This Regulation is drafted in accordance with the requirements of the GDPR and falls within the scope of responsibility of the Service, whose duty is to ensure its compliance with the law. The service is responsible for data management, as well as defines the purposes and methods of personal data processing.
1. This Privacy Policy contains an agreement between you and Us regarding the processing and protection of your personal data and is an integral part of the Public Offer – Agreement with Users Public Offer – Agreement with Users.
The privacy policy is always available at the following addresses:
https://cabinet.smartway.global/policy
https://smartway.global/privacy_policy/
Volume, categories and data sources
2. The main purpose of this SMART WAY GLOBAL LOGISTICS Mobile Application (Application / Site and Services) is to provide you with the opportunity to order services online, without being physically present at the offices of our company. After all, we want you to receive safe, properly high-quality services, in compliance with the delivery time of goods (orders) both to the end consumer and to state regulatory authorities.
For this, the following data about you may be provided at our disposal:
1) Information that you provide when registering and / or editing an account:
• Phone numbers
• Name, patronymic, surname
• Individual tax number (personal code)
• Photos
• Email addresses
• Identifiers in various message systems
• Driver’s license data
• Photos of the driver’s license
• Vehicle documents (technical passport)
• Photos of vehicles
• Other data related to your activity that allows you to be identified as an individual (for example, license numbers)
2) Information that you provide during your use of the application and / or services, incl. by placing your applications for registration and receipt of services:
• Documents and data required for ordering services
• Downloaded files required to order services
• Documents and data received as a result of the performance of services by Us
• Feedback forms
• Posting reviews
• Comments and correspondence
• Uploaded files
• Contacting support services, GPS coordinates, etc.
3) The mobile application collects and stores information about your locations (GPS coordinates) in order to enable you to order services online, and in order to obtain high-quality, safe and appropriate services that we provide you:
• Data arising from (automatically generated as a result) of your use of the Mobile Application (date and time of registration of the account date and time of visits to the Site
• Data on the use of the Mobile application: in the browser, clicks on links, search queries, etc.;
• Data about the technologies you use to access the Mobile Application: about your Internet provider, IP address, characteristics and settings used to access electronic devices and software)
• Data of communication with the technical support service, which are used to consider and resolve your complaints about the Service and correct errors in operation.
Cookies and similar technologies
Cookies are small text files located on the device for data storage, read by the web server in the domain in which they were created. This data often consists of alphanumeric strings that provide unique identification of your computer, but may contain other information. We use cookies and similar technologies to store and maintain your preferences and parameters for logging in, fighting fraud, analyzing the performance of our products, and performing other legitimate tasks.
Processing Targets Order of Use of Your Personal Data
3. We may use your data for the following purposes:
• Ensuring the provision of services online (without physical presence in our offices)
• Providing us with the opportunity to provide high-quality, safe services in order to comply with the terms of delivery of goods (orders) both to the end consumer and to state regulatory authorities.
• To evaluate the members interest in our Services and to inform about new Services and updates to the Website and Application;
• To resolve disputes and difficult situations;
• To create an information infrastructure to ensure the safety of your activities;
• For other purposes, about which we will inform you further, requesting specific information for your consent.
4. During the entire period of activity of your account, We can use your contact information to send messages of a technical, informational and administrative nature, news. You agree that you will not be able to opt out of receiving notifications.
You can refuse to receive messages only if it is provided by the functionality of the mobile application
Security
5. We take technical and organizational measures to protect your confidential information from unauthorized actions of third parties. The mobile application uses all the necessary technologies and protocols for encryption and protection of consumer personal data (HTTPS, OWASP and others). On our part, a limited number of employees and proxies have access to your personal data, who need this information to process data on Our behalf and for the purposes expressly provided for in this Privacy Policy. We undertake all obligations to maintain confidentiality and in case of violation of these obligations, we are ready to bear the appropriate measure of responsibility.
6. Access to your confidential information can also be carried out through the usual authorization system using your username and password. In case of your neglect of self-maintenance of the security of your account, third parties may gain unauthorized access to your information, for which We are in no way responsible.
Access, modify or delete personal data
Users of the Mobile Application at any time have the right to request access to information, as well as change or delete any data we process.
Distribution of Information by You
7. You understand and agree that when you provide information when registering an account in the Mobile Application and within the services (in particular, but not exclusively, when placing requests for services in the Application of some personal data (including, but not exclusively, names, addresses, phone numbers, identifiers in message systems, etc.) are thus legitimately distributed (transmitted) to an unlimited circle of persons.
8. You acknowledge the understanding that the very essence of Our Mobile application and services provides for the main purpose of the provision of services by Us online, for which the distribution and exchange of business information, part of which falls under the definition of personal data, is carried out; and, accordingly, your registration of an account in the Mobile Application and your use of the services implies the dissemination of information primarily by you and in your interests, for which we provide a technical platform
9. Taking into account the foregoing, you hereby confirm and guarantee your full consent – and, where appropriate, the duly informed consent of the respective subjects of personal data – with the public dissemination of data described above, and in addition, taking into account the very essence of the services and the public nature of the dissemination data, confirm your understanding of the objective absence of the need, as well as the practical impossibility, of additional special messages from Us about the transfer of personal data to third parties described above .
Distribution of Information by Us
10. We may provide third parties with access to your personal data only in the following cases:
• By your special consent. For all cases not expressly provided for in the Agreement, we will separately ask for your consent;
• As part of activities related to all users of the Mobile Application to ensure the safety of all users, including you;
• For outdoor decoration under our control. In order to be able to provide you with services online, We can provide access to our contractors, trusted persons for data processing solely for the purposes specified in this Privacy Policy, subject to such persons’ compliance with confidentiality obligations and all necessary security requirements, under Our responsibility;
• To maintain the rule of law and public order. We can provide access to information about you if We have reasonable grounds to believe in good faith that such use of information is reasonable for:
(1) compliance with the requirements of the legislation (including departmental instructions having supreme legal force, in the relevant territories), orders of judicial or other state bodies, which can be enforced; and / or
(2) detecting, preventing and / or taking other measures against fraud, other illegal and / or fraudulent actions that pose a threat to the interests of Users, SMART WAY GLOBAL LOGISTICS and / or public order.
Transfer of information
11. We share the information you provide as follows:
• To be able to provide you with services online, We may use the services of third parties, and such third parties may access the information you provide, in part or in full, depending on the needs. ISPs are required to protect such information and should not use it for any purpose other than performing / providing the services they perform for us in the manner described in their privacy policy.
• At the moment, the list of third parties with whom we may share your data consists of: TurboSMS, GMail, Portmone, Wayforpay, Concord. The list can be changed at any time, which will be stated here in the privacy policy.
• Also, other registered users of SMART WAY GLOBAL LOGISTICS who need it to carry out activities on our platform may have access to the information provided by you, in part or in full, if you have given your express consent to this.
Changes to the Privacy Policy
12. This Privacy Policy may be revised and updated. As a matter of principle, we do not aim to limit your rights without your express consent. Any changes to this privacy policy will be published on this page, and the User undertakes and has every opportunity to independently follow the updates
Legal Basis for Processing
13. We process your personal data based on the following legal grounds:
(a) Contractual necessity – to provide you with our services;
(b) Legal obligation – to comply with regulatory requirements;
(c) Legitimate interest – to improve our services;
(d) Your consent – for optional data processing, such as marketing.
As a data subject under the GDPR, you have the right to access, rectify, delete, restrict processing, object to processing, and request data portability. To exercise your rights, please contact us at [support@smartway.global].
We may share your data with third-party service providers for payment processing (Wayforpay, Portmone), email notifications (GMail), and SMS verification (TurboSMS). All third parties comply with GDPR requirements and ensure data protection.
If your data is transferred outside the EEA, we ensure adequate protection through Standard Contractual Clauses (SCCs) or other mechanisms approved by the European Commission.
For any privacy-related inquiries, you may contact our Data Protection Officer at: info@smartway.global
