Smart Solutions

Last updated: May 2022


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”).

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 subjectDescription
VisitorUser, who researches the website
StaffUser, who clicked “Go to staff tool”
ClientUsers, who fill out our forms


Who we are

Data controllerINNOVATIVE ACCOUNTING SYSTEM LLC, registration code: 39770806
Address49000, Ukraine, Dnipro,Viacheslava Lypynskoho Str., building 18, office 302 — for privacy questions — for 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.

technical data
data provided by users
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:

Technical data

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

Data we collectReason for data collection
IP address, UTM parameters, geolocation, device type, browser type, cookies, User-agent, User ID and data about your interaction with the website – session ID.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 whenPersonal dataLegal basisReasons for processing
You use our website
  • Technical data;
  • Necessary cookies.
Legitimate interest Website operation
You use our website
  • Marketing cookies;
  • Statistics cookies;
  • Preference cookies.

Website operation;



Period of storage
Data processed on the basis of a legitimate interestStored for up to 2 years after the last use of the website
Data processed on the basis of consentStored for up to 2 years from the last time you used the website or until you withdraw your consent
You moved to the subdomain
  • Login;
  • password;
  • name;
  • surname;
  • date of birth;
  • sex;
  • telephone number;
  • email;
  • position at work.
Performance of the contractGrant access to staff tool
Period of storage
Data processed on the basis of performance of the contractStored for the duration of use of our service + 3 years
You click “Order service”, “Request consultation”, “Call back”
  • Name;
  • position at work;
  • company name;
  • telephone number;
  • email.
Performance of the contractProvide a service
You fill in “Feedback form”
  • Your message;
  • company;
  • name, position;
  • telephone number;
  • email.
Legitimate interestDevelopment of services and advertising
You fill in “Recruitment Request Form”
  • Wishes for the candidate;
  • company;
  • name, position;
  • telephone number;
  • email.
Performance of the contractProvide a service
You fill in “Order a free Staff Tool presentation”, “How can we contact you?” forms
  • Name;
  • telephone number.
Performance of the contractProvide a service
You fill in “Request for outstaffing”, “Request for HR record-keeping outsourcing services”, “Request for the payroll outsourcing service”, “Request for outsourcing a representative office”, “Application for registration of foreigners”, “Application request for labor protection and fire safety”, forms
  • Company;
  • name, position;
  • telephone number;
  • email.
Performance of the contractProvide a service
Period of storage
Data processed on the basis of performance of the contractStored for the duration of use of our service + 3 years
Data processed on the basis of a legitimate interestStored 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 partiesDescriptionLink to privacy documents
FacebookWe use Facebook for marketingPrivacy Policy
Google AnalyticsWe use Google Analytics for statistics and analyticsSafeguarding your data
TwitterWe use LinkedIn for communication and supportPrivacy Policy
FacebookWe use Facebook for communication and supportPrivacy
LinkedInWe use LinkedIn for communication and supportPrivacy Policy
TelegramFor communication and supportPrivacy Policy
YouTubeWe use Youtube for publishing video about usYouTube 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 We guarantee that we take all necessary measures to protect your data.

Data transfer


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:

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 surveillanceLimited access to premises
Signaling24/7 security
24/7 system administrators dutyFire extinguishing system
Technical protection measures
Two-Level AuthenticationBackup
FirewallsEncryption technologies
Organizational protection measures
Staff trainingNon-disclosure agreements
Internal policies and instructionsTransmission 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:

The right to accessYou can request an explanation of the processing of your personal data
The right to portabilityYou can request all the data that you provided to us, as well as request to transfer data to another controller
The right to restrict processingYou may partially or completely prohibit us from processing your personal data
The right to file complaintsYou can file a complaint to the regulatory body
The right to be forgottenYou 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 consentFor 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 We will answer you as soon as possible.

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

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:


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.


Компания Smart Solutions имеет 13-летнюю экспертизу в сфере предоставления HR-услуг по рекрутменту, расширению IT-штата и BPO, аутсорсингу и аутстаффингу персонала. Мы помогаем бизнесу с поиском разработчиков, открытием Back Office и сопровождением IT компаний со всего мира в Восточной Европе и Центральной Азии. В развитии и совершенствовании Smart Solutions мы всегда руководствуемся ключевой идеей: “Изменять жизнь […]