trends; (ii) further develop our Services in order to provide you and others with a better, more intuitive and personalized experience; (iii) to estimate our audience size and usage patterns; and (iv) to improve our customer service and support.

3. Marketing & Advertising Communications

We utilize your data to provide you with relevant marketing and advertising content, including newsletters, new product offerings, special discounts, event notifications, and select third-party opportunities that align with our services. By engaging with us, you consent to receiving such communications.

We are committed to your privacy: every promotional email will include clear instructions for opting out of future marketing communications. You may also manage your preferences or opt-out at any time by contacting Smart Code at [email protected].

4. Who We Share Your Data With

1. With Third Party Service Providers

We share the data we collect from you with third party service providers. This may include:

• Scheduling and Communication Platforms - Currently, we use Calendly to facilitate meeting scheduling. Calendly has its own separate privacy statement that can be found at https://calendly.com/privacy.
• Payment processors and facilitators - Currently, we use Quickbooks for all payment and processing needs associated with facilitating our Services. Quickbooks has its own separate privacy statement that can be found at https://quickbooks.intuit.com/eu/privacy-policy
• Consultants, lawyers, accountants and other professional service providers; and
• Data analytics providers.

2. With Investigators, Governmental Bodies, Authorities or Law Enforcement Agencies

We may share your data if required by applicable law, regulation, legal process or governmental request, or where the disclosure is otherwise appropriate due to a safety or similar concern. This includes sharing your data with law enforcement officials, government authorities, or other third parties as necessary to enforce our Terms of Service or other policies, as well as to investigate and protect Smart Code or its users from fraudulent, abusive, inappropriate, or unlawful acts.

3. With Potential Buyers or Investors

We may share your data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restricting, financing, or acquisition of all or a portion of our business by or into any another company, or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Smart Code about its users is among the assets transferred.

4. With Other Parties You Consent To

We may share your data with any other third parties other than as described in this policy if we notify you and you consent to the sharing.

5. With Marketers and Advertisers

Smart Code may share but does not sell your data with third parties for marketing or advertisement purposes. If this changes in the future, you will be immediately notified, and this policy will be revised accordingly to provide you with the right to opt-out of any such marketing and/or advertisement.

5. How Long We Retain Your Data

Data Retention & Erasure: Smart Code retains your communication history and associated data for as long as necessary to fulfill the purposes for which it was collected or to provide the Services you have requested. You may request the erasure of your personal data at any time by contacting Smart Code at [email protected]. Upon receipt of a valid request, Smart Code will process the deletion of your identifiable communication records within thirty (30) days.

Compliance & Regulatory Records: Please be aware that Smart Code is subject to various global regulatory, tax, and legal requirements. To comply with these obligations, we maintain certain records, including transaction histories and core communication logs for a period of seven (7) years. Following this period, Smart Code will securely delete or anonymize such data in accordance with applicable laws.

6. Your Rights Relating to the Use of Your Data

We at Smart Code want you to have complete control of your data, and therefore, you always have the right to:

• Access any of your personal data we hold about you;
• Ask us to erase any personal data we hold about you;
• Ask us to not use your personal data for direct-marketing purposes;
• Restrict the way we process your personal data;
• Have your personal data provided to a third-party provider of services;
• Have a copy of any personal data we hold about you; and
• Object to our processing of your personal data.

If you need help or wish to exercise any of the above rights or have questions about them, please do not hesitate to contact Smart Code at [email protected]. If you would like to request that we delete your personal data from our system, you can do so by contacting Smart Code at [email protected].

If you ask to have your data deleted or to close your inquiry, we will use commercially reasonable efforts to honor your request; however, certain data may persist internally or for our administrative purposes subject to the records retention policy discussed in Section 5.

7. How We Secure Your Data

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer data. When our accounting software processes purchase orders, the purchase order is subject to strong security measures against unauthorized access, destruction, loss, alteration or misuse. Our security procedures require us in some cases to request proof of identity before disclosing personal information to you.

Although we use reasonable organizational, technical and administrative measures to protect your personal data, it is unfortunately true that no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, please note that while we do our best to protect your personal data, we cannot fully guarantee the security of any personal data you transfer over the Internet. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in our Services.

If you have reason to believe that your interaction with us is no longer secure, please contact us immediately at [email protected].

8. Special Information for Individuals Located in the European Economic Area

Beginning May 25, 2018, the processing of personal data of users within the European Economic Area (EEA) is subject to the EU General Data Protection Regulation ("GDPR"). This section summarizes Smart Code's grounds for processing personal data under the GDPR, and the rights of such users as it relates to Smart Code's handling of personal data.

1. EU User Rights

If you are located within the EEA, you have the following rights with respect to how Smart Code handles your data:

• Requesting Explanations of What Data of Yours Smart Code Stores and How It Is Used - You have the right to request an explanation of the data that Smart Code has about you and how Smart Code uses that data.
• Requesting Copies of Your Data - You have the right to receive a copy of the data that Smart Code collects about you if collected on the basis of consent or because Smart Code requires the data to provide the Services that you request.
• Requesting Correction to Your Data - If Smart Code has data about you that you believe is inaccurate, you have the right to request correction of your data.
• Requesting Your Data to be Deleted - You may request deletion of your personal data at any time by contacting Smart Code at [email protected]. We may retain certain data about you as required by law and for legitimate business purposes permitted by law, which is further discussed in Section 5.
• Filing an Objection or Complaint - Users in the EAA have the right to object to Smart Code's processing of personal data, including for marketing purposes based on profiling and/or automated decision-making. Smart Code may continue to process your data notwithstanding the objection to the extent permitted under GDPR. Users in the EAA also have the right to file a complaint relating to Smart Code's handling of your personal data with their local Data Protection Authority ("DPA"). You may also submit complaints or objections directly to Smart Code by contacting Smart Code at [email protected].

2. Legal Basis for Processing Your Data

The GDPR requires that companies processing the personal data of EEA users do so on the basis of specific legal grounds. As such, Smart Code will only process your personal data in the following situations:

• The Processing Is Necessary to Perform Our Contract With You. Smart Code must collect and use certain data in order to provide its Services that you have contracted with Smart Code for. This includes user data that is necessary to facilitate scheduling and provide requested information.
• The Processing is Necessary for Smart Code's Legitimate Interests. Smart Code collects and uses personal data to the extent necessary for its legitimate interests, which includes: (i) to provide customer support; (ii) to optimize our service and develop new services; (iii) for research and analytical purposes; (iv) to enforce Smart Code's Terms of Service; and (v) to provide you notices about changes to our Services.
• Your Explicit Consent Is Given. Smart Code may collect and use your data on the basis of your consent. For example, we rely on your consent for us to use your personal data to send you marketing information (such as our newsletters and promotional offers) by email, SMS, or telephone. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any part of our Services that requires collection or use of the data we collected or used on the basis of your consent.

9. International Data Transfers

The personal data we collect may be transferred to, and processed and stored in, countries outside of the jurisdiction you are located in. For example, if you are located in a country with the EEA, your personal data may be processed in the United States. All international transfers of your personal data are made:

• To a country or territory ensuring an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data as determined by the European Commission;
• To a the third party that is a member of a compliance scheme recognized as offering adequate protection for the rights and freedoms of data subjects as determined by the European Commission; or
• Pursuant to appropriate safeguards, such as the Standard Contractual Clauses (processors) approved by European Commission Decision C(2010)593 or any subsequent version thereof released by the European Commission or the EU-U.S. Privacy Shield.

If you wish to enquire further about these safeguards used, please contact Smart Code at [email protected].

10. Policy on Cookies and Similar Technologies

Smart Code and its partners may use cookies on our websites and emails for purposes described in this policy.

1. What are cookies?

A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

2. What are cookies used for?

Some examples of what these tracking technologies are used for by Smart Code may include:

• Analyzing traffic to our Services; and
• Generally reviewing and understanding the behaviors of people who have an interest in or utilize our Services.

3. How long will cookies stay on my device?

The length of time a cookie will stay on your computer or mobile device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your computer or mobile device until they expire or are deleted.

4. Who Does the Cookies Belong To?

First-party cookies are cookies that belong to Smart Code, third-party cookies are cookies that another party accesses or places on your device through our Services. Third-party cookies may be placed on your device by someone providing a service for Smart Code, for example, to help us understand how our Services is being used. These companies' use of cookies and similar technologies is subject to their own privacy policies, not the Smart Code Privacy Statement.

5. Types of Cookies Use.

The cookies we use generally fall into one of the following categories:

• Technical/Required - These cookies are essential for our Services to function properly. Like other cookies we use, technical cookies may be either first-party cookies or third-party cookies.
• Analytics - We use these cookies to help us understand and improve our Services. For example, we can use these cookies to learn more about which features are the most popular with our users and where we may need to make improvements.

6. How to Control Cookies or Other Collection Mechanisms

You have the right to choose whether or not to accept cookies. However, please be advised that if you set your browser to disable cookies or other tracking technologies, you may not be able to access certain parts of our Services or the functionality of certain aspects of the Services may be limited. In addition, you have other choices with respect to how cookies are used:

• Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser which are usually located within the "Help" or "Preferences" menu. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link.
• Removing or rejecting browser cookies does not necessarily affect third-party flash cookies which may be used by us or our partners in connection with our Services.
• For mobile users, you should have controls on your device that enables you to choose whether to allow cookies.
• To help control or block certain ads in mobile applications, you may choose to download and utilize the DAA mobile app.

7. Web Beacons

In addition to Cookies, pages of our website or emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Smart Code, for example, to count users who have visited those pages or emails and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

8. Why Does Smart Code Use Cookies and Web Beacons?

We use cookies and similar technologies to show you relevant content, improve your experience, and help protect Smart Code and our users. We may use these technologies to deliver the service, provide you with a service that is easy to use, enable you to move around the Services and use its features, and storing data so that Smart Code can respond faster. We may use these technologies to collect data about how you use our Services, for example which pages you go to most often and if you get error messages from certain pages.

In alignment with our structural commitment to engineering integrity and privacy, smartcode.news does not deploy invasive third-party tracking pixels, programmatic ad network tracking mechanisms, or behavioral profiling cookies. While the Platform features exclusive enterprise underwriting placements (such as 'The Executive Spotlight'), these placements are served directly via our static infrastructure without tracking scripts or behavioral data harvesting. If you select an external link belonging to a corporate sponsor, you will leave our domain and interact with their independent privacy policies and tracking frameworks.

11. Links to Third Party Sites

Our Services may contain links to other sites. If you click on a third-party link, you will be directed to that site. We do not operate these external sites. Therefore, we strongly advise you to review the privacy statement and any terms of use for any such websites, as those websites may collect personal data from you or have their own policies regarding the use of tracking cookies and related technology. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. Age Restrictions; Parental Consent

Our Services are intended for users of all ages; however, unfortunately, no one under the age of 13 may use the Services unless such person has a parent or guardian who first provides verifiable parental consent. We do not knowingly collect personal data from children under 13, unless such an individual has provided explicit verifiable parental consent. If you are under 13, do not use our Services or provide any data about yourself to us, including your name, email address, company or any screen name or user name you may use, without first having your parent contact us to provide verifiable consent. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that data. If you believe we might have any data from or about a child under 13 without having the necessary parental consent, please contact Smart Code at [email protected]. To request a parental verification, please contact Smart Code at [email protected].

13. Changes to this Privacy Statement

The date this Privacy Statement was last revised is identified at the top of this agreement. If we make changes to this Privacy Statement about how we treat our users' personal data, we will notify you by email to the primary email address specified in your inquiry. We will also post the updated privacy statement on our website in the same location as the previous version. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you, and for periodically visiting our website and this Privacy Statement to check for any changes. If we make material changes to this Privacy Statement, we will notify you by email at least fifteen (15) days prior to the date on which such changes take effect.

14. How to Contact Us

We are here to help and be as transparent as possible regarding how we use, store and transfer your data. If you have any questions regarding this Privacy Statement, or if you wish to exercise any of your rights in relation to your personal data, or if you want to object to the collection or processing of your data by Smart Code, whether entirely or partially, please contact us at [email protected].