Smarter Apps Privacy Policy

Last Updated: April 30, 2025

This Privacy Policy explains how your personal information is collected, used, disclosed and otherwise processed by Smarter Apps.com, Inc. ("Smarter Apps", "we", "our" or "us").

This Privacy Policy applies to our mobile applications, including ScannerKit, CaptureQR and StepsAhead, and associated web pages, products and services (each an "App" and collectively, the "Apps"). Our Apps are intended for use in the United States and North America. Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in various US states and other countries. If you reside in a US state that has enabled consumer privacy laws, you may have additional rights with respect to your personal information, which are explained in Section 8 below^[a]. If you reside in the European Economic Area, the UK or Switzerland, you have additional rights with respect to your personal information which are explained in Section 9 below^[b].

1. Information We Collect

We may collect information about you in a variety of ways when you install and use our Apps. The types of information we collect and how we use it is explained below.

Depending on the type of App you have installed, we may also collect additional personal information as more detailed in Section 2 below.

2. Sources of Information and Purposes of Use

Some information is provided to us by you directly, and some is collected by us automatically when you use our Apps. We also may obtain personal information about you from our business partners, such as Apple or Google and social media networks you subscribe to.  When you interact with out Apps, some information may also be collected by these third parties and our advertising partners via cookies or other tracking mechanisms, as detailed in Section 4 (Advertising partners).

You may choose not to provide some or all of your personal information to us or our partners, but doing so may prevent us from providing certain functionalities in our Apps that you would otherwise expect.

2.1 Information collected from you

The following are examples of the types of information we may collect directly from you:

• Name. We may ask your name to personalize your user experience.
• Email address. We may ask your email address to communicate with you about the products and Apps we offer, respond to requests, inquiries, comments, and suggestions and update you with information about your account. We may also use your email address to send you promotional offers regarding our Apps, if you do not opt out upon creating your account with us.
• Username and password. Certain of our Apps use this information to facilitate your access to our Apps and validate your login.
• Other User Information: When using some of our Apps, you may choose to input or provide access to certain additional information to enhance your experience or for using certain functionalities, such as images and documents for scanning Apps. This information will be stored on your device and will not be transmitted to Smarter Apps unless we notify you otherwise at the time of asking you to grant us access to the information.
• For Fitness related Apps, we also collect and store information about your use of the App such as number of steps and goals.
• For QR scanning Apps, we collect links and other associated information included in the QR codes that you submit to the App.  
• Feedback: From time to time, we may request your opinions, suggestions, or modification and improvement ideas through surveys, or other similar requests.
• Payment Information: In the event you purchase subscriptions for services or other products from us, we or a third party on our behalf may collect payment card and other payment information, solely as required to process payment for such purchase. Your failure to provide payment information may prevent you from using certain functionalities of our Apps.
• Location Information: When you use our Apps, we may determine your general location (e.g., city and state) based on your IP address. Additionally, we may also collect precise location data (e.g., longitude/latitude) if you consent within the App to sharing your precise location. Failure to provide such consent will only prevent you from using the features of the App that require your precise location, or obtaining results that the App intends to provide you with based on your location information, but will not affect your use of other features. We may use location information to operate and enhance our Apps as well as customize the content, notifications, and advertising we provide to you. For Apps with advertisements, if you have enabled location tracking, our third-party partners may also collect and use location data to customize advertisements shown to you.  See Your Privacy Choices and Rights^[c] for more information on how to opt-out of receiving relevant advertising.
• Apple Apps: Certain of our Apps may enable syncing with some Apple applications such as Apple Face Tracking and the Apple "Health" App to enhance your experience of the Apps we provide. In such cases, we will ask you for permission to do this and will explain the benefit of syncing the information. You can "un-sync" or alter permissions for our Apps from your Apple "Health" App or general settings at any time. We may also offer the option to store some documents you process via the App using your iCloud account.  

2.2 Information Collected by Tracking Tools

We may collect information using technologies such as the ones described below (“Tracking Tools”):

• Cookies which are small bits of data or code that are used to identify your devices when you use and interact with our websites and other services. They are often used for remembering your preferences. A cookie also may contain information about your device, such as user settings, browsing history and activities conducted while using our website.
• "Pixel tags" (also known as a "clear GIFs" or "web beacons") which are tiny images (in most cases, typically just one-pixel) that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you've opened one of our emails or seen one of our Web pages.
• "HTML5" (the language some websites, such as mobile websites, are coded in) may be used to store information on your computer or device about your website usage activities and to help determine how our Apps are being used by our visitors, how the Apps can be improved and to customize our Apps for our users.

These Tracking Tools may be deployed by us, our service providers on our behalf, or by our advertising partners.  If you reside in the European Economic Area, the UK or Switzerland, your consent will be requested prior to collecting personal information via such tracking tools.

Information gathered by Tracking Tools includes:

• IP address
• Operating system used (for example: iOS)
• Time zone
• Screen resolution
• Cellular data service provider and signal strength
• Internal resolution of the browser window
• Device type
• Country code
• Identifiers associated with technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address)
• Dates and times of access
• IDFA
• Subscription information
• Latitude/longitude (if you allow location tracking)
• AdvertisingID (such as Google's AdvertisingID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device's settings)
• Adjust ID (this identifier lets us know where our users found our Apps online, record user app events and optimize our advertising efforts)

We or our third-party service provider may assign you a unique identifier in order to match information collected from you through Tracking Tools at different times, combine this information with your name or email, and to use such information as described in this Privacy Policy.

2.3 Email marketing

We may send you marketing emails to tell you about our products (including promotions, offers, discounts and new features), and about products of our advertising partners. Where we require your consent to send you marketing emails, we will ask for and keep a record of your consent. We will also provide you with an easy way to opt-out of receiving future marketing emails at any time.

In our marketing emails to you, we may use pixel tags to help us learn how to improve our email delivery and recipient engagement. Data collected in this way is used for aggregated analytics and may include the browser and email service you use, general location derived from your IP address and details about how you engage with the email (e.g., if you  opened, read the email or interacted with any of the content in the email).

2.4 Information collected from Apple or Google.

You may be given the option to sign into our Apps through the use of your device provider accounts, such as Apple or Google. If you select this option, Apple or Google may make some of your account information available to us, such as your email address or other unique identifier or we may be asked to share certain information with such provider. If you choose to sign on through your third party provider, you authorize us to collect your information from such provider and process it in accordance with this Privacy Policy and you also authorize us to share your information with your provider as necessary to permit you to access our Apps using your provider account. We recommend that you review your provider's privacy policies carefully before using your account with them to sign into our Apps.

2.5 Social Media and Other Communications

Certain Apps may enable you to interact with several social networking and blogging platforms, such as Facebook, Instagram, Google, LinkedIn, Twitter, Snap, TikTok and Pinterest. We may incorporate some third-party social networking features into our App functionalities, including, allowing users to interact with others and share certain content and information on social media platforms. Through these platforms and features, we may receive form or share information with social media platforms about you. In addition, the providers of third-party social media or blogging platforms have their own privacy policies that govern their use of your information and their sharing of your personal information with us.

If you choose to communicate with us or another user through social features available on our websites or mobile applications or through our social media pages, or other similar communication or messaging features or services, such information may be made publicly available. For security purposes, please do not include any password, social security number, payment card or other sensitive information via these features. We may monitor messages and communications between and among users for security purposes.

3. How We May Use Your Personal Information

In addition to the purposes described elsewhere in this Privacy Policy, we may use the information we collect the purposes described below.

• Performing Our Services
• facilitating your access to our Apps , operating our Apps, performing tasks and actions as per the functionalities of the Apps, providing you with a functioning, user-friendly experience
• developing customized or personalized experiences of our Apps, such as remembering your information so you do not have to re-enter it each time you use one of our Apps
• processing or fulfilling orders and transactions, verifying user information, processing payments
• maintaining or servicing accounts, providing customer service
• communicating about the Apps and features we offer, and responding to requests, inquiries, comments, and suggestions
• Marketing/Promotion of our Apps
  • Understanding our users and customers in order to more effectively market our Apps
• Monetizing our Apps with Advertisements

• Serving advertisements relevant to you in our Apps as well as in emails we send to you (see also Section 4 below^[d] on how our third party advertisers use Tracking Tools to serve relevant ads to you)

• Auditing Interactions with Users and Consumers

• measuring usage of our Apps
• measuring our advertising and marketing activity (e.g., analyzing how a user or customer was acquired to determine effectiveness of our Apps promotion campaigns)

• Internal Research

• Understanding and evaluating how our Apps and their features perform with our users to inform our development of new features and products improve the Apps and provide users and customers with enhanced features

• Debugging/Repair
  • identification and repair of impairments to intended, existing functionality of our Apps
• Quality and Safety Maintenance and Verification
  • activities related to improving the technical aspects of the Apps we provide, including upgrade or enhancement of the Apps
  • verification or maintenance of the quality or safety of Apps
  • Tracking and responding to quality and safety matters
   
• Security
  • To provide you with a secure experience and to take measures to protect our Apps from cyber risks
  • Protecting against, identifying, investigating, preventing, and responding to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the Apps we provide

• Protecting our rights and property

• Other purposes
  • Complying with legal or regulatory requirements, judicial process and our company policies
  • Other purposes that may be described at the time you choose to provide personal information to us.

We will inform you if it is necessary for us to use your personal information for any purpose other than those stated in this Privacy Policy and obtain your consent (where required by applicable privacy laws) before using your information for such other purpose.

4. How We May Share Information about You with Others

The types of third parties to which your data may be transmitted are as follows:

• Third party service providers 

We may share your personal information with service providers that help us with the development of our Apps, analytics of use of our Apps, our business and operations (for example, software development, analytics, data hosting and storage, marketing, subscription management, payment processing and customer support). Such vendors operate on our behalf as service providers or data processors.

• Apple and Google to enable sign in with your Apple or Google account
• Marketing Partners
• To market our Apps, we may allow ad networks where we promote our Apps to collect information about you via Tracking Tools to provide promotion campaign optimization services to us.  For example we may use Google Ads and Google Analytics to advertise our Apps, and for remarketing and optimization purposes and to understand how you interact with us across different devices. Where individuals allow for personalized ads in their Google settings, we use Google Signals on our applications to target those interested in our Apps with advertisements and understand different groups of users based on the different device combinations. You may opt-out of the use of this tracking technology by turning off personalized ads in your Google settings or by visiting  Google's Advertising and Privacy page.
• Companies like Facebook, TikTok, Pinterest or Snapchat allow us to create “Custom or Lookalike Audiences”. You may learn more about Facebook Lookalike Audiences click here and about your off-Facebook activity and how to opt out of having such activity sent to Facebook click here and about Off-Facebook activity generally here. You can also visit your Pinterest Settings and Snapchat Advertising Preferences to learn more about your privacy options on those platforms. Tik Tok allows you to customize your ads personalization and targeting and clear information tracked by advertisers in the Settings and privacy feature.
• Apple Search Ads may use information from your Apple Account and your activities in the App Store (browsing activity, applications you downloaded and your in-app purchases).
• These ad partners may also use data collected by Tracking Tools to determine payments owed to them, analyze fraudulent traffic patterns, detect and fix errors in their service, and to conduct internal research to improve their service and increase their revenues.
• Advertising Partners
• Some of our Apps are ad supported.  For these Apps, our advertising partners use Tracking Tools to place ads in our Apps and emails we send to you and customize such ads for you based on your past actions in our Apps or on other websites and apps (interest based advertising). These ad partners and ad networks also use Tracking Tools to develop their own ad targeting algorithms and help other advertisers optimize their campaigns. They may also combine information about your activities on our Apps with information about you from other sources not affiliated with us.
• We may co-organize a contest, sweepstakes, event, offering or other promotional activity jointly with third parties. By entering such contest or sweepstakes, you authorize and direct us to share your information with our co-sponsor. We may also share your information with a third-party service provider who administers the promotion, contest and/or sweepstakes. We may also share aggregate information to third party providers and platforms that help us understand our user demographic, including user demographic interests, habits and usage patterns for certain of our Apps so that we may market our products more effectively.
• Corporate Affiliates and potential new owners.

Smarter Apps is part of the Media.net family of businesses. We may share your information with other parts of Media.net for legitimate business purposes, including: (i) to assist us in technical processing operations, such as data hosting and maintenance, finance, legal, HR and accounting assistance, securing our data and systems and fighting against spam, abuse, fraud, infringement and other wrongdoings; (ii) for corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. In addition, we may share personal information of our users and customers to a potential new owner of our Apps, in the event that we carry out a corporate transaction or operation such as a merger, acquisition, reorganization, sale of assets or assignments, and as a part of the associated due diligence.

• Government, judicial, or police authorities, if we receive a request and we are as required to respond to it under applicable laws.
• Other parties as necessary (for example, competent authorities), if we have reason to believe that your actions are inconsistent with our user agreements or policies or that you’ve violated the law, or if it’s necessary to protect our rights, property, and safety or that of our users, the public, or others. Additionally, we may share your personal data if it’s required for the fulfillment of a legal obligation, or if you give us your consent to do so.

5. Your Privacy Choices and Rights

We describe below the ways in which you can control your privacy options.  If you reside in a US state that has enacted a consumer privacy law, you may have additional rights to opt out of our sharing of personal information for interest based advertising.  See Section 8 below^[e].  If you reside in the European Economic Area, the UK or Switzerland, you have additional rights to opt out of our collection or sharing of personal information via automated means. See Section9 below^[f].

Device permissions and settings

Mobile platforms have permission systems for specific types of device data and notifications, such as geolocation, camera and microphone as well as push notifications. Where applicable, you can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain Apps may lose full functionality.

If you choose to opt-in, to location information, some of our Apps may collect your device's precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the App and/or on your device.

When you allow Notifications, we may send you offers and promotions related to our Apps. You may opt-out of these through the Settings menu on your device.

Uninstall

If you uninstall the App from your mobile device, we will no longer collect additional personal information, but some information we have collected prior to your uninstall will continue to be stored on our systems. For example, the unique identifier associated with your mobile device, your email address and password will continue to be stored. If you reinstall the App on the same mobile device, we will be able to re-associate these identifiers to your previous transactions and activities.

Email

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the footer of the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time, by sending a request to privacy@smarterapps.com. Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive transactional or administrative messages from us regarding the Apps or your purchases or subscriptions.

Advertising Opt-Outs

To provide you with more control over the ads you see in our App, we support the Digital Advertising Alliance's AppChoices program. AppChoices is a mobile application that allows you to opt out of interest-based in-app advertising from participating companies.

How to Use AppChoices:

1. Download AppChoices: You can download the AppChoices app from your device's app store. It is available for both iOS and Android devices.
2. Manage Your Preferences: Once installed, open the AppChoices app to view and manage your preferences for interest-based advertising. You can choose to opt out of interest-based ads from participating companies.
3. Effect of Opting Out: Please note that opting out through AppChoices does not mean you will no longer see ads. You will still receive ads, but they may not be as relevant to your interests.

You can change your preferences at any time by revisiting the AppChoices app. We recommend periodically reviewing your settings to ensure they reflect your current preferences.

For more information about AppChoices and how it works, please visit http://www.aboutads.info/appchoices.

Note that other industry self regulatory programs for online behavioral advertising such as the Digital Advertising Alliance's WebChoices tool at http://www.aboutads.info/choices/ and the Network Advertising Initiative cookie opt-out tool available at http://www.networkadvertising.org/choices/ are designed for ads placed on web pages and are not the best option for in-App ads.

Cookie Settings

Your web browsers may offer you the ability to disable receiving certain types of cookies that support interest based advertising. Your internet browser will contain information on how to disable cookies, or you can visit www.aboutcookies.org/how-to-control-cookies/. However, such settings will not affect ads that are displayed within our Apps. Mobile apps have their own mechanisms for managing privacy settings and user preferences, independently from browser settings or features.  

Do Not Track Disclosures

Some web browsers may transmit "do-not-track" signals to the websites with which the user communicates. "Do-not-track" signals are not an effective way to opt-out of interest based advertising for in-App ads because mobile apps operate independently of web browsers and are unable to read "do-not-track" signals from a mobile browser. Mobile apps have their own mechanisms for managing privacy settings and user preferences. In addition, because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our Apps do not currently process or respond to "do-not-track" settings in your web browser. If and when a final standard is established and accepted, we will reassess how to respond to these signals. Our advertising or marketing partners may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.

6. Data Retention

Except as provided below, we may retain your personal information three (3) years after we become aware that you have ceased using our Apps or opening our emails or for so long as necessary to fulfill any contractual obligation governing the information or our legal and regulatory obligations. However, we may not know if you have stopped using our Apps, so we encourage you to contact us at privacy@smarterapps.com if you are no longer using your Apps. We may retain other information that is aggregated and/or not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so.

7. International data transfers

Smarter Apps is headquartered in California. To access our Apps, your device interacts directly with our servers in the United States. If you are installing one of our Apps, your data is automatically collected, processed and stored on servers located in the United States.  If you are installing one of our Apps from the European Economic Area, the UK or Switzerland, or any other country that is not the United States, your data is automatically collected, processed and stored on servers located in the United States. The United States may not have the same data protection laws as the country in which you reside.

8. Information for Residents of Certain US States that have enacted Consumer Privacy Laws

If you are a resident of a US state that has enacted a consumer privacy law such as California (“State Privacy Law”), you may have rights that are in addition to those set forth elsewhere in this Privacy Policy regarding your personal information. These rights apply to "Consumers" as defined by the State Privacy Laws. This section describes your rights as a Consumer under these State Privacy Laws and explains how to exercise those rights.

8.1 Access Rights

You may request the right to know what personal information we have collected about you, including the categories of personal information, specific pieces of personal information, categories of sources from which we collected your personal information, business or commercial purposes for our collection, sale or sharing of your personal information, and categories of third parties to whom we’ve disclosed your personal information.  

You may also request a list of the categories of personal information about you sold or shared (as those terms are defined in each of the State Privacy Laws including the California Consumer Privacy Act) in the prior 12 months, or that no sale or share occurred. If we sold your personal information, we will explain the categories of your personal information we have sold and the categories of third parties to which we sold personal information, by categories of personal information sold for each third party.

You may also have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information stored on our systems that we have collected in the last 12 months prior to your request date.

8.2 Data Correction Rights

You may request to have inaccurate personal information corrected and updated.

8.3 Data Deletion Rights

Except to the extent we have a basis for retention under State Privacy Laws, you may request that we delete from our systems your personal information that we have collected directly from you.

8.4 Opt Out of Interest Based Advertising (or selling/sharing your personal data)

You may request that we stop using or sharing your personal information for interest based advertising (or “selling” / “sharing” your personal data as those terms are defined in the California Consumer Privacy Act).

8.5 Exercising Your Rights

To make a request for exercising your rights under State Privacy Laws, send your request to privacy@smarterapps.com. You may exercise these rights via an authorized agent. We cannot respond to your request or provide you with personal information if we cannot verify your identity or the authority of your agent to make the request and confirm that the personal information relates to you. Any request you submit to us is subject to an identification and residency verification process. You must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Some personal information we maintain about our users is not sufficiently associated with enough personal information for us to be able to verify that it is a particular individual’s personal information. In accordance with State Privacy Laws, we do not include such information in response to Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify personal information that we collect, process, store, disclose, and otherwise use and to respond to a verified request. We will typically do not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

To exercise your right to opt out of interest based advertising or “selling” / “sharing” your personal data as those terms are defined in the California Consumer Privacy Act), follow these steps:

1. In-App Settings: Navigate to the Privacy Settings section in the App and select “Do Not Sell or Share My Personal Data.”
2. Email: Submit your request via email to privacy@smarterapps.com.
3. Global Privacy Control (GPC): GPC signals are not an effective way to opt-out of interest based advertising for in-App ads because mobile apps operate independently of web browsers and are unable to read GPC settings from a mobile browser. Mobile apps have their own mechanisms for managing privacy settings and user preferences, such as the ones described above. In the event we place interest based ads on web pages accessible via our Apps, we will automatically honor your opt-out preferences if you use a mobile browser or extension that supports GPC signals.

We will not discriminate against you in a manner prohibited by the State Privacy Laws because you exercise your rights under State Privacy Laws. However, we may charge a different price or rate or offer a different level of functionality of the App, to the extent that doing so is reasonably related to the value of the applicable data. In addition, we may offer you financial incentives for the collection, sale and retention and use of your personal information as permitted by the State Privacy Laws that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly.

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. As discussed above, if we share Personal Information with third parties for their marketing purposes you will be able to elect for us not to do so by submitting your request to privacy@smarterapps.com (please include your name, mailing address, and email address).

Notice to Nevada users

We do not sell covered information, as defined under Chapter 603A of the Nevada Revised Statutes, and we do not have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, please contact us at privacy@smarterapps.com. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our practices change.

9. Information for Individuals in the European Economic Area (EEA), the UK or Switzerland

9.1 Your Choices and Rights.

As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:

• Access: you may request access to your personal information and receive copies of it;
• Correction: you may have inaccurate/incomplete personal information corrected and updated;
• Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
• Deletion: in certain circumstances, you can request a right "to be forgotten" (this is a right to have your information deleted or our use of your data restricted). We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
• Portability: in certain circumstances, exercise the right to data portability (this is a right to obtain a transferable version of your personal information to transfer to another provider); and
• Consent Management: where we rely on consent to process your personal information, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.

To exercise your rights, you may contact us at  privacy@smarterapps.com (please include your name, mailing address, and email address). If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with our Services or some of the features and functionality of our Services. In addition, you may contact us to request that we not disclose your personal information to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as data processors). Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

For your protection, we may require proof of identity and verification before we can answer the above requests.

9.2 Legal basis for processing and storing personal information in the US

In this section, we identify the legal grounds on which we rely to process your personal information in the United States.

• In some cases, we have a legitimate interest to process the personal information that we collect, such as to develop, administer and support our products and services; to operate, evaluate and improve our business; to facilitate and manage engagement programs; to promote research; to support our recruitment activities; or to facilitate a corporate transaction such as a sale of assets or merger or acquisition.
• In other cases, we process personal information to fulfill our contracts with business partners, such as third parties that distribute our products.
• It may also be necessary for us to process personal information to establish, exercise or defend against fraud, illegal activity, and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide.
• Our processing of certain information may be necessary to comply with our legal obligations, and for reasons of public interest, such as with respect to adverse event and product safety reporting.
• We may also process personal information as specifically permitted by applicable legal requirements.
• If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.

10. How We Protect Personal Information

We use various efforts intended to safeguard the security and integrity of personal information collected through our Apps. Despite these measures, however, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk.

If you correspond with us by email or using Web forms like a "contact us" feature available through our Apps, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Apps, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.

If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. If we have your email address, we may notify you by email to the most recent email address you have provided us in your account profile. Please keep your email address in your account up to date. You can change that email address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application.

11. Links to Websites and Third-Party Content

For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by us. The websites and third-party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of any entity that we do not own or control. We encourage you to review the privacy policies of such third parties before providing them with any personal information.

12. Information Relating to Children

We do not knowingly collect information from children under the age of 13 (or 16 in the EEA, or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 13 years of age (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE APPS. If you are a parent or legal guardian and believe that we may have personal information from or about your child under 13, please contact us at privacy@smarterapps.com.  Note that we'll attempt to delete the account of any child under the age of 13 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.

13. Updates to Our Privacy Policy

We reserve the right to update this Privacy Policy to reflect changes in our practices and Apps. When we post changes to this Privacy Policy, we will update the date of this Privacy Policy. Continued use of the Apps after such date constitutes acceptance of such updates. When required by applicable law, we may inform you by additional means, such as through a notification on the website or in our mobile applications if we make material changes to how your personal information is collected, accessed or otherwise used as a result of your use of the Apps or if your rights under this Privacy Policy are materially impacted by changes to our privacy practices. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Policy.

We understand that privacy laws are constantly evolving. New US state laws and new international privacy laws are consistently emerging, developing and being enacted. We will respect all applicable privacy laws.

14. How to Contact Us

If you want to submit a request by email or if you have any other questions about privacy or data protection at Smarter Apps, you can contact us at privacy@smarterapps.com.