This Privacy Policy (“Policy”) describes how Smart CoReg, LLC and its affiliated companies and subsidiaries based in the United States (collectively, “Smart CoReg ” or “we” or “us” or “our”) collect information, what information Smart CoReg collects, how Smart CoReg uses it, to whom Smart CoReg discloses this information and how you can access, change, and remove your information.
This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent, that any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.
Collection of Your Information
Smart CoReg may collect personally identifiable information from you in various ways. Smart CoReg may use the following sources:
by signing up to mailing lists at Smart CoReg websites;
from your purchases;
from a third party with your consent (e.g., your bank or one of our partners);
from our information technology systems (e.g., door entry systems, automated monitoring of our websites);
from pixel tags us or our partners may place in email advertisements sent to your email address; and
when contacting Smart CoReg or visiting Smart CoReg websites, affiliates, clients, and/or partners.
Personally identifiable information refers to information about you that can be used to contact or identify you. It includes, but is not limited to, your name, phone number, email address, postal address, and social networking information. The collected information falls into the following categories:
identifiers (e.g., name, alias, postal address, online identifier, Internet Protocol address, email address, account name, similar identifiers, or unique personal identifiers such as cookies, beacons, or pixel tags);
information that identifies relates to, describes, or is capable of being associated with a particular individual (e.g., credit card number, telephone number, address, or similar information);
characteristics of protected classifications under California or federal law;
commercial information (e.g., records regarding goods or services purchased, or other purchasing histories or tendencies);
internet or other electronic network activity (e.g., browsing history, search history, and information regarding a consumer’s interaction with an online site or application, or similar information);
IP addresses;
audio, electronic, or similar information; and
information drawn from any of the above to create a consumer profile that includes characteristics, psychological trends, predispositions, behaviors, or similar information.
Smart CoReg may also collect certain non-identifying information, or aggregate information, such as anonymous demographic information including zip codes, dates of birth, customer preferences, information about customer computer hardware and software, as well as information about the links and pages that users access within Smart CoReg ’ Websites, as defined in Smart CoReg ’ Terms of Use and Conditions.. Certain non-identifying information may be considered personally identifiable information if combined with other information which may enable you to be identified (such as a zip code with a street address); however, the same information when taken alone or combined with other non-identifying information, will be considered non-identifying information.
Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Smart CoReg operated public message boards, such information may be collected and used by others. As mentioned in our Terms of Service, you are required to comply with all laws, including all privacy laws- thus if you provide us with personal information of others, you are responsible for ensuring that you have thoroughly reviewed our Terms of Service and this Policy and that you have gathered sufficient consents (and have sufficient compliance policies and procedures in place) to lawfully provide us with the personal information of others. If at any point you have reason to believe you have inadvertently provided us with the personal information of others without sufficient consents, you must notify us immediately.
Occasionally, Smart CoReg will offer links to third-party websites. Smart CoReg encourages you to review the privacy policies of websites you choose to link to from Smart CoReg ’Websites so that you can understand how those websites collect, use, and share your information. Smart CoReg is not responsible for the privacy policies or content of third-party websites.
Use of Your Information
Smart CoReg may store and use your personally identifiable information for (i) product or service fulfillment, (ii) marketing, promotional, and advertising purposes, such as to inform you of products or services available from Smart CoReg or our partners, (iii) internal operations, such as improving and optimizing your user experience – this includes auditing current interactions, (iv) detecting security incidents, protecting against malicious, deceptive activity, and taking all necessary and appropriate steps to mitigate current and future risk; (v) debugging and repairing internal information technology as necessary; (vi) undertaking internal research for technological development and demonstration; and (vii) to share with trusted third-party service providers to help Smart CoReg perform activities to improve your customer experience with your consent (“Business Purposes”). In addition, Smart CoReg may share, sell, rent, or lease your personally identifiable information to third parties for marketing, promotional, or advertising, including targeted advertising, purposes (the “Advertising Purposes”). We may sell or share personally identifiable information to or with any of the following:
our affiliates and subsidiaries in the United States;
credit card processors and other companies that help facilitate your transactions;
our banks, insurers, and brokers;
companies that provide statistical analysis of your interactions with us;
companies that provide customer support or arrange for deliveries;
companies that provide advertising and digital content;
companies that support e-commerce marketing efforts; and
third parties approved by you.
The following categories of information are sold or shared for Business Purposes or Advertising Purposes:
identifiers (e.g., name, alias, postal address, online identifier, Internet Protocol address, email address, account name, similar identifiers, or unique personal identifiers such as cookies, beacons, or pixel tags);
commercial information (e.g., records regarding goods purchased, or other purchasing histories or tendencies);
internet or other electronic network activity (e.g., browsing history, search history, and information regarding a consumer’s interaction with an online site or application, or similar information);
information drawn from any of the above to create a consumer profile that includes characteristics, psychological trends, predispositions, behaviors, or similar information.
Smart CoReg may, from time to time, contact you on behalf of external business partners or third parties about a particular offering that may be of interest to you.
Smart CoReg does use third-party service providers to serve ads and collect data on our behalf across the Internet. Some of these service providers may collect information about your visits to our Websites, and your interaction with our products and services to tailor marketing messages on our Websites or to trigger real-time interaction, customize our website,or enhance your profile. Some of these services providers may be able to collect personal information that you share the Websites via a web form automatically and prior to your pressing a submit button, and they may be able to use information from your visits to send marketing messages to you in a way that may personally identify you. This information is collected through the use of a cookie, a javascript tag, as well as a pixel, which is industry-standard technology used by most major websites. The information collected by these service providers may include your device’s IP address, user agent, email addresses (where hashed or otherwise rendered pseudonymous), and other user and device level pseudonymous information. Please keep in mind that your browser settings may not permit you to control the technologies utilized by these third-party companies. If you would like more information about these practices,please click: http://optout.aboutads.info/#!/.
Smart CoReg is not limited in our use of aggregate information that does not permit direct association with any specific individual, such as the number of users of our services, the geographic distribution of our users, the amount of information located or removed, etc. For example, Smart CoReg may use aggregate information concerning which links and pages users access within the Websites for many reasons including to determine which Smart CoReg products and services are the most popular. This data may be used to deliver customized content and advertising to customers whose behavior indicates that they are interested in a particular subject area.
Smart CoReg will disclose your personally identifiable information, without notice, if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or to comply with legal process served; (b) protect and defend the rights or property of Smart CoReg ; or (c) act under exigent circumstances to protect the personal safety of users of and Smart CoReg website or the public.
Additionally, Smart CoReg may disclose personally identifiable information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
As with any other business, Smart CoReg may merge with or be purchased by another company. If Smart CoReg is acquired, the company that acquires us would have access to the information maintained by us, including personally identifiable information, but would continue to be bound by this Policy unless and until it is amended.
Retention of your Information
Smart CoReg will retain your personal information for as long as necessary for uses related to the Business Purposes or Advertising Purposes. If your information has not been used for the Business Purposes or Advertising Purposes for a period of at least 24 months and it is reasonably anticipated that Smart CoReg no longer has use for your information, Smart CoReg will take commercially reasonable steps to delete your information in a timely manner.
Security Protections for your Information
Smart CoReg takes the security of your personally identifiable information very seriously. Smart CoReg uses reasonable administrative, physical, and technical safeguards to secure the personally identifiable information you share with us. Despite these safeguards and our additional efforts to secure your information, Smart CoReg cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your personally identifiable information.
The security of your Smart CoReg ’account relies on your protection of your user profile information. You are responsible for maintaining the security of your user profile information, including your password, and for all activities that occur under your account. You may not share your password with anyone. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the Websites.
Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and report it immediately.
Use of Cookies or Similar Technology
Smart CoReg ’Websites work with a first-party cookie that collects anonymous traffic data, a form of aggregate information. “Cookies” are simple text files stored on your computer for use by a browser. Smart CoReg may use “cookies” to assist in data collection and to track visitor website usage and trends to help us better serve you. If you reject cookies, you will still be able to view our websites, but your ability to use some areas of the websites will be limited. Some of our business partners and publishers (e.g., analytical tracking software providers) use cookies and tracking technologies on our websites. We have no access to or control over these third-party cookies or tracking technologies. This Policy covers the use of cookies on our Websitesby us only and does not cover the use of cookies or tracking technologies by any such business partner.
We may also use cookies, pixels, beacons, or other web tracking technologies to track when you view email advertisements from us, our business partners, or other third parties, as well as the amount of time spent on our Websites and whether certain content, such as a video, was viewed. We may work with a trusted third party to collect and process this information for us, based on our instructions and in compliance with this Policy.
When you visit Smart CoReg ’Websites, Smart CoReg automatically collects the name of the website you visited from (called the “Referring Page”) and the name of the website you chose to visit immediately after ours (called the “Exit Page”), and information about other websites you have recently visited. This information is used to improve our Websites, but we cannot identify you from any information we receive from cookies. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, and our websites are not currently set up to respond to those signals for tracking on our Websites.
Third Party Cookies
Notwithstanding anything else in this policy, we and/or our partners may place or read use cookies to enable you to receive customized ads or content. These cookies contain no personally identifiable information. The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form. Users can also express their choices for display advertising, through the following platforms: Digital Advertising Alliance
opt-out platform or the Network Advertising Initiative opt-out platform.
We and/or our partners may also use cookies for delivering personalized advertising emails. These cookies are used to identify the visitors of our advertisers’ websites and send personalized emails based on the visitors’ browsing experience. To learn more click here. To opt out, click here.
We and/or our partners use cookies and web beacon technology to associate certain Internet-related information about you, such as your Internet Protocol address and what Web browser you are using, with certain of your online
behaviors, such as opening emails or browsing websites. Such information is used to customize ads or content and may be shared with our partners.
Participation in Interest-Based Advertising
Smart CoReg may also participate in interest-based advertising using cookies, beacons, pixel tags, or other similar technology. Therefore, you may receive email advertisements from us, our business partners, or other third parties coinciding with when you view email advertisements from us, our business partners, or other third parties. You may also see advertising on our Websitestailored to how you browse or shop, or you may see advertising for Smart CoReg or its business partners or other third parties on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for Smart CoReg and its Websites. Other websites where you see our ads, such as Facebook, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites such as Facebook, and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser, or your device settings for additional information.
You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (the “NAI”) or who follow the Digital Advertising Alliance’s (the “DAA”) Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website (http://www.networkadvertising.org/choices/) and DAA website (http://www.aboutads.info/choices/).
Opt-Out/Unsubscribe
You may opt-out of the disclosure, sharing, or sale of your personal information at any time using the “Do Not Sell or Share My Personal Information” link on Smart CoReg ’ homepage, or by clicking. Alternatively, you may contact Smart CoReg via email at legal@inboxmailers.com.
You may also opt-out or unsubscribe from receiving email correspondence from Smart CoReg at any time by contacting us or by following the instructions contained in any email received. It may take time to process opt-out requests, so you may receive emails from Smart CoReg after your opt-out request.
Additionally, the DAA offers tools to provide consumers with choices as to whether participating third parties can use your information to provide interest-based ads. To opt out of sharing your information with participating third parties for interest-based ads, please visit https://optout.aboutads.info/
Smart CoReg may not, and will not, treat you differently if you opt out of the disclosure, sharing, or sale of your information. We may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.
Children’s Privacy
Smart CoReg ’ Websites are not targeted for use by children under the age of 18. Smart CoReg does not knowingly collect personally identifiable information from children in connection with the features of our websites without the consent of a parent or guardian. Smart CoReg requests that all visitors under 18 to our websites not disclose or provide any personally identifiable information. Upon notification that a child under 18 has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records.
Special Notice for California Residents
In compliance with California law, we provide California residents with certain information upon request (“Data Subject Request”). This Policy outlines how California residents can receive the information and what you can receive.
If you would like to submit a Data Subject Request, email us at legal@inboxmailers.com. The information you provide to Smart CoReg must be accurate and complete before Smart CoReg can respond. If you choose to submit a Data Subject Request you must provide us with enough information to identify you (e.g., Smart CoReg profile information (including personal information), order number, or other identifying information such as name and email address) and enough specificity on the requested data. Smart CoReg will only use the information it receives for verification. Smart CoReg will not be able to disclose the information if it cannot verify that the person making the Data Subject Request is the person about whom we collected information, or someone authorized to act on such person’s behalf.
You may submit a Data Subject Request to receive information about Smart CoReg ’data collection practices. You may request information on the categories of personal information (in this section, as defined by California law) Smart CoReg has collected about you; the categories of data collection sources; Smart CoReg ’business or commercial purpose for collecting or selling personal information; the categories of information about you that Smart CoReg has sold or shared, the third parties to whom Smart CoReg has disclosed, shared, or sold your personal information if any; and the specific pieces of personal information we have collected about you. You may also request that Smart CoReg use commercially reasonable efforts to correct any inaccuracies in your information.
If you would like to also receive information about Smart CoReg ’data disclosure for Business Purposes or Advertising Purposes, then please include that in the Data Subject Request. Smart CoReg will clarify whether the information was disclosed, shared, or sold, or simply collected and kept internally.
Please note that the categories of personal information and sources will not exceed what is contained in this Policy. Additionally, Smart CoReg is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. Smart CoReg is also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.
You may request that Smart CoReg delete your personal information. Your deletion request should be submitted through a Data Subject Request. Subject to certain exceptions set out below we will, on receipt of a verifiable Data Subject Request, delete your personal information from our records and direct any service providers to do the same. We will also notify third parties, including our business partners and service providers, to whom we have disclosed, shared, or sold your information of your request to delete your personal information.
Please note that we may not delete your personal information if it is necessary to:
complete the transaction for which the personal information was collected;
provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk;
debug and repair internal information technology as necessary;
undertake internal research for technological development and demonstration;
exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
comply with an existing legal obligation; or
otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Smart CoReg may not, and will not, treat you differently because of your Data Subject Request activity. As a result of your Data Subject Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services, or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.
In addition, if you are a California resident under the age of 18 and are a registered user, you may request us to remove content or information posted on our websites or stored on our servers by (a) submitting a request in writing to legal@inboxmailers.com and (b) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed. However, please note that we are not required to erase or otherwise eliminate content or information if (i) other state or federal laws require us or a third party to maintain the content or information; (ii) the content or information was posted, stored, or republished by another user; (iii) the content or information is anonymized so that the minor cannot be individually identified; (iv) the minor does not follow the instructions posted in this Policy on how to request removal of such content or information; and (v) the minor has received compensation or other consideration for providing the content. Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.
Users Outside the United States
Smart CoReg is headquartered in the United States. If you are visiting one of our Websites from another country, the laws governing our Websites’ collection and use of personally identifiable information may be different from the laws of your country. If you decide to visit our website, or share your personally identifiable information with Smart CoReg , you are agreeing to be governed by the laws of the United States, and you are expressly consenting to the transfer of your data to the United States.
In particular, please note that neither our Websites, nor the products and services we offer on our Websites, nor any other activities we carry out as set forth in this Policy, are aimed at individuals based in the United Kingdom or any jurisdiction within the European Economic Area (“EEA”).
Changes to this Statement
Smart CoReg will occasionally update this Policy. Smart CoReg encourages you to periodically review this Policy to be informed of how Smart CoReg is using and protecting your information. At a minimum, this Policy will be updated every twelve months.
Contact Information
Smart CoReg welcomes your comments regarding this Policy. If you believe that Smart CoReg has not adhered to this Policy, please contact Smart CoReg at legal@smartcoreg.com.We will use commercially reasonable efforts to determine and remedy the problem promptly.
Effective as of April 3, 2022