Privacy Policy
We at Smart Transfer (hereinafter "Smart Transfer"/"We") recognize that privacy is significant. We provide this Privacy Policy to inform users of the Smart Transfer application (the "Application" or "Applications"), about the related services we provide ("Services"), and the site about our policies and procedures regarding the collection, use, and disclosure of information.
Personal Data We Collect
We collect personal data from a variety of sources, including directly from you, the information generated during our relationship with you, and information from other sources, such as public databases and third-party services. This personal data may include information that can be used to identify you. We may also be required to collect certain personal data from you by law or as a part of our contractual relationship. If you do not provide this information, it may prevent us from fulfilling our obligations. When we collect your personal data, we will inform you if certain data is required and the consequences of not providing it.
Types of Data Collected
Categories of Personal Information that We Collect or Send
Among the types of Personal Information that the Application collects intentionally, by itself or through third parties, are:
- Audio files
- Music files
- Videos
- Calendar data
- Contacts
- Camera media
- Storage data
- Precise Location information
- Reminders
- Device ID
- Installed Apps
- Phone Numbers
- Contact Information: We may collect your email address or phone number. This information may be required to enter into an agreement with you, provide our services, and communicate with you effectively.
- Precise Location Data/Location Information: We may collect geographical information about where you interact with our Application using your computer and mobile devices. This information may be used to determine your general geographic location, comply with data protection regulations, and offer you content that is tailored, localized, and personalized.
- Device ID: We may collect data from your computer or mobile device, including hardware and software information (such as your operating system and browser type) and unique device IDs for Smart Transfer-enabled devices. This information is necessary to provide you with the best possible experience, ensure compatibility, and deliver updates to our services.
- Installed Apps: The Application may share information about installed apps as part of its features.
By using the Application, you acknowledge and consent to the collection, processing, and sharing of your personal information as described in this Privacy Policy. You also understand that you have the option to control certain permissions and choices related to your personal information through your device settings.
For any questions or concerns regarding our Privacy Policy or the handling of your personal information, please contact us at support@smarttransferapp.com.
Complete details on each type of Personal Data permission are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed before the Data collection. Personal Data may be freely provided by the user or, in the case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory, and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences of the service's availability or functioning.
This Application and any third-party services may collect files that record interaction with this Application (System logs) and use other Personal Data (such as the IP Address) for operation and maintenance purposes.
Device Permissions for Personal Data Access
Depending on the user's specific device, this Application may request certain permissions to access the user's device Data, as described below.
By default, the user must grant these permissions before the respective information can be accessed. Once the permission has been given, it can be revoked by the user at any time. To revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the document.
The exact procedure for controlling app permissions may depend on the user's device and software.
Please note that revoking such permissions might impact the proper functioning of this Application.
If the user grants any of the permissions listed below, this Application may process the respective Personal Data (i.e., accessed, modified, or removed).
Collect or Send Precise Location Data:
Smart Transfer will access your "Locations" to use a hotspot for data transfer.
Collect or Send Categories of Personal Data:
Smart Transfer will securely access the "Personal Data" categories selected to transfer to the other device.
Device ID Access/Collection Permission:
Smart Transfer will access your "Device" to use hotspot/Wi-Fi for data transfer.
Audio Access/Collection Permission:
Smart Transfer will access your "Audio Files" from Music Library to transfer them to the other device.
Calendars Access/Collection Permission:
Smart Transfer will access your "Calendars" to transfer it to the other device.
Camera Roll Access/Collection Permission:
Smart Transfer will access your "Camera Roll" to transfer pictures to the other device.
Contacts Access/Collection Permission:
Smart Transfer will access your "Phone Contacts" to remove duplicates and transfer the rest to the other device.
Photo Library Access/Collection Permission:
Smart Transfer will access your "Photo Library" to transfer pictures to another device.
Reminders Access/Collection Permission:
Smart Transfer will access your "Reminders" to transfer it to the other device.
Text Messages Access/Collection Permission:
Smart Transfer will access your "Text Messages" to transfer them to the other device.
SMS/MMS Access/Collection Permission:
Smart Transfer will access your "SMS/MMS" to transfer it to the other device.
Storage Access/Collection Permission:
Smart Transfer will access your "Storage" to transfer various types of media files to the other device.
How We Use Your Data and The Basis of Usage
We need to have your explicit consent to share your Personal Data. The user data accessed by the permissions are used to complete the direct transfer between two devices, and user data is not uploaded on our server at any time.
Subscription Options
The subscription options provided adhere to the terms outlined in the Apple End User License Agreement (EULA).
- Yearly Premium Access
- Monthly Premium Access
- Yearly Premium Access with Free Trial
- Monthly Premium Access with Free Trial
Users Have the Right to Know Whether Their Data is Sold
We may use your data for the following purposes:
- Identification and authentication: To verify your identity, create a profile for you, and ensure the security of your data when you register with us, access and use our services, or otherwise engage with us. This is necessary to provide the requested service.
- Contractual obligations: To fulfill our contractual obligations to you under our terms and conditions of use or to take steps at your request before entering into such a contract.
- Service operations: To provide the services you request, such as connecting you with other users. We may also use information about the other apps you have installed to provide the app's core functionality, a peer-to-peer transmission service.
- Service improvements: To analyze usage information, including site analytics, to continually improve the user experience.
- Communications: To provide information about changes to the terms and conditions, updates regarding our services, or responses to questions you pose.
- Advertising and marketing: To build a profile about you, understand your preferences, and determine which marketing materials would be of interest to you. Where the law requires, we will obtain your consent before sending such marketing materials.
- Exercising our rights: To exercise our legal rights where it is necessary, for example, to detect, prevent, and respond to intellectual property infringement claims or violations of law.
- Complying with our obligations: To carry out fraud prevention checks or comply with other legal or regulatory requirements when required by law.
- Customizing your experience: To improve your experience of the services, such as by providing interactive or personalized elements and content based on your interests.
We must have a legal basis to process your data as specified under applicable laws. In most cases, the legal basis will be one of the following:
Your consent, as outlined in this notice.
- To fulfill our contractual obligations, such as providing the services you request.
- To comply with our legal obligations, such as obtaining proof of your identity to meet fraud prevention and anti-money laundering obligations.
- Where permitted under applicable laws, to meet our legitimate interests, such as understanding how you use our services, developing new services, ensuring the stability and security of our services, preventing crime, fraud, and misuse of our services, providing non-personalized advertising, and improving user experience. When we process personal data to meet our legitimate interests, we put in place robust safeguards to protect your privacy.
- As required by law, such as obtaining your consent for direct marketing activities. You may withdraw your consent at any time by contacting us using the details provided at the end of this notice.
- As otherwise permitted under applicable laws.
How and When We Share Your Data
We may share your data as follows:
- With service providers and other third parties that perform marketing services and support our other business operations. These service providers may include cloud service providers, advertising agencies, and fraud prevention agencies, which will use your personal data only as described in this notice.
- Advertisers and third-party measurement companies show how many users of the app have clicked on an advertisement.
- With our affiliate companies, joint venture partners, and other partners or collaborators for processing, analyzing or storing your information or otherwise as needed to provide the services to you or achieve other purposes for which we collect information, in each case, consistent with the terms of this notice.
- With law enforcement agencies, courts, other government authorities (whether in your jurisdiction or abroad), or other third parties where we or any of our affiliates believe it is necessary to comply with a legal or regulatory obligation or otherwise to protect our rights or the rights of any third party.
- With potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. If such a sale or transfer occurs, we will use reasonable efforts to obligate the entity to which we transfer your personal data to use it in a manner consistent with this notice.
Users Have the Right to Know Whether Their Data is Sold
Our users have the right to know whether their data is being sold or shared with third parties. We are committed to being transparent about our data collection and usage practices and giving our users control over their data. We will always clearly disclose any instances in which we sell or share user data with third parties, and we will allow our users to opt out of such data sharing if they so choose. We are committed to protecting our users' privacy and only using their personal data in ways that align with their expectations and preferences.
How Users Can Opt Out of the Sharing and Selling of Their Data
As a company that values the privacy of its users, everyone has the right to opt out of allowing the sale of their data. We understand that personal data is just that - personal - and it is important for users to have control over how their information is used and shared. That is why we offer all of our users the option to opt out of allowing the sale of their personal data. This means that if you do not want your personal data to be sold to third parties, you have the right to request that we do not do so. Contact us through the appropriate channels, and we will ensure that your data is not sold. We are committed to respecting the privacy of our users and giving them the control they deserve.
(i) How to Opt Out of Targeted Advertising
At Smart Transfer, we strive to provide you with a personalized and relevant user experience. As part of this, we may use targeted advertising to display ads that are tailored to your interests and preferences. However, we understand that some users may prefer not to receive targeted ads.
If you wish to opt-out of targeted advertising, you can do so by following the instructions below:
Adjust Your Device Settings:
Most mobile devices and web browsers allow you to manage your preferences for personalized advertising. You can visit the settings on your device or browser and opt-out of ad tracking or reset your advertising identifier. Keep in mind that this may not completely stop all ads but will reduce the relevance of ads based on your interests.
Please note that even if you opt-out of targeted advertising, you may still see general advertisements that are not based on your specific interests or preferences. If you have any further queries, you can contact us at support@smarttransferapp.com.
(ii) How to Opt Out of Sale of Personal Data
Smart Transfer does not sell your personal data to third parties. We prioritize safeguarding your information and maintaining your trust. Therefore, you do not need to take any specific action to opt-out of the sale of your personal data, as this is not a practice we engage in. Refer to, “Users have the right to know whether their personal data is shared with third parties.” section of the Privacy Policy for more detail.
(iii) How to Opt Out of Profiling for Legal Consequences
At Smart Transfer, we understand the significance of transparent and fair data practices, especially when it comes to decisions that may have legal or similarly significant consequences for our users. We may utilize profiling techniques to ensure that our services meet your individual needs effectively. However, we also recognize the importance of providing you with the option to opt-out of such profiling processes.
If you wish to opt-out of profiling that may have legal or similarly significant consequences, please contact us at support@smarttransferapp.com, and our support team will guide you through the process.
International Data Processing and Transfer
Your personal data may be transferred, stored, and processed outside your jurisdiction, including in countries that may not have data protection laws that provide the same level of protection as your home country. This may include the United States and Hong Kong if you are an EU or UK-based user of the services.
We have implemented appropriate safeguards, such as contractual commitments, to protect your personal data in accordance with legal requirements. If you would like more information about these safeguards or to obtain a copy, please get in touch with us at the contact information provided below.
Retention Time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- In the case of Remote Sharing, we delete users' data after one day if it has been downloaded by the receiver or if it has not been downloaded at all.
- 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 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 consented 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 the expiration of the retention period.
Users have the right to know whether their personal data is shared with third parties.
Smart Transfer does not share your Personal Data/personally identifiable information with third parties. 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 processing their Personal Data.
- Object to processing of their Data Users has 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 the Owner is processing Data, 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. Under certain circumstances, Users have the right to restrict their Data processing. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Data been 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 the data is processed by automated means based on the user's consent, on a contract the user is part of or on pre-contractual obligations.
- Complain. Users can 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 official authority vested in the Owner, or for 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 Data be processed for direct marketing purposes, they can object to that processing 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.
Reference Rights Under the CCPA
The California Consumer Privacy Act (CCPA) gives California residents certain rights regarding their personal information. As a user of our services, you have the right to:
- Know what personal information we collect, use, and disclose about you.
- Request that we delete any personal information we have collected about you.
- Opt out of the sale of your personal information.
- Non-discrimination for the exercise of your CCPA rights.
Reference Rights Under the GDPR for Users in the UK
The General Data Protection Regulation (GDPR) gives individuals in the European Union certain rights regarding their personal information. As a user of our services, you have the right to:
- Access your personal information and receive a copy of it.
- Request that we rectify any inaccurate or incomplete personal information we have about you.
- Request that we delete your personal information.
- Object to the processing of your personal information for certain purposes.
- Request that we restrict the processing of your personal information in certain circumstances.
Reference Rights Under the VCDPA for Users in Virginia
The Virginia Consumer Data Protection Act (VCDPA) gives Virginia residents certain rights regarding their personal information. As a user of our services, you have the right to:
- Know what personal information we collect, use, and disclose about you.
- Request that we delete any personal information we have collected about you.
- Opt out of the sale of your personal information.
Reference Rights under the LGPD for Users in Brazil
The Brazilian General Data Protection Law (LGPD) gives individuals in Brazil certain rights regarding their personal information. As a user of our services, you have the right to:
- Access your personal information and receive a copy of it.
- Request that we rectify any inaccurate or incomplete personal information about you.
- Request that we delete your personal information.
- Object to the processing of your personal information for certain purposes.
- Request that we restrict the processing of your personal information in certain circumstances.
To exercise these rights, don't hesitate to contact us at support@smarttransfer.com. We will verify your identity before fulfilling your request.
Changes to this Privacy Policy
The Owner reserves the right to change this privacy policy at any time by giving notice to its Users on this page and possibly within this Application 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.
Contact Information of Our DPO:
Name: Aomata Data Dept
Email: dataprotection@smarttransferapp.com
Updated date: March 26 2024