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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).
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
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.
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.
4.1 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
4.4 Hubspot statement
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.
The purpose of our processing determines for how long we store your personal data. We store your personal data as stipulated below:
We protect the data with encryption and other security measures.
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 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.
According to Regulation (EU) 2016/679 (General Data Protection Regulation) you can request
You may also object to the processing. To the extent our processing is based on your consent, you may withdraw your consent.
SMOC.AI AS
Email: legal@SMOC.AI
Fritzners gate 19
0264 OSLO
