General Data Protection Regulation (GDPR) Compliance Policy

The Company collects personal data primarily through its official website forms, specifically utilizing the WordPress – Contact Form 7 infrastructure, and through direct professional communications. This systematic collection is conducted in strict accordance with the principle of Data Minimization.

Data collected is limited to information relevant for contacting you and understanding your business needs. By submitting a form, the data subject acknowledges that this transmission is essential for the Company to provide consultation and software development services.

Smartup Network LLC processes specific data categories voluntarily provided by the data subject. These include:

• Identity Identifiers: Full legal name and verified phone number.
• Professional Profiles: Category that describes the user best (e.g., Founder, Investor, Enterprise).
• Project Specifications: Type of product intended for development and specific technical needs.
• Financial Framework: Information regarding the proposed financing of the product development.
• Attribution Data: Information regarding the marketing channel through which the user discovered the Company.
• Optional Data: Brief product descriptions (2–3 sentences).

Automatically Logged Information: We may collect IP addresses and device/browser log data for operational security and forensic auditing purposes. Cookies are utilized to optimize site performance and improve user interaction.

Processing is performed in a manner that is transparent, purpose-bound, and limited to necessity. The Company processes personal data for the following strategic objectives:

• Bilateral Communication: Contacting the data subject regarding their project submission and professional requirements.
• Marketing Alignment: Segmenting communications based on form responses to ensure relevance.
• Newsletter Delivery: Sending informational updates and company announcements where legally permitted.
• Service Optimization: Understanding demand patterns to improve communication flows and user experience.
• Security Management: Preventing fraud, misuse, or malicious activity on our digital properties.

To protect the rights of data subjects, the Company maintains strict exclusions in its processing activities. Smartup Network LLC explicitly confirms that it does not process form data for:

• Engineering Feasibility Scoring: No automated technical feasibility analysis is performed solely based on form data without human oversight.
• Automated Sales Quotations: We do not utilize standalone automated tools for preparing binding sales quotations.

All project evaluations are performed by qualified professionals to ensure accuracy and fairness.

Consistent with the principle of Storage Limitation, personal data is retained only as long as necessary to fulfill the purposes described in this Policy.

• Standard Retention Horizon: Form submission data is retained for a period of two (2) years from the date of last meaningful interaction.
• Deletion Protocol: At the end of the retention period, data is either securely deleted or anonymized to prevent the identification of individuals.
• Early Erasure: Requests for early deletion are evaluated in line with legal obligations, GDPR requirements, and the necessity to maintain records for compliance and security.

Personal data is accessed and processed internally by authorized Smartup Network teams on a need-to-know basis. Data is not shared externally except to maintain secure operations.

• HubSpot CRM: The Company utilizes HubSpot for managing client relationships and marketing communications. This involves storage on systems that may be located outside of your country of residence.
• International Safeguards: Where cross-border processing occurs, we apply appropriate safeguards, including Standard Contractual Clauses (SCCs) and strict access controls, to ensure data protection.

Smartup Network LLC may send informational updates and marketing communications based on your form submission and professional preferences, where legally permitted.

• Communication Channels: This includes E-mail newsletters and outreach via Phone or WhatsApp.
• Opt-Out Mechanism: You can revoke your marketing consent at any time by using the "unsubscribe" link or by contacting hello@smartup.network.
• Administrative Messages: Opting out of marketing does not affect communications that are strictly necessary to fulfill your specific service request.

Under the GDPR, you possess several key rights regarding your personal data:

• Right of Access: To learn how your data is processed and request a copy.
• Right to Rectification: To correct inaccurate or incomplete data.
• Right to Erasure: To request deletion where applicable.
• Right to Restriction: To limit processing in certain circumstances.
• Right to Portability: To receive your data in a structured, machine-readable format.

To exercise these rights, please contact hello@smartup.network. Requests will be evaluated and responded to within a reasonable timeframe.

Smartup Network LLC reserves the right to update this Policy to reflect changes in legal requirements or operational practices. Updated versions will be published on the website and take effect immediately.

Severability: If any part of this Policy is found to be invalid or unenforceable, the remaining provisions will remain in full effect. This policy is interpreted in light of the GDPR and the laws of the State of Wyoming.

Document Reference: SN-GDPR-2024 | Last Updated: January 2024. Smartup Network LLC, 30 N Gould St, Ste R, Sheridan, WY 82801.