Privacy Policy

Effective date: 31 July 2026. Last updated: 31 July 2026. This policy applies to SMARTe Inc., its website at smarte.pro, the SMARTe web application at app.smarte.pro, and the SMARTe Prospector browser extension distributed through the Chrome Web Store (Item ID chmbpmgcdmieijfjglncokblanmgkcpl). 

SMARTe Privacy Policy

SMARTe Inc. (“collectively known as SMARTe”) is the world’s Data-As-A-Service platform for sales and marketing. We understand that you care about how information about you is used. This privacy policy describes how SMARTe manages personal information collected, received, or maintained. We collect information pertaining to businesses and business people (“Business Information”) and all other types of information through our website and other online services (the “Site”)., including the SMARTe Prospector browser extension (the “Extension”). 

At SMARTe Inc., we take utmost care to protect your privacy. This privacy policy pertains to the different means of how we collect your information and describes how your personal information is stored and treated. 

For residents of the State of California, please click here to find out more about your rights under the California Consumer Privacy Act of 2018 (“CCPA”).

SMARTe Prospector Browser Extension — User Data Disclosure 

This section describes, in full, the user data that the SMARTe Prospector browser extension collects, and how that data is used, handled, transmitted, stored, retained, shared and deleted. It is provided to satisfy the Chrome Web Store User Data Privacy policy and applies in addition to the rest of this privacy policy. Where this section conflicts with any other section of this policy, this section controls for data collected through the Extension. 

1. What user data the Extension collects 

The Extension collects only the categories of data listed below. It collects no other categories. 

  • Account and authentication data — the email address and account identifier of the signed-in SMARTe user, and a session authentication token issued by SMARTe. Collected when you sign in to the Extension. 
  • Extension usage and activity data — records of actions you take in the Extension, such as profile lookups performed, contacts revealed, records exported and credits consumed, together with timestamps. Collected to enforce subscription entitlements, meter usage and support billing. 
  • Website content you choose to submit — when you click the Extension on a supported business networking or company website page, the Extension reads publicly displayed business identifiers from that page (for example, person name, job title, employer name, company website and company location) and sends them to SMARTe so we can return matching business contact records. The Extension reads page content only on supported sites and only when you actively invoke it. It does not read page content in the background, and it does not read personal email, banking, health or other unrelated pages. 
  • Technical and diagnostic data — browser version, Extension version, operating system type, IP address, error and crash messages, and API response codes. Collected to secure the service, prevent abuse and diagnose faults. 

2. What the Extension does not collect 

  • Personal communications, including the contents of your email, messages or chats. 
  • Keystrokes, clipboard contents, screenshots, audio or video. 
  • Browsing history, or page content from sites the Extension does not support. 
  • Passwords or credentials for any third-party service. 
  • Financial account numbers or payment card data (payments are handled outside the Extension by our payment processor). 
  • Health data, biometric data, precise geolocation, or the special categories of data described in Article 9 of the GDPR.
     
  • Data from users we know to be under 16 years of age. The Extension is a business tool and is not directed to children. 

3. How the Extension uses the data (purpose) 

  • To authenticate you and maintain your signed-in session. 
  • To match the business identifiers you submit against the SMARTe database and return business contact records to you. 
  • To meter and enforce your subscription entitlements, credits and fair-use limits, and to invoice your organisation. 
  • To provide customer support that you request. 
  • To detect, investigate and prevent fraud, credential sharing, scraping abuse and security incidents. 
  • To diagnose faults and improve the reliability and functionality of the Extension. 

We do not use Extension data for advertising, for building advertising profiles, for determining creditworthiness or lending eligibility, or for any purpose unrelated to the single purpose of the Extension. We do not sell Extension user data, and we do not transfer it to data brokers or information resellers. 

4. Limited Use commitment 

Our use of data received through the Extension adheres to the Chrome Web Store User Data Privacy policy, including the Limited Use requirements. Specifically: (a) we use the data only to provide or improve the single purpose of the Extension — surfacing verified B2B contact and company data for the SMARTe user; (b) we do not transfer the data to third parties except as necessary to provide or improve that single purpose, to comply with applicable law, or as part of a merger, acquisition or sale of assets with notice to users; (c) we do not use or transfer the data for serving advertisements, including retargeting, personalised or interest-based advertising; and (d) we do not allow humans to read the data unless we have your affirmative consent for specific messages, it is necessary for security purposes or to comply with applicable law, or the data has been aggregated and de-identified. 

5. How the data is handled and transmitted 

  • All data transmitted between the Extension and SMARTe servers is encrypted in transit using TLS 1.2 or higher. The Extension makes no unencrypted network requests. 
  • The Extension communicates only with SMARTe-controlled endpoints (app.smarte.pro and api.smarte.pro) and the sub-processors. It does not send data to any other destination. 
  • Authentication tokens are stored in the browser’s extension storage on your own device and are cleared when you sign out or remove the Extension. 
  • Data at rest on SMARTe infrastructure is encrypted using AES-256. 
  • Access to Extension data by SMARTe personnel is restricted by role, granted on a least-privilege basis, requires multi-factor authentication, and is logged. 
  • The Extension contains no remotely hosted code. All executable code is contained in the package submitted to the Chrome Web Store. 

6. Where the data is stored, and for how long 

Extension data is stored on servers operated by our cloud infrastructure provider in the United States, with encrypted backups in the same region. Retention periods are as follows: 

  • Authentication session token — held on your device for the life of the session; deleted on sign-out, on session expiry, or when the Extension is uninstalled. 
  • Account and profile data — retained for the duration of your organisation’s subscription and for 90 days after termination, after which it is deleted or irreversibly anonymised. 
  • Usage and activity logs — retained for 24 months for billing, entitlement and abuse-prevention purposes, then deleted. 
  • Business identifiers submitted from page content — used transiently to perform the match and retained for no more than 30 days for support, quality assurance and abuse investigation, then deleted. 
  • Technical and diagnostic logs — retained for 90 days, then deleted. 
  • Records we are required by law to keep (for example, invoices and tax records) — retained for the period required by applicable law. 

7. Who the data is shared with 

We do not sell Extension user data. We share it only with the following categories of recipient, each under a written data processing agreement that limits them to processing on our instructions: 

  • Cloud hosting and storage — to host the application and store data (United States). 
  • Product analytics and error monitoring — to measure feature usage and capture crash diagnostics; configured to exclude page content. 
  • Customer support and ticketing — to handle support requests you raise. 
  • Payment processing — to process subscription payments. SMARTe does not store full payment card numbers. 
  • Your own organisation — if you access SMARTe under an employer or company licence, your organisation’s administrators may view your account details and usage logs. Raise any questions about internal access rights with the appropriate person at your company. 
  • Legal and safety recipients — as described under “Disclosures for Legal Reasons” below. 
  • A successor entity — as described under “Disclosures to a Buyer of the Company” below. 

A current list of our sub-processors, including entity names and processing locations, is available on request at privacy@smarteprivacy.com. We give notice of material changes to that list before they take effect. 

8. Permissions the Extension requests, and why

  • storage — to keep your session token and Extension preferences on your device. 
  • activeTab / scripting — to read publicly displayed business identifiers from the page you are viewing, only on supported sites and only when you click to invoke the Extension. 
  • host permissions for SMARTe endpoints — to send your request to SMARTe and return results. 
  • identity or cookies (where requested) — solely to establish and maintain your signed-in SMARTe session. 

We request the narrowest set of permissions needed for the Extension’s single purpose, and we do not use any permission for a purpose other than the one stated above. 

9. Your choices, and how to delete your data 

  • You may sign out of the Extension at any time, which clears the session token from your device. 
  • You may uninstall the Extension at any time from chrome://extensions, which removes all data the Extension stored locally. 
  • You may request access to, correction of, export of, or deletion of the personal data we hold about you by emailing privacy@smarteprivacy.com with “Extension Data Request” in the subject line. We verify the request and respond within 30 days, and in any event within the period required by applicable law. 
  • You may ask us to stop processing your data, or object to processing carried out on the basis of legitimate interests, using the same address. 

Individuals whose business contact information appears in the SMARTe database — as distinct from Extension users — may opt out of the database by emailing privacy@smarteprivacy.com, or by using the unsubscribe form at smarteprivacy.com/unsubscribe. 

10. Security incidents 

We maintain an incident response process and will notify affected users and, where required, the relevant supervisory authority of a personal data breach without undue delay and within the timeframes required by applicable law. Security concerns may be reported to privacy@smarteprivacy.com. 

11. Changes to this section 

If we materially change what data the Extension collects or how we use it, we will update this policy, revise the “Last updated” date above, and — where the change expands our use of previously collected data — obtain your consent before the change takes effect. 

12. Contact 

SMARTe Inc., 440 N Wolfe Road, Sunnyvale, CA 94085, United States. Telephone +1 (408) 834 8842. Privacy enquiries: privacy@smarteprivacy.com. 

SMARTe Website 

You may access and browse this website without revealing any of your personal information. However, while downloading any of our material which have been developed by our internal Subject Matter Experts OR while subscribing to our blogs/newsletters OR while filling in a demo request form, we may collect your personal information such as your name, phone number or e-mail id that may be necessary to help us provide better customer service and we maintain the highest levels of confidentiality pertaining to your information. 

This portion of the policy applies to the Website. It does not apply to any website of any third party, even if the third-party website links to (or is linked from) the Website; the data practices of the SMARTe Prospector browser extension are described in the section above. By accessing, using, and/or submitting information through the Website, you consent to the practices described in this policy with regard to the information collected thereby as described herein. If you do not agree with this policy, you must delete all cookies from your browser cache after visiting the website and refrain from visiting or using the website. 

How does SMARTe collect Website Visitor Information? 

To browse the Website only, you are not required to provide any personal information. However, we may gather non-personally-identifiable information. Similar to many commercial websites, we utilize “cookies” and other technologies to collect non-personally-identifiable information on visitors to the Website. Cookies allow web servers to recognize the computer used to access a website. Cookies store information accessed through your browser to streamline activities on related web sites, and make the online experience easier and more personalized. Information gathered through cookies and web-server log files may include information such as the date and time of visits, the pages viewed, IP addresses, links to/from any page, and time spent at a site. 

Information collected from Website submissions will be used for SMARTe’s internal business purposes, including its investigations, sales, and marketing. We may use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address. 

The website may include options for visitors to submit information to SMARTe, for example, to request a product demonstration, download an article, etc. Such forms may provide the option of submitting personal information, such as your name, job title, company, email address, or phone number. In addition, when submitting information on a Website, your submission will be associated with the IP address you are then using, which is automatically assigned to your computer by your Internet Service Provider. 

If you have visited any of the Website and would like to know what information, if any, SMARTe has about you and would like to correct such information or have it deleted, you may contact us at privacy@smarteprivacy.com. We respond to such requests within 30 days. If you do not want us to contact you via phone, you can email us at privacy@smarteprivacy.com with “Do not call” as the subject line and we will opt you out. 

How does SMARTe collect Customer Information? 

Visitors to our Site may choose to submit their name, email address and/or other information so that they can learn more about our services, register to take part in a SMARTe-sponsored event, or participate in a survey, contest or sweepstakes, among other things. 

In order to use SMARTe products and services, you may be required to register as a user. From time to time, we may use your email address to send you information and keep you informed of products and services in which you might be interested. You will always be provided with an opportunity to opt out of receiving such emails. Your contact information may also be used to reach you regarding issues concerning your use of our Site, including changes to this privacy policy. 

You may be a user that has been provided access to SMARTe’s solutions through your company license agreement. Your employer may require that one or more users have global rights to access any and all information of every user that has access through the company. If you have questions or concerns regarding the rights of other individuals in your company to access your User Information, Uploaded Information, or Usage Logs, you should raise those concerns with the appropriate person at your company. 

SMARTe gives you an option of buying subscription to SMARTe’s solutions via your Credit Card. We will use that information solely for the purpose of fulfilling your purchase request. We will store credit card information in an encrypted form and will not sell, share or use it again without your prior consent. (The only exceptions are described in the sections below on “Disclosures to Service Providers,” “Disclosures for Legal Reasons,” and “Disclosures to a Buyer of the Company”). 

How does SMARTe Use Customer Information? 

Customer Information may be used for SMARTe’s legitimate business interests in connection with your use of the Services, including to respond to user inquiries and fulfill user requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Services. We may use Customer Information to better understand our users in general and to improve the content and functionality of the Services. We may use Customer Information to contact you in the future to tell you about services, promotions, opportunities, and other general information about SMARTe we believe will be of interest to you. We may use Customer Information to investigate and prosecute potential breaches of SMARTe security or license agreements. 

SMARTe will not disclose Customer Information to any third party except in connection with a legitimate use as set forth herein, in connection with a bona fide legal dispute to which such information is relevant, in response to valid, compulsory legal process, or as otherwise required by law. SMARTe will, whenever possible, obtain confidentiality agreements from any person or entity to whom Customer Information is disclosed and ensure any recipients are committed to employing appropriate technological security measures. 

SMARTe employs reasonable technical, administrative and physical security and back-up procedures to protect Customer Information, including encryption in transit (TLS 1.2 or higher) and at rest (AES-256), role-based access control, multi-factor authentication for administrative access, and access logging. No method of transmission or storage is completely secure; we encourage our users to retain copies of all Uploaded Information on their own system. Nothing in this paragraph limits any right or remedy you have under applicable data protection law. 

SMARTe will use Payment Information solely for the purpose of fulfilling purchase requests. We will store Payment Information in an encrypted form and will not sell, share, or use it again without prior consent. 

How does SMARTe get the Business information for its Products? 

“Business Contact Information” means any of the following information as used in connection with an individual’s business or profession: Name, Title, Company Name, Business Email Address, Business phone number, Work address, Public professional profile address, and/or supplementary information such as business role and responsibility designations. 

Using next-generation focused crawling, SMARTe builds profiles of business people and companies, which we call “Contacts” from different sources including Corporate Websites, Annual Reports, Social Networks, Tradeshows, Conferences, User Groups, Publications, Associations, News Releases, Technical Papers, List Directories, Communities, Blogs, Press Releases, Company Reports, Trade Magazines, Journals, Newsletters, Professional and Social Networking Sites and Search Engines, etc. 

Once we have collected business Information about a person or company, we combine multiple mentions of the same person or company into a CONTACTS. The resulting master of Contacts (the “MASTER”) is then made available to the users of the Site and our customers and strategic partners. 

SMARTe Products and Services 

SMARTe collects information regarding companies and their employees, including Business Contact Information on company executives, decision makers, and other employees. The information collected is like that which is typically included on online professional profile, a business card, or business email signature etc. including: name, company name, job title, business email address, business phone number, business address, and corporate website URL. SMARTe gathers, verifies, and organizes this data for purposes of licensing such information to SMARTe clients and strategic partners for sales and marketing purposes. 

SMARTe obtains data for its database from web crawling, first-hand research including telephone interviews, publicly available resources, and third-party licensors. All the business contact information that SMARTe obtains through any of the foregoing means is verified by SMARTe’s technologies and in-house research team, and information that is found to be inaccurate or irrelevant to the purposes of the Services is removed and deleted. SMARTe endeavors to publish highly accurate business contact information on influencers and decision makers and other agents and employees of the companies it profiles. 

The General Data Protection Regulation GDPR For EU Residents 

Our data operations are guided by the principles of global privacy laws, ensuring respect for individual privacy rights. As part of our commitment to these principles, we regularly send opt-out notices to individuals in our database, offering them the opportunity to have their information removed from our master database in accordance with global privacy regulations. We are committed to adhering to the key principles outlined in Article 5(1) of the General Data Protection Regulation (GDPR). 

We operate in a dual capacity: 

Data Processor: We act as a data processor specifically for the user data managed within our app. This involves handling user data according to our users’ instructions and in compliance with relevant data protection laws. 

Data Controller: We act as a data controller for the master data we aggregate. This includes collecting, storing, and using master data independently, determining the purposes and means of processing this data. 

SMARTe complies with the recent GDPR regulation by processing data along the GDPR norms. Under GDPR there are six grounds to process personal data, these are equally valid. There are two of these which are relevant to our business (direct B2B marketing) they are: consent or legitimate interest. As Recital 47 of the GDPR states that “The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.” Using legitimate interest as the basis for B2B marketing involves ensuring key conditions are met: 

“The processing must relate to the legitimate interests of your business or a specified third party, providing that the interests or fundamental rights of the data subject do not override the business’ legitimate interest.” 

“The processing must be necessary to achieve the legitimate interests of the organization.” 

Along with the above compliance, SMARTe DOES NOT share personal data with customers / partners, RECORDS all data processing activities, DON’T SOURCE any sensitive information such as religion, political inclinations, gender, age etc., has an EXPLICIT OPT-IN, OPT-OUT process and is proud to be operating for over 15 years without any data breach. 

As a ‘data processor’, SMARTe Inc. follows the following data privacy requirements honoring the GDPR law (Article 13 and 14). SMARTe provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten. 

SMARTe informs individuals about the collection and use of their personal data, retention periods for the data, and who it will be shared with. Our retention periods are set out in the “Where the data is stored, and for how long” section above; for records in the master database, we retain Business Contact Information for as long as it remains accurate and relevant to the Services and delete it on verified opt-out request or when it is found to be inaccurate. This is a key transparency requirement under the GDPR, provides privacy information to individuals at the time of collecting their personal data. When SMARTe obtains personal data from other sources, we provide individuals with privacy information within a reasonable period of obtaining the data and no later than a month. If any EU resident information is sourced in SMARTe database then SMARTe will provide such individual with a notice detailing the information SMARTe has on such person, the purpose for which it will be used, and informing such person of their rights with respect to such information, including the right to know what information SMARTe possesses on them, to correct such information, or to opt out of data collection entirely. Such persons may opt out of the SMARTe database by emailing privacy@smarteprivacy.com. 

Information we provide to people is concise, transparent, intelligible, easily accessible, and in clear and plain language. We conduct regular review, and where necessary, update our privacy information. If there are any new uses of an individual’s personal data, we make sure to bring it to their attention before we start processing. 

International Data Transfers 

Personal data collected through the Site and the Extension is processed in the United States and may be accessed by our personnel and sub-processors in India for support, research and engineering purposes. Where we transfer personal data out of the European Economic Area, the United Kingdom or Switzerland, we rely on the EU-U.S. Data Privacy Framework and its UK Extension and the Swiss-U.S. Data Privacy Framework as described below, and, where the Framework does not apply, on the European Commission’s Standard Contractual Clauses together with supplementary technical and organisational measures. 

Disclosures of Public Profiles 

We may make any Business Information that our users contribute for inclusion in our Directory, that we collect from public web sources or that we license from third parties available to users of the Site, to our strategic partners and to our customers. 

Disclosures to Service Providers 

SMARTe may from time to time disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose. Each service provider acts under a written data processing agreement that restricts it to processing on our instructions, requires appropriate security measures, and prohibits onward disclosure. A current list of sub-processors is available on request 

For example: 

SMARTe uses service providers to process credit card payments on our Site. When you use a credit card to pay for SMARTe services, information such as your name, billing address, phone number, email address and credit card Information will be submitted to service providers for verification and to manage any recurring payments. 

SMARTe uses software hosted by a service provider to provide us with information regarding our visitors’ activities on our Site. When you visit our Site, that service provider may set cookies on our behalf and may receive information about your browsing activity on our Site. 

Disclosures for Legal Reasons 

We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property or safety of SMARTe, its users or the public, or (iv) to allow SMARTe to exercise its legal rights or respond to a legal claim. 

Disclosures to a Buyer of the Company 

If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to SMARTe may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. 

Other Disclosures 

SMARTe Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SMARTe Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. SMARTe Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To view SMARTe Inc.’s certification, visit the Data Privacy Framework List: https://www.dataprivacyframework.gov/list. To learn more about the Data Privacy Framework (DPF) Program, please visit: https://www.dataprivacyframework.gov/ 

Choice for Swiss & UK Individuals 

We do not collect or process “sensitive” personal data for our services. Swiss and UK individuals may opt out of (a) our disclosure of their personal data to any third party not acting as our agent, and (b) our use of their personal data for a purpose that is materially different from the purpose for which it was collected or subsequently authorized. To exercise your choices, email privacy@smarteprivacy.com with “DPF Choice” in the subject line. 

Access for Swiss & UK Individuals 

Swiss and UK individuals have the right to access personal data we hold about them and to correct, amend, or delete it where it is inaccurate or processed in violation of the DPF Principles (subject to limited exceptions). To submit a request, email privacy@smarteprivacy.com with “DPF Access Request” in the subject line. We respond to access requests within 45 days. 

Complaints, DPAs/ICO/FDPIC, and free recourse 

Independent Dispute Resolution and Cooperation with DPAs. In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, SMARTe Inc. commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. We will respond to complaints within 45 days and provide, at no cost to the individual, an independent recourse mechanism capable of investigating and resolving complaints and disputes. 

Binding Arbitration (Last Resort). Under certain conditions, individuals may invoke binding arbitration for unresolved complaints about our compliance with the DPF Principles. 

Onward Transfer Liability 

SMARTe Inc. remains liable under the DPF Principles for the processing of personal data it transfers to a third-party agent if that agent processes such personal data in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage. For transfers to third-party controllers, we comply with the Notice and Choice Principles. 

SMARTe Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). 

Changes to This Privacy Policy 

We may update this privacy policy from time to time. When we do, we will revise the “Last updated” date at the top of this policy and, for material changes affecting how we use previously collected personal data, we will provide notice through the Site, the Extension or by email before the change takes effect. Prior versions of this policy are available on request to privacy@smarteprivacy.com. 

Contact 

SMARTe Inc., 440 N Wolfe Road, Sunnyvale, CA 94085. +1 (408) 834 8842. Privacy enquiries and data subject requests: privacy@smarteprivacy.com. Unsubscribe: smarteprivacy.com/unsubscribe.