PRIVACY POLICY

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PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICES

Smart Option Seller, LLC (“Company” or “we” or “us”), recognizes the importance of your privacy.  This Privacy Policy outlines the types of Personally Identifying Information we gather when you use any website made available by Company with this Privacy Policy (each a “Service”), and how we use that information, as well as some of the steps we take to safeguard it.  It is important to review this Privacy Policy in its entirety.

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When we provide the Services (free and/or paid), we gather certain pieces of information about the users (individually, “you” or a “User” and collectively, “Users”).  This Privacy Policy explains the types of information collected, what we do with such information, and how you may correct or change the information.

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The Information We Collect

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Information you Provide to Company.  We collect Personally Identifying Information that you provide to Company.  “Personally Identifying Information” is information that identifies you, and may include your name, physical address, phone number, and e-mail address, and any other information that would allow someone to identify or contact you.  Of course, if you do not provide us with Personally Identifying Information, we might not be able to provide you with the information or Services that you requested or that could be offered to you.

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Information We Collect Automatically When You Use the Services.  When you access or use the Services, we may collect information about you, including:

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·         Usage, System, and Log Data.  Your IP address, browser, and activity on the Service, including, but not limited to, date and times of use, clicks, page and profile views, and the amount of time you spend on each page.

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·         Data Collected Through Cookies and Similar Technologies. Like many online services, we use various technologies to collect usage data and store preferences. One such technology is called a “cookie”. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to understand how you interact with the Services and to monitor aggregate usage by our Users and web traffic routing on the Services.We may also create a unique device or User ID for you and store it in a cookie so we can recognize you and customize your experience based on your preferences.  Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies or to prompt you before accepting such a cookie.  Please note that removing or rejecting browser cookies might affect the availability or functionality of the Services.  We may also use web beacons as part of the Services.

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Using the Information

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Use in General.  We may use your information for a variety of purposes, including to:

·         Provide, operate, maintain and improve the Service;

·         Respond to your comments, questions, and requests and to provide customer service and support;

·         Conduct research;

·         Prevent potentially illegal activities;

·         Fulfill your requests through the Services;

·         Provide information relevant to you;

·         Send you promotional materials and information;

·         Monitor and analyze trends, usage, and activities in connection with the Services and for marketing or advertising purposes; and

·         For other purposes about which we notify you.

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Use of Aggregate or De-Identified Information.  In addition to using the Personally Identifying Information pursuant to this Privacy Policy, we may aggregate information about you and other individual Users together, or otherwise de-identify the information about you, so that the information does not identify you.  We may use information in these forms for a variety of purposes, including for research and analysis, administration of the Services, and advertising.

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Sharing and Disclosure of Information

 

We will not share Personally Identifying Information about you with anyone else except as described in this Privacy Policy:

·         Service Providers.  We may share your Personally Identifying Information with third-party vendors, consultants, and other service provides who are working on behalf of Company and who require access to your Personally Identifying Information to carry out that work.

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·         Compliance with Laws.  We may disclose your Personally Identifying Information to a third party if (1) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (2) to enforce our agreements, policies, or Terms of Use, and (3) to respond to an emergency which we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person.

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·         Business Transfers.  We may share or transfer your Personally Identifying Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

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·         Affiliates.  We may share your Personally Identifying Information with affiliates of Company for use as otherwise described in this Privacy Policy.

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Safeguards

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Company protects your Personally Identifying Information by using safeguards that are appropriate to the sensitivity of the information.  Unfortunately, neither the network nor data transmission over the internet can be guaranteed to be 100% secure. As a result, although we strive to protect a User’s information, Company cannot ensure or warrant the security of Personally Identifying Information or other information submitted through a Service. Thus, when a User transmits any information to us, that User does so at the User’s own risk.

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Online Tracking

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The Services do not respond to Do Not Track signals.  Third parties cannot collect Personally Identifying Information about you when you use a Service.

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Accountability and Compliance

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You may address any question regarding how Company complies with this Privacy Policy to the e-mail address set forth in this Privacy Policy.

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Third-Party Websites

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On occasion, “hyperlinks” connects the Services to other third party’s websites.  Please note that Company is not responsible in any way for the privacy practices of other websites and suggests that you review the privacy policies of those other companies’ websites before using them.

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Accessing Your Personally Identifying Information Once Given

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If you believe your Personally Identifying Information is inaccurate, you may contact Company to amend or delete your Personally Identifying Information.  You have the right to request information about the existence, use, and disclosure of your Personally Identifying Information and to challenge the accuracy and completeness of your Personally Identifying Information, and to have your Personally Identifying Information amended where inaccurate or deleted from the Company database.  To do so, simply e-mail Company at the e-mail address set forth in this Privacy Policy.  

 

Minors

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We do not intend the Services for people under the age of 13.  Further, we do not knowingly collect Personally Identifying Information from children under the age of 13.  If you are a parent or guardian of children under the age of 13 and believe that they have disclosed Personally Identifying Information to us, please contact us at the e-mail address set forth in this Privacy Policy and Company will delete that Personally Identifying Information.

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California Residents – Your California Privacy Rights

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Section 1798.83 of the California Civil Code permits residents of California to request from Company certain information about the disclosure of certain categories of information to third parties for the direct marketing purposes of those third parties.  The California legislature permits websites to comply with that statute by disclosing in the privacy policy or notice that the website permits consumers to choose, i.e., to opt in or opt out, regarding the sharing of personal information with third parties for direct marketing, as we do, and information on how to exercise that choice.

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If you are a California resident and you have questions about our sharing information with third parties for direct marketing and your ability to opt in or out, please send your request to us at the email address set forth under the “Contact Information” heading.  You must put the statement “Your California Privacy Rights” in the subject field of your email.  You must include your name, street address city, state and zip code.  We are not responsible for notices that you did not label or send properly, or lack complete information.

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If you are a California resident under 18 and a registered user of the Services, Section 22581 of the California Business and Professions Code permits you to ask that we remove content that you have posted publicly.  To make such a request, please email us with a detailed description of the specific content to be removed.  Please be aware that your request will not ensure complete or comprehensive removal of the content or information that you have posted and that in certain circumstances the law does not require or even allow removal even when requested.

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European Union General Data Protection Regulation (“GDPR”) Rights

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You may have certain rights under the European Union’s GDPR 2016/679.  Some of the GDPR is complex and we do not intend to provide every detail here.  Therefore you should read the GDPR and the relevant guidance provided by the applicable authorities for a fuller explanation.

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The GDPR provides the following principal rights: (a) to access, (b) to publication, (c) to erasure, (d) to restrict processing, (e) to object to processing, (f) to data portability, (g) to complain to a supervisory authority, and (h) to withdraw consent.

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The GDPR provides the right to confirm whether Company has processed one’s personal data and, when we do, access to that data, together with certain additional information, including the purposes of the processing, the categories of personal data concerned, and the recipients of those data.  Providing that we do not affect the rights and freedoms of other parties, we will supply you a copy of your personal data.  The first copy is free.  But we may charge a reasonable fee for additional copies.

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The GDPR provides the right to rectify any inaccurate personal data about you and, taking into account the purposes of the processing, to have any incomplete data about you completed.

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In some circumstances the GDPR provides you the right to erase your personal data without undue delay, including when the data are no longer necessary for the purposes for which they were collected or otherwise processed, if you withdraw your consent to consent-based processing, if you object to the processing under certain rules of the GDPR, if the processing is for direct-marketing purposes, and is the personal data have been unlawfully processed.  However, there are exceptions or exclusions to the right to erase, including where processing is necessary, for the exercise of free expression and information, to comply with a legal obligation, or to establish, exercise or defend a legal claim.

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The GDPR provides the right to restrict the processing of your data in some circumstances, namely, to contest the accuracy of the data, where the processing is unlawful but you oppose erasure, when we no longer need the data for the purpose of our processing but you require personal data to establish, exercise or defend legal claims, and you have objected to the processing pending the verification of that objection.  When processing has been restricted on this basis, we may continue to store your personal data.  However, we will otherwise process your data only with your consent, to establish, exercise or defend legal claims, or to protect another natural or legal person’s rights, or for reasons of important public interest.

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The GDPR provides the right to object to our processing of your personal data on grounds relating to your situation, but only to the extent that the processing is necessary for a task carried out in the public interest or to exercise any official authority vested in Company, or for legitimate interests pursued by Company or someone else.  If you object, we shall stop processing the personal information unless we can demonstrate compelling legitimate grounds to process the information that override your interests, rights and freedoms, or the processing is to establish, exercise or defend a legal claim.

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You may object to our processing of your personal data for direct marketing purposes including profiling for direct marketing purposes.  If you notify us of such an objection, we shall stop processing your personal data for that purpose.

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You may object to our processing of your personal data for scientific or historical research or statistical purposes on the grounds relating to your particular situation, unless the processing is necessary for a task carried out for reasons of public interest.

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If the legal basis for our processing your personal data is consent or that the processing is necessary to perform a contract to which you are a party, or in order to take steps at your request before entering into a contract, and such processing is carried out by automatic means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format.  But this right does not apply when its application will adversely affect the rights and freedoms of others.

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If you believe that our processing of your personal information infringes any data-protection laws, you may lodge a complaint with a supervisory authority responsible for data protection.  You may do so in the European Union member state of your habitual residence, your workplace, or the pace of the alleged infringement.

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To the extent that the legal basis for our processing of your personal information is consent, you may withdraw that consent at any time.  Withdrawal will not affect, however, the lawfulness of any processing before the withdrawal.

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You may exercise any of your rights in relation to your personal data by email to the address below.

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Consent to Transfer

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Please be aware that information we collect through the Service may be transferred to and processed in the United States, where the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.  By using the Services or providing Company with any information, you consent to transfer, processing, and storage of your information in the United States or such other countries as Company choose in its sole discretion.

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Changes to This Policy

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Please note this Privacy Policy is subject to change from time to time.  We will notify you of material changes to this Privacy Policy by either sending you an e-mail or by including a prominent notice of the change on a Company website or other applicable Service.  The effective date of each version of the Privacy Policy will be included in this Privacy Policy.  We will keep prior versions of this Privacy Policy in an archive for you to view for a reasonable period of time. 

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Contact Information

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If you want to contact Company about anything related to this Privacy Policy, please send an e-mail to support@smartoptionseller.com.

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Effective Date:    5/18/2018

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