Updated as per Feb 07th, 2021
Eternal Consulting Ltd (“We” or “SmGains”) owns and operates the website www.smgains.com, (the “Website”). This privacy policy has been created to demonstrate our firm commitment to protect the privacy of our users and to comply with the European General Data Protection Regulation (GDPR).
The following policy discloses the information gathering and dissemination practices for our Website. The Privacy Policy forms an integral part of the Terms of Use. By using our Website and by accepting our Terms of Use, the user (“User” or “You”) agrees to adhere and to accept this Privacy Policy. If you do not agree to this Privacy Policy or this Privacy Policy is not valid in your legal jurisdiction, you must not use our Website.
Introduction
This is a notice to inform you of the SmGains policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with the English laws accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR). The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data.
- On May 1, 2018, we’re updating our Privacy Policy. You can get a preview of these updates before they go live. If you keep using smgains.com hereafter referred to as our websites after May 25, you’re letting us know that you’re okay with the updates.
What’s changing? We’re adding more detail about how and why we use the information we collect about you, how we share it, who we share it with, and your rights with that data.
Why are you making these updates? There are some new European privacy rules that will apply across Europe or all business owners and website to comply to the new EU GDPR Compliance Regulation, which comes into effect on May 25. We’re using this opportunity to make sure we’re really clear on how we use your information—regardless of where you live, or using our website
Does this affect the way I use the websites?
Not at all—your experience will stay the same.
What if I’m not okay with the changes? If you’re not okay with the changes, you can close your account. But before you do that, please get in touch with us so we can answer any questions you have.
Remember, if you keep using the websites after May 25, 2018, you’re letting us know that you’re okay with these updates.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
General
SmGains website is a source of support, inspiration and friendship to help you find your own joy, invite miracles and live your greatest self.
Our mission is to support you to live your most fulfilled life. We show you content we think you’ll be interested in based on information we collect from you. We only use that information where we have a proper legal basis for doing so.
We wrote this policy to help you understand what information we collect, how we use it and what choices you have about it.
Scope
This privacy policy describes how we handle the information that you supply to us directly and through your use of our services available through the smgains.com website and any affiliated websites (our “Sites”), and SmGains platform (the “SmGains Platform”). This privacy policy is divided into four sections: the first section describes how we process personal data, the second section describes how we collect and use information you may supply through our Sites, the third describes how we collect and use information you may supply through the SmGains Platform, and the fourth describes practices that apply to both.
By accepting the Privacy Policy and Terms of Use in registration or by using our Sites and any affiliated websites, you expressly consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy.
Why Do We Process Personal Data
When we offer our service, our customers are data controllers so they are responsible for any personal data processing involved in the provision of this service. We only process personal data on their behalf and upon their instructions.
Also, we continuously improve the functionality of our website and service, and in this regard we are the personal data controller for the processing of personal data in relation to the improvement of our services.
Our purpose for processing the personal data is that it enables us to improve user experience on our website and makes our service to you convenient, by adding data to our database.
The data that is collected and used to achieve this purpose is information about the IP-address from which you visited our customer’s website, and technical information that enables us to tell different visitors apart that are originating from the same IP-address (cookies). If you provide information yourself on our customer’s website, we may collect and store personal information and domain information about your employer therein, in order to correlate the IP-address with your us.
The legal ground for this is your consent to the processing, which you expressed at our customer’s website. You may at any time withdraw this consent, either at our customer’s website or by letting us know directly that you wish to do so.
How Do We Process The Personal Data
We store personal data regarding cookies for twenty-four (24) months. When information regarding IP-address is collected by the tracking pixel it is read by our system and instantly deleted after it has been matched with our database of companies if a match is not found. Only IP-addresses belonging to registered companies are therefore stored by SmGains. If you are a user/clients on the website, the IP-address is personal data and will be stored for a period of twelve (12) months.
Your rights according to the GDPR Regulation are the right to information about the processing (provided to you here, in this privacy statement); the right to access personal data relating to you; the right to have such data rectified, erased or restricted from processing; the right to object to our processing of personal data; as well as the right to not be subject to automatic decisions and the right to data portability. To exercise your rights please contact us via sales@SmGains.com and provide us with your IP-address and Personal information. If you want to know more about this, or have concerns about your rights, please do not hesitate to contact us.
If you consider that our processing of personal data infringes the General Data Protection Regulation (the GDPR), you always have a right to lodge a complaint with your local supervisory authority or the supervisory authority closest to us –
How We Collects Your Information On Our Websites
Collection Of Information
When you visit our Sites, we gather personal and non-personally identifiable information such as your name, email address, your browser version, your operating system version, your IP address, cookie information, time stamps (time page accessed as well as time spent per web page), and clickstream information (for example, which pages you viewed and for how long). SmGains automatically receives and records such information on our server logs from your browser.
In certain sections of our Sites, we may invite you to contact us to pose questions, request information, or complete a registration form. We may ask you to supply Personally Identifiable Information in order to register before allowing you to access certain parts of our Sites. We may also collect Personally Identifiable Information when you use certain SmGains services, through the use of our Sites, or when you enter promotions or contests offered by us.
“Personally Identifiable Information” means any information that identifies you personally, including your name, e-mail address, password, login ID, and other contact information that you voluntarily submit to us.
Comments
We collect the data shown in the comments form, when visitors leave comments on the site, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to us to see if you are using it.
Cookies And Web Beacons
The cookies we place do not contain any personal information; however, they do contain identifiers that may be linked to certain non-personally identifiable information described in this privacy policy, as well as certain non-personally identifiable advertising IDs from third parties.
- If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
- If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
- When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
- If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just
We also use the SmGains Platform on our Sites, which utilizes cookies and web beacons, such as invisible tracking pixels, to help us better serve you and to provide targeted advertising we place on third party websites.
Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit SmGains,
for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Marketing
We do not sell or rent the personal information we collect from your use of our Sites to third parties for their marketing purposes. We may combine your information with information we collect from other companies (such as demographic data) to improve and personalize the services provided to you.
Account Protection
Your password is the key to your account. We recommend the use of unique numbers, letters, and special characters in combination and that you not disclose your SmGains password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify us and change your password.
Phishing
In order to protect yourself from third parties unlawfully seeking your personal information through email that appears to be from SmGains, you should never provide any personal information directly in response to an email you believe you have received from us. Rather, you should always close any such email, open your browser, log directly in to the SmGains Site and change, update, or modify any such personal information only using our Sites. In the event that you believe that you have received a request for personal information in an email message that is made to appear that it was sent by us, please inform us immediately at sales@SmGains.com .
How We Share Information
We may share your information, including personal information, as follows:
- We may disclose the information we collect to our affiliates or subsidiaries; however, if we do so, their use and disclosure of such information will be subject to this Policy.
- Service Providers. We may disclose the information we collect to third party vendors, service providers, contractors or agents who perform functions on our behalf.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected to the other company.
- In Response to Legal Process. We also may disclose the information we collect from in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We also may disclose the information we collect where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which SmGains is involved.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information collected through the AdBeacon technology about images captured and associated data with our customers for marketing, advertising, research or similar purposes.
Opting Out Of Cookie-Based Advertising
We try hard to make our advertising more relevant to you, but if you would rather opt out of seeing personalized ads from SmGains and our affilliates utilize SmGains cookies, please contact sales@SmGains.com . If you opt out, you will still see ads from us and our clients, but they will not be tailored based on information that may have otherwise been associated with a SmGains cookie stored on your computer.
Please note that our opt-out requires that we be able to set an opt-out cookie in your browser.
Browser-based “Do Not Track”
Some browsers have incorporated “Do Not Track” (DNT) features. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to browser DNT signals on our Sites or on third party sites that use the SmGains Platform.
Third Party Cookies
We like other sites, incorporates functionality provided by third party cookies. Disabling these cookies will likely break the functions offered by these third parties.
- a) Analytical cookies
- b) Google cookies
- SmGains uses Google Analytics to analyze the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store and use this information. Google’s privacy policy is available at: https://www.google.com/privacypolicy.html
- SmGains publishes Google AdSense interest-based advertisements on this website. These are tailored by Google to reflect your interests. And to determine your interests, Google will track your behavior across the web using cookies. You can view, delete or add interest categories associated with your browser using Google’s Ads Preference Manager, available at: https://www.google.com/ads/preferences/
- You can opt-out of the AdSense partner network cookie at: https://www.google.com/privacy_ads.html However, this opts-out mechanism uses a cookie, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you should use the Google browser plug-in available at: https://www.google.com/ads/preferences/plugin
The Cookies We Set On Our Website Under GDPR Compliance Regulation
Account Related Cookies
If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.
Login Related Cookies
We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
Email Newsletters Related Cookies
This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
Orders Processing Related Cookies
This site offers payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
Surveys Related Cookies
From time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.
Forms Related Cookies
When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Site Preferences Cookies
In order to provide you with a great experience on this site we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.
Blocking/Disabling Cookies
Most browsers allow you to block cookies. In Internet Explorer, you can block all cookies by clicking “Tools > Internet Options > Privacy and selecting Block all cookies” using the sliding selector. In Firefox, you can adjust your cookies settings by clicking “Tools > Options >Privacy”.
However, cookies are perfectly safe to be stored on your computer and almost all web browsers have cookie storing enabled as default. However, all browsers have the option of disabling cookies being stored on your computer if you wish to do this. Please be aware that disabling cookies on your browser will reduce your ability to use our website features
How long we retain your data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Terms Applicable To Both Our Websites And The SmGains Services
Use of information
Our primary purposes in collecting your information are to provide you with an efficient and customized experience and to deliver smarter advertising. You agree that we may use your information to:
- provide the services and customer support you request;
- resolve disputes, collect fees, and troubleshoot problems;
- prevent prohibited or illegal activities;
- customize, measure, and improve our services and our Sites’ content and layout;
- share service updates, and promotional offers based on your communication preferences;
- make inferences about your interests for advertising or service-related purposes;
- provide you with offers or promotions that may interest you, or otherwise deliver you advertising, including on other websites.
Our disclosure of your information
We may disclose your information:
- as required to respond to legal matters, enforce our policies, or protect individual rights, property, or safety;
- to employees and agents of SmGains in order to help detect and prevent prohibited or illegal acts;
- to service providers under contract who help with our business operations;
- to other third parties to whom you explicitly ask us to send your information;
- to those serving apparently valid subpoenas;
- to other business entities, should we plan to merge with, or be acquired by, that business entity.
We also use certain third party analytics, advertising, widget, and other plugins to provide certain services on our Sites and to deliver you targeted advertisements on third party websites. The third parties operating these plugins may use cookies, web beacons, or other technologies to collect personal information about your online activities over time and across different websites when you use our Sites.
Without limiting the above, in an effort to respect your privacy we will not otherwise disclose your personal information except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.
Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
Intellectual Property Rights
All copyrights, trademarks, patents and other intellectual property rights in and on our website and all content and software located on the site shall remain the sole property of or its licensors. The use of our trademarks, content and intellectual property is forbidden without the express written consent from.
You must not:
- Republish material from our website without prior written consent.
- Sell or rent material from our website.
- Reproduce, duplicate, create derivative, copy or otherwise exploit material on our website for any purpose.
Redistribute any content from our website, including onto another website.
Security
The security of your Personal Information is important to us, but remembers that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
However, please note that Email is not recognized as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information are never transmitted via email.
Your information is stored on servers located in London England. We treat data as an asset that must be protected and use certain tools (including but not limited to encryption, passwords, and physical security) to protect your personal information against unauthorized access and disclosure. However, third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we take reasonable steps to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
Transferring your information
Our websites are a worldwide service. By using our products or services, you authorize us to transfer and store your information outside your home country, including in the United States, for the purposes described in this policy. The privacy protections and the rights of authorities to access your personal information in such countries may not be equivalent to those of your home country.
For all transfers of your information from the EEA to the US, our websites is certified under Privacy Shield and follows its principles. Learn more about Privacy Shield and the principles.
Where we share information we receive under Privacy Shield with third parties, we’re responsible for making sure those third parties also comply with Privacy Shield, unless we can prove we’re not responsible for the damaging event.
If you are a user in the EEA and have a question or a complaint about our websites and Privacy Shield, please contact us. If we’re not able to resolve the issue, our websites will cooperate with the JAMS Arbitration and Mediation Service. This provides an independent dispute resolution service for Privacy Shield complaints in the US. In certain circumstances, and if the dispute resolution process still doesn’t resolve the problem, users in the EEA may pursue binding arbitration. our websites is also subject to the investigatory and enforcement powers of the Federal Trade Commission.
Where we transfer information from the EEA to a country that doesn’t provide an adequate level of protection, we’ll only do so under appropriate safeguards to protect your information, like standard contractual clauses, or Privacy Shield certification.
What rights you have over your data
If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.
Your options:
You have options in relation to the information that we have about you described below. To exercise these options, please contact us. If you’re an EEA user, you can:
- Access the information we hold about you. We’ll usually share this with you within 30 days of you asking us for it.
- Have your information corrected or deleted. You can update your information in your settings. If you have problems updating the information or if you would like us to delete it, contact us.
- Object to us processing your information. You can ask us to stop using your information, including when we use your information to send you marketing emails or push notifications. If you opt out of receiving marketing messages from us, we may still send you newsletters and updates about your account, such as when another user comments on one of your posts. We only send you marketing material if you’ve agreed to it, but if you’d rather we don’t, you can easily unsubscribe at any time.
- Complain to a regulator. If you’re based in the EEA and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Ireland or with your local supervisory authority.
Consent Declaration
How do you get my consent?
When you provide us with personal information, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How Do I Withdraw My Consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at
Children’s Privacy
Our Service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.
Third Party Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Governing Laws
Our privacy policy has been prepared to comply with the laws of England and every country or legal jurisdiction in which we aim to do business including the European Union Regions under the GDPR Compliance Regulation. If you think this Privacy Policy fails to satisfy the law of your jurisdiction, please contact us and do not use our Website until the Policy is compliant to applicable laws in your jurisdiction.
However, ultimately it is your choice as to whether you wish to use our website. Any dispute arising in connection with these terms of use shall be subject to the exclusive jurisdiction of the Courts of England
Changes To Our Privacy Policy
We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our Website.
Anti-Abuse
If you suspect a client of abusing our services, please contact us at sales@SmGains.com . All complaints are investigated, and you will receive a response on the action we will take to resolve the issue.
Complaints should be submitted in writing or by e-mail to the addresses of the Seller provided in these Regulations.
It is recommended that the complaint include a brief description of the defect, circumstances (including date) of its occurrence, data of the Customer submitting the complaint, and the Customer’s request in relation to the defect of the goods.
The Seller shall respond to the complaint request immediately, or no later than within 14 days. If the seller does not respond to the complaint within 14 days, it is considered that the Customer’s request was considered justified.
Contact Us
We are committed to respecting the freedoms and rights of all our SmGains users who have placed their trust in our service. If you should have any questions or concerns regarding this Privacy Policy, or if you would like to file a Data Protection request, please contact us on our channels on