In conjunction with your business collaboration with SMART TECN (for the purposes of this privacy notice, “SMART TECN”), we process information about you, as an external expert or customer (“personal data”), depending on the essence of our business relationship.

The term  “customer”  includes customers, represented by an individual (individual entrepreneurs) and employees and representatives of legal entities with whom we establish business relationships. The processing of personal data takes place to establish and manage operations and obligations to you as a business management consultancy.

The term  “external expert”  includes individuals who collaborate directly with us for the purpose of business development or project delivery, or employees and representatives of legal entities with which we establish this type of business relationship.

We protect your personal data and privacy by taking all relevant measures in accordance with applicable law, including EU Regulation 2016/679 – known as the General Data Protection Regulation (GDPR).

This privacy notice describes how SMART TECN uses your personal data, how we guarantee its protection and what privacy rights are granted to you by law.

For purposes of this notice, “we” and “our” will refer to SMART TECN and “you” and “your” will refer to customers and external partners/experts.

Data provided by customers or specialists for project delivery

In certain situations, you may provide us with personal data (eg in the form of databases) in order to provide you with a service. The categories and purposes of data may vary according to the information contained in these databases. Therefore, in these situations, SMART TECN will become a processor and will need specific instructions from you to process this personal data (eg in the form of a data processing agreement).

1. Why do we process your personal data?

SMART TECN generally processes your personal data to ensure our daily business activity. This data is primarily provided by you when establishing a business relationship with us. Personal data will be generated and requested in the course of our contractual or informal cooperation, always in relation to a specific and well-defined purpose. See below the main purposes for which we will treat your personal data:

If we collaborate with you as a customer, we process your data to:

• formalize our relationship in agreements;
• understand and document your needs and requests;
• manage the service you have requested from us, including contacting you;
• receive payments for services provided;
• create statistics related to the use of our services;
• contact you for direct marketing purposes and propose cooperation opportunities;
• ensure the safety of our work facilities;
• respond to possible project-related requests after the end of our contractual relationship;

If we collaborate with you as an external expert or consortium representative, we process your data to:

• maintain a database of experts;
• apply for tenders or projects where your experience is relevant and execute the project;
• communicate with you about collaboration opportunities;
• answer contractors’ questions about their experience;
• keep in touch to ensure the continuity of our common projects;
• ensure the safety of our work facilities.

2. On what legal basis do we process your data?

When one of the aforementioned purposes is pursued, we have a clearly defined legal basis for processing your data. Thus, SMART TECN guarantees that we collect and use your personal data only if:

• we needed it to fulfill an agreement between you and SMART TECN;
• this data is necessary to comply with a legal obligation under applicable laws in our jurisdictions;
• you have given us your consent to use your personal data for a specific purpose;
• we have a legitimate interest in using your data for the stated purpose and this interest does not override yours;

In addition, we will also have a valid legal basis when:

• require the processing of your data to protect your vital interests or those of another person;
• need to carry out a task in the public interest or in the exercise of official authority vested in us.

We will only use your data for the interests listed above, as long as they are not overridden by your interests and fundamental rights. In this sense, each time this legal basis is used, we will make a balance test between this interest and your rights and freedoms, in order not to disproportionately limit the latter.

3. What categories of your personal data do we use?

As mentioned above, in fulfilling our purposes we process different categories of personal data. The amount of data will vary depending on the purpose of our cooperation with you, but in most cases it will include the following categories:

• General information: name, surname, position, telephone, e-mail, signature, corporate name and company data (that you represent); bank account number;
• Historical data of our cooperation: history of requests, projects carried out together and feedback; results of our cooperation (project documentation, proposals, etc.);
• Social aspects and publications: publication of photos and contact information on our official website and social networks;
• Data for tender applications (exclusively for external experts): professional experience, company name, project experience, training, languages;

4. Storage, retention and disposal of personal data

SMART TECN ensures that your data is stored in a centralized and organized manner, namely in the administrative account of our cloud accounting systems and in our internal management system. Your information may also be stored in secure corporate email accounts as a result of intra-group data transfers. In addition, we also store relevant documents (eg contracts, invoices) in paper format in suitable physical storage spaces.

We keep your personal information only as long as we need it for the purposes described in this Privacy Notice. Our retention periods are based on criteria including legally mandated retention periods, our intellectual property or proprietary rights, contractual requirements, directives or operational needs, and for potential and pending litigation.

5. Security of your personal data

To guarantee the security of the data provided by you within the scope of our services, we implement the necessary technical, legal and organizational means to guarantee a high level of protection of your personal data. We implement and monitor constantly complete access rights system, which ensures that only authorized and relevant personnel can access it exclusively for legal and clearly defined purposes.

In addition, secrecy agreements are signed with all those involved in order to maintain the confidentiality of the documents and information provided by you.

6. Personal data transfers

In the course of our activities, your personal data may be transferred within our group of companies (intra-group transfers).

6.1. Intragroup transfers of personal data

SMART TECN is made up of several legal entities, forming what is called a group of enterprises. For the exercise of our activity, personal data may be exchanged with the aim of:

• respond to requests and needs of your client or specialist;
• apply for tenders in which other offices and branches of SMART TECN are involved ; It is
• share experiences and statistical information with other branches;

SMART TECN develops a holistic approach to the protection of its customers’ personal data, thus ensuring that you will benefit from the same guarantees and rights for the entire group.

6.2. Extragroup transfers of personal data

Within the scope of its operations, SMART TECN may share your personal data with external entities of companies. This mostly happens with:

• (private companies or public authorities) on the basis of your explicit consent or fulfillment of contractual obligations (e.g. to apply for a tender);
• public authorities or law enforcement agencies, upon request and to comply with a legal requirement;
• third parties, to provide specific services (eg accounting services);

7. Your rights

7.1. Right of access to your personal data

You can request and have the right to obtain information from us about the personal data we process, where it comes from and what we use it for. You can obtain information about how long we store your data and who receives data about you. Your right to access may, however, be restricted by law, protection of the privacy of others and considerations relating to our business and practices. Our know-how, confidential business data, as well as internal reviews and materials may also be exempt from the right to know.

7.2. Right to rectification and erasure of data

If you discover that the personal information we hold about you is incorrect, incomplete or irrelevant, you have the right to have the data corrected or deleted with the restrictions arising from existing legislation and data processing rights.

7.3. Right to restriction of use

If you believe that the data we process about you is incorrect or incomplete, or if you object to the use of the data, you can demand that we restrict the use of that data to storage. Use will be restricted to storage only until the accuracy of the data can be established or it is possible to verify that our legitimate interests outweigh your interests.

If you have a right to delete the data we have collected about you, you can request that we restrict the use of that data for storage.

7.4. Right to data portability

If we use data based on your consent or as a result of an agreement, and the data processing is automated, you have the right to receive a copy of the data you have provided in a machine-readable electronic format.

7.5. right of opposition

You have the right to object to the processing of your personal data by SMART TECN when we invoke our legitimate interest for such operation when carrying out a public interest task or for direct marketing purposes.

7.6. Automated individual decision making

You will also have the right to object to a decision based solely on automated processing, including profiling. In these situations, SMART TECN will guarantee adequate measures to safeguard its rights, mainly the right to human intervention in the analysis of such cases.

You will be notified if any automated decision is made regarding your personal data.

7.7. Withdrawal of consent

If we process personal data based on your consent, you can withdraw your consent to data disclosure at any time. Please also note that we will continue to use your personal data if we have to comply with a legal or contractual obligation.

8. Accuracy and updating of your personal data

We will update your personal data continuously during the period it is stored in our database. This is done for internal organization purposes and to allow a better match between your needs and requests and the services we provide. In this sense, it is possible to update your data by notifying it via an email to  contact@smarttecn.com  .

9. Updates to this Privacy Notice

We may revise this Policy from time to time by posting an updated version on our website. If substantial changes are made that could significantly influence your rights or increase your responsibilities, we will notify you by email. We may also provide notice of changes in other circumstances. We encourage you to periodically review this page for the latest information about our privacy practices.

10. Contact details and submission of complaints

You can contact us if you have any questions about your privacy rights and how we record and use personal data provided by you for business purposes. You can contact the person in charge at contact@smarttecn.com  .

If you are not satisfied with the way we process your personal data and you are not satisfied with your interaction with the responsible person, you can file a complaint.