Privacy Notice of

Last updated April 24, 2024

This Privacy Notice (the “Notice,” “Privacy Notice”) explains how we, smrtStudio Global, Inc. (operating under the brand name “smrtPhone”) (“we,” “smrtStudio”) process personal information when you visit our and websites, mobile applications, (collectively, the “Sites”) and/or use the services, features, or content we offer (“Services”), how we maintain, use, and share that information; and how you can manage the way information about you is handled.

This Notice supplements our Terms and Conditions. Please read this Notice and the Terms and Conditions before you use the Sites. If you do not understand and agree with this Privacy Notice, please do not use the Services.

Note that this Privacy Notice does not apply to any other data, such as personal data that may be included in the files, documents, recordings, transcripts, and similar information that we maintain on our customers’ behalf, nor does it apply to information our customers might upload to their smrtPhone account(s) in connection with their use of our Services, or information gathered from other channels, such as publicly available sources.  We process such customer content, including personal data that might be included therein, solely for the purpose of providing and operating our Services to our customers and only in accordance with their written instructions, which take the form of our Terms and Conditions or similar written agreements between smrtStudio and our customer.

I. Summary

This summary of our Privacy Notice serves to help you quickly learn who smrtStudio is, how you can opt-out of our database, and what remaining in it may potentially entail. 

smrtStudio collects personal data from its users and the personal data its users share with it and authorize it to collect by connecting their customer relationship management (“CRM”) systems to the Sites, importing the data to the Sites through third-party systems, and uploading documents to our Sites.

Under the law of some jurisdictions, you may have certain rights with respect to your personally identifiable information. In that case, request a copy of your profile and amend your profile information or have it deleted by contacting us at [email protected]. You can opt out of our database by contacting us at [email protected]. Alternatively, you can mail us at 651 N. Broad Street, Suite 206, Middletown DE 19709.

II. How We Collect Information


Type of Information Collected

We may collect three general types of information when you use the Sites (collectively, “User Information”):

    1. Personally Identifiable Information (“PII”), which includes your first and last name, email address, IP address and other identifiers that permit online contact with you. You also may engage with our Sites and Services through third-party CRM Sites, plug-ins, or applications. When you engage with the Sites and its content through such third-party Sites, plug-ins or applications, we may have access to certain information, such as your profile photo, username/customer number, and API key, etc.
    2. Non-personally identifiable information (“non-PII”) such as Usage Data (the IP addresses or domain names of the computers utilized by the Users who use the Sites, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Sites) and the details about the path followed within the Sites with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment), the web pages you have visited before and after you visit the Sites, and the type of device used to access the Sites or other device-specific information.
    3. Sensitive Personal Data, which includes financial Information (such as bank, debit, credit or mutual fund account number); account log in data; and contents of mail, email, instant or text messages.

How Information is Collected

We collect information both actively and via automated means. We will collect information about you that you voluntarily provide while on the Sites, including when integrating the Services with your CRM service. In addition to information provided directly by you, we may collect non-PII using “cookies,” “web beacons,” “flash cookies” or by other electronic means. We may obtain personal data from public records and third parties with whom we do not have business relationships.

Active Information Collection

Information submitted through our Sites. Visitors to our Sites may choose to submit their name, email address, and/or other information so that they can learn more about our Services, register to take part in a smrtStudio-sponsored event, participate in a survey, contest, or sweepstakes, or apply to smrtStudio’s open job positions, among other things. By accessing, using, and/or submitting information through the Sites, including by filling out forms, regardless of whether the form is ultimately submitted, a user of the Sites consents to the practices described in this Notice with regard to the information collected about them. If you do not agree with this Notice, you should not submit any information through our Sites and you must delete all cookies from your browser cache after visiting the Sites and refrain from visiting or using the Sites.

Use of our Services. In order to use certain Services, users may be required to create an account. From time to time, we may use a user’s email address to send information about our products and services. Users are provided with an opportunity to opt out of receiving such emails. We may also communicate with users regarding their use of our Services or Sites, including changes to this Notice.

Purchasing our products and Services. Purchasers of our online subscription-based Services may need to provide credit card or other payment information. We will use that information solely for the purpose of fulfilling the purchase request. We will store credit card or other payment information in an encrypted form and will not sell, share, or use it again without prior consent. (The only exceptions are described in the sections below on “Disclosures to Service Providers,” “Disclosures for Legal Reasons,” and “Disclosures to a Buyer of the Company”).

Using our mobile applications. We collect certain information including your device type, operating system, location, platform used, device ID, and the date of last use, among other non-PII, through the downloading and use of our mobile applications. We may also collect other information such as the user’s name, email, company name, and information about the user’s account with us.

Connecting the Services to the User’s CRM service. In order to provide certain Services, smrtStudio may require access to the User’s CRM service account. Depending on the specific Services being used, we may collect API keys, User’s customers’ data, records of text messages, voicemails, call transcripts, and other call data.

From our affiliates. smrtStudio may obtain personal information from our affiliates, such as our subsidiaries or other companies under common control and ownership with smrtStudio. We may use this information to enhance the information that we already maintain and to improve the accuracy of our records, in addition to other purposes described in this Notice.

From third parties. smrtStudio may obtain personal information from third-party sources such as our service providers and strategic partners. We may use this information to enhance the information that we already maintain and to improve the accuracy of our records, in addition to other purposes described in this Notice. 

Creation of aggregated information. smrtStudio may aggregate collected information about our users in a form that does not allow users to be personally identified for the purpose of understanding our customer base and enhancing the Sites and the Services that we and our strategic partners and customers can provide you. 

Creation of information from inferences. We may use personal information we already have in order to draw inferences or to produce scores or ratings. We may use scoring models and algorithms that evaluate selected data points to produce a score predicting the likeliness of a User’s customer to respond to certain outreach efforts. We do not use such models and algorithms to make any decisions about individuals. 

Automated Information Collection

We also collect information using cookies and similar automated technologies, as described below.

Cookies. In general, a cookie is a small amount of data sent to your browser from a web server and stored on your computer’s hard drive, where it can be used to identify your computer. Cookies can be used to measure web Sites usage, improve navigation around web Sites, and personalize a returning visitor’s experience on the web Sites. In most cases, you can set your browser to turn off cookies or to notify you before you receive one so that you can decide whether to accept it or not. Because cookies allow you to take advantage of some of the features on the Sites, we recommend that you leave them turned on. If you block or reject our cookies, some of the features on the Sites may not work for you. You can refer to the instructions for your browser to learn more about these functions.

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Third-Party Cookies. The use of cookies and similar technologies by our partners, affiliates, and service providers is not covered by this Notice. We do not have access to or control over these cookies. Our partners, affiliates, tracking utility company, and service providers may use session ID cookies in order to:

  • track which areas of our Sites individuals visit in order to remarket to them 
  • personalize visitors’ experience
  • provide website features such as social sharing widgets
  • analyze which pages our visitors visit
  • measure advertising effectiveness

To disable or reject third-party cookies generally, please refer to the third-party’s relevant website or configure your browser settings appropriately. Individuals can also reject third-party analytics cookies by clicking the “Close” button on the cookie banner when visiting our Sites. 

Analytics. We use Meta Pixel for conversion tracking, Google Analytics, and Google Ads conversion tracking (“Analytics Tools”) on our Site. Analytics Tools use cookies or other tracking technologies to help us analyze how users interact with and use the Sites, compile reports on the Sites’ activity, and provide other services related to Sites activity and usage. The technologies used by Analytics Tools’ providers may collect information such as IP address, time of visit, whether a visitor is a return visitor, and any referring website. The information generated by Analytics Tools will be transmitted to and stored by Analytics Tools’ providers and will be subject to their privacy policies. Please see below in more detail:

Meta pixel (Meta Platforms, Inc.)

Meta Pixel is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta advertising network with actions performed on the Sites. Meta Pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and Audience Network.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of the Sites, to prepare reports on its activities and share them with other Google services.
Google may use the User Information collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Google Ads conversion tracking (Google Inc.)

Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how smrtStudio manages the ser Information processing, that connects data from the Google Ads advertising network with actions performed on the Sites.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Web Beacons. We, our third-party service providers, advertisers, and partners also may use “web beacons” or similar technologies. Web beacons are small strings of code placed on a web page to collect data about how visitors use the Sites. For example, web beacons may be used to count the number of users who visit the Sites or to deliver a cookie to the browser of a visitor to the Sites. If you set your browser to turn off cookies, web beacons and similar technologies will detect your visits to the Sites, but they will not associate your activity on the Sites with information that otherwise would be stored in cookies. We do not control tracking technologies used by third parties on the Sites.

Third Party Links. Please note that this Sites may contain links to other web Sites that do not follow this Notice. For instance, clicking on an advertisement, links or other elements on the Sites may take you to an entirely different site. Links to other sites may use our Sites logo or style as a result of a co-branding agreement. These sites may send their own cookies to you and may collect data and make use of that data in ways that this Sites would not. After you leave our Sites, this Notice will no longer apply to PII or any other data collected from or provided by you. You should check the other web sites’ applicable privacy notices to determine how they will handle such data.

Certain features available within the Sites will require you to submit PII about yourself as a condition of participation. Some of the features may be offered by us, while others may be offered by third parties. (For example, you may be required to submit PII in order to request information and offers from us and our partners.) When you choose to submit PII to a third party in connection with your use of the Sites, the third party’s privacy notice, rather than this Notice, will control the use of your PII. YOU CAN ALWAYS REFUSE TO PROVIDE PII TO US, BUT THIS MAY RESULT IN DECREASED FUNCTIONALITY OF THE SERVICES FOR YOU, LIMIT YOUR ABILITY TO RECEIVE INFORMATION ABOUT SERVICES THAT MAY BE OF PARTICULAR INTEREST TO YOU, AND FAIL TO RECEIVE LEADS OR OFFERS YOU COULD OTHERWISE RECEIVE THANKS TO OUR SERVICES.

III. How We Use Your Data

We may use User Information for smrtStudio’s legitimate business interests in connection with a User’s use of the Sites, including to respond to inquiries and fulfill requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Sites. We may process User Information to better understand our users in general and to test, develop, improve, and enhance our Services and Sites. We may process Use Information to contact customers in the future about services, promotions, opportunities, and other general information about smrtStudio. We may use User Information to investigate and prosecute potential breaches of smrtStudio’s security or license agreements.

For example, we may use PII for one or more of the following purposes:

  • Create user account(s) and identify users signing in to their account
  • Provide the products and Services
  • Analyze the use of our Sites
  • Maintain and improve the Sites
  • Manage the Sites and Services
  • Verify your identity
  • Tell Users about other products and services that may be of interest to them (Users can opt out of receiving such communications by following the instructions provided in the communication)
  • Process payment for purchases
  • Develop new products and services
  • Understand how users arrived at the Sites
  • Send technical notices, updates, security alerts, and support and administrative messages
  • Respond to comments, questions, and requests, and provide customer support
  • Monitor and analyze trends, usage, and activities in connection with the Sites
  • Detect, investigate, and prevent fraud and other illegal activities
  • Protect the rights and property of smrtStudio, our Users, and others
  • Personalize and improve the Sites
  • Provide notice of important changes to the Sites, including changes or updates to this Privacy Notice
  • Facilitate contests, sweepstakes, and promotions, process entries, and deliver rewards
  • Consider persons for possible employment with smrtStudio, and communicate about employment opportunities or submitted employment applications
  • Respond to requests from individuals to access, correct, or delete their information, or requests to exercise other rights related to their information under applicable law
  • Create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or Users may use to provide and improve our respective services
  • Interact with external social networks and platforms
  • Comply with our contractual and legal obligations, resolve disputes with users, and enforce our agreements
  • Carry out any other purpose described at the time the information was collected

Remarketing and behavioral targeting

This type of service allows smrtStudio and its partners to inform, optimize and serve advertising based on past use of the Sites by the User. This activity is facilitated by tracking usage data and by using trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Meta Custom Audience (Meta Platforms, Inc.)

Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Application with the Meta advertising network.

Personal Data processed: Cookies; email address.

Place of processing: US – Privacy Policy – Opt Out.

Meta Retargeting (Meta Platforms, Inc.)

Meta Retargeting is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of this Application with the Meta advertising network.

Personal Data processed: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Google Ads/Remarketing

Google Ads/Remarketing is a marketing and behavioral targeting service provided by Google LLC. that connects the activity of this Application with the Google advertising network.

Personal Data processed: Usage Data

Place of processing: US – Privacy Policy.

LinkedIn Ads

Google Ads/Remarketing is a marketing and behavioral targeting service provided by LinkedIn Corporation. that connects the activity of this Application with the Google advertising network.

Personal Data processed: Usage Data

Place of processing: US – Privacy Policy.

Tag Management

This type of service helps smrtStudio to manage the tags or scripts needed on the Sites in a centralized fashion. This results in the User Information flowing through these services, potentially resulting in its retention.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Usage Data.

Place of processing: US – Privacy Policy.

Hotjar (Hotjar Ltd.)

Hotjar is a company headquartered in the European Union that provides qualitative analytics.

Personal Data processed:  Usage Data.

Place of Processing: EU – Privacy Policy

Event Tracking

This type of service helps smrtStudio to track customers’ actions on the Sites in a centralized fashion to facilitate custom pop-up messages and product tours and to ultimately improve the customer experience. This results in the User Information flowing through these services, potentially resulting in its retention.

            Intercom (Intercom, Inc.)

            Intercom is a Delaware corporation that provides customer analytics tools.

Personal Data processed:  Usage Data, Subscription Level

Privacy Policy.

IV. How We Share the Data

smrtStudio does not sell personal data and will not disclose User Information to any third party except in connection with a legitimate use as set forth in this Notice, in connection with a bona fide legal dispute to which such information is relevant, in response to valid, compulsory legal process, in response to a valid data subject request where required by applicable law, or as otherwise required by law.

Disclosures to Affiliates. We may share the data we collect with our affiliates who may act for us for any of the purposes set out in this Privacy Notice, including our current and future parents, subsidiaries, and other companies under common control and ownership with smrtStudio. 

Disclosures to Service Providers. smrtStudio may from time to time disclose PII and Non-PII or other collected information to service providers, solely for providing functions related to our operation of the Sites and provision of the Services and for no other purpose. For example:

  • smrtStudio uses service providers to process credit card payments on our Sites. Information such as name, billing address, phone number, email address, and credit card information will be submitted to service providers for verification and to manage any recurring payments. We do not store this information.
  • smrtStudio uses a service provider to identify user identities and shares personally identifiable information such as first and last names with the service provider. smrtStudio does not collect or store photos of government-issued IDs or face scans.
  • smrtStudio uses software hosted by a service provider to provide us with advertising services. We may share information such as name and email address to request that a particular User be removed from our remarketing targeting. smrtStudio does not authorize any other use of this information by the service provider.

In addition, we may share your information as described below:       

Disclosures for Legal Reasons. We may disclose collected information to a third party if we believe in good faith that such disclosure is necessary or desirable:

  • to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements;
  • to address a violation of the law;
  • when we believe it is necessary to prevent, investigate, or address (a) possible illegal activities, including fraud, (b) violation of our Terms and Conditions, (c) threats to the physical safety of any person;
  • to protect the rights, property, or safety of smrtStudio, its users, or the public;
  • to allow smrtStudio to exercise its legal rights or respond to a legal claim; or (v) to respond to data subject requests for access to data to the extent necessary to comply with applicable laws.

Information You Elect to Share: You may choose to share information with Third Parties by clicking on links to those Third Parties from within the Sites. In addition, you may elect to share information, including PII, through the Services offered on the Sites by, for instance, posting comments on comment boards. Some of your activity on the Sites, including content you have posted, is public by default. Some of this content may include PII.

Disclosures to a Buyer of the Company. In the event that Company is considering a sale of its business, in its entirety or a component thereof, or substantially all of its assets are acquired, or a portion thereof, PII and non-PII, may be one of the transferred assets, and may therefore be used by a third-party acquirer in accordance with this Notice. Such use by a third party may include review of PII, using such PII to contact you either before or after such a transfer or sale, use or transfer of non-PII before or after such a transfer or sale, or for other purposes.

Testimonials. We post User testimonials on our Sites which may contain the User’s first names and cities of residence. We obtain consent from the Users prior to posting any testimonial. If a User wishes to update or delete their testimonial, they can contact us at [email protected].

V. Your Rights

Under the law of some jurisdictions, you may have certain rights with respect to your PII. These rights include the right to: (i) request access to and rectification or erasure of your PII; (ii) obtain restriction of processing or object to processing of your PII; and (iii) ask for a copy of your PII to be provided to you or a third party in a machine-readable format. If you wish to exercise one of the above-mentioned rights, please send us your request to the contact details set out below.

VI. The Choices You Make

Update Profile. Individuals or authorized corporate representatives can keep their smrtStudio profile up to date by verifying it and updating information such as email address, phone number, or billing address. To view, verify, and update your profile, please contact us at [email protected].

Request Access to Information smrtStudio has Collected. Individuals who want to access the information that smrtStudio has collected about them can contact us at [email protected] to submit an access request. Once we have verified an individual’s identity, we will send a report with the information we have collected about the individual. 

Remove smrtStudio Profile Completely. If you wish to completely remove your existing profile from the database, please contact us at [email protected]. If you make this choice, your profile and the information within it will be removed from our database as soon as possible.

VII. How Do We Keep Information Secure?

Information security is important to us. We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the User Information.

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We employ reasonable administrative, technical, and physical safeguards to protect the PII we collect from unauthorized access, use or disclosure. However, no method of Internet transmission or electronic storage is 100% secure, nor can we have control over the security of other websites on the Internet that you might visit. Therefore, while we strive to use commercially acceptable means to protect information, we cannot guarantee its absolute security. If you share your computer or use a computer that is accessed by the public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.

Additionally, and as you are likely aware, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your information, we do not promise, and you should not expect, that your PII, searches or other communications always will remain secure.

smrtStudio employs reasonable security and back-up procedures to protect User Information. However, in the unlikely event there is a loss or corruption of User Information, smrtStudio is not responsible or liable for such loss or corruption.

In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. You should also take care with how you handle and disclose your PII. Please refer to the Federal Trade Commission’s Web Sites at for information about how to protect against identity theft.

VIII. Data Retention

We will retain personal information for a period of time consistent with the original purpose(s) for which we collected it, as described in this Privacy Notice, including, as applicable,

  • for as long as we have an ongoing relationship with the individual to whom the information pertains;
  • as long as needed to provide the Services;
  • as necessary to comply with our legal obligation(s);
  • as necessary to resolve disputes or to protect ourselves from potential future disputes; or
  • as necessary to enforce our agreements. Retention periods will be determined considering the amount, nature, and sensitivity of the personal information and the purpose(s) for which it was collected. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.

IX. Social Media Interactions and Widgets

Our Sites include social media features, such as “Widgets,” a “Share” button or interactive mini programs that run on our Sites. These features may collect IP address and which page was visited on our Sites and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Interactions with these features are governed by the privacy policy of the company providing it.

Our Service allows interaction with social networks or other external platforms directly from the Sites. The interaction and information obtained through the Sites are always subject to the User’s privacy settings for each social network. Third-party social media applications might still collect traffic data for the pages from where the Service is accessed, even when Users do not use them. It is recommended to log out from the respective social media applications in order to make sure that the processed data on the Sites is not being connected back to the User’s profile.

X. Users Outside of the U.S.

Individuals who use our Sites outside of the United States should understand that we collect, process, and store their personal information in the United States. The laws in the U.S. regarding personal information may be different from the laws of such individuals’ state or country. If you are using the Sites from outside the United States, please be aware that smrtStudio is located in the United States and your PII will be stored and processed in the United States where we locate and operate the servers and databases we use. The data protection laws in the United States may not be as strict or comprehensive as those in your country. However, we value your privacy and always strive to treat it in accordance with applicable law. By voluntarily sharing your PII with us, you understand that your PII will be stored and processed in the United States.

XI. Children’s Privacy

Our Sites are not directed to or intended for individuals under the age of 18. We do not knowingly collect or use any personal information from users of our Sites who are under the age of 18. No personal information should be submitted to our Sites by individuals who are under 18 years of age. If we learn that we have collected information from someone who is under 18, we will take steps to delete the personal information as soon as possible. Individuals who believe we may have collected personal information from someone under 18 should contact us at [email protected]

XII.  Changes to this Notice

smrtStudio reserves the right to modify this Notice from time to time, so please review it regularly. If we make material changes to this Notice, we will notify individuals here, by email, and/or by means of a notice on our homepage prior to the changes becoming effective. Continued use of the Sites after any updates to this Privacy Notice constitutes acceptance of the updated Privacy Notice. 

XIII. Contact Information      

Questions concerning this Notice or the Sites or Services, including any request to review or change your PII, should be directed to [email protected].

Our address for inquiries is:

651 N. Broad Street, Suite 201, Middletown DE 19709