SMOC.AI Privacy Statement
This is the privacy statement (policy) of SMOC.AI AS, business registration number 923 403 418.
Our aim is to provide you with a privacy friendly solution where you can have more control over your digital marketing exposure and receive rewards for interacting with our partners (providers). This is possible due to the structure of our service, which is based on only first party data, server site functionality, and not third party functionality or added networks. This privacy-friendly set up is managed from Norway and delivered from within the European Economic Area (EEA), where the EU General Data Protection Regulation (GDPR) applies.
If you have any questions about the privacy policy or any other questions regarding our privacy practices, please contact us at [email protected].
1. In what use cases do we process your personal data
A) Product our clients use with their end users (white label service) - such as you
- i) Landing pages - We provide SMOC landing pages as conversational flows that are shown to you. Methods for accessing this can be any channel - direct traffic, search, email links, QR code, Social Media and advertising ads.
- ii) Page embeds on client pages - Our clients can embed SMOC conversational flows into their landing and web pages that are shown to you. These pages are then presented to clients. Methods for accessing these pages are as i) above.
- iii) Advertising landing pages - Based on i) and ii) for click through banner ads among publishers and social media.
B) As an ad product our clients uses embedding the conversation in an ad channel
- Done by embedding the conversational flow as an ad in the publishers channel. Typically the embed happens by HTML5 technology.
- The flow stays on the site of the publisher, but links to our clients’ pages may be served to you as part of the flow.
C) When you enter our site (smoc.ai) as a business client
We process when you enter our site (smoc.ai) and consent to processing.
2. Why we process your personal data
Use case A: On behalf of our clients as a white label service we process your personal data for the purposes of
- providing you with rewards for your interactions
- to understand what products and services you prefer
- marketing of goods and services
- to provide support and improve our service
Use case Area B: In cases of embedding ads on 3rd party channels such as publishers we do not process personal data.
Use case Area C: For our direct business clients we process your personal data for the purposes of
- performing sales and marketing activities such as, sending direct emails and newsletters and other b2b marketing activities
- to process your application for employment in SMOC.AI
3. How we collect your personal data
As stated we only collect personal data in use case areas A and C. In C, we do not process personal identifiable data (PII).
On behalf of our clients as a white label service we collect data during your dialogue with our platform. Choices you make, such as preferences, interests, as well as contact details and other details will be shared with us to ensure that we provide you with relevant content. We ask for your consent to access your personal data from third parties, and to share your personal data. You can always change your consents and stored details on your profile.
When you use our platform in relation to another provider (for example, your electricity provider), the new provider can also share your personal data with us. This is to identify you so that you can use the platform, make choices and receive your earned rewards from these providers.
You may choose to share data from other providers with us. If you do, we will process your personal data to offer you even better offers and rewards.
4. What personal data we collect and on what legal basis
When you visit the conversational flow as a white label service for our clients (Use Case area A), we collect the following information from your device:
IP address,
- date and time of the access,
- name and URL of the accessed file,
- browser type and version, and
- further information sent by the browser (such as your computer’s operating system, the name of your access provider, geographical origin, etc.).
We only process this data to ensure trouble-free connection to the website, comfortable use of our website, for evaluating system security and stability and for administrative purposes, unless otherwise stated in section 5 (cookies).
We collect user profiles as part of the interaction with our clients end users. We do not buy any third party data through cookies or similar to enrich the profiles.
We process your personal data based on
- your consent
- because processing is necessary to complete requests from you or fulfil our agreement with you, and/or
- legitimate interests
If you have specifically consented, we process personal data about your
- location - The granularity of location is based on us asking the user about their address. We are not collecting the user position from the browser or similar.
- gender
- age
- how often you want to and do interact
- data you shared with us from other providers
- contacts who have accepted your invitations
The above processing is based on your consent (GDPR art. 6 (1) a).1
Regardless of whether you have given us your consent, if you identify yourself with PII (such as email or phone number) in a client flow we may process personal data about
- your contact information
- rewards, to make it possible to give you rewards
- your interactions and preferences, such as your interests and answers to surveys
- which provider shared your data
- information about your device, such as screen size, performance and operating system
- your IP-address and session ID
- language
- reward history
- data on complaints and claims
- users you have sent a referral to, after they have logged in, to ensure that you receive your earned bonus if your referred friend completed the intended action (for example redeemed a coupon)
Processing of information about your interactions and preferences (profiling) is a core way we create value for you and provide the service. Being able to understand your preferences is necessary to improve our services and tailor our message to you.
See legal section below regarding your legal rights on your data according to GDPR.
The following processing is done at your request and/or is necessary in order to fulfil our agreement with you (GDPR art. 6 (1) b):
- provide you with an account and with rewards
- manage reward credit, collection and redemptions towards third parties providing the rewards
- managing the necessary profile information to handle the above
The following processing is done based on legal obligation (GDPR art. 6 (1) c):
- financial transactions required for our bookkeeping
- recording of safety logs
- related regulatory requirements
As our processing constitutes profiling, you are entitled to protest against the processing. If you do so, SMOC.AI must stop the profiling, and you will receive fewer and/or less suitable offers. See your rights section 9 below on how to do this.
Our processing is also of legitimate interest to us. Our interests are not outweighed by your privacy interests, as you provide us with information and because this information is likely to be only of moderate sensitivity, such as what brands or brand categories you prefer.
5. Marketing and use of cookies
5.1 What do we use cookies for and why?
When used in conjunction with our partners (use case area A & B), we use «cookies» and similar technologies on our digital channels only in order to sign in and hold a customer session. Such use is required to communicate over the network and provide the service, upon your explicit request.
Hereunder, information about your browsing device, software and your visit may automatically be collected by us. This information can include your IP address, browser type, domain name, internet provider, operating system, timestamp and the referring web page.
For business clients visiting our homepage (use case area C) or associated pages we use cookies to track their engagement with our pages and interest in our products in order to give the best possible sales and marketing experience. Business customers can opt out of this processing.
5.2 Pixels
Pixels are not stored on your computer, but invisibly incorporated into our web pages. They enable us to measure the performance of our services.
If you visit our social media pages or profiles, they will use cookies and process your personal information. More information about this processing and how they’re using cookies can be found in the respective social media’s pages about privacy and use of cookies.
For information about how to disable cookies on commonly used browsers, please refer to http://www.allaboutcookies.org/manage-cookies/index.html.
5.3 Trackers and cookies
For end users interacting with our technology for one of our providing clients in use case area B (ad embeds), we do not use cookies from external sources.
For end users interacting with our technology for one of our providing clients in use case area B (landing pages and own page embeds), we might use the following cookies to enable content.
| Name | Purpose | Optional? | Storage time | Recipients of data |
|---|---|---|---|---|
| Youtube | Track the views of embedded videos on Youtube pages. Also measure bandwidth, determining whether the user gets the new or old player interface | Yes | Please see youtube privacy overview |
For company users entering our website (Use case area C), the following trackers are used:
| Name | Purpose | Optional? | Storage time | Recipients of data |
|---|---|---|---|---|
| Google Analytics* | Analytics | Yes | Google Analytics | Please see Google Analytics Cookie overview |
| Hubspot | CRM & Analytcs | Yes | Hubspot | Please see Hubspot Cookie overview |
| Youtube | Track the views of embedded videos on Youtube pages. Also measure bandwidth, determining whether the user gets the new or old player interface | Yes | Please see youtube privacy overview |
(*) Our Google Analytics data is anonymized. No personal email address or username need be collected. IP addresses are generalized to prevent indirect identification of person. No personal data is therefore stored.
Data collected through cookies are only handled within EEA in infrastructure in in Ireland.
5.4 Opting out and Deletion of trackers cookies
When acting as white label service for clients (use case area A) and as embedded Ads (use case area B) we only use cookies for tracking your session and tracking for anonymous analytics. You can at any time go into your privacy settings in the browser that uses SMOC on your device to delete all associated cookies related to the domain smoc.ai. In order to delete trackers and cookies related to trackers mentioned in 5.3, please see the associated products deletion routine described under its pages (see link in table above).
Cookies used on our standard web site (Use case area C) can also be deleted as above. There is also an opt in / opt out popup that is shown to every new user. If you opt out, cookies will not be used. In order to delete trackers and cookies related to trackers mentioned in 5.3, please see the associated products deletion routine described under its pages (see link in table above).
6. How we share your data
We do not share your personal data unless strictly necessary. It is strictly necessary to share your contact data with the operator providing the reward in order to credit you with the rewards. This is the only way the operators can know you are entitled to the reward. We also anonymise your personal data and share the anonymous data with brand-owners, to give them insights about their markets.
7. Our storage of your personal data
The purpose of our processing determines for how long we store your personal data. We store your personal data as stipulated below:
| Data and purpose | Storage time |
|---|---|
| Data on visit at web pages, such as operating system, browser type and IP address. Purpose: To conduct the session and security reasons. | Duration of visit, and for [30] days |
| Data on financial transactions, such as storage of reward credits, payment of rewards. Purpose: To enable keeping of books and financial audits. | Five years after end of relevant financial year. |
| Data on complaints and claims, such as if you disagree with our payment of rewards. Purpose: To enable us to shed light on the case and defend us against claims. | Six months after the expiry of the limitation period for the relevant claim. |
| Data on your preferences and friends referrals, such as what drink and food you like, if you like to travel, gender (optional), where you travel (geographically). Purpose: To enable us to provide you with the best and most relevant offers and rewards. | For the period you use our service and for 30 days. We deem you to have stopped using our service if you delete your account, or has not used it in six months. |
| Data from our chat, message and setting history, such as when you consent to our request, withdraw a consent, tell us what you like. Purpose: To be able to document our agreements, your actions (for example consent) and understand your preferences better. | For the period you use our service and for six months. We deem you to have stopped using our service if you delete your account, or has not used it in six months. |
We protect the data with encryption and other security measures.
8. Joint Controllership
Some personal data is processed jointly with our partners. As there will then be two data controllers, we have divided the responsibility as follows:
SMOC.AI is acting processor for the following processing:
- Gathering and processing insights through interaction, including data from visits on web pages
- Assessing if end user is entitled to reward
- Securing that that data is handled in according to Operator settings.
- Data storage, management, governance, security and privacy of the customers data and derived insights and models.
- Reporting on the performance on the platform.
- Processing of data on financial transactions, such as storage of reward credits, payment of rewards.
Our partner is is acting processor for the following processing:
- Initial transfer of Personal Data from Operator to SMOC.AI
- Setting data sharing settings with other Operators acting on the SMOC.AI platform.
- Processing of complaints and claims.
See below in sec. 8 about the rights you may exercise towards anyone of us.
8. Your rights
According to Regulation (EU) 2016/679 (General Data Protection Regulation) you can request
- information about our processing of your personal data
- rectification of your personal data
- right to erasure of your personal data
- restriction of processing
- your data in a portable format
You may also object to the processing. To the extent our processing is based on your consent, you may withdraw your consent.
Requests to enforce your rights can be sent to [email protected].
9. Contact information
SMOC.AI AS
Email: [email protected]
Fritzners gate 19
0264 OSLO