Privacy Policy

Personal data processing when you register for our services

Upon registration to the Smartproxy dashboard, you will be asked to provide your username and email address which are necessary to create your account. We also require you to specify how do you use proxies to provide you with services that may be of interest to you and to further improve our services. Without providing the above-mentioned information, you cannot create a Smartproxy account.

Our payment service provider might ask you for additional information when administering your payments for our services from your account (for example, location information for VAT purposes, etc.). To learn more about the way our payment service provider processes your data, please refer to its privacy policy (the link is provided upon request for your information).

Personal data processing when performing identity verification, related checks

At Smartproxy, we are committed to ensuring the security and privacy of your personal information. We are also committed to providing our users with secure and efficient access to our services. As part of our services, we use Onfido Ltd. ("Onfido") for identity verification and related checks to help us confirm your identity securely and efficiently. This section in our Privacy Policy outlines how we collect, use, and protect your personal information, particularly in the context of identity verification and related checks.

For more detailed information on how Onfido handles your data when performing verification and/ or related checks, please review the Onfido Privacy Policy here: https://onfido.com/privacy/. Onfido may also use your information independently to enhance their services - for more details on their data usage in this regard, please refer to their privacy policy.

I. The information we process and how we use it

To perform identity verification and related checks, we process certain personal information received from you and/or access information about you, which is processed by Onfido. The majority of the personal information described below is not directly collected or fully processed by us. Instead, it is gathered, stored, and processed by Onfido to perform identity verification, complete checks, and generate the report („Onfido Report“).

Once your identity is verified and/ or a check is completed, Onfido generates the Onfido Report that is provided to us. If your identity is verified and no issues are detected, the report will indicate a “Clear” result. If your identity cannot be verified or there are signs of fraud, the report will indicate a “Consider” result, with details explaining why. We do not have access to the categories of personal information listed below unless the Onfido Report returns a "Consider" result. In such instances, we may obtain access to the personal information utilized by Onfido. We access this information to make informed decisions regarding the provision of services to you. However, we do not store any of this information on our systems. We only have access to it through Onfido.

We only use the data for the purpose specified below. We do not sell, lease, trade, or otherwise profit from the data collected, as described below.

Identification Document (ID) checks

Purpose: to verify the authenticity of your ID and ensure compliance with legal obligations.

Categories of data that might be processed: personal information extracted from your identity document, such as your name, document number, date of birth, nationality, type of document, issuing country, expiration date, and metadata associated with the image of the document, your photo on the ID document.

Legal basis: the processing of your personal data for ID verification is necessary for the legitimate interests of Smartproxy (Art. 6(1)(f), GDPR), to prevent fraud, ensure the security of our services. Additionally, we might be obliged to ensure compliance with the anti-money laundering (AML), know-your-customer (KYC) regulations, and other statutory obligations that mandate ID verification (Art. 6(1)(c), GDPR).

Onfido verifies identity documents by extracting and analyzing information from your document.

Photo checks and identification

Purpose: to verify your identity by comparing your image (selfie) with the image on your ID, and to detect the potential tampering or fraud.

Categories of data that might be processed: images (selfies) you provide for identification purposes.

Legal basis: Onfido may ask you to provide an image (selfie) that they compare with your ID image to verify and confirm your identity, using automated technology. They also analyze the authenticity of these images and detect signs of tampering or fraud. We require your explicit consent (Art. 9(2)(a), GDPR) to use the images you provide to verify your identity. You may withdraw your consent at any time by contacting us at [email protected].

II. Data storage

We retain your personal information only as long as necessary to provide our services or as required by law. The retention period may vary based on the type of data and legal requirements. For identity verification and related checks, we keep your data for the duration of your contract with us, plus an additional five years after the contract ends. Please note that we only retain Onfido Reports and do not store the full range of your data as outlined below.

III. Contacts

If you have any questions or concerns about identity verification or related checks, please contact us at [email protected]. If you wish to find out more about your privacy rights, please refer to the „Your privacy-related rights“ section of this Privacy policy.

Personal data processing when you contact us

We can be contacted by various means: – you can send us an email; – you can fill in an online contact form; – you can send us a request using our live chat platform; or – you can contact us through social media.

In all these cases, we process your personal data for the purposes of responding to your inquiry and administering it. By contacting us you consent to your personal data processing, therefore the legal basis for your data processing in this case is a consent.

Personal data processing when using our live chat platform

When you engage with our live chat platform, we use a third-party service, DeepL translator, to facilitate communication by translating the text you submit. We process the following data: 1) messages and other text-based communication that you provide through the live chat; 2) any personal data included in those communications, such as your name or contact details. The text you submit is processed by DeepL for the purpose of real-time translation to facilitate better communication between you and our support team. By using the live chat and submitting text for translation, you provide your explicit consent for the processing of your personal data. You can withdraw your consent at any time by discontinuing the use of the live chat function. Your data is shared with DeepL SE, the service provider of the translation tool. DeepL processes the text submitted during live chat interactions solely for the purpose of translation. DeepL’s privacy policy can be reviewed at https://www.deepl.com/en/privacy which outlines how they process and protect personal data.

We do not retain any translated data beyond the duration of the live chat session. The text submitted is processed only for the duration of the chat interaction.

Personal data processing for marketing purposes

Smartproxy may use your personal data to contact you with marketing related offers.

You will receive information about our services if you provide your contact details in the contact form on our website. We consider that by providing your information in the online form you give us a consent to contact you for purposes mentioned in this section.

In cases where applicable law permits us to contact you without a separate consent, we will contact you under the legal basis of our legitimate interests to make you an offer of our services. You can opt-out from any marketing related communication that we send you at any time by clicking an unsubscribe button in our emails or by contacting us at [email protected].

How long do we store your data?

Smartproxy stores your personal data up to 2 years from our last contact with you or from your last log-in. Your data may be stored for a longer period, if it is necessary to defend ourselves against claims, demands or actions and exercise our rights or if law demands it.

Data sharing

Smartproxy will use certain service providers (data processors) to process your personal data. Such data processors are: CRM software providers, email and email tracking service providers, online live chat service providers, business development service providers, customer support specialists, data analysis service providers, payment services firms, web hosting companies and other service providers. In all cases, your personal data is disclosed only to the extent necessary for the provision of their services. We do not share your data with any third parties that are not our service providers.

We may share personal data with state agencies, government bodies, law enforcement, courts, and regulatory authorities when legally mandated. This may include responding to official requests, such as subpoenas, or supporting investigations. Such actions are taken to fulfill our legal duties and respond to legitimate demands from law enforcement or to safeguard our rights, interests, and the safety of our company, employees, clients, and the public.

Your privacy-related rights

You have the following rights with respect to your personal data: – to get access to your personal data and related information about processing; – to demand to correct inaccurate data; – to demand to erase your personal data or restricting the processing of your personal data when there is a legal basis for that; – to demand to transfer your personal data to another data controller or provide it directly to you in a convenient format (on conditions set in the applicable law); – in cases where your personal data is processed on a consent basis, you have the right to withdraw your consent at any time; – to object to the processing of your personal data, if the processing is based on a legitimate interest (on conditions set in the applicable law); – to contact a relevant data protection authority of your habitual residence, place of work or of an alleged infringement and file a complaint, if you believe that your data is processed unlawfully. If you like to exercise any of the above-mentioned privacy-related rights, please contact us at [email protected].

Data processing when you visit our website

When you visit our website, we ask you for a consent to collect certain personal data with the help of cookies and other similar technologies.

Cookies, pixels and other similar technologies are usually small text or image files that are placed on your device when visiting our website. We mostly use cookies on our website and they usually fall within one of the following categories: – Essential cookies. Without these cookies we cannot provide many services that you need on the website. For example, essential cookies help remember your preferences as you move around the website. – Functionality cookies. These cookies are used to remember information you have entered or choices you make (such as your username or language) on the website, so the next time you visit the website you will not have to set them again. – Analytics cookies. These cookies track information about visits to the website so that we can make improvements and report our performance. For example, analyze visitor and user behavior to provide more relevant content. – Advertising cookies. These third-party cookies are placed by third-party advertising platforms or networks to deliver ads and track ad performance. In some cases, these cookies enable advertising networks to deliver ads that may be relevant to you based upon your activities on our website and other websites (in such cases, ad serving might be based on automated decision-making).

Cookies on our website can be classified to session or persistent cookies. Session cookies are temporary and are erased when you close your browser at the end of your surfing session. Persistent cookies remain on your hard drive until you erase them or they expire. Please find cookies and other technologies used on our website in the table below:

You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you want to learn more about cookies, or how to control, disable or delete them, please visit https://www.aboutcookies.org/ for detailed guidance.

The content of the table above is for your general information and use only. Cookies are subject to change without notice. You acknowledge that this information may contain inaccuracies or errors and is subject to change and we expressly exclude liability for any such inaccuracies or errors fully permitted by law.

This Policy was updated on: October 9th, 2024