We hereby inform you that SmartProbashi Ltd. present Privacy Policy applies to the use of all SmartProbashi services offered through the Website, through online and offline mobile devices, and through the desktop application.
The present Privacy Policy also details how we handle and process your data when you access our website and when you give us your personal data through the available forms.
In order to provide clear and transparent information, we have created different sections in accordance with the data that is processed:
These sections detail the purposes for which we process your data, for how long we will have access to and process your data, with whom we are able to share it, what your rights pertaining to said data are, and additional relevant
information, in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement
of such data (the "European Regulation" or "GDPR"), and the current Organic Law on Data Protection in Spain (LOPD).
For the sake of clarity, the General section applies to all users of our Website and provides a general
outline of our data processing policy for those cases not included in the abovementioned specific sections.
Finally, and before proceeding to the specific sections, we hereby inform you that all of them are subject to the following Security Policy. Moreover, all sections, with the exception of the SmartProbashi Platform that has
its own specific content, are subject to the “Rights of the Data Subject” part below.
SmartProbashi Ltd. has adopted the necessary security measures to ensure compliance with article 32 of the GDPR. In this sense, SmartProbashi Ltd. has established all technical and organizational measures to ensure a level of security
appropriate to the risk, taking into the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms
of natural persons.
In any event, SmartProbashi Ltd. commits to implement measures to:
We inform you that you have the right to request SmartProbashi Ltd. to confirm if it is processing your personal data. You have the right to access your personal data, the right to request the rectification of incorrect data, or to request us to erase unnecessary data at any time. You may also request the portability of your personal data and restrict its use. In said even your data will only be held for the purpose of exercising or defending claims. Under certain circumstances, or personal reasons, you may object to processing of your data. In said event, SmartProbashi Ltd. will refrain from processing your data unless for legitimate purposes, or for the purpose of exercising or defending any potential claims. Said rights may be exercised by sending a letter to SmartProbashi Ltd. at [email protected]. Identification may be required (national identity card, passport or equivalent) to prove your identity.
SmartProbashi Ltd. reserves the right to modify the present Privacy Policy at any time, and, when required to do so by law, we will inform you of those changes. In the event substantial changes are made, we will notify you of the update in advance, via email or through our SmartProbashi platform.
SmartProbashi
SmartProbashi Ltd.
Plot#68 (Old 45), Block H, Road 11,Banani, Dhaka 1213
Email: [email protected]
SmartProbashi Ltd. is only responsible as per the processing of the contact information and invoicing data of its Clients.
As per the Data, as this term is defined in the General Terms and Conditions of Contract and Use set forth by SmartProbashi Ltd. ( and for your convenience, detailed in sections b) to e) below, all included), SmartProbashi Ltd. is the Data Processor. As such, SmartProbashi Ltd.’ responsibility is limited to comply with mentioned General Terms and Conditions and, where appropriate, with any specific Data Processing Agreement entered into.
By means of the acceptance of the present Privacy Policy, the Client and User accept and expressly consent to the collection, use, processing and, where appropriate, transfer of data to third parties, in accordance with the terms stated herein.
For the avoidance of doubt, references to SmartProbashi Ltd. or SmartProbashi shall be understood to be made to any of the companies within the SmartProbashi’ group, in case the Services are directly contracted to one of them.
Categories of data that we process:
The Client and, where appropriate, the User may unsubscribe for the features detailed in point c) above, through the personalized settings on the application or by contacting SmartProbashi Ltd. The Client may also activate new features by contacting SmartProbashi Ltd. to request a quote. The Client is responsible for informing their users of any changes.
The aforementioned data shall be processed by SmartProbashi Ltd for the following purposes:
SmartProbashi Ltd. will store and keep the Data during the provision of our Services. Upon termination of Services, SmartProbashi Ltd. will store all Data for a period of thirty (30) days. Further to this period, we will block all
necessary data so that it cannot be directly accessed but it can be made available to Public Administrations, Judges and Tribunals in the event of any subsequent claims, for the corresponding prescription period. Once the prescription
period has terminated, all data will be deleted and/or destroyed. Notwithstanding the aforementioned, Tritium SmartProbashi Ltd. may store anonymous data relating to the use of services for the purpose of quality control and
improvements.
In the event consent has been given to receive Newsletters and commercial information, SmartProbashi Ltd. will store client and/or user contact details, as the case may be, unless consent is revoked by the Client or User.
The SmartProbashi Ltd. solution/platform enables Clients to process the Data. For this reason, the legal basis for SmartProbashi Ltd. to act as Data Processor, is the need to render the Services according to our General Terms and Conditions of Use and Services (article 6.1 b) GDPR). Processing of Client and User contact details for commercial communications purposes is based on their express consent. Clients and Users may revoke their consent at any time by sending an email to [email protected]. They may also unsubscribe from Newsletters and commercial communications at any time by following the instructions indicated in each message.
SmartProbashi Ltd. may automatically collect certain data about Users when they access and use the SmartProbashi platform. Said information will not necessarily reveal the identity of the User but it may include user’s device information
such as: hardware model, devise ID, operating system, web browser (such as Firefox, Safari or Internet Explorer), MAC address, IMEI and IP address. As an example, SmartProbashi Ltd. may collect and store in its logs, user browser
data, language preference, geographical location (in a broad sense, i.e. country or city) and other technical data collected using Cookies, pixel tags and other technology that serves to identify your browser. For more information
please refer to our Cookies Policy at SmartProbashi Policy
In addition, when a Client and, where appropriate, a User submits a sign up form, we may collect data relating to geographic location, including continent, country, city, postcode and location.
The aforementioned data is collected and processed by SmartProbashi Ltd. for the following purposes:
This data may be collected directly or by means of third-party providers subject to our instructions and the corresponding Data Processing Agreement. The legal basis for the processing of all the aforementioned data is your express consent (article 6.1
a) GDPR).
SmartProbashi Ltd. will store this data for the duration of the aforementioned purposes unless you revoke your consent, as indicated in the “Rights” section below.
Our client’s personal data and all data listed above, can be shared with and communicated to SmartProbashi Ltd., a company domiciled in Dhaka Plot#68 (Old 45), Block H, Road 11,Banani, Dhaka 1213, all of them companies of SmartProbashi’ group, to the extent
necessary to fulfill purposes mentioned above. SmartProbashi Ltd. has entered into data processing agreements with those companies, which include standard data protection clauses.
In any case,
SmartProbashi Ltd. takes any and all appropriate measures to maintain the security of your personal data, both throughout the transmission of said data and at destiny, and as a group of companies, it guarantees compliance of
data protection regulation in force, including GDPR. Finally, our service providers may also process the aforementioned data and act as Data Processors under our specific instructions and in compliance with the corresponding
Data Processing Agreement, so SmartProbashi Ltd. can render the Services according to approved General Terms and Conditions of Contract and Use. Said suppliers provide ancillary services that are required to ensure the proper
provision of our services.
In the event any personal data processing needs to be subcontracted to a third party, SmartProbashi Ltd. shall communicate this in writing and at least one month in advance to our Clients, explaining
what data is being subcontracted and who the subcontracting party is, including relevant contact details.
As regards to our client’s personal data, if any, and users’ personal data, both, clients and users have the right to request SmartProbashi Ltd to confirm if it is processing their personal data. You have the right to access your
personal data, the right to request the rectification of incorrect data, or to request us to erase unnecessary data at any time. You may also request the portability of your personal data and restrict its use. In said even
your data will only be held for the purpose of exercising or defending claims. Under certain circumstances, or personal reasons, you may object to processing of your data. In said event, SmartProbashi Ltd will refrain from processing
your data unless for legitimate purposes, or for the purpose of exercising or defending any potential claims. Said rights may be exercised by sending an email to SmartProbashi Ltd at [email protected]. Identification may be
required (national identity card, passport or equivalent) to prove your identity.
As regards to Third-Party Data, as defined in the General Terms and Conditions of Contract and Use, the Client, as the Data Controller,
is responsible for managing all data subjects requests, especially when Third-Party Data includes special categories of personal data, with full indemnity for SmartProbashi Ltd.
We hereby inform you that any and all data supplied to us will be processed and used by SmartProbashi Ltd. for the purposes of processing your information request and providing you with the requested technological, operational or commercial data and information on SmartProbashi products and services, and those of its group entities, including, as the case may be, information about our new products and services or any possible promotions. Once expressly accepted by you, by activating the corresponding box, your data will also be used to send you the SmartProbashi Newsletter with sales, technological and industry news and updates, as well as periodical marketing campaigns related to SmartProbashi products and services.
SmartProbashi Ltd. will keep your personal data after receipt of your request unless you file a request to the contrary. This means that your data can be used throughout this period for the aforementioned purposes.
You are responsible for the lawfulness and veracity of data filled in in the correspondent form. The processing of your data is based on your explicit consent. Said consent for the processing of your data may be revoked at any time by sending an email to [email protected] You may also opt out of marketing communications at any time by following the instructions contained within each issued communication.
In any case, SmartProbashi Ltd. takes any and all appropriate measures to maintain the security of your personal data, both throughout the transmission of said data and at destiny, and, as a group of companies, it guarantees compliance of data protection
regulation in force, including GDPR.
Finally, our service providers may also process the aforementioned data and act as data processors under our specific instructions and in compliance with
the corresponding Data Processing Agreement. Said suppliers provide ancillary services that are required to ensure the proper functioning of our services and the fulfillment of purposes stated above.
We hereby inform you that any and all data supplied to us will be processed and used by SmartProbashi Ltd., for the purposes of processing your job application, for the provision of SmartProbashi services to you as an applicant, and, if applicable, to determine if your profile is a match for any other job opening within the SmartProbashi Group, as detailed below.
SmartProbashi will maintain a record of your personal data for a period of one (1) year further to receiving your application. This means that throughout this period we may use your data to contact you in the event a suitable position arises.
The processing of your data is based on your explicit consent. You may review or deactivate your candidate profile, or revoke your consent for the processing of your personal data, at any time by sending an email to [email protected]
We normally collect your data directly from you. However, in some cases, your data can be collected through third-parties. In such a case, we will inform you within a reasonable period of time, once your data is collected,
but no later than one (1) month from that date.
Data Processing
In the event of a request by a data subject, only information deemed strictly necessary for identifying and addressing its request shall be collected. Said information will be treated faithfully and
lawfully by SmartProbashi Ltd. Additionally, personal data may be collected for specific and legitimate purposes and will be processed according to such purposes. Data collected from each data subject will be appropriate, relevant
and non-excessive in relation to the corresponding purposes for each case, and information will be updated whenever necessary. The data subject will be informed, prior to the collection of their data, of the general terms of
the present Policy so that they can provide their express, precise and unequivocal consent for the processing of their data, in accordance with the following aspects.
The explicit purposes for which data is processed are detailed in the informative clauses (Basic Data Protection Information) included in each of the data collection channels (website forms, paper forms, conversations, notices or informative messages).
Notwithstanding, personal data shall only be processed in order to provide an effective response to data subject requests, as specified in the form or data collection system used. If the data subject has expressly provided
consent by activating the corresponding box, their data will also be used to send a) SmartProbashi Newsletters with sales, technological and industry news and updates, and b) periodical marketing campaigns related to SmartProbashi
products and services.
In general, prior to the processing of personal data, SmartProbashi Ltd. must obtain express and unequivocal consent from the data subject by means of the consent clauses incorporated in the various data collection systems.
Notwithstanding, in the event User consent is not collected, the legal basis for our processing of data will be a specific law or regulation authorizing or requiring access and processing of such data by us.
You are responsible
for ensuring the veracity and lawfulness of all data included in the form. You may revoke your consent at any time by sending an email to [email protected]. You may also unsubscribe for commercial communications at any time
by following the instructions indicated in each message.
As a general rule, personal data is always collected directly from the interested party. However, under specific circumstances, data may be collected through third-parties. In said event, we will inform the interested party in
a timely manner once data has been obtained and within one (1) month at the latest.
SmartProbashi Ltd. may automatically collect certain data about Users when they access the SmartProbashi corporate Website. Said information may not necessarily reveal the identity of the website user but it may include information
about operating system version, web browser (such as Firefox, Safari or Internet Explorer) and geographical location, including, continent, country, city, postal code and specific location.
This data is collected and processed by SmartProbashi Ltd. for following purposes:
This data may be collected directly or by means of third-party providers subject to our instructions and the corresponding Data Processing Agreement. Said third-party providers are located both in and outside of the EU, in countries
with the adequate guarantees.
The legal basis for the processing of all data detailed in this section for the aforementioned purposes, is your express consent (article 6.1 a) GDPR).
SmartProbashi Ltd. will store this
data for the duration of the aforementioned purposes unless you revoke your consent, as indicated in the “Rights of the Data Subject” section included in the introduction of the present Privacy Policy.
Your data may be shared with and communicated to SmartProbashi Ltd. Ltd., a company domiciled in Dhaka Plot#68 (Old 45), Block H, Road 11,Banani, Dhaka 1213, to the extent necessary to fulfill purposes for which they have been collected. SmartProbashi Ltd. has entered into data processing agreements with those companies, which include standard data protection clauses. In any case, SmartProbashi Ltd. takes any and all appropriate measures to maintain the security of your personal data, both throughout the transmission of said data and at destiny, and as a group of companies, it guarantees compliance of data protection regulation in force, including GDPR. Finally, and as the case may be, our service providers may also process the aforementioned data and act as data processors under our specific instructions and in compliance with the corresponding Data Processing Agreement. Said suppliers provide ancillary services that are required to ensure the proper functioning of our services and the fulfilment of purposes stated above.