Privacy Policy

We are SmartGuide s.r.o. (“SmartGuide”), a company that turns every smartphone into a private multimedia guide through engaging content, interactivity and state-of-the-art technology. We fully respect your privacy. At the same time, we need to access some of your information, such as your location in order to provide you with the best guiding services and user experience. In the following text we explain what data we collect, how do we use it and what you can do.

Personal data are handled in accordance with applicable legal regulations concerning protection of personal data, in particular with General Data Protection Regulation (EU) 2016/679 (“Regulation”). SmartGuide is considered the controller for the purposes of the Regulation.

Company details:

  • SmartGuide s.r.o.
  • Company ID: 07254890
  • Tax ID: CZ07254890
  • Registered company address: Dopravní 500/9, 104 00, Praha 10, Czech Republic
  • Court registration: Commercial Register maintained by the Municipal Court in Prague, Section C, File 297779

This Privacy Policy applies to information that we collect about you when you use in particular:

  1. the SmartGuide mobile application ("Application") owned and developed by SmartGuide;
  2. our website at www.smart-guide.org, www.smartguide.cz or www.smartguide.app ("Website"); or
  3. our content management system ("CMS").

Information we collect about you

We only collect information about you if we have a reason to do so – for example, to provide our services, to communicate with you or to make our services better.

SmartGuide provides mainly two kinds of services: it delivers multimedia guides to users and it allows people to create multimedia guides. We collect different types of data for different purposes, depending on how you use our services.

Data collected if you use our Website

If you use the Website, your browsing history and information on your browser and your operating system is collected through Google Analytics. SmartGuide can use this personal information to suggest information to you; to analyze the use of the Website; and to protect, adjust and update SmartGuide's services.

When you visit our Website or use our Application, some information is automatically collected. This may include information such as the operating system (“OS”) running on your device, internet protocol address (“IP Address”) (which may be used to obtain your geolocation), access times, browser type, language settings of the OS and the website you visited before our Website. We also collect information about how you use our Website, including the elements you have interacted with, metadata and other details about these elements, clicks, change states and other user actions.

Data collected if you use our Application

If you want to use our Application to listen to multimedia guides, you can do so without creating an account.

The Application may offer the option to create a user account. If so, you will be asked to provide your personal details, such as name and email.

Some information is automatically collected when you use the Application, such as: your browsing and usage history within the Application, IP Address, browser type, your mobile device and OS.

The Application also collects precise information about the location of your device. It tracks your path, the places you visited and your interactions with the user interface. We use your location information to provide requested location services and learn your travel habits to provide you with tailor-made offers based on your requirements. We only collect photos, videos and comments you directly share with us via the Application.

SmartGuide may also process information collected via the Application to share aggregated information with certain content providers. It will, however, not be possible for content providers to identify particular users from this aggregated data.

If you use the in-app payment system to purchase content, the applicable platform provider (Google, Apple or Windows) will collect data on the payment in accordance with its privacy policy. SmartGuide will obtain from Google, Apple or Windows information on which content you purchased, and use this information to handle its payments to content providers.

Data collected through our CMS

As noted, it is also possible to upload multimedia guides and other information for publication via our CMS. In order to do so, you must create an account, which requires you to provide your name, email address where we can reach you and other personal details.

After logging in and registering as a so-called 'content provider' in the CMS you can submit additional information.

The main function of the CMS is to allow you to upload information. If the content you upload contains personal information of you, we assume that you agree to the processing of this information in line with this Privacy Policy. If you plan to upload personal information of others and there is a significant risk that permission would be required for the processing described in this document, please obtain permission for this.

If you use our CMS, your browsing history, IP Address, information on your browser and your OS is collected through Google Analytics.

SmartGuide can use this personal information to develop and offer content for our Application; to analyze the use of the CMS; to communicate with you about the CMS and to respond to any complaints and/or questions; and to protect, adjust and update SmartGuide's services.

Please note that most of the information you provide through the CMS, such as your name and the uploaded content, will be made publicly available mainly through our Application in the course of the publication of your contribution.

Access to your profile on the Website is only possible after entering your login and personal password. It is essential that you do not disclose your login information to third parties. SmartGuide does not assume the responsibility for any misuse of passwords.

Data collected for communicating with you

SmartGuide may process your e-mail address for the purpose of distribution of generic (non-personalized) commercial communications relating to SmartGuide own products and services (e.g., Website, Application or CMS) in case you did not decline such communications.

If you do not agree to this processing, please inform us via [email protected] and SmartGuide will not process your personal data for these purposes. Also, an opt-out option is provided in every e-mail that SmartGuide sends you.

SmartGuide may also use tools to create and present personalized offers (content that better matches your preferences and interests) based, for example, on your age group or geographical location. For this purpose, SmartGuide may use data of your purchase history or activity on the Website and within the App or CMS which contain information about browsing (including your activity on social networks, if allowed through cookies or similar technology). The processing of your personal data for the purpose of personalized (profiled) offers is carried out only on the basis of a consent; such consent may be revoked at any time.

How we use information about you

SmartGuide relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • provide, maintain and improve our services (for instance we cannot provide the services unless we collect and use your location information);
  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  • where necessary for the purposes of SmartGuide’s legitimate interests;
  • research and develop new services;
  • suggest information to you, i.e. send you technical notices, updates and other support and administrative messages (in particular on the basis of your location);
  • provide customer service or respond to any complaints and/or questions you might have;
  • communicate with you about SmartGuide and its products, services, offers, promotions and events or provide other news and information we think might be of interest to you;
  • monitor and analyze trends, usage and activities in connection with provision of our services (including by means of Google Analytics);
  • personalize the services and provide advertisements, content and features that match user profiles or interests;
  • keep the services safe and secure (i.e. to protect against fraud, spam and abuse etc.); and
  • where you have consented to the processing, which you can revoke at any time.

How we share information about you

We do not sell your private personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

  • Subsidiaries, employees, and independent contractors. We may disclose information about you to provide products and services to you to assist those who help us in designing and operating the Website, the Application or the CMS or help us analyze collected data. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.
  • Service providers. We may work with analytics companies, such as Google Analytics, to help us understand how the Application is being used, such as the frequency and duration of usage. We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis.
  • Law, harm, public interest, defense of own rights. We may disclose information about you in response to a subpoena, court order, or other governmental request on account of national or international laws as well as when SmartGuide considers it necessary to do so in order to defend its own rights.
  • Business transfers. If SmartGuide is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of this information, as well as any choices you may have regarding this information
  • Aggregated or de-identified information. We may publish aggregate statistics on the use of the Application (including location data), the Website and the CMS to others. For example, we may choose to publish statistics regarding how many registered SmartGuide users live in Germany versus how many live in France. This data is sufficiently aggregated so as to be anonymous.
  • With your consent. We may share information about you with your consent or at your direction.

When using services of personal data processors, SmartGuide concludes relevant data processing agreements. Personal data may also be transferred to companies with their registered offices in countries which do not provide an adequate level of protection according to the Regulation. In these cases, SmartGuide concludes standard contractual clauses for the transfers of personal data approved by the European Commission with the recipients in order to ensure an adequate level of personal data protection.

Your choices

Opt-out of all information collection by uninstalling the Application or deleting of your CMS account. You can stop all collection of information by the Application or CMS easily by uninstalling the Application or deleting the CMS account. You may use the standard uninstall processes of the Application as may be available as part of your mobile device or via the mobile application marketplace or network.

Data retention policy, managing your information. We will retain your personal information for as long as you use the Application or CMS and for a reasonable time thereafter. If you would like us to delete your personal information that you have provided via the Application or CMS please contact us at [email protected]. Please note we may be required to retain some of your personal information by the applicable law.

Your rights

In connection with personal data processing, you have the rights listed below that you may exercise at any time under the terms stipulated in Articles 15 through 21 of the Regulation.

These include the right (i) to access personal data; (ii) to rectify inaccurate data or complete incomplete data; (iii) to erase personal data if it is no longer needed for the purposes for which it has been collected or processed, or if it has been collected illegally; (iv) to restrict data processing; (v) to data portability, (vi) to object to the data processing which will therefore be terminated, unless there are serious legitimate grounds for the processing which outweigh your interests, rights, and freedoms, especially if the reason is an enforcement of legal claims, and (vii) to contact the respective data protection supervisory authority to lodge a complaint. If you have granted consent to personal data processing, you may withdraw it at any time.

Other information

  • Security. We are concerned about safeguarding the confidentiality of your information. We provide appropriate technical and organizational measures (i.e. physical, electronic and procedural safeguards) to protect information we process and maintain against loss or any form of unlawful use. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application or the CMS.
  • Children. If you have not yet reached the age of sixteen (16) years, you are obliged to obtain consent of your parents or legal guardian before using our services. By using our services, you guarantee that you are sixteen (16) years old or older or you have permission from your parents/legal guardian to use these services. If a parent or guardian becomes aware that his or her child (minor) has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files.
  • Changes. This Privacy Policy may be updated from time to time. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy https://smart-guide.org/privacy-policy/. You are advised to consult this Privacy Policy regularly for any changes.

Contact us

If you have any questions regarding Privacy Policy while using the Application or the CMS, or have questions about our practices, please contact us via email at [email protected].

This Privacy Policy is effective as of 24th September 2024