SMOC.AI Privacy Statement

This is the privacy statement (policy) of SMOC.AI. 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).

1. Why we process your personal data

We process your personal data for the purposes of:
- providing you with rewards for your interaction
- to understand what products and services that you prefer
- marketing of goods and services
- to provide support

2. How we collect your personal data

We collect data during your dialogue with our platform. Choices you make, such as preferences, interests, 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 awards.

3. What personal data we collect and on what legal basis

We process your personal data based on
- your consent
- because processing is necessary to complete requests from you or fulfill our agreement with you
- legitimate interests

If you have specifically consented, we process data about your
- location
- gender
- age
- how often you want to interact
- data you shared with us from other providers
- contacts who you have accepted your invitations

Regardless of whether you have given us consent we 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
- award history
- 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 how we create value and provide the service. Being able to understand your preferences is necessary to provide our services, and thus done at your request and/or in order to fulfill our agreement with you.

As our processing constitutes profiling, your 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.

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.

Based on the above, and given our risk mitigation measures, we base our processing of interaction on legitimate interest, necessity and consent as a legal basis.

4. Marketing and use of cookies

4.1 What do we use cookies for and why?

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.

4.2 Pixels

Some of our websites use Google Analytics pixels to help improve our digital communication.

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 Manage Cookies Article

4.3 Trackers and cookies

Name
Purpose
Analytics
Optional?
Yes
Storage time
Google Analytics
Recipients of data
  • 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.

4.4 Hubspot statement

Name
Purpose
Analytics & Customizing Browsing
Optional?
Yes
Storage time
Hubspot
Recipients of data

5. 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.

6. 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.


7. 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.

9. Contact information

SMOC.AI AS
Email: legal@SMOC.AI
Fritzners gate 19
0264 OSLO