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Here you can find all the information regarding the data processing principles of SMARTdo. 


1.    Definitions 


1.1    Data Subject is a natural person about whom SMARTdo has got information or data enabling to identify the natural person. Data Subjects are, for example, clients, cooperation partners, as well as the employees who are natural persons and whose personal data are held by   



1.2    Privacy Policy is this text which sets out the principles for Personal Data Processing by 



1.3    Personal Data is any information concerning an identified or identifiable natural person. 


1.4    Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject. 


1.5    Agreement is any agreement entered into between SMARTdo and the Data Subject 

1.6    Child is a person who is under 13 years of age in the context of Personal Data Processing. 


1.7    SMARTdo’s Person Responsible for Data Protection is the person who monitors the implementation of the Personal Data Processing principles at SMARTdo and who can be contacted by the Data Subject in case of a complaint. 


1.8    Data Concerning Health means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status. 


The above words and expressions are used in the meanings set out above in the Privacy Policy, Agreement, Terms and Conditions and in the communication between the parties. 


2.    General Provisions 


2.1    SMARTdo is a legal person (private limited company), registry code 12898621, with registered address: Niine Põik 4, Haapsalu 90507 Estonia.  


2.2    SMARTdo may process Personal Data as: 


(1)   a controller, while determining the purposes and means of processing; (2)   a processor in accordance with the instructions from the controller; and 

(3)   a recipient to the extent to whom the Personal Data are transferred. 


2.4  The rights and obligations set out in the Privacy Policy shall be followed by all the employees and cooperation partners of SMARTdo who come into contact with the Personal Data that are in the possession of SMARTdo. 



3.    Principles 



3.1    SMARTdo shall always take into account the interests, rights and freedoms of Data Subjects. The objective of SMARTdo is to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes. 



3.2    All the processes, guidelines, operations and activities of SMARTdo that are related to Personal Data Processing are based on the following principles: 

(1)   Lawfulness. There is always a legal basis for the Processing of Personal Data, i.e. consent; (2)  Fairness. Personal Data Processing shall be fair, while providing a Data Subject with sufficient information and communication on how the Personal Data are Processed; (3)   Transparency. Personal Data Processing shall be transparent for the Data Subject; 

(4)    Purposefulness. Personal Data shall be collected for legitimate purposes that have been established precisely and clearly, and shall not later be processed in any manner which is in conflict with these purposes. A Data Subject will always be able to examine the established purpose of Processing for a specific purpose; 

(5)    Minimisation. Personal Data shall be adequate, relevant and limited to what is necessary for the purpose of Processing the given Personal Data. SMARTdo shall be guided by the principle of minimum Processing in Personal Data Processing, and as soon as the Personal Data are no longer necessary or are no longer needed for the purposes for which they were collected, the Personal Data shall be deleted or archived; 

(6)    Accuracy. Personal Data shall be correct and shall be updated as necessary, and all reasonable measures shall be taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing shall be deleted or corrected without delay; (7)  Limit of storage. Personal Data shall be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data are processed. It means that in case SMARTdo wishes to store the Personal Data for a longer period of time than necessary for the purpose of collecting the data, SMARTdo shall anonymise the data in such manner that the Data Subject shall no longer be identifiable. SMARTdo shall store the data that have been received in accordance with data in accordance with deadlines set by law.  

The data processed under the basis of consent will generally be retained by SMARTdo until consent is withdrawn or data is no longer necessary.  

(8)  Reliability and confidentiality. Personal Data Processing shall be carried out in the manner ensuring the adequate security of Personal Data, including their protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organisational measures.  


3.3  Upon Personal Data Processing, SMARTdo shall act with the purpose of always being capable of evidencing the conformity to the aforesaid principles and additional information regarding the conformity to these principles can also be requested from the Person Responsible for Data Protection. 


4.    Composition, bases and purposes for processing Personal Data 


4.1 Personal Data generated for the management of relationships with the clients and suppliers (e. g.  name, phone number, e-mail address, postal address, correspondence, information about accounts and invoices) is processed on the basis of the Agreement to which the Data Subject is party or in order to take steps at the request of the Data Subject prior to entering into the Agreement. Purposes for processing this data: 

(1)    to take steps at the request of the Data Subject prior to entering into the Agreement; 

(2)    to identify the Client to the extent required by due diligence; 

(3)    to perform the obligations to the Client regarding the provision of its Services; 
(4)    to communicate with the Client; 
(5)    to ensure the performance of the payment obligation of the Client; 
(6)    to submit, realise and defend claims. 

When processing on the basis of the Agreement, depending of content of the Agreement we will retain Personal Data after the expiry of the Agreement for 3 years or until the deadlines specified in the law. 

4.2    Personal Data generated for the management of relationships with the clients could also include data concerning health and legal basis for processing data is explicit consent of the Data Subject. The purpose of processing this data is to ensure that vibroacoustic therapy is not contraindicated for the client. Data Subject has a right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.  

​4.3    Personal Data generated in regards with the employment relationships (e. g. name, contacts, education, former work experience, personal data collected from state databases) is processed on the basis of legal obligations of SMARTdo and employment contracts.  


​4.4    Personal Data manifestly made public by the Data Subject (e.g. in social media) is processed on the basis of the legitimate interests of SMARTdo to be competitive in the market. SMARTdo shall process Personal Data on this legal basis only after careful consideration in order to ascertain the legitimate interest of SMARTdo, based on which the Personal Data Processing is necessary and is in compliance with or overrides the interests and rights of a Data Subject. 


​4.5    SMARTdo uses Personal Data for direct marketing only with the consent of the Data Subject. SMARTdo follows the principle that every consent shall be clearly distinguishable from other matters, in an intelligible and easily accessible form, using clear and plain language. A Data Subject shall give the consent freely, specifically, informedly and unambiguously, for example by ticking a box on the Website. On the basis of consent, SMART do processes Personal Data, for example if the Data Subject wishes to subscribe to the newsletter, such consent is for an indefinite period and is valid until the Data Subject has withdrawn his/her consent. 


​4.6    Generally, SMARTdo retains data in accordance to deadlines set by law. 


​5.    Processing Personal Data of children 


​5.1    SMARTdo does not knowingly collect any information on persons under 13 years of age, i.e. Children. In case SMARTdo finds out that it has still collected Personal Data from a Child or regarding a Child, SMARTdo shall use its best efforts to discontinue the Processing of the respective Personal Data. 


​6.    Rights of Data Subject 


​6.1    A Data Subject will always be entitled to inform SMARTdo about his or her wish to withdraw the consent for the Personal Data Processing by contacting SMARTdo via  


​6.2    In general, the data subject has the following rights: 


​(1)    Right to receive information i.e. the right of a Data Subject to receive information regarding the Personal Data collected about him or her. 

(2)    Right of access to data which, inter alia, includes the right of a Data Subject to a copy of the Processed Personal Data. 

(3)    Right to rectification of inaccurate Personal Data. A Data Subject will be able to correct inaccurate data by contacting

(4)    Right to erasure of data i.e. in certain cases a Data Subject will be entitled to demand the deletion of Personal Data, for example if the Processing is carried out only on the basis of a consent. 

(5)    Right to demand restriction of Personal Data Processing. This right is created, inter alia, in case the Personal Data Processing is not permitted under law or if the Data Subject challenges the accuracy of the Personal Data. A Data Subject will be entitled to demand the restriction of the Personal Data Processing for a period enabling the processor to check the accuracy of the Personal Data or if the Personal Data Processing is unlawful but the Data Subject does not request the deletion of the Personal Data. 

(6)    Right to data portability i.e. a Data Subject shall have, in certain cases, the right to receive the Personal Data in a machine-readable format, and to take these data along or transfer them to another controller. 

(7)    Right to the assessment of a supervisory authority on whether the Processing of the Personal Data of the Data Subject is lawful; 

(8)    Compensation for damage, if the personal data processing has caused damage to the data subject. 


7. Filing of complaints 


7. 1  A Data Subject will be entitled to address SMARTdo using the contact details set out in section 10 in case of any question, request or complaint related to Personal Data Processing. A Data Subject will be entitled to address a complaint to SMARTdo and the Person responsible for data protection of SMARTdo, to the Data Protection Inspectorate or to a court if the Data Subject is of the opinion that his or her rights have been infringed in Personal Data Processing. 

​7.    The contact details of the Data Protection Inspectorate are available on the website of the Data Protection Inspectorate: 


​8.    Social media accounts of SMARTdo 


SMARTdo has created and manages accounts in social media Facebook and Twitter. All the information Data Subjects provides on social media Facebook, Twitter (including notifications, use of "Like" and "Follow" and other communications) or which comes from Data Subject visiting SMARTdo’s Facebook or Twitter accounts (including information from cookies used by social media) or reading SMARTdo’s posts on social media network is controlled by Facebook, Twitter. Therefore, it is recommended to read Facebook and Twitter privacy notices, and contact them directly for the use of Personal Data. 


As a Facebook and Twitter accounts administrator, SMARTdo selects the appropriate settings based on its target audience and goals for performance management and promotion. SMARTdo cannot influence what information Facebook and Twitter will collect about the Data Subject via the accounts on the social networks. 


To learn more about Facebook Privacy Policy, click here 


To learn more about Twitter, click here 


More     information     about     cookies     Facebook     uses     is     available     at  


More information on cookies Twitter uses is available at  

​9.    Cookies 


​9.1    SMARTdo may collect data regarding the visitors of the website by using cookies for this purpose (i.e. small pieces of information stored by the visitor’s browser on the hard disk of the computer or any other device of the visitor) and process these data. 


​9.2    SMARTdo uses these types of cookies which you can accept: 


9.3    SMARTdo uses a number of cookies that are strictly necessary for the functionality of the platform and thus do not require consent. Therefore, Cookies that are required are always set for the following features: 

(1)    Login; 

(2)    User-defined browser settings (e.g. country, language or font size); 

(3)    Authentication cookies (verification of user ID for access to secure websites); 

(4)    User validation cookies (protection against (repeated) login errors); 

(5)    Media player cookies (network speed or image quality control and video or audio file activation); 

(6)    Social media plugins (share or like features); 

(7)    Load balancing (balancing access to the platform). 


9.4 Cookies can be disabled in the browser, including deleting the browser history. However, if that is done, the way how the platform works might be affected.  


10.    Contact details 


Regarding Personal Data issues, SMARTdo can be contacted by e-mail


11.    Other terms 


SMARTdo will be entitled to unilaterally amend this Privacy Policy. SMARTdo shall inform Data Subjects about the amendments via its website.  

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