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Privacy and Policy

SMHub, owned by UAPP Ltd (“we,” “us,” or “our”), recognizes the importance of privacy and is committed to protecting your personal data with the utmost seriousness.

Our Privacy Policy explains how we collect, use, and disclose information about you. The terms “SMHub,” “we,” “us,” and “our” refer to SMHub and its operations under the ownership of UAPP Ltd. The terms “user,” “you,” and “your” refer to any individual using our “Service,” including this website (https://www.smhub.co), related websites, applications (including mobile apps), products, or services we offer, as well as any communication with us.

This Privacy Policy applies to the processing of information about you that we collect when you use our Service. However, it does not cover information that you may provide to third parties, such as other users or individuals with whom you share your information.

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What information do we collect about you?

‍Information you give to us

We may be unable to provide certain products and services if you do not share specific information with us. Therefore, to process your requests and orders, it may be necessary to collect personal data, including but not limited to your name, email address, phone number, and payment information (such as credit or debit card details). Additionally, we may collect optional information that you choose to provide, such as your interests, preferences, feedback, survey responses, or other details shared through web forms, forums, or direct communication with us. This helps us better understand our users and improve our services. We may also obtain information about you where we have the appropriate permissions or as authorized by applicable laws.‍

Information we collect automatically when you use our sites or services

We may collect information about your interaction with our platform and services from the devices you use, including your unique device ID, device type, and advertising ID. Additionally, we may gather information about your visits and activity on SMHub, such as the content and advertisements you view or interact with, the site you visited before arriving at SMHub, and other technical data about your device, browsing behavior, and patterns. This may include details such as the pages you view, links you click, items you interact with, the duration of your session, your IP address, and your approximate location while browsing. This information is collected using cookies or similar technologies to enhance your experience and improve our services.

Information collected from other sources

We may combine your information with data we collect from third parties or public sources, including analytics providers, advertising networks, and publicly available databases.

Social media

Certain sections of SMHub may require you to set up an account to access specific services. To create a secure account, you will need to register using your email address and a password.

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Children’s data

Our Site is not intended for children under the age of 13. If you are under 13, please do not provide us with any information and instead ask your parent or guardian to do so on your behalf. You must be at least 18 years old to purchase products or services from us. If you are under 18, you must ensure that your parent or guardian makes purchases on your behalf.

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How will we use the information about you?

We may use your information for the following purposes:

  • Service Access and Registration: To register you as a new customer when you purchase a product from us.
  • Sales and Fulfillment: To process and deliver your order, or to manage payments, fees, and charges.
  • Customer Relationship Management: To contact you about your account, subscription, or other orders; to provide you with customer service (such as responding to questions, concerns, and feedback, and contacting you via email, post, direct message, or other similar communication methods for this purpose); to notify you of material changes to our terms or this Privacy Policy; to send you service-related communications; to ask you to leave a review or participate in a survey.
  • Service Access and Registration: To register you as a new customer when you purchase a product from us.
  • Sales and Fulfillment: To process and deliver your order, or to manage payments, fees, and charges.
  • Customer Relationship Management: To contact you about your account, subscription, or other orders; to provide you with customer service (such as responding to questions, concerns, and feedback, and contacting you via email, post, direct message, or other similar communication methods for this purpose); to notify you of material changes to our terms or this Privacy Policy; to send you service-related communications; to ask you to leave a review or participate in a survey.
  • Data Analytics: To measure the performance of our marketing campaigns (for example, analyzing open and click rates); to provide insights and analysis about our customers for internal use and for our business partners; and for future product development.
  • Marketing: To provide you with marketing through email, post, social media, and other digital channels; to make suggestions and recommendations about goods and services that may interest you. We do not use telephone or SMS/text-based marketing. See the "Marketing" section below for more details.
  • Advertising: To select and deliver advertising and content to you, and to measure the delivery and effectiveness of such advertising and content.
  • Personalization: To personalize content, services, and communications, as well as to target advertising, as further detailed in the "Personalization and Advertising" section below.
  • Aggregation and Anonymization: To aggregate and anonymize your data, enabling us to use it for selling advertising and monitoring the efficacy of our business partnerships.

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Personalization and Advertising

We want the ads and content displayed on our Site to be relevant to you. Personalizing and targeting advertising, content, services, and communications allows us to enhance your experience with our online content.

‍We will use your information to provide you with personalized content, services, and communications, as well as targeted advertising on our Site and on selected partner sites. We do this by matching, combining, or linking different sources of information we hold about you (e.g., linking your contact or subscriber information with your activity across our Site or linking your activity on our Site across your devices using your email). We may also create segments based on factors such as your age, gender, device details, or inferred interests.‍

We also use your information for retargeting (for example, you may see an advertisement on a partner site, such as Facebook, for a product you recently viewed on our Site).

‍These activities may involve the use of cookies and other similar technologies.

Marketing

Where we have the appropriate permissions or as otherwise authorized by applicable law, we will use your information to market and advertise our products and services, as well as occasionally third-party products and services that may interest you. This includes third-party offers, advertisements, competitions, or commercial communications via post, email, online platforms, or applications.

You can always let us know if you wish to stop receiving direct marketing communications from us. However, please note that if you choose not to receive these communications, you may miss out on exclusive offers.‍

If you prefer not to receive direct marketing communications, simply let us know at any time by writing to info.smhubco@gmail.com or by following the opt-out instructions in the relevant communication. Please note that this will not stop you from receiving service-related messages from us.

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What is our legal basis for processing your data?

We rely on one or more of the following legal bases when processing your data:

Fulfilling a Contract or Legal Obligation: We process your data to fulfill a contract with you or to comply with legal obligations, including:

  • Registering you as a new customer or creating an account to access our products or services.
  • Processing and delivering your orders.
  • Managing payments, fees, and charges.
  • Collecting and recovering debts owed to us.
  • Contacting you about your account, subscription, or other orders.
  • Providing you with customer service (e.g., responding to questions, concerns, and feedback, and contacting you via email, post, or direct message).
  • Sending you service-related communications.
  • Providing you with the services you requested when we collected your information.
  • Enabling you to participate in sweepstakes, contests, product trials, events, awards, surveys, polls, and quizzes, and delivering any prizes or awards as applicable.
  • Notifying you of material changes to our terms or this Privacy Policy.
  • Administering and protecting our business and sites (e.g., troubleshooting, system maintenance, support, reporting, hosting data, ensuring network and system security, and investigating fraud or illegal activities).
  • Verifying your identity.

‍Our Legitimate Interests: We process your data based on our legitimate interests (to operate an effective and successful business) or the legitimate interests of a third party, where not outweighed by your interests. These purposes include:

  • Measuring the performance of our marketing campaigns (e.g., analyzing open and click rates).
  • Providing marketing via post, social media, and other digital channels (e.g., Facebook Custom Audiences and Google Custom Match).
  • Sending marketing emails where you have purchased goods or services from us.
  • Requesting reviews or survey participation.
  • Administering and protecting our business and sites, including troubleshooting, testing, system maintenance, support, reporting, and hosting data.
  • Using data analytics to provide insights into our customers for internal use and by our business partners.
  • Making suggestions and recommendations about goods and services that may interest you.
  • Selecting and delivering advertising and content and measuring its delivery and effectiveness.
  • Personalizing content, services, and communications, and targeting advertising.
  • Aggregating and anonymizing your data to sell advertising and monitor the efficacy of our business partnerships.

The legitimate interests we rely on for this processing include:

  • Keeping our records updated.
  • Studying how customers use our products and services.
  • Improving the customer experience.
  • Developing our products and services.
  • Growing and managing our business.
  • Providing administrative and IT services.
  • Ensuring network security and preventing fraud.
  • Supporting business reorganization or restructuring efforts.
  • Informing our marketing and content strategy.
  • Keeping our sites and content updated and relevant.

‍Your Consent: We process your data with your consent, including to:

  • Provide you with marketing via email, post, and other channels, including from our third-party service providers.

You can withdraw your consent at any time. See the "Marketing" section above for further details.

What will we disclose and share with third parties?

Sharing Your Data with Third Parties:

We share your personal data with our third-party service providers for the purposes outlined in this Privacy Policy. This includes enabling them to process requests, orders, or services; providing you with a prize if you win a competition; or obtaining necessary information. We may use several IT service providers, both inside and outside the European Union, to store data, manage customer information, provide disaster recovery services, and offer related IT services necessary to conduct our business and fulfill contracts we enter into with you. Any third parties we engage to process your data on our behalf are subject to contractual obligations to ensure the security and confidentiality of your data, as outlined in this Privacy Policy.

Sharing Your Information with Advertisers and Analytics Providers:

We share your information with advertisers, ad servers, ad networks, and content recommendation services to select and deliver advertising and content, and to target and personalize advertising and content both on our sites and on selected partner sites. This does not include any information that directly identifies you in the real world, such as your name, email address, physical address, or phone number. However, by interacting with or viewing an advertisement or content, you should be aware that the third party may assume that you meet the targeting criteria used to display the advertisement or content. We also share your information with analytics and search engine providers to assist us in improving and optimizing our sites.

Business Transfers:

We may merge with or be acquired by another business. If this occurs, we will share the information related to you with that other business. You will be notified of such an event.‍

Legal Compliance and Protection:

We reserve the right to disclose your personal data to comply with the law, applicable regulations, and government requests. We also reserve the right to use such information to protect our operating systems, integrity, and other users.

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How do we protect your information?

Data Security:

Once we have received your data, we will take steps to ensure it is treated in accordance with applicable laws. However, the transmission of information via the internet is not completely secure. While we will do our best to protect your personal data, we cannot guarantee the security of data transmitted to our site; any transmission is at your own risk.

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Other websites

Third-Party Links and Advertisements:

Please note that clicking on links and advertisements on our site may transfer you to another website where data privacy practices differ from ours. If you are transferred to another website, you should review their privacy policy, as we are not responsible for and have no control over the information submitted to or collected by these third parties.

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‍How long do we keep your information?

Data Retention:

We are required by law to retain certain information about our customers (such as financial and transaction-related data) for seven years after they cease being customers, for tax purposes. This retention period may be adjusted to comply with changes in the law.

Data Retention Periods:

Our data retention periods vary depending on the context of the services we provide to you and our legal obligations. To determine the appropriate retention period for your data, we consider the amount, nature, and sensitivity of your data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data (and whether these purposes can be achieved through other means), and any applicable legal requirements.

International Data Transfers:

If you choose to provide us with Personal Data, it may be stored in various jurisdictions, including the United States. If you are visiting our Site from the European Union or other regions with strict data protection laws, please note that your Personal Data may be transferred to jurisdictions that do not have the same level of data protection as the European Union and may not provide the same rights to data subjects. By using our Site, you acknowledge and agree that: (i) Your Personal Data may be used as described in this Privacy Policy. (ii) Your Personal Data may be transferred to the United States or other jurisdictions, as outlined above.‍

Hosting and Data Transfers:

Although SMHub is owned by a private entrepreneur based in Ukraine, our Site is hosted in the USA, and some of our business operations may involve international data transfers. Accordingly, any information you provide to us may be transferred to countries outside the European Union. By submitting your personal data, you agree to the transfer, storage, and processing of your data outside the European Union. Your data may be transferred to countries that do not have the same data protection laws as the country where you initially provided the information.

‍We have implemented advanced encryption and authentication tools to protect the security of your personal data on our Site. When collecting your personal data, we use industry-standard encryption to safeguard your information before it is transmitted over the Internet, ensuring secure online transactions. Additionally, we employ technologies such as secure routers and firewalls to maintain the safety of your personal information. However, due to the nature of the Internet, we cannot fully guarantee the security of data transmission.

‍Once we receive your personal data, we implement industry-standard security measures to safeguard it against loss or misuse. However, we cannot fully guarantee that such loss or misuse will not occur. We strongly encourage you to protect your password for our Site and not share it with anyone. Always log out of our Site when you are finished, especially if you are using a shared or public computer.

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Your Rights

You have certain rights regarding the personal data we hold about you, as detailed below. Some rights apply only in specific circumstances, as outlined further. We have also explained how you can exercise these rights. When you choose to exercise your rights, we may request specific information to confirm your identity and ensure your entitlement to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who does not have the right to access it. Additionally, we may contact you for further details regarding your request to expedite our response.

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You have the right to:

  • Request Access to Your Personal Data: This right allows you to request a copy of the personal data we hold about you and verify that we are processing it lawfully.
  • Request Correction of Your Personal Data: This right allows you to request the correction of any incomplete or inaccurate data we hold about you. We may need to verify the accuracy of the new data you provide to us.
  • Request Erasure of Your Personal Data: This right allows you to ask us to delete or remove your personal data where there is no legitimate reason for us to continue processing it. You may also request erasure if you believe we have processed your information unlawfully or if we are required to erase your personal data to comply with local law. Please note that we may not always be able to comply with your request for specific legal reasons, which will be communicated to you at the time of your request, if applicable.
  • Object to Processing of Your Personal Data: You have the right to object to the processing of your personal data if we are relying on a legitimate interest (or those of a third party) and you believe the processing impacts your fundamental rights and freedoms. You can also object to the processing of your personal data for direct marketing purposes. More details on your marketing choices can be found in the Marketing section above. In certain cases, we may demonstrate compelling legitimate grounds for processing your data that override your rights and freedoms.
  • Request Restriction of Processing of Your Personal Data: You have the right to request that we suspend the processing of your personal data in certain circumstances. For example, this may apply if you want us to verify the accuracy of the data, if our use of the data is unlawful but you prefer not to have it erased, if you need us to retain the data to establish or defend legal claims, or if you have objected to our use of your data and we are verifying whether we have overriding legitimate grounds to continue processing it.
  • Request the Transfer of Your Personal Data: You have the right to request the transfer of your personal data to you or a third party of your choice. We will provide your personal data in a structured, commonly used, machine-readable format. Please note that this right applies only to automated information that you initially consented for us to use or that we used to perform a contract with you.
  • Withdraw Your Consent: You have the right to withdraw your consent at any time if we are relying on it to process your personal data. However, withdrawing your consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.

If you wish to exercise any of the rights outlined above, please contact us using the details provided in the "How to Contact Us" section below.

To exercise your rights to access, data portability, and deletion, please submit a verifiable request by emailing us at: info.smhubco@gmail.com. 

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Our Response Time:

We aim to respond to a verifiable request within 45 days of its receipt. If we require additional time (up to 90 days), we will notify you of the reason and the extension period in writing. If you have an account with us, our response will be delivered to your account. If you do not have an account, we will provide our response via mail or electronically, based on your preference. Any disclosures we provide will cover only the 12-month period preceding the date of the verifiable request. If we cannot comply with a request, our response will explain the reasons for non-compliance. For data portability requests, we will provide your personal information in a readily usable format that allows you to transmit it to another entity without hindrance. 

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that your request warrants a fee, we will inform you of the reason for this decision and provide a cost estimate before completing your request.

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Changes to This Privacy Notice:

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on the homepage of our website. Your continued use of our Website and/or Services following the posting of changes constitutes your acceptance of those changes.

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Contact Us:

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or if you wish to exercise your rights, please contact us at: info.smhubco@gmail.com 

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Use of Cookies and Tracking Technologies:

Like many other websites, we and our third-party service providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your usage and browsing activities on the Site and across third-party sites or online services. A cookie is a small piece of data stored on your computer or mobile device by your web browser. We use cookies to identify the areas of our Site that you have visited. Cookies also enhance your online experience by eliminating the need to log in multiple times for specific content. Additionally, we may use cookies to personalize the content you see on our Website or to tailor marketing and other information we provide to you. We may combine this information with other data we collect about users to improve our services and offerings.

Most web browsers allow you to disable the use of cookies. Additionally, our Website provides buttons that allow you to opt-in and opt-out of various types of communications from us. Please note, however, that if you disable cookies or choose not to opt-in to our use of cookies, certain features of our Website may not function correctly or may become inaccessible.

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Dispute Resolution:

By using the Site, you and SMHub agree to resolve any controversy, claim, action, or dispute ("Dispute") arising from the Site or this Privacy Policy. Both parties shall first attempt in good faith to settle the Dispute. To do this, a written notice must be sent to the other party, describing the facts and circumstances of the Dispute. The receiving party will then have 30 days to respond or resolve the Dispute. This will be done by providing written notice to the other party describing the facts and circumstances of the Dispute and allowing the receiving party 30 days to respond or settle the Dispute. Notice should be sent to: info.smhubco@gmail.com. 

Both you and SMHub agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party.

IF ANY DISPUTE CANNOT BE RESOLVED THROUGH THE DISPUTE RESOLUTION PROCEDURE OUTLINED ABOVE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR RESOLVING SUCH A DISPUTE WILL BE THROUGH BINDING ARBITRATION ON AN INDIVIDUAL BASIS. BINDING ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WAIVE THE RIGHT TO HAVE A JUDGE OR JURY DECIDE YOUR CLAIMS, AND YOU ALSO WAIVE THE RIGHT TO PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY.

Other rights that you and we would have in court may be limited in arbitration, including discovery and appeal rights. All such disputes shall be resolved in accordance with the laws of the United Kingdom or Ukraine, as applicable, depending on the nature of the dispute and the parties involved. Arbitration shall take place under a mutually agreed upon arbitration provider, following the rules then in effect in the jurisdiction designated by the dispute. The arbitrator, and not any court or agency, shall have the exclusive authority to resolve any dispute related to the interpretation, applicability, enforceability, or formation of this Privacy Policy, including any claim that all or part of this Privacy Policy is void or voidable.

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Choice of Law and Forum

You agree that this Privacy Policy and any claim or dispute arising between you and us are primarily governed by the laws of the United Kingdom. For certain matters directly related to the service ownership or compliance with local laws, the laws of Ukraine may apply, as the owner of the service is a private entrepreneur based in Ukraine. Notwithstanding the above, any arbitration conducted under this Privacy Policy shall adhere to the arbitration laws applicable to the jurisdiction agreed upon by the parties.

You further agree that this Privacy Policy is governed by the laws of the United Kingdom for most matters, including data protection, user rights, and service compliance. For specific issues related to ownership and compliance with local regulations, Ukrainian law will apply. PLEASE NOTE THAT BY AGREEING TO THIS PRIVACY POLICY, YOU ARE: (1) WAIVING CLAIMS THAT YOU MIGHT OTHERWISE HAVE AGAINST US BASED ON THE LAWS OF OTHER JURISDICTIONS, INCLUDING YOUR OWN; (2) IRREVOCABLY CONSENTING TO THE EXCLUSIVE JURISDICTION OF, AND VENUE IN, COURTS OF THE UNITED KINGDOM OR UKRAINE FOR ANY DISPUTES OR CLAIMS BROUGHT UNDER THIS PROVISION; AND (3) SUBMITTING YOURSELF TO THE PERSONAL JURISDICTION OF SUCH COURTS FOR THE PURPOSE OF RESOLVING ANY DISPUTES OR CLAIMS.

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‍Changes to our Privacy Policy

We keep this Privacy Policy under regular review and update it to reflect changes in our privacy practices. Any updates will be posted on this page, allowing you to always stay informed about what information we collect, how we use it, and under what circumstances we disclose it.

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‍How to contact us

If you have any queries relating to this Privacy Policy, please contact us by writing to us at:

info.smhubco@gmail.com