Customer Data Privacy Policy

This Customer Data Privacy Policy supplements privacy and confidential information obligations stated in Smartempo LLC Master Services Agreement.

Customer Data is data that resides on Smartempo LLC, customer, or third party systems to which Smartempo LLC is provided access for providing Digital Marketing Services. As such, the data may include personal information about the Customers’ employees, customers, partners or suppliers. Smartempo LLC websites may query a User’s browser to see if there are “cookies” previously sent by the Smartempo LLC system. In these cases, Smartempo LLC may receive User information that could include network routing information, equipment information, IP address, and date and time. Smartempo LLC also may use cookies to collect general usage and volume statistical information. The ma jority of any such cookies are set to expire within 30 days.

Smartempo LLC may access, collect and/or use Customer Data for the following purposes: To fulfill the requirements and activities specified in the Customer’s Master Services Agreement and related Order Forms and Statements of Work. Technical staff may obtain periodic access to Customer Data to administer customer systems, test systems, develop, and implement changes. Any temporary copies of Customer Data created as a necessary part of this process are maintained for a time period relevant to those purposes. In accordance with the terms of Master Services Agreements and/or with notice to Customers, Smartempo LLC may access and/or use a copy of the Customer’s test, development or production environment, including Customer Data, to test such new configurations, versions, patches, updates, fixes, and validate that they work to required specifications.

If Smartempo LLC hires subcontractors to assist in providing services, their access to Customer Data will be consistent with the terms of the Customer’s Master Services Agreement and this privacy policy.

Smartempo LLC does not use Customer Data except as stated above. Smartempo LLC may process Customer Data, but does not control its Customers’ information collection or use practices for Customer Data. If a Customer provides any Customer Data to Smartempo LLC, the Customer is solely responsible for providing any notices and/or obtaining any consents necessary for Smartempo LLC to access and use Customer Data as specified in this policy and the Customer’s Master Services Agreement.

Smartempo LLC retains the right to update this policy from time to time. We will post a prominent notice in this section of this policy notifying Users when it is updated. If we are going to use Customer Data in a manner different from that stated at the time of collection, we will notify our Customers via email, and they will have a choice as to whether or not Smartempo LLC uses the Customer Data in this different manner.