Privacy Policy
Effective Date: July 24, 2026
Last Reviewed: June 2026
Company: Smart Marketer ("Company," "we," "our," or "us")
Address: 292 Gordon Ave NE Unit E Atlanta, GA 30307
Phone: (404) 777-0685
Email: [email protected]
1. Overview
Smart Marketer is committed to protecting the privacy of every individual and organization that interacts with us — including visitors to our website , consumers and end users of our clients' products or services, and business clients engaging our consulting, data, software, and marketing services.
This Privacy Policy explains:
- What personal information we collect, across both consumer and business contexts
- How we use, share, and retain it
- How we safeguard it
- Your rights and choices under applicable law
This Policy applies to:
- Visitors to our Site and any associated subdomains
- Consumers and end users whose data we process as part of delivering client services
- Prospective and current business clients and professional contacts
- Authorized users of Smart Marketer platforms and tools
- Individuals and organizations whose data is processed on behalf of our clients as a service provider or data processor
Note for Clients: If Smart Marketer processes personal data on your behalf under a service agreement, the terms of that agreement (including any Data Processing Addendum) govern such processing and supplement this Policy.
2. Definitions
Personal Data / Personally Identifiable Information (PII)
Any information that identifies or could reasonably be used to identify a natural person, directly or indirectly. Examples include name, postal address, email address, phone number, job title, and IP address when linked to a user profile. Aggregated, de-identified, or anonymized data is not considered PII.
Consumer Data
Personal data relating to individuals acting in a personal or household capacity, including end users, buyers, subscribers, or prospects of our clients' consumer-facing products or services.
Business Contact Information
Professional information used in commercial contexts, including business email addresses, business phone numbers, company names, job titles, and publicly available professional credentials (e.g., NPN, CRD numbers). Applicable law in many jurisdictions treats this category differently from consumer PII; we apply appropriate protections to both.
Sensitive Personal Information
A subset of PII requiring heightened protection under laws such as the CCPA/CPRA, state comprehensive privacy statutes, and GDPR. Categories include government-issued IDs, financial account details, health data, biometric data, and precise geolocation. Smart Marketer does not intentionally collect sensitive personal information absent explicit legal basis or consent.
Data Controller / Data Processor
Where Smart Marketer determines the purposes and means of processing personal data, it acts as a Data Controller. Where Smart Marketer processes personal data solely on behalf of a client pursuant to a contract, it acts as a Data Processor or Service Provider.
3. Information We Collect
A. Information You Provide Voluntarily
- Contact form submissions, demo or consultation requests
- Account registration and platform credentials
- Email communications and scheduling requests
- Billing and payment information
- Content or data you upload to our platforms
- Consumer-facing form submissions or lead captures managed on behalf of a client
B. Information Collected Automatically
When you visit our Site or use our services, we may automatically collect:
- IP address and approximate geolocation (city/region level)
- Device type, operating system, and browser
- Pages viewed, referring URLs, and navigation paths
- Session duration and interaction events
- Identifiers captured via our pixel technology or third-party analytics tools (e.g., smart pixel)
C. Information from Platform Use
For clients and authorized users of Smart Marketer platforms:
- Account activity logs and feature usage data
- Uploaded or API-integrated customer data (processed as a service provider on your behalf)
- Support tickets and communications
D. Intent, Identity-Resolution & Audience Data
When clients deploy our identity-resolution, intent-data, or audience services, Smart Marketer may process:
- Contact and profile information sourced from public, licensed, or client-provided databases — spanning both consumer and professional audiences
- Behavioral and intent signals from website visits, content interactions, or engagement events
- Publicly available professional and regulatory information (e.g., NPN, CRD) where applicable
- Visitor identity-resolution events generated by our pixel technology, where lawful
- Audience segmentation and enrichment attributes used for targeting, personalization, or analytics
All such processing is conducted under applicable law, contractual obligation, and — where required — appropriate client-side disclosures and consent mechanisms. Clients are responsible for ensuring their use of audience data in consumer contexts complies with applicable consumer protection and privacy laws, including opt-in or opt-out requirements where mandated.
4. Legal Basis for Processing
Where applicable law requires a legal basis for processing personal data (e.g., GDPR, state privacy statutes), we rely on one or more of the following:
| Basis | Example Use |
|---|---|
| Contract performance | Providing services a client has engaged us for |
| Legitimate interests | Outreach, fraud prevention, platform security, analytics |
| Legal obligation | Responding to lawful regulatory or legal requests |
| Consent | Email marketing; cookie consent; consumer opt-in programs where required |
| Vital interests | Emergency safety situations (rarely applicable) |
For California residents, processing is further governed by the CCPA/CPRA framework, including rules effective as of the 2025–2026 CPRA regulatory amendments.
5. How We Use Information
We use personal information — across both consumer and professional contexts — to:
- Provide, operate, and improve our services and platforms
- Respond to inquiries and deliver requested content or proposals
- Send marketing, educational, or product communications (with opt-out available)
- Support identity-resolution, intent-based targeting, audience segmentation, and lead-generation services for clients across B2B and B2C verticals
- Enrich and validate contact and audience data for client campaigns
- Conduct analytics, performance monitoring, and product development
- Detect fraud, enforce security, and maintain system integrity
- Fulfill contractual and legal obligations
For platform users specifically, data may be used to authenticate accounts, deliver integrations and automations, provide technical support, and generate reporting. See platform-specific service agreements for additional detail.
Automated Decision-Making: Where Smart Marketer uses automated processes (including AI-assisted tools) to make decisions that produce legal or significant effects on individuals, we will disclose this and provide a mechanism to request human review, as required by applicable law.
6. How We Share Information
We may share information in the following circumstances:
- Service Providers: Vendors who support hosting, analytics, CRM, email delivery, payment processing, and AI-assisted processing tools, bound by confidentiality and data processing obligations.
- Integration Partners: When a client requests data delivery to platforms such as Meta, Google, LinkedIn, or connected CRM or marketing automation systems.
- Authorized Clients: Where the service requires visibility or interaction across shared audiences, subject to appropriate access controls.
- Business Transfers: In connection with a merger, acquisition, or sale of assets, personal data may be transferred to the successor entity.
- Legal Compliance: When required by subpoena, court order, government request, or applicable law; or to protect the rights, property, or safety of Smart Marketer, our clients, or the public.
What We Do Not Do:
- We do not sell consumer PII as defined under the CCPA/CPRA or equivalent state statutes without providing the required opt-out rights.
- We do not share personal information with third parties for their independent direct marketing purposes without appropriate consent or opt-out opportunity.
Audience & Contact Data Services: We may license or provide access to audience data, contact information, and intent signals as part of our identity-resolution, lead-generation, or audience platform services — for both business-to-business and business-to-consumer use cases — consistent with applicable law, our legitimate-interest assessments, and any client data processing agreements in place.
7. Cookies, Tracking Technologies & Pixel Services
We use cookies, web beacons, pixel tags, and similar technologies on our Site to:
- Maintain session functionality and site performance
- Analyze usage and navigation patterns
- Enable personalization and content relevance
- Support attribution, analytics, and retargeting
Cookie Consent: Where required by applicable law (including states with opt-in or opt-out consent requirements effective in 2025–2026), visitors will be presented with a cookie preference mechanism. You may also manage cookie preferences through your browser settings; note that disabling certain cookies may affect functionality.
smart pixel Technology
When our pixel technology is deployed on a client's website, it may:
- Identify or resolve the identity of website visitors — including both consumer and professional audiences — based on behavioral signals and database matching
- Detect intent or engagement signals at the individual, household, or organizational level
- Link visitor events to contact-level information for outreach, retargeting, or audience-building purposes, across B2B and B2C campaigns
Our pixel technology supports both business-to-business and business-to-consumer identity resolution use cases and does not rely solely on visitor form submissions to function. Clients deploying our pixel are responsible for ensuring that appropriate privacy disclosures, cookie notices, and consent mechanisms (where required by law for their audience type) are in place on their websites prior to deployment. Consumer-facing deployments may require stricter consent standards than professional-context deployments; clients are responsible for determining and meeting those requirements.
8. Your Rights and Choices
Depending on your jurisdiction and relationship with us, you may have the following rights:
| Right | Description |
|---|---|
| Access | Request a copy of the personal data we hold about you |
| Correction | Request correction of inaccurate or incomplete data |
| Deletion | Request deletion of your personal data, subject to legal retention obligations |
| Portability | Receive your data in a structured, machine-readable format (where applicable) |
| Opt-Out of Sale/Sharing | Under CCPA/CPRA, opt out of the sale or sharing of your personal information |
| Opt-Out of Targeted Advertising | Opt out of your data being used for cross-context behavioral advertising |
| Opt-Out of Profiling | Opt out of automated profiling used for decisions with significant effects |
| Restriction | Request restriction of certain processing activities |
| Objection | Object to processing based on legitimate interests |
| Withdraw Consent | Where processing is based on consent, withdraw it at any time without affecting prior lawful processing |
To exercise your rights, contact us at [email protected]. We will respond within the timeframe required by applicable law (generally 30–45 days, with extensions as permitted).
We honor opt-out, suppression, and removal requests from both consumers and business contacts promptly, regardless of the legal jurisdiction of the requestor.
Non-Discrimination: We will not discriminate against you for exercising any privacy rights.
9. Data Security
We implement commercially reasonable administrative, technical, and physical safeguards to protect personal data, including:
- Encryption of data in transit (TLS 1.2+) and at rest (AES-256 or equivalent)
- Role-based access controls and principle of least privilege
- Multi-factor authentication for system access
- Regular security audits, penetration testing, and vulnerability assessments
- Vendor and subprocessor due diligence and contractual data security obligations
- Incident response procedures and breach notification protocols consistent with applicable law
No method of electronic transmission or storage is completely secure. While we take reasonable measures to protect your information, we cannot guarantee absolute security.
Data Breach Notification: In the event of a security breach involving your personal data, we will notify affected individuals and relevant authorities as required by applicable federal and state law.
10. Data Retention
We retain personal data only as long as necessary to fulfill the purposes described in this Policy, including to:
- Deliver contracted services and support
- Comply with legal, regulatory, and tax obligations
- Resolve disputes and enforce agreements
- Support legitimate business operations
When data is no longer required, we delete, anonymize, or securely dispose of it in accordance with our data retention schedule. Residual copies in encrypted backups may persist for a limited period before routine purging.
Clients may request information about applicable retention periods for their data by contacting us at [email protected].
11. Children's Privacy
Our services are not directed to children under the age of 13 (or 16 where required by applicable law, including COPPA 2.0 requirements effective 2026). We do not knowingly collect personal data from children without verified parental consent. If you believe we have inadvertently collected such data, contact us immediately at [email protected] and we will delete it promptly.
Clients operating consumer-facing platforms directed to or likely to reach children are solely responsible for implementing age-gating, parental consent mechanisms, and any additional protections required by COPPA, state law, or other applicable child privacy regulations.
12. State-Specific Privacy Rights
Residents of certain U.S. states have additional rights under state comprehensive privacy laws. As of June 2026, comprehensive consumer privacy laws are in effect or operative in a growing number of states, including (but not limited to) California, Virginia, Colorado, Connecticut, Texas, Montana, Oregon, and others. Residents of these states may exercise the rights described in Section 8 above. Where state law provides additional or different rights, we will honor those obligations.
California Residents (CCPA/CPRA): You have the right to know what personal information is collected, used, shared, or sold; the right to delete personal information; the right to opt out of the sale or sharing of personal information; the right to correct inaccurate personal information; and the right to limit use of sensitive personal information. To submit a verifiable consumer request, contact [email protected].
Texas Residents: Under the Texas Data Privacy and Security Act (TDPSA), Texas residents have rights to access, correct, delete, and obtain a portable copy of their personal data, as well as to opt out of targeted advertising, the sale of personal data, and automated profiling. Contact [email protected] to exercise these rights.
13. International Data Transfers
If you access our services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. We take steps to ensure such transfers comply with applicable legal requirements, including — where applicable — use of standard contractual clauses or other transfer mechanisms recognized under relevant law.
14. Third-Party Links
Our Site may contain links to third-party websites, services, or social media platforms. We are not responsible for the privacy practices or content of those external sites. We encourage all visitors to review the privacy policies of any websites they navigate to.
15. AI and Automated Processing Disclosure
Smart Marketer uses AI-assisted tools in some operational and service-delivery contexts, including data processing, analytics, audience modeling, and client-facing automations. Where personal data is processed using AI tools:
- We ensure that third-party AI service providers are bound by appropriate data processing agreements and confidentiality obligations.
- We do not use personal data to train third-party AI models without appropriate authorization or consent.
- Where AI-driven outputs directly affect individuals — including consumers — in a legally or materially significant way, we provide a means for human review upon request.
16. Changes to This Policy
We may revise this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. When changes are material, we will update the "Effective Date" and "Last Reviewed" at the top of this document and, where appropriate, provide additional notice (e.g., via email or a banner on our Site). Continued use of our Site or services following the posting of changes constitutes acceptance of the updated Policy.
We recommend reviewing this Policy periodically. Archived versions are available upon request.
17. Contact Us
For privacy questions, rights requests, or data concerns, please contact:
Smart Marketer
292 Gordon Ave NE Unit E Atlanta
GA 30307
Phone: (404) 777-0685
Email: [email protected]