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Privacy Notice

IT SMART HEADS

Last updated: May 2022

Intro
We in INNOVATIVE ACCOUNTING SYSTEM LLC ("IT SMART HEADS") take care of your ("you", "user" or "data subject") personal data and do everything possible to protect it.

This Privacy Notice is written to help you understand how your personal data is collected, stored and used and what happens to it when you use our website ("website") and its subdomain ("subdomain").

Please note!
This Notice does not cover recruiting data, but does cover B2B relationships

This Privacy Notice is our (data controller) statement to you that describes how we collect, use, retain and disclose personal data.

For us, you can be:

Data subject (Description)
Visitor (User who researches the website)
Staff (User who clicked "Go to staff tool")
Client (Users who fill out our forms)

Content
Intro
Who we are
Personal data we process


  • Technical data
  • Data provided by users
  • Data obtained from third parties
Information on data transfer

  • General
  • Transfer of data outside the European Economic Area
Your privacy rights
The use of cookies
Update


Who we are

Data controller: INNOVATIVE ACCOUNTING SYSTEM LLC, Company ID No.: REGON: 39770806 Address: 18 Lipinskiy Str., of. 302, 49000, Dnipro, Ukraine
Email: hello@itsmartheads.com — for privacy and general questions


Personal data we process
The data we process is divided into categories: technical data, data provided to us by the users and data obtained from third parties.

Pay attention!
We do not knowingly process personal data of visitors under the age of 16 without consent from a legal representative(s). If you are such a visitor or the legal representative of the visitor, please let us know by email: hello@itsmartheads.com .

Technical data
When you visit our website, some data is collected automatically.

Data we collect
IP address, UTM parameters, geolocation, device type, browser type, cookies, User-agent, User ID and data about your interaction with the website – session ID.

Reason for data collection
The smooth operation of our website

Session ID is your interaction with a website, a website's name from which you came to our website, the features you use, the pages used on our website, how you use our website and the actions you take if any.

Data provided by users
We collect data when (Visitor): You use our website
Personal data: Technical data; Necessary cookies
Legal basis: Legitimate interest
Reasons for processing: Website operation

We collect data when (Visitor): You use our website
Personal data: Marketing cookies; Statistics cookies; Preference cookies
Legal basis: Consent
Reasons for processing: Website operation; Analytics; Statistics.

Period of storage
Data processed on the basis of a legitimate interest (Stored for up to 2 years after the last use of the website)
Data processed on the basis of consent (Stored for up to 2 years from the last time you used the website or until you withdraw your consent

We collect data when (Staff): You moved to the subdomain
Personal data: Login; password; name; surname; phone number; e-mail; position at work.
Legal basis: Performance of the contract
Reasons for processing: Providing access to the Help Desk system

Period of storage
Data processed on the basis of performance of the contract (Stored for the duration of use of our service + 3 years)

We collect data when (Client): You click "Invite to tender", "Request a consultation", "Order a consultation", "Apply", "Call back"
Personal data: Company name; name; phone number; e-mail;
Legal basis: Performance of the contract
Reasons for processing: Provide a service

We collect data when (Client): You fill in "Leave feedback"
Personal data: Company name; name; phone number; e-mail, your feedback;
Legal basis: Legitimate interest
Reasons for processing: Development of services and advertising

Period of storage
Data processed on the basis of performance of the contract (Stored for the duration of use of our service + 3 years)
Data processed on the basis of a legitimate interest (Stored for the duration of use of our service + 3 years OR until you want to delete the feedback)

Please note! You can exercise your right to delete your data. In this case, we will delete your data from our servers within 30 days of your request.

Data obtained from third parties
Also, we can collect some data from third parties. The scope of the data collected, the purposes and the legal basis for the processing is determined by the respective privacy documents of these parties:

Third parties -> Description -> Link to privacy documents
Facebook -> We use Facebook for marketing ->Privacy Policy
Google Analytics -> We use Google Analytics for statistics and analytics ->Safeguarding your data
Twitter ->We use LinkedIn for communication and support -> Privacy Policy
Facebook ->We use Facebook for communication and support -> Privacy
LinkedIn ->We use LinkedIn for communication and support ->Privacy Policy
Telegram ->For communication and support -> Privacy Policy
YouTube ->We use Youtube for publishing video about us -> YouTube Privacy Controls

Please note! We use a large number of third parties to provide services to you, and this list may change periodically. If you want to see the full list, please write to us at hello@itsmartheads.com .
We guarantee that we take all necessary measures to protect your data.

Data transfer
General

We use your personal data to perform a contract and for communication between the users and us.

Also, we transfer your data on the following grounds:

Consent. We transfer your personal data based on your explicit consent.

Compliance with the law. We will disclose your personal data to third parties to the extent that it is necessary:



  • to comply with a government request, court order, or applicable law;
  • to prevent unlawful use of our website or violation of the Terms and Conditions of our website and our policies;
  • to protect against claims of third parties;
  • to help prevent or investigate fraud.
Legitimate interest or performance of the contract. We transfer your personal data to third parties based on a public offer for processing on our behalf, subject to technical and organizational measures to protect your personal data.

Business transfers. We will transfer your data between Smart Solutions companies and between structural departments of Smart Solutions. We will also transfer data to individual controllers in the context of service provision and to the extent strictly necessary to provide it.

Transfer of data outside the European Economic Area
The personal data we collect is stored on our servers in Germany. The data is processed in Ukraine. There is no decision on adequacy by the European Commission. If we need a data transfer, we will take necessary steps to protect it. We will transfer your personal data outside the EEA to provide service with all appropriate safeguards to protect your personal data.

In addition, we use technical, administrative and physical security measures to protect against the loss and misuse of information under our control. However, if a data transfer is required to perform a contract or to provide you services, we have the right to do so without your consent.

Please note! We do not plan to transfer your data outside the EEA by default.

Data protection
We protect the information on computer servers in a controlled secure environment that is protected from unauthorized access, use or disclosure. We take reasonable administrative, technical and physical security measures for protection.

More about our protection measures:

Physical protection measures:
Video surveillance, Limited access to premises, Signaling, 24/7 security, 12/7 (24/7) system administrators duty, Fire extinguishing system
Technical protection measures:
Two-Level Authentication, Backup, Firewalls, Encryption technologies
Organizational protection measures:
Staff training, Non-disclosure agreements, Internal policies and instructions, Transmission protection

Your privacy rights
You, as a data subject, have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them:

Right (Description)
The right to access (You can request an explanation of the processing of your personal data)
The right to portability (You can request all the data that you provided to us, as well as request to transfer data to another controller)
The right to restrict processing (You may partially or completely prohibit us from processing your personal data)
The right to file complaints (You can file a complaint to the regulatory body)
The right to be forgotten (You can send us a request to delete your personal data from our systems unless there is a legal requirement to keep it)
The right to withdraw consent (For data that you have previously consented to, you can always withdraw your consent, and we will stop processing it)

Please note! We may ask you to verify your identity before responding to a request. To exercise your rights, write us an email at hello@itsmartheads.com .
We will answer you as soon as possible.

If we do not satisfy your request, you can file a complaint to the regulatory body in Ukraine:
All appeals are sent to the Secretariat of the Verkhovna Rada Commissioner for Human Rights at the address: 01008, Kyiv-08, str. Institutskaya, 21/8, or to Regional representatives of the Commissioner.

The use of cookies
We process technical data and use cookies. You may find our Cookies Policy on our website.

If you want to disable cookies, you can find instructions for managing your browser settings at these links: Internet Explorer Microsoft Edge Chrome Vivaldi Firefox Safari Opera

Update
This Privacy Notice and the relationships falling under its effect are regulated by the GDPR and Law of Ukraine "On Protection of Personal Data".

Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on our website.

If significant material changes are made that affect your privacy and confidentiality, we will notify you by email or display information on the website and ask for your consent.