SmartFlow Compliance Solutions, LLC (“SmartFlow”) Privacy Policy

SmartFlow Compliance Solutions believes it is your right to know what information we collect on our website (www.smartflowcompliance.com), how we use it, and what your options are for its use. Below you can find details about:

1) Privacy Policy
2) Use of Cookies
3) Personal Information You Provide and How It Is Used
4) Data Security
5) External Links
6) EU-U.S. Privacy Shield and the U.S.-Swiss Privacy Shield Framework
7) How Long SmartFlow Will Store Your Information
9) Changes to the Privacy Policy

1) Privacy Policy

This Privacy Policy applies to the SmartFlow Compliance Solutions website located at www.smartflowcompliance.com, and governs its data collection, usage, and services. This Privacy Policy discloses how we collect, protect, use, and share information gathered on our website.  When you visit our website, we log general data, such as your domain name, the name of the web page from which you entered our website, which pages you visit on our website, and how much time you spend on each page. We use this information to monitor use of and improve our website, as well as for internal analysis. In particular, we use IP addresses to analyze trends, administer the website, and gather information for aggregate use.  SmartFlow Compliance Solutions (“SmartFlow” “we” or “our") is owned and operated by QuatreWave, LLC.

2) Use of Cookies

Our website uses “cookies” to help personalize your online experience, such as recognizing repeat visitors. A cookie is a text file that is anonymously placed on your hard disk by a web page server. SmartFlowCompliance.com cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. We will not share or sell non-aggregated information contained within cookies with any third party. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website or receive some of our services.

3) Personal Information You Provide and How It Is Used

You can use our website without divulging any personally-identifiable information (PII), including your email address. Our website does not collect PII about you unless you expressly provide such information to us on a voluntary basis, for example, when logging into our support center or requesting more information to be sent to you about SmartFlow. We may also add the information you provide to our databases, subscriber lists, and/or contact lists. When you submit personal information to SmartFlowCompliance.com, you understand and consent to the transfer of your personal information across national borders and the storage and processing of your information in a country that may not provide privacy protections similar to those your country provides. SmartFlow does not rent, sell, or share personal information about you with third parties or nonaffiliated companies, except as required to meet lawful requests by public authorities, including to meet national security or law enforcement requirements.  To the extent third parties assist SmartFlow in the provision of this website or services offered on this website, those third parties have no independent rights to your data and have agreed via contract to adhere to this Privacy Policy.

SmartFlow’s accountability for personal data that it receives under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, SmartFlow remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless SmartFlow proves that it is not responsible for the event giving rise to the damage.

4) Data Security

To prevent unauthorized access to your personal data, maintain data accuracy, and ensure the correct use of information, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect through this website.

5) External Links

SmartFlowCompliance.com may provide links to external web sites for your convenience. The links and information these sites contain are not monitored by us and those sites are subject to their own privacy policies. We are not responsible for the content, accuracy, or practices of these sites, nor do we endorse these sites or content provided thereon.

6) EU-U.S. Privacy Shield 

SmartFlow complies with the EU-U.S. Privacy Shield and the Swiss-US Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively.  SmartFlow has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program and to view our certification page, please visit https://www.privacyshield.gov/

In compliance with the Privacy Shield Principles, SmartFlow is committed to resolving complaints about your privacy and our collection or use of your personal information.  EU or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact SmartFlow at:

SmartFlow Compliance Solutions, LLC
9465 Wilshire Blvd Suite 300
Beverly Hills, CA 90212-2612
P: +1-424-278-9990
F: +1 (424) 278-9980
info@smartflowcompliance.com

SmartFlow has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. 

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

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

8) How Long SmartFlow Will Store Your Information

We may keep your information as needed to provide you services. We may also retain and use your information as necessary to comply with our legal obligations, resolve disputes, prevent fraud and abuse, and enforce our agreements.

SmartFlow acknowledges that EU and Swiss individuals have the right to access the personal information that we maintain about them.  EU or Swiss individuals who seek access, or who seek to correct, amend, or delete inaccurate data, should direct their query to info@smartflowcompliance.com or by mail to the following address: Head of Customer Service, SmartFlow Compliance Solutions, LLC, 9465 Wilshire Blvd Suite 300, Beverly Hills, CA 90212-2612, USA. If requested to remove data, we will respond within a reasonable timeframe.

SmartFlow will provide an individual opt-out or opt-in choice before we share data with third parties other than our agents or before we use it for a purpose other than which it was originally collected or subsequently authorized.

If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.

9) Changes to the Privacy Policy

SmartFlow may make improvements or changes in the information, services, products, and other materials on the SmartFlow website at any time without notice. SmartFlow may modify this Privacy Policy at any time and such modifications shall be effective immediately upon posting of the modified Privacy Policy. Notification of material changes to this Privacy Policy will be provided by noting a new "updated" date in connection with the Privacy Policy link that appears at the bottom of each page.

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this Web site, please contact us.

Updated June 14, 2017