Privacy Policy
WEBSITE PRIVACY POLICY
Last updated: May 19, 2025
Smart Subha Trading CO. L.L.C, as data controller, (“Smart Subha”, “we” or “us“) present this privacy policy, as may be amended from time to time (the “Privacy Policy“) in order to provide our website visitor (“Visitor“, “you” or “your“) information about Smart Subha’s data protection practices in relation to Personal Data that is collected, used and/or otherwise processed by Smart Subha and/or third parties acting on its behalf, through its website available at www.smartsubha.com (the “Website“).
The Website presents our products and activities and provides a means for resellers wishing to sell our products to contact us.
This Privacy Policy supplements our Terms of Use [To link]. If you have questions or concerns regarding this Privacy Policy, please contact us at info@smartsubha.com
PLEASE SEE OUR FULL PRIVACY POLICY BELOW IN ORDER TO BETTER UNDERSTAND OUR PRACTICES IN DETAIL.
1. Types of Personal Data We Collect and Process
Definition. When we use the term “Personal Data” in this Privacy Policy, we mean any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly.
Personal Data Collection and Processing. When you fill in the forms available on the Website to contact us and/or become a reseller of our products, we collect and process the following Personal Data: full name, company name and role, work email address, phone number, country and city; and any information you decide to add when you send us a message.
The provision of certain types of Personal Data may be necessary or optional, depending on your requests. Mandatory data will be marked as such at the moment of collection of your Personal Data. If you refuse to provide mandatory data, Smart Subha may not be able to process your request (e.g., reply to your business request).
2. Purposes and EU Legal Basis
We process the Personal Data described in section 1 above for the following purposes:
Purposes
Example of use of Personal Data
Legal Basis (for EEA Visitors only)
Managing your request
- To answer your questions and inquiries
- To contact you if necessary
- To review your request to become a reseller
Legitimate interest of Smart Subha in managing the contact requests sent to it
Managing any litigation
- To take action against any identified security breach, manage any dispute or litigation
- To seek advice from lawyers, auditors, and other professional advisers
Legitimate interest of Smart Subha in defending our rights and interests
Complying with legal and regulatory obligations
- To perform any reporting and notifications obligations we may be subject to, to competent governmental agencies and authorities;
- To process your requests to exercise your rights;
- To detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights
Legal obligations to which Smart Subha is subject
3. With Whom Do We Share Personal Data?
We may share your Personal Data with third parties as detailed below:
Service Providers, including data storage providers, data security services, fraud detection and prevention services, website design service provider, insurers.
We share Personal Data with selected third-party companies we engage to perform services on our behalf. We only provide such service providers with Personal Data so they can perform their required functions on our behalf.
Governmental, Administrative or Judiciary Authorities
We will disclose or allow government and law enforcement officials access to certain Personal Data, exclusively in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Corporate Transactions
We may share Personal Data in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Lawyers and Interested Parties
We will share Personal Data exclusively in case of the management of possible disputes and other legal matters where appropriate, including with respect to the Website; to establish, protect, or exercise our legal rights; as required to enforce agreements; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights.
4. Cross-Border Data Transfers
We may host, store, transfer or otherwise process the Personal Data to various sites worldwide, outside your jurisdiction. Where specific laws or regulations relating to Personal Data transfer apply to us, we will implement our best effort to ensure that the Personal Data is protected and transferred in a manner consistent with legal requirements.
5. Data Retention
We retain Personal Data for as long as Visitor is using our Website. Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal and regulatory requirements, or (ii) for us to have an accurate record of your interaction with us in the event of any inquiries or contact requests, or (iii) if we reasonably believe there is a prospect of litigation.
If you have any questions about data retention, please contact us by e-mail at info@smartsubha.com
6. Data Security
We endeavor to maintain appropriate technical and organizational measures compliant with industry standards to protect Personal Data in particular, against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, although we make every effort to protect the Personal Data which you provide to us or we generate, we cannot completely ensure the security of any Personal Data you transmit to us over the internet or guarantee that this Personal Data will not be accessed, disclosed, altered, or destroyed.
If you have found a vulnerability or would like to report a security incident, you may send an email at info@smartsubha.com
7. Your Rights Regarding your Personal Data
General Provisions. Please note that under certain circumstances and depending on your jurisdiction, you are entitled to specific rights regarding your Personal Data (subject to some exceptions). In most cases, you can exercise such rights free of charge. When you ask us to exercise any of your rights under this Privacy Policy and the applicable privacy and data protection laws, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of Personal Data which is related to others that you are not authorized to receive, and to ask you questions to better understand the nature and scope of Personal Data that you request to access. Applicable privacy and data protection laws in your jurisdiction may provide you with different or additional rights related to the Personal Data we collect from you, which may also apply. Please note that you can deliver your request by contacting us at info@smartsubha.com
EEA Visitors. If you are based in the EEA, you have the following rights: (i) to access your Personal Data in order to obtain clear, transparent and understandable information on how we process your Personal Data and on your rights, as well as a copy of your Personal Data; (ii) to rectify your Personal Data in case your Personal Data is obsolete, inaccurate or incomplete; (iii) to object the processing of your Personal Data when the processing is based on Smart Subha’s legitimate interest. We will no longer process your Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation (e.g., legal obligation involving the retention of documents), or for the establishment, exercise or defense of legal claims; (iv) in certain circumstances under GDPR, you have the right to restrict the processing of some of your Personal Data during a limited period of time; (v) to withdraw your consent when it has been obtained and processing is based on consent; (vi) in certain circumstances under GDPR, you have the right to request data portability, meaning that you can receive the Personal Data originally provided by you in a structured and commonly used format or that you can request the transfer of the Personal Data you provided to another data controller; (vii) in certain circumstances under GDPR, you have the right to delete your Personal Data (also known as the right to be forgotten); (viii) if applicable, not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect concerning you or similarly significantly affects you and if automated processing is used; (ix) to lodge a complaint with your national data protection authority. If you have a complaint about how we use your Personal Data, we will always prefer you to contact us first. If you are unsure which data protection authority to contact, please contact us at info@smartsubha.com
8. Children
The Website is not intended for use by minors (an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 18). If we nevertheless receive Personal Data from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 18, we will endeavor to delete such Personal Data from our systems.
9. Changes to This Privacy Policy
This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post new or updated privacy policy in our Website. Each version of this Privacy Policy will be identified by its effective date, which you can find at the top of this Privacy Policy. The new or updated privacy policy will be effective from the date mentioned at the top page of the new privacy policy.
We strongly encourage you to review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.
10. Contact Information and Data Controller Details
If you have any questions about this Privacy Policy, or in the event that you wish to exercise certain rights you are eligible for with respect to your Personal Data, please contact us as follows: info@smartsubha.com