Data Subject Rights Policy

As stated in our privacy policy, our advertising technology does not collect any information that directly identifies you as an individual, and instead only collects certain digital identifiers that may identify your device or your Internet browser.

As such, in order to provide you with access to personal data connected with your Digital Identifiers, you will need to provide us with additional information, as explained below, to enable us to locate relevant records.

Your rights

If you are a resident within the European Economic Area (EEA), you have the right to access, correct and erase any data we might have concerning you, as well as to withdraw the consent for processing such data – wholly, or only for certain forms of processing.

If you make a data subject rights request as set out in this policy, we will provide you with any information we might have concerning your data identifier, including where available transaction logs reflecting where we have used our technology in order to deliver an advertisement to you, and we will follow your instructions concerning the correction, removal and processing of such data.

Please note, however, that we have a very short retention period for most files with Digital Identifiers that we store or process. As such, we may not be able to provide you any files at all. In such cases, however, we will inform you that we have not been able to locate any records associated with your digital identifiers.

How to make a request

Step 1: Locating your digital identifiers

In order for us to locate relevant records, we will need you to provide us with your digital identifiers. You can find your digital identifiers as follows:

  • Web Browsing

As described in our privacy policy, our advertising technology may operate by using text files called “cookies” that are placed on your device. Some of these cookies include a digital identifier. To locate these digital identifiers, you can search through your cookies for the cookies named smxtrack, or smaxtrackid_{{order_id}}, where “order_id” is a number. The text in each of these cookies is a separate digital identifier.

Please keep in mind that different cookies are placed on each browser that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox), you will need to locate the different cookies for each browser. If you need assistance locating these cookies for your browser, please feel free to email us for assistance at privacy@smadex.com

  • Mobile Devices

Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate a persistent “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifier.

Step 2: Verification of Your Digital Identifiers

In order to make sure that we are only providing personal data to the correct person, we also will need some supporting proof to demonstrate that you are indeed connected to the digital identifiers you located in Step 1. For digital identifiers stored in cookies, please take a screenshot of each cookie, taking care to make sure that the screenshot shows both the name of the cookie and the full digital identifier. For digital identifiers located on a mobile device, please take a screenshot of a screen that displays the digital identifier. Additionally, please sign and send a scanned copy of a statement attesting that the Digital Identifiers you have locate are indeed associate with you, with a copy of a national ID or passport.

Step 3: Contacting us

Once you have located your digital identifiers and can provide us with verification concerning them, you should reach out to us. The easiest way to do so would be to email us at privacy@smadex.com. Please make sure to include the following information in your email:

  • Your full name
  • The country in which you are located at the time you are making your request
  • A full list of your Digital Identifiers
  • Supporting proof, as described in Step 2
  • A signed statement, as described in Step 2

You can also make a subject access request by mail, by sending a written request with all of the above-listed information to the following address:

Data Protection Officer

Smadex S.L.

c/ Rosselló 33 SA

08029 Barcelona-Spain