Smarte Group Privacy Policy

Effective May 11, 2026

WELCOME! This Privacy Policy is here to help you understand how we collect, use, disclose, and process your Personal Data (as defined below). We also describe your choices and rights with respect to how we process that Personal Data. Please read this policy carefully.

Your use of our Services indicates your acknowledgment of the practices described in this Privacy Policy.

WHO WE ARE

This is the Privacy Policy (“Privacy Policy”) of Smarte Group, Inc. (“Company”, “us”, “our”, or “we”), a company registered in the United States of America with an address of 4455 White Bear Parkway, St. Paul, MN 55110-7641. You can contact us using the information below.

SCOPE

This Privacy Policy applies to our “Services” which include:

• our website at smarte-group.com (including any subdomains or mobile versions of the “Corporate Site”); and
• any other website or services where we post or reference this Privacy Policy.

This Privacy Policy applies only to our Services. This Privacy Policy does not apply to information processed by other third parties unless those parties collect or process information on our behalf. Please review any relevant third party’s privacy policy for information regarding their privacy practices.

COLLECTION AND USE OF PERSONAL DATA

Personal Data We Collect

We may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data:

Identity Data — Personal Data about you and your identity, such as your name, employer/company affiliation, and other similar identifiers.

Contact Data — Personal Data used to contact an individual, e.g. email address, physical address, or phone number.

Device Data — Personal Data relating to your device, browser, or application, e.g. IP addresses, MAC addresses, identifiers from cookies, session history and similar browsing metadata, and other data generated by your device or browser, including via cookies and similar technologies.

User Content — Any information or content you provide in connection with a request or inquiry submitted through our Services, including any additional Personal Data you may include.

Sources of Personal Data

We collect Personal Data from the following sources:

You — We collect Personal Data from you directly, for example, when you input information into an online form or contact us directly.

Your Devices — We may collect certain Personal Data automatically from your devices. For example, we collect Device Data automatically using cookies and similar technologies when you access our Corporate Site or when you open our marketing communications.

Service Providers — We receive Personal Data from third parties with whom we have a relationship in connection with their performance of services on our behalf.

Data we create — We (or third parties operating on our behalf) create and infer Personal Data based on our observations or analysis of other Personal Data we process, and we may correlate this data with other data we process about you.

Personal Data Processing Contexts

Marketing Communications

We may process Identity Data, Device Data, and Contact Data in connection with email or other marketing or promotional communications, which you might receive if you choose to opt in. We may use Identity Data and Contact Data as necessary to customize, deliver, and otherwise process marketing communications, and for other appropriate Business Purposes.

We may also automatically collect Device Data and related Identity Data from devices receiving marketing communications if you open or interact with those communications. We may process such Personal Data as part of our business interests in understanding engagement with our marketing activity.

Feedback and Surveys

We generally process Identity Data, Contact Data, and User Content collected in connection with surveys or questionnaires. We process this Personal Data to respond to requests or concerns, to create aggregate analytics, and to improve our Services.

Contact Us

When you contact us through the Services using a contact form, via chat, or via email, we process Personal Data such as Identity Data, Device Data, and any User Content you provide. We use this Personal Data as necessary to communicate with you about the subject matter of your request and related matters. We may use such Personal Data for marketing purposes where permitted by applicable law, as well as for appropriate Business Purposes.

Corporate Site

When you access our Corporate Site, we automatically collect and process Device Data and certain Identity Data (such as your IP address or similar identifiers). We use this data as necessary to deliver certain features or functions through our Services, such as maintaining sessions, delivering pages, and logging activities for security purposes. We use this Personal Data as necessary to provide the Services and features that users access and for appropriate Business Purposes.

Cookies and Similar Tracking Technologies

We, and certain third parties, automatically collect and process Identity Data, Contact Data, and Device Data when you interact with cookies and similar technologies on our Corporate Site. Subject to your rights and choices, we may use this information as follows:

1. For “essential” or “functional” purposes, such as to enable various features of the Services and maintain a session. Strictly necessary cookies may be installed without consent, and you may be unable to limit the collection of data via strictly necessary cookies in order to use our Services.
2. For “analytics” and “personalization” purposes, consistent with our legitimate interests in understanding how the Services are used and how users engage with and navigate through the Services. For example, we use Google Analytics to better understand who is using the Service and how. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information.
3. For “advertising,” so that you may see content from us or relating to our Services on other websites or devices. These tracking technologies may help prevent you from seeing the same content too many times and help us understand whether you have interacted with or viewed material delivered to you.

Support

We collect and process Identity Data, Contact Data, and in some cases Device Data and User Content when you contact us for support. We use this Personal Data as necessary to respond to your request and for appropriate Business Purposes.

Business Purposes of Processing

In addition to the specific processing purposes described above, we typically process Personal Data for the following general Business Purposes:

Contractual Necessity; Service Provision — We process Personal Data as necessary to provide the Services and fulfill our contractual obligations to you.

Our Legitimate Interests and Internal Business Purposes — We may process Personal Data as appropriate in connection with our legitimate interests, including: improving or optimizing the design and functionality of our Services; developing new features; personalizing the Services; customer service; assessing compliance with applicable agreements and laws; internal reporting and modeling; detecting, preventing, and responding to information security risks; and detecting and mitigating fraud.

Aggregate Data — We process Personal Data as necessary in connection with our legitimate interests in creating aggregate analytics relating to how our Services are used. The resulting aggregate data will not contain information from which an individual may be readily identified.

Transactional Communications — To respond to communications, reach out to you about your use of our Services, and provide relevant notifications or information.

Security, Safety, and Fraud Prevention — To protect our users, employees, and Company, for loss prevention, to enforce our contractual rights, and to prevent fraud.

Corporate Activity — We may process Personal Data as necessary to carry out actual or prospective corporate transactions, including mergers, acquisitions, and related due diligence.

Compliance and Public Interest — We may process Personal Data as necessary to comply with legal obligations, for the establishment and defense of legal claims, in response to lawful requests from government or law enforcement officials, or as required to meet national security or law enforcement requirements or to prevent illegal activity.

DATA SHARING

Information we collect may be shared with or made available to a variety of parties depending upon the purpose for and context in which that information was provided.

Service Providers — We may share Personal Data with processors, service providers, or subprocessors who provide services or process data on our behalf, such as cloud-based hosting providers.

Corporate Events — Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, sale of assets, joint venture, bankruptcy, reorganization, or dissolution.

Affiliates — We may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies to streamline business operations and develop products and services.

Legal Disclosures — In some circumstances, we may, without notice or your consent, disclose your Personal Data to the extent we believe such disclosure is legally required, in response to requests from government agencies or authorities, to prevent or respond to a crime, or to investigate violations of applicable contractual obligations.

Other Disclosures — We may disclose any Personal Data in accordance with your consent or on certain public interest grounds.

YOUR RIGHTS AND CHOICES

Your Rights

You may have certain rights in the Personal Data we process. Please note these rights may vary based on the country or state where you reside and our obligations under applicable law. To submit a request to exercise your rights, you may email us at [email protected].

Rights Request Verification

If you submit a request, we typically must verify your identity to ensure that you have the right to make that request, reduce fraud, and to ensure the security of Personal Data. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

Your Choices

Consent — If you consent to processing, you may withdraw your consent at any time.

Marketing Communications — You have the choice to opt out of or withdraw your consent to marketing communications. You may exercise your choice via the links in our communications or by contacting us directly.

Cookies and Similar Technologies — If you do not want information collected through the use of cookies and similar technologies, you can manage or deny cookies using your browser’s settings menu. You must opt out of some third-party services directly via the third party. For example, to opt out of Google’s analytic and marketing services, visit the Google Ads Privacy Policy, or download and install Google’s opt-out browser add-on.

Under the California Consumer Privacy Act (“CCPA”) and other state privacy laws, residents of certain US states may also have the following rights, subject to regional requirements, exceptions, and limitations:

Confirm — Right to confirm whether we process your personal data.

Access/Know — Right to request information about the categories and specific pieces of personal data we have collected, the sources from which it was collected, the purposes for which it was collected, and the categories of third parties with whom it has been shared.

Portability — Right to request that we provide certain personal data in a common, portable format.

Deletion — Right to delete certain personal data that we hold about you.

Correction — Right to correct certain personal data that we hold about you.

Non-Discrimination — California residents have the right not to receive discriminatory treatment as a result of their exercise of rights conferred by the CCPA.

To exercise your rights and choices, please contact Smarte Group at smarte-group.com/contact.

SECURITY

We implement and maintain commercially reasonable security measures to protect your Personal Data from unauthorized processing. While we endeavor to protect our Services and your Personal Data from unauthorized access, use, modification, and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

DATA RETENTION

We retain Personal Data for so long as it is, in our discretion, necessary to achieve the processing purposes described in this Privacy Policy, and in any event for so long as is required by law or necessary to provide the Services. We will review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods. We may also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and for the period required or permitted by applicable law.

MINORS

Our Services are neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. We do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.

CONTACT US

Smarte Group, Inc. 4455 White Bear Parkway St. Paul, MN 55110-7641 Phone: 651-429-3614 1-800-838-1176 (toll-free) [email protected]