Smart Alto

Privacy Policy

Protecting Your Privacy



Last Updated: May 2, 2016


SmartAlto ("SmartAlto" "we" “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy.

Please note that by visiting or using
(the “Site”), the SmartAlto desktop and mobile applications (the
“Applications”) and/or the real estate-related services and the various other
related features, functions, software, applications, websites and networks
(collectively, the “Services”) provided by SmartAlto, you are accepting the
practices described in this privacy policy. This privacy policy is incorporated
by reference into the Terms of Service (the “Terms”) that govern your use of
the Site, the Applications and the Services.


This policy describes the types of information we may
collect from you or that you may provide when you access or use the Site, the
Applications, the Services or other features, functions, services products and
our practices for collecting, using, maintaining, protecting and disclosing
that information.


This policy applies to information we collect:


In accessing and using the Site.

In registering to use the Applications and the Services.

In accessing and using the Applications and the Services.

In e-mail, text and other electronic messages sent through or use of the Site, the Applications and the Services.

When you interact with other users of the Applications and the Services.

When you send any content through the Site, the Applications or the Services.

When you interact with our advertising and applications on third-party websites and services.

Through services provided to us by companies, agents or contractors.

Through services provided to you by companies, agents or contractors.

It does not apply to information collected by:


Us offline or through any other means, including on any other website operated by SmartAlto or any Third party; or

Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site, the Applications or the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Services, the Applications or the Site. By accessing or using the Services, the Applications or the Site, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Services, the Applications and/or the Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.


Minors under the Age of 18


Neither the Site nor the Applications are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site, the Applications or the Services. We do not knowingly collect personal information from children under 13. If you are under 18, do not use or provide any information on or through the Site, the Applications or the Services or any of its features/register on the Site or the Applications, use any of the interactive or public comment features of the Site. the
Applications or the Services or provide any information about yourself to us,
including your name, address, telephone number, e-mail address or any screen
name or user name you may use. If we learn we have collected or received
personal information from a child under 13 without verification of parental
consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at


Information We Collect About You and How We Collect It


We collect or may collect several types of information from
and about users of the Site, the Applications and the Services, including:


Information by which you may be personally identified, such
as name, postal address, mobile number and e-mail address ("personal

Financial and billing information;

Analytics information

Information that is about you but individually does not
identify you, such as IP address and date and time of visit;

Information from your device, including contact information,
and images and other information from your device’s camera and photos;

Usage information, including how you communicate with other users of the Services, the Applications and the Site, such as the time, date, sender, recipient of a picture, the number of messages you exchange with other users, which users you exchange messages with the most, and your interactions with messages (such as when you open a message or capture a screenshot);

The content you provide and information about that content,
such as if the recipient has viewed the content, replayed the content, and the metadata
that is provided with the content;

Information contained in the comments and postings on or through the Applications or the Site;

Device information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number);

Location information when you use the Applications or the
Site; and/or

About your internet and mobiles connections, the equipment and operating system you use to access the Services, the Applications and the Site usage details.

We collect this information:

Directly from you when you provide it to us.

Automatically as you navigate through or use the Site, Applications and the Services. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies.

From third parties, for example, our customers, business partners and other third parties that provide us or you with certain services.

Certain web transactions may also involve you calling us or our calling you. Please be aware that we may monitor and in some cases record such calls for staff training or quality assurance purposes.


Personal Information Definition


Information You Provide to Us. The information we collect on
or through the use of the Services, the Applications or the Site may include:


Information that you provide by registering or filling in
forms or applications on or through the Applications or the Site. This includes
information provided in connection with registering to access and use the
Services and the Applications, posting photos, comments and other information
or requesting further services or products. We may also ask you for information
when you report a problem with the Services, the Applications or the Site.

Records and copies of your correspondence (including e-mail
addresses), if you contact us.

Your responses to surveys and questionnaires that we might
ask you to complete for research and marketing purposes.

Details of transactions you carry out through the Services,
the Applications or the Site, including registration for the Services. You may
be required to provide financial or payment information before being able to
access certain features and services available through the Applications or the

Your search queries on or through the Site, the Applications
or the Service

You also may provide pictures, audio and video recordings,
text, data, information and other input or any other content linked, posted,
and/or submitted by you or other users to be published or displayed
(hereinafter, "posted") on the Site or the Applications, or
transmitted to other users of the Services, the Applications or the Site or
third parties (collectively, "User Content"). Your User Content is
posted on and transmitted to others at your own risk. We cannot control the
actions of other users of the Services, the Applications or the Site with whom
your User Content is shared. Therefore, we cannot and do not guarantee that
your User Content will not be viewed by unauthorized persons.


Information We Collect through Automatic Data Collection
Technologies. As you navigate through and interact with the Services, the
Applications or the Site, we use or may use automatic data collection
technologies to collect certain information about your equipment, browsing
actions and patterns, including:


Details of your use of the Services, the Applications or the
Site, including traffic data, location data, logs and other communication data
and the resources that you access and use on or through the Services, the
Applications or the Site.

Information about your computer, mobile phone and other
devices, internet and mobile connection, including your IP address, operating
system and browser type.

The information that we collect automatically is statistical
data and does not include personal information, but we may maintain it or
associate it with personal information we collect in other ways or receive from
third parties or you provide to us. It helps us to improve the Services, the
Applications and the Site and to deliver a better and more personalized
service, including by enabling us to:


Estimate our audience size and usage patterns.

Store information about your preferences, allowing us to
customize the Applications and the Site according to your individual interests.

Speed up your searches.

Recognize you when you return to the Applications or the

Use of Cookies and Other Tracking Technologies.


The technologies we use for this automatic data collection
may include:


Cookies (or browser cookies). A cookie is a small file
placed on the hard drive of your computer. You may refuse to accept browser
cookies by activating the appropriate setting on your browser. However, if you
select this setting you may be unable to access certain parts of the Site.
Unless you have adjusted your browser setting so that it will refuse cookies,
our system will issue cookies when you direct your browser to the Site.

Other Tracking Technologies. In the future, we may use other
tracking technologies for automatic data collection.

Third-party Responsibilities and Services.


We may use or partner with other third party companies,
agents or contractors for various purposes in connection with our business and
operations (“Service Providers”), including, billing and payments, relationship
building, the marketing and growth of our business and the performance of
services on our behalf, such as gathering and analyzing information and the
provision of services to you. In the course of performing these
responsibilities and providing such services, these other companies may have
access to your information. We may also share information, including your
information, with these Services Providers in order to enable them to perform
these responsibilities and to provide these services. Many Services Providers
have adopted their own privacy policies, which are not subject to control by
SmartAlto. You should always review the policies of these Service Providers to
make sure that you are comfortable with the ways in which they collect, use,
maintain, protect and disclose your information.


Use of Remarketing with Google Analytics and Google Adwords


The Site may use the Google AdWords remarketing service to
advertise on third party websites (including Google) to previous visitors to
the Site. It could mean that we advertise to previous visitors who haven’t
completed a task on the Site, for example using the contact form to make an
enquiry. This could be in the form of an advertisement on the Google search
results page, or a site in the Google Display Network. Service Providers,
including Google, use cookies to serve ads based on someone’s past visits to
the Site. Of course, any data collected will be used in accordance with this
privacy policy, Google’s privacy policy or the privacy policy of other
remarketing services used by SmartAlto.


You can set preferences for how Google advertises to you
using the Google Ad Preferences page, and if you want to, you can opt out of
interest-based advertising entirely by cookie settings or permanently using a
browser plugin.


DoubleClick: We may use Google Analytics remarketing codes
to log when users view specific pages or take specific actions on a website.
This allows us to provide targeted advertising in the future. If you do not
wish to receive this type of advertising from us in the future you can opt out
using the DoubleClick opt-out page or the Network Advertising Initiative
opt-out page.


Google has additional information available about its
Remarketing Privacy Guidelines, Policies, and Restrictions on its website.


How We Use Your Information


We use information that we collect about you or that you
provide to us, including any personal information:


To provide you the Services and the Applications and the
content and the other products and services that you request from us.

To provide the Site and its contents to you.

To process and complete transactions, including registration
for the Services, and send you related information.

To provide technical and other support to you.

To send you promotional communications, such as providing
you with information about services, features, surveys, newsletters, offers and
events; and providing other news or information about us, our customers and our
select partners. You have the ability to opt out of receiving any of these
communications through the unsubscribe mechanism at the bottom of the
applicable email.

To enable Service Providers to perform certain
responsibilities and provide certain services in connection with our business
and operations.

To fulfill any other purpose for which you provide it.

To provide you with notices about your account.

To carry out our obligations and enforce our rights arising
from any contracts entered into between you and us, including for billing and

To notify you about changes to the Services, the
Applications or the Site and other products and services we offer or provide
though it.

To allow you to participate in interactive features on or
through the Services, the Applications and/the Site.

To personalize the services by, among other things,
providing advertisements, content, or features that match user profiles,
interests, or previous activities.

To enhance the safety and security of the Services, the
Applications and the Site and our products and services.

To verify your identity and prevent fraud or other
unauthorized or illegal activity.

To enable marketing, remarketing and similar services from
Service Providers, including advertisement on third party websites.

To perform targeted and other advertising on third party

In any other way we may describe when you provide the

For any other purpose with your consent.

We may store any information that we collect (personal or
otherwise) ourselves or in databases owned and maintained by our affiliates,
agents or service providers. If you use the Services, the Applications or the
Site outside of the United States, information that we collect about you may be
transferred to servers inside the United States and maintained indefinitely,
which may involve the transfer of information out of countries located in the
European Economic Area and other parts of the world unless otherwise prohibited
by applicable law or agreed by SmartAlto and you. By allowing SmartAlto to
collect information about you, you consent to such transfer and processing of
such information without restriction. We may also store some information
locally on your computer or other devices. For example, we may store
information as local cache so that you can open the Site and the Applications
and view content faster.


We may also use your information for on-line behavioral
advertising regarding our own and third party products and services that we
believe may be of interest to you. If you do not want us to use your
information in this way, you may opt-out as described below in Choices About
How We Use and Disclose Your Information.


Although users from all over the world may access the Site,
the Applications and the Services, keep in mind that no matter where you live
or where you happen to use our services, you consent to us processing and
transferring information in and to the United States and other countries whose
data-protection and privacy laws may offer fewer protections than those in your
home country.


SmartAlto will not sell or disseminate personal, end user
information to third parties.


Disclosure of Your Information


We may disclose aggregated information about our users, and
information that does not identify any individual, without restriction.


We may disclose personal information that we collect or you
provide as described in this privacy policy:


To our subsidiaries and affiliates.

To our customers in connection with the Services.

To Service Providers, contractors and other third parties we
use to support our business, including credit card payment processors and
marketing support.

To a buyer or other successor in the event of a merger,
divestiture, restructuring, reorganization, dissolution or other sale or
transfer of some or all of SmartAlto's assets, whether as a going concern or as
part of bankruptcy, liquidation or similar proceeding, in which personal
information held by SmartAlto about users of the Site or the Applications is
among the assets transferred.

To fulfill the purpose for which you provide it.

For any other purpose disclosed by us when you provide the

With your consent.

We may also disclose your personal information:


To comply with any court order, law or legal process,
including to respond to any government or regulatory request.

To enforce or apply the Terms and other agreements,
including for billing and collection purposes.

If we believe disclosure is necessary or appropriate to
protect the rights, property, or safety of SmartAlto, our customers or others.

Choices About How We Use and Disclose Your Information


We strive to provide you with choices regarding the personal
information you provide to us. We have created mechanisms to provide you with
the following control over your information:


Tracking Technologies and Advertising. You can set your
browser to refuse all or some browser cookies, or to alert you when cookies are
being sent. To learn how you can manage your Flash cookie settings, visit the Flash
player settings page on Adobe's website. If you disable or refuse cookies,
please note that all or some parts of the Site, the Applications and/or the
Services may then be inaccessible or not function properly.

Promotional Offers from SmartAlto. If you do not wish to
have your e-mail address/contact information used by SmartAlto to promote our
own or third parties' products or services, you can opt-out through the
unsubscribe mechanism at the bottom of the applicable email. This opt out does
not apply to information provided to SmartAlto as a result of a service or
other transactions.

We do not control third parties' collection or use of your
information to serve interest-based advertising. You may be able to opt out of
receiving personalized advertisements from companies who are members of the
Network Advertising Initiative or who subscribe to the Digital Advertising
Alliance's Self-Regulatory Principles for Online Behavioral Advertising. For
more information about this practice and to understand your options, please
visit: and
You may also use TRUSTe's Preference Manager at


Accessing and Correcting Your Information


You can review and change your personal information by
logging into the Applications and visiting your account profile page.


You may also send us an e-mail at to
request access to, correct or delete any personal information that you have
provided to us. We cannot delete your personal information except by also
deleting your user account. We may not accommodate a request to change
information if we believe the change would violate any law or legal requirement
or cause the information to be incorrect.


If you delete your User Content from the the Applications or
the Site, copies of your User Content may remain viewable in cached and
archived pages, or might have been copied or stored by other users of the
Servers, the Applications or the Site. Proper access and use of information
provided on or through the Site, the Applications or the Services, including
User Content, are governed by the Terms.


Your California Privacy Rights


California Civil Code Section § 1798.83 permits users of the
Application or the Site that are California residents to request certain
information regarding our disclosure of personal information to third parties
for their direct marketing purposes. To make such a request, please send an
e-mail to


Data Security


We understand that the security of your personal information
is important. We provide reasonable administrative, technical, and physical
security controls to protect your personal information. However, despite our
efforts, no security controls are 100% effective and SmartAlto cannot ensure or
warrant the security of your personal information. Any transmission of personal
information is at your own risk. We are not responsible for circumvention of
any privacy settings or security measures contained on the Site.


The safety and security of your information also depends on
you. Where we have given you (or where you have chosen) a password for access
to certain parts of the Site and/or or the use of the Services and the
Applications, you are responsible for keeping this password confidential. We
ask you not to share your password with anyone. We urge you to be careful about
giving out information in public areas of the Applications or the Site. The
information you share in public areas may be viewed by any user of the
Applications or the Site.


Changes to Our Privacy Policy


It is our policy to post any changes we make to our privacy
policy on this page with a notice that the privacy policy has been updated on
the home pages of the Applications or the Site for at least 30 days. If we make
material changes to how we treat our users' personal information that are
materially less protective than provided in this policy, we will use reasonable
efforts to notify you by e-mail to the e-mail address specified in your account
and/or through a notice on the home pages of the Site and to attempt to get
your consent to the changes. The date the privacy policy was last updated is
identified above. You are responsible for ensuring that we have an up-to-date
active and deliverable e-mail address for you, and for periodically visiting
the Site and this privacy policy to check for any changes. Like our Terms, of
which this policy is a part, your use of the Services, the Applications or the
Site, and/or continued use of the Services, the Applications or the Site after
our efforts to contact you means that you agree to be bound by such changes.




The policies indicated in this privacy policy will remain
effective, even if the Terms and the agreement between us are terminated and
you are no longer using the Services, the Applications or the Site.


Contact Information


To ask questions or comment about this privacy policy and
our privacy practices or need to reach us for any other reason, you may contact
us by e-mail at


© Copyright SmartAlto 2017