SL4 Technology India private limited (hereby “SL4”, “Smartlinks”, “us” or “we”) operates the website located at www.smartlinkstech.com (“Site”). We are committed to protecting your privacy. This privacy & cookies policy (this “Policy”) explains how your information (as defined below) is collected, used, and disclosed by us and how we collect information through the use of cookies and related technologies. Smartlinks is primarily responsible for the operations of the platform solutions offered to its customers.

This policy also tells you how you can access and update your information and describes your data protection rights, including a right to object to some processing that we carry out or where we rely on consent, and how to withdraw that consent.

This policy applies to information we obtain from or about you in an online and offline context such as when you (i) visit our website at www.smartlinkstech.com and other locations where this policy appears (collectively, our “sites”) and use the Smartlinks mobile, cloud and other client applications (our “applications”), (together, our “platforms”); (iii) interact with our social media pages and adverts, customer support, online chats or community forums, surveys, webinars or blogs; (iv) participate in our training solutions or attend our events and demonstrations; or (v) interact with us as vendors, alliance partners, resellers, technology partners or other professional advisors. Certain sections may not be applicable to you depending on how you provide your information to us or interact with us.

By visiting the website, you agree to be bound by this privacy policy and other policies. If you do not agree please do not use or access the website. This privacy policy describes the information, as part of the normal operation of our services; we collect from you, and what may happen to that information. If we need or are required, to contact you concerning any event that involves your information we may do so by email, telephone, or mail as appropriate (and in accordance with your communication preferences).

Introduction and summary

This policy is intended to inform you about how we collect and use your information. Although we encourage you to read the entire policy, the following provides a summary of some of the important aspects of our privacy practices:

• We use your information primarily to provide you access to our platforms and other products, services, and information we offer.
• We combine or link information that we collect about you from our different interactions with you, both online (e.g., via our platforms) and offline (e.g. via our events or via calls to customer support).
• We share your information across our organization and combine the information we collect.
• We share your information with certain trusted third parties as outlined below.
• We take reasonable and appropriate measures to secure your information, but we cannot promise, and you should not expect, that your information will remain secure in all circumstances.

Information received, collected, and obtained by Smartlinks

The information we receive, collect, and obtain includes information that is both personal and non-personal. “personal” information is a broad concept and refers to any information relating to an identified or identifiable living individual. This includes references to obvious identifiers such as a name and also non-obvious identifiers such as an identification number or an online identifier such as an IP address or cookie identifier. “non-personal” information refers to information that is anonymous whereby you are not or no longer identifiable from that information.

We receive, collect, and obtain the following general types of personal and non-personal information (together, “information”):

Information obtained directly from you

We collect information about you directly when you voluntarily provide it to us through the platform or during other interactions with us. This information may include your name, contact information, gender, preferred language, job title, and function. We may also collect information about your access to the platform, use of the platform solutions, and other collaterals available for download on the website or any other information you may voluntarily provide (e.g., event feedback, profile photo, business card).

Information automatically collected about you

We automatically obtain information about you when you access our platforms. This includes (i) information about the devices you use to access the platforms including your device’s IP address, your browser type and version, time zone setting, operating system, and platform; (ii) information about your visit to our platforms including the URL clickstream to, through and from our platforms (including date and time); products and services you have viewed or searched for, your account activity (when logged in); the content (and any ads) you view or interact with, page response times, download errors, length of visits to certain pages and page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. Some of this information is collected using cookies and related technologies (see the section on cookies and related technologies below for more detail).

We do not share your information for commercial or marketing purposes unrelated to the sales, marketing, and delivery of Smartlinks’ products and services.

We also receive information you provide to our authorized resellers and alliance partners of our products and services. We may use this information for the purposes outlined in this policy. When you pay for our products and services, we get the information from our payment processing service provider, who will carry out credit and antifraud checks on you, and the payment method you provide to verify your identity, validate your credit or debit card, obtain an initial credit or debit card authorization, and/or to authorize the purchase.

To ensure data accuracy and offer you a better experience, we link or combine the information that we collect from the different sources and channels outlined above (e.g., to provide targeted communications and advertising and for the other purposes outlined below).

You do not have to provide personal information to access the platforms but certain functionalities (such as getting access to customer support or training) will not otherwise be available to you. You may however choose whether or not to receive marketing communications from us and we will only send you such communications where we have the appropriate consent to do so.

You should not provide personal information about anyone else unless you have their permission to do so and they understand how we will use their personal information as set out in this policy.

Collection of information by third parties.

The websites and services of third parties may be accessible through our website. You may be asked to provide information through these other sites or services. For example, when you click on a link on a site or application. These third parties maintain their own information privacy policies and practices.

This policy covers only information received, collected, and obtained by Smartlinks and does not extend to any third parties (including its authorised resellers or alliance partners. Smartlinks is not responsible for the policies or practices of any of these third parties). You should review the applicable privacy policies of the applicable third parties before providing them with any information.

Use of personal information by smartlinks and our lawful basis for processing.

We process your personal information through electronic and manual means for the following purposes:

To fulfil a contract or to take steps at your request linked to a contract. This includes:

• To administer and authorise your access to the applications, your accounts and other features, and functionality of the platforms;
• To process orders, provide our products and services, and send you service-related communications; and
• For customer support purposes, including responding to your queries and investigating any complaints about the platforms and our products and services;

As required to conduct our business and pursue our legitimate interests, in particular:

• To improve and personalize your experience with us and our platforms and to provide you with tailored content, advertisements, and communications both on our platforms, on our partner websites, and offline;
• To operate, support and maintain our platforms, conduct identity verification, authentication, and other fraud prevention or detection activities;
• To send you the information you have requested;
• To ask your opinion or to take part in market research or a survey;
• To monitor and improve the performance of our platforms, analyse trends, usage, and activities in connection with our services, and optimize our marketing efforts and measure the effectiveness of our advertising campaigns;
• For our own internal functions such as keeping our platforms secure, for management, corporate reporting, and record-keeping purposes, for internal research and analytics, for developing our products and services and improving business efficacies;
• To enforce compliance with our terms of use and other policies or otherwise in connection with legal claims, compliance, regulatory and investigatory purposes as necessary (including disclosure of such information in connection with legal process or litigation); to avoid injury to a third party, or to otherwise enforce or protect Smartlinks’ rights under applicable law, including, without limitation, Smartlinks’ intellectual property rights; and
• To create and aggregate statistical data (which cannot be used to identify you). For example, aggregate data may include data that describes the general demographics, usage, or other characteristics of a platform’s users. We reserve the right to transfer and/or sell aggregate and anonymous data about a platform’s users for lawful purposes.

Where you give us consent:

• Where you ask us to send marketing information via a medium where we need your consent.
• Where you give us consent to place cookies or similar technologies; and
• On other occasions where we ask for your consent, for the purpose we explain at the time.

As required by law:

• In response to requests by government or law enforcement authorities conducting an investigation.

Sharing of personal information by Smartlinks

We share your personal information with the following third parties:

• Alliance partners and technology partners for them to provide you with the applicable products and services.
• Service providers. We share personal information with third parties who process personal information on our behalf. For example, we use third parties to: (a) maintain and manage our database of information; (b) to host and maintain our platforms; (c) assist us with information collection; (d) provide analysis of our information; (e) to enhance or overlay our information with other information obtained from third parties; (f) to deliver, and provide information regarding the delivery of, electronic messages; or (g) provide other marketing services to assist us in our business. We require that these third parties agree to use the information we share with them only to perform their obligations to us and to treat all information they receive from us in compliance with this policy.
• Government authorities and law enforcement officials. We share personal information with these bodies if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

In the event that the business is sold or integrated with another business, your personal information will be disclosed to our advisers, any prospective purchaser and their advisers and will be passed-on to the new owners of the business.

Sensitive information

You are not required to provide us with any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, or other categories of information defined as sensitive, or special categories of data under applicable data protection laws (“sensitive information”) - to use our platforms and services. Smartlinks does not knowingly solicit or collect, and you should not provide to Smartlinks any such sensitive information, whether through the platforms or any other means.

Children

Our platforms are intended for a general audience and are not directed to children under 18 years of age. Smartlinks does not knowingly receive, collect, or obtain personal information from children under 18 years of age.

Do not track

Certain web browsers and other devices you may use to access the platforms may permit you to indicate your preference that you do not wish to be “tracked” online. At this time, we do not modify your experience on the platforms or the information we collect from you through the platform based on whether such a preference is indicated.

Cookies and related technologies

We and our third-party service providers use “cookies,” “web beacons,” and other automated tracking technology to monitor and collect information regarding your interaction with the platforms. “cookies” include commonly used pieces of information in the form of small files that are placed on an individual’s computer or mobile device to allow us to recognize your computer or mobile device. “Web beacons” (also known as “single-pixel” or “clear” gifs) include electronic images imbedded in a site, application or email used to pass information from your computer to us.

We may use cookies, web beacons, and other tracking technologies that expire once you close your web browser or that persist and stay on your computer until you delete them.

Disabling/enabling cookies

We require your consent for most cookies and tracking technologies that we use on our platforms. Most browsers will allow you to erase some or all of the cookies from your computer or mobile device, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain web beacons by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions. To find out more about these technologies, visit: www.allaboutcookies.org/manage-cookies. By rejecting or disabling certain platform content or functionality.

We use the following types of cookies of our platforms:

Strictly necessary cookies: These cookies are essential for you to use the platforms and its features, such as accessing secure areas of the sites. We have to use these cookies to make the platforms work as they should, whether or not you agree to use of such cookies.

Analytical / performance cookiesThese cookies collect information about how you use our platforms and services in order to enhance your performance and develop them according to the preferences of our customers and visitors. For example, cookies and web beacons may be used to:

• Test different designs and to ensure that we maintain a consistent look and feel across our platforms;
• Track and provide trend analysis on how you interact with our platforms and communications;
• Track errors and measure the effectiveness of our promotional campaigns.

The data collected will generally be aggregated to provide trends and usage patterns for business analysis, site/platform improvement and performance metrics. We may share our cookies, and the resulting analysis with our business partners. The type of information we collect includes how many visitors visit our websites, how many customers log in when they visit, for how long and which areas of our platforms and services but is generally not used to identify you directly. We also receive similar information about visitors to our partner websites. Smartlinks will provide you with a list the information of analytical / performance cookies used by our sites upon request.

Functionality cookies

These cookies allow the platform to remember you and provide enhanced customised features (e.g., language preferences). These cookies can also be used to remember the changes you have made to the text size, fonts, and other parts of the website pages you can customize. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites. Smartlinks will provide you with a list the information about functionality cookies used by our sites upon request.

Social media cookies

These cookies are used when you share information using a social media sharing button or “like” button on the website or engage with us on or through social networking websites such as Facebook, LinkedIn, or Twitter, which may link your use of our platforms to targeting/advertising activities. We do not control how these social networks use cookies. Interactions with these features are governed by the privacy policy of the company providing them. Smartlinks will provide you with a list the information about social media cookies used by our sites upon request.

Targeting/advertising cookies

These cookies are used to deliver advertisements more relevant to you and your interests on our platforms and on our partner websites. We conduct targeted advertising on our existing customer base and target other individuals who we think will be interested in our products and services. They are also used to limit the number of times you see an advertisement and help measure the effectiveness of the advertising campaigns. They allow us to understand and evaluate clicks on our adverts so that we can improve the service you receive. They are usually placed by advertising networks with our permission. They remember that you have visited a website, and this information is shared with other organizations such as advertisers. Advertisers and other third parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content are part of the group that the ad or content is directed towards. Smartlinks will provide you with a list the information about targeting/ advertising cookies used by our sites upon request.

Your rights and choices

Whenever we rely on your consent, you will always be able to withdraw that consent, unless we have another legal ground for processing your personal information. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests (and where other laws do not require consent).

You have an absolute right to opt out of direct marketing (including personalized marketing), at any time. You can opt-out of direct marketing by following the unsubscribe function in the communication or you can opt-out of direct marketing (including personalized marketing) by contacting contact@smartlinkstech.com. Even if you opt-out of marketing communications from us, please note that you may still be contacted with services related communications (such as account notifications and software upgrades).

While Smartlinks takes reasonable steps to ensure that the personal information we collect is reliable for its intended use, accurate, complete, and current, we rely on you to update and correct your personal information.

Additionally, in some circumstances, you have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine- readable format, and to ask us to share (port) this personal information to another controller. In addition, you can object to the processing of your personal information in certain circumstances.

These rights may be limited; for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information that is mandatory to keep as per the law, or if there are compelling legitimate interests in keeping the information. To exercise any of these rights, you can get in touch with us by emailing contact@smartlinkstech.com. If you have unresolved concerns, you may have the right to complain to the relevant data protection authority in your country of residence or place of the alleged infringement.

Retention of your personal information

Your personal information will be retained for as long as necessary to fulfil the purposes outlined in this policy or to comply with applicable legal requirements. For more information, please contact us using the details set out below.

Notification of changes

We reserve the right to make changes to our practices and this policy at any time. If we change the way we handle your personal information, we will update this policy and notify you as appropriate.

Security

Smartlinks is committed to protect and secure your personal information. Despite our commitment, no security system can be 100% effective and we cannot guarantee that your information will be secure in all situations. We will nonetheless take all reasonable and appropriate steps to ensure the safety and security of your personal information. This includes using at least industry-standard security measures to protect against the loss, misuse, and unintended alteration of the personal information under our control. For example, our policy is that only those individuals who need your personal information to perform a specific job for us are granted access to that personal information. Likewise, all employees and contractors are kept up-to-date on our security and privacy practices. Finally, the servers that we store personal information on are kept in a secure environment.

Transfer of personal information

To provide our products and services, we may transfer your personal information around the world, including the US, India, and other places which may have different data protection standards to those which apply to your country of residence. Much of your personal information is stored and supported on servers and systems in the US and India and accessed globally by Smartlinks personnel to the extent necessary for the purposes outlined in this policy.

Contact Information

sl4 technology India private limited

nos. 134 and 135, smartlinks, inspire workplace, Karthik Nagar, lrde layout,

Doddanakundi, Bangalore, ka 560037, India | CIN number: u74999ka2017ptc103399

contact@smartlinkstech.com