Thank you for visiting SmartNet.Global. We are committed to safeguarding your privacy and ensuring that your personal data is protected in accordance with the European Union (EU) General Data Protection Regulation (GDPR) and any other applicable Republic of Türkiye data protection laws. This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you visit our Website or interact with our services.
By using our Website, you consent to the practices described in this Privacy Policy.
1. Data Controller and Contact Information
The data controller responsible for the processing of your personal data on this Website is:
If you have any questions or concerns regarding this Privacy Policy or about how we process your personal data, please contact us.
2. Purpose and Scope of this Privacy Policy
- This Privacy Policy applies to all visitors, users, and others who access the Website or any related pages, resources, and services.
- It has been drafted in accordance with EU data protection requirements and with reference to relevant guidance, including the EU Visibility Guidelines for External Actions, ensuring transparency and accountability in EU-funded project contexts.
3. Data We Collect
We may collect and process the following categories of personal data:
- Personal Identification Information: such as your name, email address, telephone number, or other contact details you voluntarily provide (e.g., when subscribing to newsletters, filling out contact forms, or requesting further information).
- Usage Data: information about how you use and navigate the Website, including IP address, browser type, device information, time zone, language settings, and pages visited.
- Cookies: data collected through cookies and other tracking technologies to improve your browsing experience. (See Section 7 for more details.
4. How We Use Your Data
We use your personal data for one or more of the following purposes:
- Service Provision: To provide you with information, products, or services that you request from us.
- Communications: To respond to your inquiries, send you updates, newsletters, or event invitations, and communicate about any relevant EU-funded activities or projects.
- Website Improvement: To personalize and improve your experience on the Website by analyzing how you use it and by delivering relevant content.
- Compliance and Legal Obligations: To comply with applicable laws, regulations, and EU project requirements, particularly regarding reporting and visibility obligations under EU-funded projects (in line with the EU Visibility Guidelines for External Actions) as well as the related legistation of Republic of Türkiye.
- Security: To maintain the security of our Website, including preventing or detecting fraud or abuses of our services.
5. Legal Bases for Processing
We process personal data based on at least one of the following legal grounds:
- Consent (Article 6(1)(a) GDPR): Where you have given clear and explicit consent for us to process your personal data for specific purposes (e.g., newsletter subscriptions).
- Contract (Article 6(1)(b) GDPR): Where the processing is necessary for the performance of a contract or to take steps at your request before entering a contract.
- Legal Obligation (Article 6(1)(c) GDPR): Where we are required to comply with a legal or regulatory obligation.
- Legitimate Interests (Article 6(1)(f) GDPR): Where the processing is necessary for our legitimate interests, provided such interests are not overridden by your fundamental rights and freedoms.
6. Disclosure of Your Data
We may share your personal data with:
- Service Providers and Partners: To assist us in operating the Website, conducting our business, or servicing you. This may include hosting providers, email service providers, and analytics services.
- EU Institutions or Granting Authorities: Where required under EU-funded project agreements or regulations, personal data may be shared with relevant EU institutions or project partners to fulfill EU visibility and reporting requirements.
- Legal or Regulatory Authorities: Where required by law, or if necessary for the purposes of our legitimate interests in maintaining legal claims or defending legal disputes.
We do not sell or trade your personal data to third parties.
7. Cookies and Tracking Technologies
Our Website uses “cookies” (small text files placed on your device) and similar technologies to:
- Remember your preferences;
- Analyze how you use our Website;
- Measure the effectiveness of our communications and campaigns.
You have the option to accept or decline non-essential cookies when you first visit our Website. You can also adjust your browser settings to remove or block cookies. For further information, please see our detailed [Cookies Policy]([Link to Cookies Policy]) (if applicable).
8. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, and to comply with applicable legal, contractual, or EU project-related reporting obligations. We will securely delete or anonymize your data when it is no longer needed.
9. International Data Transfers
If we transfer your personal data to a third country we will ensure adequate safeguards are in place (e.g., Standard Contractual Clauses, binding corporate rules) to protect your personal data in compliance with applicable data protection laws.
10. Your Data Protection Rights
Subject to applicable data protection laws, particularly the GDPR, you have the following rights regarding your personal data:
- Access: The right to request access to your personal data and obtain information about how we process it.
- Rectification: The right to request that we correct any inaccuracies in your personal data.
- Erasure (“Right to be forgotten”): The right to request the deletion of your personal data under certain circumstances.
- Restriction of Processing: The right to request that we restrict the processing of your personal data, under certain conditions.
- Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to have that data transferred to another controller if feasible.
- Objection: The right to object to the processing of your personal data on grounds relating to your particular situation, including for direct marketing purposes.
- Withdrawal of Consent: If we process your personal data based on your consent, you have the right to withdraw that consent at any time.
To exercise any of these rights, please contact us at [Contact Email]. We will respond to your request in accordance with applicable GDPR timelines and requirements.
11. Data Security
We have implemented appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures are regularly reviewed and updated as necessary.
12. Third-Party Websites and Links
Our Website may contain links to other websites or resources which are not under our control. We are not responsible for the privacy practices of such external sites. We encourage you to review the privacy policies of any third-party sites you visit.
13. Children’s Privacy
Our Website and services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child under 16 has provided us with personal data, please contact us so we can take appropriate steps to delete or anonymize that data.
14. Compliance with EU Visibility Guidelines
As part of an EU-funded project or in compliance with EU visibility requirements, we may feature logos, disclaimers, or other identifiers as required by the EU Visibility Guidelines for External Actions. Personal data processing carried out in the context of EU projects strictly adheres to the GDPR and other legal obligations to ensure transparency and accountability.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in legal requirements or how we process your personal data. Any changes will be effective upon posting the updated version on this page, with the “Last updated” date at the top. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.
Thank you for reading our Privacy Policy. We are committed to safeguarding your data and operating in full compliance with EU regulations and relevant guidelines. If you have any further questions or requests, please do not hesitate to contact us.