This Privacy Policy was last updated on January 30, 2020 and applies solely to your use of SMART FED Tools or the Feedback App, not the SMART FED website.

SMART FED is committed to protecting the privacy of its customers or users of the feedback tool. SMART FED uses reasonable efforts to protect personal information from loss, misuse, unauthorized access, disclosure, alteration or destruction.

In principle, the Swiss Federal Data Protection Act (DSG) and the European General Data Protection Regulation 2016/679 (GDPR) apply when processing personal data.

Your data in the SMART FED Tool/App

When you use the SMART FED Tool or Feedback App, personal information about you is stored on our providers’ servers. There are two user groups for this purpose:

a) Contact persons

For SMART FED, contact persons are the official contact persons of customers within the framework of concluded license agreements. Their names and business contact data (address, email, telephone number, position) are indispensable for establishing and maintaining the business relationship. This data is stored and maintained in a separate CRM system to which only employees of smart-fed AG have access. This data is not passed on or sold to third parties.

b) SMART FED Tool / App user

SMART FED defines users as all persons who are granted access to the SMART FED Tool or SMART FED App by their organization, in whatever role. The necessary collection and maintenance of personal data, e.g. name, email, organisation area or personnel number, is carried out exclusively by the persons with administrator rights named by the customer. This data is located in a protected area to which third parties have no access. Nor does smart-fed AG and its IT partners.

The recording of a person in the feedback tool by the administrators of the organisation is purely passive in nature. Each user decides on the activation of his or her personal user account. Each user account and the associated access rights can be deleted by the administrators if a user leaves the organization or wishes to do so.

The feedback data of the users themselves are encrypted and stored anonymously in a protected data area to ensure the anonymity of the feedback providers. This data area is also not accessible to persons within the organization with administrator rights. The consolidation and provision of feedback data for analysis is carried out anonymously in the corresponding reporting modules (for example, Management Cockpit). The anonymized feedback data remains stored even if a user account is deactivated or deleted.

Access control

SMART FED takes various measures to ensure that third parties cannot access customer or user accounts without authorisation.
A central element in the SMART FED security concept is a SMS code with a transaction number that is valid for a limited time. This code is sent to the user via SMS before each login and thus guarantees a high level of access control to the user account. The otherwise usual entry of a user name and password is no longer necessary with this procedure.

A prerequisite for this is that the user must have an electronic terminal device (e.g. smartphone or tablet) with a personal telephone number to receive the SMS.

Log data

We host the feedback tool at Nine Internet Solutions AG, 8047 Zurich (Switzerland). The server provider automatically collects and stores information in so-called server log files, which are automatically transmitted by every browser. These are:

• IP address
• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request

These data are not directly attributable to specific persons. A consolidation of this data with other data sources is not carried out. We reserve the right to check this data subsequently if we become aware of concrete indications of illegal use.

Cookies / Tracking Codes

The SMART FED tool or feedback app does not store cookies or other tracking codes on your electronic device (computer, tablet, smartphone, etc.). It is important to us that all access to the tool or app is as anonymous as possible.
Third party services

For user login and payment transactions SMART FED uses the following third party services, some of which use or transfer personal or business data.

Twilio to send the access code via SMS to login to the App. The privacy policy of Twilio can be found here.
SendGrid to send login e-mails to the users. The SendGrid privacy policy can be found here.
Stripe for processing credit card payments. The privacy policy of Stripe can be found here.

Advertisement

The use of the feedback tool or app is free of advertising. We do, however, take the liberty of sending information via email to the contact persons registered by us,

1. if new functionalities, parameters or other enhancements have been activated for customers under current license agreements (software releases);
2. if existing software errors have been corrected (bug fixing).

Inactive accounts

SMART FED reserves the right to delete user accounts and the data contained therein if a non-extended license agreement has been inactive for more than 1 year.

Data location

The data in the feedback tool or app are stored on Severn in Switzerland.

Retention period of personal data

SMART FED only keeps personal data of the contact persons for as long as legally necessary or in accordance with the purpose of processing. If we store data on the basis of a contractual relationship with you, this data will remain stored at least as long as the contractual relationship exists and at most as long as the limitation periods for possible claims from us run or legal or contractual storage obligations exist.

Right of access, rectification, erasure or appeal

Contact persons have the right to assert their data protection rights at any time and to request information on whether and which personal data about them are processed by us. They can also have their personal data corrected, blocked or deleted at any time by sending a written notification and appropriate proof of their identity to the following address:

For correspondence and operational reasons, each organization using the feedback tool must have designated at least one contact person. For this reason, the data of a contact person can only be deleted if a new contact person is named in advance or if the contractual relationship with smart-fed AG as a whole has been terminated.

We reserve the right to correspond with you in this context. Please note that even after your request for deletion of your personal data, we will still have to store it in part within the scope of our legal or contractual obligations to retain it (for example for billing purposes) and in this case we will only block your personal data to the extent necessary for this purpose.

Note! SMART FED cannot provide information about the personal data of users in SMART FED App, as this data is processed and managed exclusively by the organization itself. SMART FED has no access to this data. Users must therefore contact the administrator(s) in their organization directly for this purpose.

Contact person

If you have any questions regarding data protection when using SMART FED Tool or the Feedback App, would like to request information or request the deletion of your data, please contact our contact person for data protection law by sending an email to

contact@smart-fed.com

The contact details of our data protection officer are as follows: