Smart Solutions

Last updated: May 2022

Intro

We in Smart Solutions 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”).

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:

Who we are

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.

Technical data

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

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

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:

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.

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:

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:

To exercise your rights, write us an email at privacy@smart-hr.com.ua. We will answer you as soon as possible.

If we do not satisfy your request, you can file a complaint to the regulatory body:

• Ukrainian Parliament Commissioner for Human Rights by email hotline@ombudsman.gov.ua or write a letter: 21/8, Instytutska Str., Kyiv-08, 01008.

The use of cookies

We process technical data and use cookies. You may find our Cookies Policy here.

If you want to disable cookies, you can find instructions for managing your browser settings at these links:

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.