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Privacy policy
SmartAn LLC ("SmartAn", "We", "us", "our") is a privacy conscious organization. We are committed to protecting your personal information and your right to privacy. This Policy explains how we handle and treat your data when you (1) visit our site, ("Site"), and (2) engage with us regarding our Product/Services. By using our Site, you hereby consent to our Privacy Policy and agree to its terms.

Information We Collect

We may collect information from you in the course of our business, including through your use of our Site, when you request information about us or our Product/Services, or otherwise when you contact us.
The personal information we collect depends on the context of your interactions with us and the Site.
The personal information we collect may include the following:
We may also collect other personal information you may choose to provide us with in the context of our business purposes.

Use of Cookies and Tracking Technologies

We may use cookies to access or store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.

You can choose to disable cookies through your individual browser options. For more information on Cookies, please see in Cookie Policy.

We also may use Log Files to log visitors when they visit the Site. The information collected by log files include internet protocol (IP) addresses, browser type, operating system, Internet Service Provider (ISP), date/time stamp, click activity on the Site. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the Site.

Purposes of Processing Information

We use the information you provide for the following business purposes:

To fulfill contract obligations regarding our Product/Services.
We may use personal information to contact customers, to facilitate the use of our Product, and to deliver Services you request in order to comply with our contract obligations.

To administer your requests, inquiries, and feedback.
We may use personal information to respond to your inquiries and requests, and to solve any potential issues you might face with the use of our Site or/and Product/Services.

To send administrative information to you.
We may use personal information to send you updates and other information regarding our Product/Services, and changes to our policies, terms.

To send marketing and promotional information to you.
We may use personal information for marketing and promotional communications. You can opt-out from our marketing emails at any time.

To deliver targeted advertising to you.
We may use personal information (with or without assistance of third parties) to develop and deliver content and advertising specifically tailored to your interests or/and location. It also may be used to measure effectiveness of that advertising.

To understand and analyze how you use our Site.
We may use personal information to identify you when using our Site, to understand your activity on our Site, to conduct analytics of such activity to be able to improve, personalize our Site/Services, to create new functionality and features.

To operate and protect our Site.
We may use personal information to ensure the efficiency of the Site, and as part of our efforts to keep Site safe and secure, for example for fraud detection and prevention purposes.

To enforce our terms and policies.

To comply with legal and regulatory requirements, to respond to legal requests.

Disclosure of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

Affiliates and Business Transfer Partners. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). We also may share or transfer personal information in connection with, or during the negotiations of any merger, acquisition, asset selling, or financing negotiations.

Vendors, Consultants, Other Service Providers. We may share your data with third-party vendors, consultants, and other service providers who perform services for us and require access to personal information. Among other things such third parties help us to administer our Site, promote our Product/Services, analyze data, conduct surveys, deliver emails, and provide technical support. We may allow selected third parties to use tracking technologies on the Site, which will enable them to collect data on our behalf about how you interact with the Site. Unless described in the Policy we do not share or sell personal information with third parties for their promotional interests. We have contracts in place with our data processors which are designed to safeguard your personal information, meaning they are obliged to protect the data, and not share the information with any organization apart from us.

Business Partner
s. We may share personal information with our business partners to offer you certain Products, Services and Promotions.

Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, or a violation of our policies.

International Transfer of Information

We and our servers are located in Russia. If you are accessing our Site from outside, please be aware that your information may be transferred to, stored, processed by us in our facilities and by those with whom we share your personal information in other countries. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, despite the difference of certain jurisdictions in comprehension of data protection regulations, we take measures to provide an adequate level of data protection in accordance with applicable law.

By submitting your personal information to us, you agree to the transfer, storage, and processing of your information other than your country of residence.

We have implemented the tools to protect personal information of the EEA and UK residents, including the use of the European Commission's Standard Contractual Clauses for transfers of personal information inside our company's group and between us and our third-parties contractors. These clauses require all parties to process personal information of the EEA and the UK residents according to the European data protection laws and regulations.

Term of Holding Information

We retain your personal information for the period necessary to fulfill the purposes outlined in the Policy, but generally no longer than 3 years from the date of the last interactions with us, unless a longer retention period is required or permitted by law for the certain type of personal information.

When there is no more legitimate business purpose to process your personal information, we may then either delete or anonymize such data, or, if this is not possible, we may securely store it without further processing until deletion is possible.

Protection of Information

We take a number of organizational, technical, and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is fully secure. Despite our safeguards or reasonable efforts to keep your personal information from unauthorized access, use, or disclosure, we cannot guarantee the 100% security of your personal information.

In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Privacy Rights

You have the following rights in relation to the personal information we hold:

The right to access.You have the right to know whether we are processing your personal information and, if necessary, to request copies of your personal data. We may need to charge a reasonable fee for copies. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.

The right to rectification.

If you believe that the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified.

The right to erasure.You have the right to ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable).

The right to restrict processing.You have the right to ask us to "block" or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us.

The right to object to processing.

You have the right to ask us to stop processing your personal information, and we will do so, if we are (1) relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; (2) processing your personal information for direct marketing purposes.

The right to data portability.You have the right, in certain circumstances, to obtain personal information you've provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

The right to withdraw consent.If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

To exercise mentioned privacy rights, please make a request using contact details provided below. We will consider your request and act upon applicable law.

If you have a concern about any aspect of our privacy practices, you can report it to the relevant Supervisory Authority.

Other Important Information

Contact Details.

If you have questions, comments or requests regarding your private information, please contact our Data protection officer (DPO), Maria Mikhailenko, by email:, or by mailing address:

Smartan LLC,
38-2, Zvezdnyi Bul'var, app. 44
Moscow, Russian Federation 129075

Updates to Privacy Policy.

We may make changes to this Privacy Policy over time. The updated version will be indicated by the "Revised" date, and the updated version will be affected as soon as posted. We will notify you about material changes either by posting a notice or by email, if it is practicable. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

Use of Minor's Information.

We do not knowingly collect any personal information from children under the age of 18. By using the Site you represent that you are at least 18 years old. If you are aware of any data that may be collected from children, please contact us via email: We will do our best efforts to promptly remove such information from our records.