Privacy Policy

Smartywak, is a product designed by Smartywak OÜ, and yes, we collect some Personal Data from our Users.

Policy Summary

Personal Data is collected for the following purposes and using the following services:

  • Access to third-party accounts
    • Facebook graph data (you don't have to login with Facebook, but we do track visitors for retargetting purposes)
      Permissions: About Me and Contact email
  • Analytics
    • Google Analytics (we do this because we need to know our audience so as to serve them better)
      Personal Data: Cookies and Usage Data
  • Contacting the User or Business
    • Contact Form
      Personal Data: email address, fullname
  • Displaying content from external platforms
    • Google Fonts (we use free fonts to design beautiful content plus we are cheap bustards!)
      Personal Data: Usage Data and various types of Data as specified in the privacy policy of the service
  • Hosting and backend infrastructure
    • Linode Hosting
      Personal Data: various types of Data as specified in the privacy policy of the service
  • Location-based interactions
    • Geolocation
      Personal Data: geographic position
  • Managing contacts and sending messages
    • Postmarkapp
    • Google Apps SMTP
    • Sendgrid

    Personal Data: email address, fullname
  • Registration and authentication
    • Personal Data: various types of Data as specified in the privacy policy of the service
  • User database management
    • Personal information is securely stored using MongoDB and Redis behind a Securely encrypted communication line
      Personal Data: Cookies, email address, Usage Data and various types of Data as specified in the privacy policy of the service

Further information about Personal Data

  • Push notifications
    Smartywak may send push notifications to the User
  • Analytics and predictions based on User's data (a.k.a. "profiling")

The Owner may use the Personal and Usage Data collected through Smartywak to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.

User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.

The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

Contact information

  • Owner and Data controller
    Smartywak OÜ
    Juhkentali 8-2
    Tallinn, Estonia

    Owner contact email:

Full policy

Owner and Data Controller

Smartywak OÜ
Juhkentali 8-2
Tallinn, Estonia

Owner contact email:

Types of Data collected

Among the types of Personal Data that Smartywak OÜ through the Smartywak application collects, by itself or through third parties, there are: Cookies, Usage Data, first name, last name, email address, picture, various types of Data and geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using any Smartywak product

Unless specified otherwise, all Data requested by Smartywak is mandatory and failure to provide this Data may make it impossible for Smartywak to provide its services. In cases where Smartywak specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by Smartywak or by the owners of third-party services used by Smartywak serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Smartywak and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Smartywak and Smartywak OÜ (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.


The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Access to third-party accounts, Analytics, Contacting the User, Displaying content from external platforms, User database management, Social features, Registration and authentication, Managing contacts and sending messages, Location-based interactions and Hosting and backend infrastructure.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Basic information

By default, this includes certain User’s Data such as id, name, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Contact email

Access the User's contact email address.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Access to third-party accounts
    This type of service allows Smartywak OU to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User.
    Facebook account access (Smartywak)
    This service allows Smartywak OU to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
    Permissions asked: About Me and Contact email.
    Place of processing: United States – Privacy Policy. Privacy Shield participant.
  • Analytics
    The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior. Google Analytics (Google Inc.)
    Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Smartywak, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    Personal Data collected: Cookies and Usage Data.
    Place of processing: United States – Privacy Policy Opt Out. Privacy Shield participant.
    Personal Data collected: Cookies and Usage Data.
  • Contacting the user
    Contact form (Smartywak)
    By filling in the contact form with their Data, the User authorizes Smartywak to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
    Personal Data collected: email address, name
  • Displaying content from external platforms
    This type of service allows you to view content hosted on external platforms directly from pages of Smartywak and interact with them.
    Google Fonts (Google Inc.)
    Google Fonts is a typeface visualization service provided by Google Inc. that allows Smartywak to incorporate content of this kind on its pages.
    Personal Data collected: Usage Data and various types of Data as specificed in the privacy policy of the service.
    Place of processing: United States - Privacy Policy. Privacy Shield Participant.
  • Hosting and backend infrastructure
    This type of service has the purpose of hosting Data and files that enable Smartywak to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Smartywak. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
    Linode is a hosting service provided by Linode, LLC.
    Personal Data collected: various types of Data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy; Privacy Shield participant.
  • For Financial Information
    Smartywak may ask Customers to enter credit card or account information in order to process orders for services placed with Smartywak. Financial information provided via its website is transferred over a secure connection via Stripe, a payment processing company based in United States of America. Smartywak does not collect this information and will not authorize the release of the information to anyone not directly involved in processing the transaction. This information may be encrypted and stored for logging purposes by Stripe.

    Credit card numbers are used by Stripe only for processing payments and are not used for any other purposes. Smartywak through Smartywak OU entered into a written agreement with Stripe and it will continue to enter into written agreements with third parties that provide credit card processing services. Smartywak will ensure that appropriate security and confidentiality measures are in place in safeguarding your personal data. Place of processing: United States (and Ireland for EU-based operations)- Privacy policy and Legal.
  • Location-based interactions Geolocation (Smartywak OU) Smartywak may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by Smartywak. Personal Data collected: geographic position. Managing contacts and sending messages This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
  • Sendgrid (Sendgrid) Sendgrid is an email address management and message sending service provided by Sendgrid Inc. Personal Data collected: email address, first name and last name. Place of processing: United States – Privacy Policy.
  • Registration and authentication By registering or authenticating, Users allow Smartywak to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, Smartywak will be able to access some Data, stored by these third-party services, for registration or identification purposes. User database management This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Smartywak OU, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Smartywak OU. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Smartywak OU.
  • The rights of Users Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following: Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
  • Details about the right to object to processing Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
  • How to exercise these rights Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
  • Cookie Policy
    Smartywak uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Smartywak or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities. Additional information about User's Personal Data In addition to the information contained in this privacy policy, Smartywak may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Smartywak and any third-party services may collect files that record interaction with Smartywak (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Smartywak does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Smartywak and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification of a natural person.

Usage Data
Information collected automatically through Smartywak (or third-party services employed in Smartywak), which can include: the IP addresses or domain names of the computers utilized by the Users who use Smartywak, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

The individual using Smartywak who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Smartywak. The Data Controller, unless otherwise specified, is the Owner of Smartywak.

Smartywak (or this Application)
The means by which the Personal Data of the User is collected and processed.

ServiceThe service provided by Smartywak as described in the relative terms (if available) and on this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User's device. It has nothing to do with the edible snack on most shelves.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to Smartywak, if not stated otherwise within this document.