Privacy Policy

Protection of personal data and request for consent for the processing of personal data collected from the data subject


The following privacy policy is provided by Datasmart LLC with the purposes to describe the management modalities of the website (di seguito anche “Sito”) with specific reference to the handling (o processing) of personal data provided by User/Interested.

The policy specifies the modalities, the purpose and the limits of the personal data processing; is compliant with the provisions of Art. 13 of the Regulation (UE) 2016/679 (hereinafter “GDPR” or “Privacy Code”) for the users that enter the website of Datasmart LLC.

This Privacy Policy is valid only for and not other wesites or o sections/pages/spaces owned by third parties and accessed by the user through links present in this website.

Users are kindly invited to read carefully this Privacy Policy before providing any personal information and/or filling in any form present on the Site.

1. Identity and contact data of the of the Responsable of Treatment

For the purposes referred to under the article 2 letter a) and b), the responsable of treatment is Datasmart LLC, address 530-B HARKLE ROAD STE 100, Santa Fe, NM 87505 USA. For the purposes referred to under the article 1 letter c) independent data controllers are the Sponsors below mentioned in section 8 and the third parties belonging to one of the categories listed in section 9.

He is responsable of treament (hereinafter “Responsable”) with the purposes of statistical analysis, export, control and supervision to ensure the correct operation of the platform the DATASMART LTD based in 6 AKSAKOV STREET, ZIP / City: 1000 SOFIA (Bulgary), email:

The list in detail of the companies responsable of treatment may be requested to the Responsable with a written request at the contacts specified above

2. Collected data, purposes of and legal basis for the processing

User’s data collected by the Responsable for the purposes of the registration on and the registration to services, contests and events (hereunder Services) accessible from the Site include: e-mail address, mobile phone number, account profile, date of birth, gender, county and city of residence and any of the user’s personal information eventually and voluntarily submitted and published.

Unless the User will give to the Responsible a specific and optional consent to the processing of his personal data for the additional purposes foreseen in the following sections, User’s personal data will be used by the Responsable for the exclusive purpose of confirming the User’s identity (also by confirmation of e-mail address and/or mobile phone number), thus avoiding possible frauds or abuse, and contact the User for operational services only (e.g. send notifications concerning the services offered from the Site). Without prejudice to the provisions elsewhere in this Privacy Policy, under no circumstances the Responsable will make available to other Users and/or Third Parties the User’s personal data.

The personal data submitted by the Users are collect and processed by Datasmart LLC for the following purposes:

  1. Registration to the Site, Event, Contest provided by Datasmart LLC via the Site
  2. Provide the services of the Site: the data submitted by the User will be processed with the purpose to provide the services that the Site offers and will enable the services for the User to use.
  3. The data submitted may be, following specific and voluntary consent by the User, be utilized for marketing purposes (including, but not limited: direct and indirect marketing, market research, prize contests, surveys, marketing communications, also via e-mail).
  4. Profiling concerning individuals or groups, carried out through the analysis of the information provided by the Interested Users referring to identifying data preferences, behaviour and habits of the User in order to improve the needs of those which gave explicit consent.
  5. Communication to the Sponsors listed in section 8 and to the thirds of the categories referred to in the section 9, that may use them for activities referred to under previous letters c) e d).

Transmission of personal data referred to under previous letters a) and b) are required in order to have access to the Services and provide the services the User requested. Legal basis for the processing: fulfillment of the contractual obligations and regulatory, fulfillment to the request of Services of the User.

The processing referred to letters c) d) and e) require the User’s explicit consent and shall not affect the provision of the requested services.

Legal basis for the processing: execution of enquiries of newsletter and advertising information in accordance with explicit consent of the Interested User.

We recall that the User can object in any moment at the processing of his personal data for these purposes and can also exercise the further rights referred to UE n. 679/2016, as envisaged in the next article 10 (Rights of the Data Subject)

3. Processing Methods

The processing of the data collected for the purposes referred to in section 2, will be done through IT/telematic tools, paper support and/or tools adequate to guarantee the fulfilment of security and confidentiality measures required by the GDPR.

Such methods will be pertinent and not excessive in relation to the type of services provided.

4. Processed Data

  1. Data submitted by the user voluntarily at the site registration or in subsequent phases in order to benifit of the services provided by Datasmart LLC.
  2. Navigation Data: IT/telematic systems and the software processes designed for the useful efficiency of the Site acquire, in the course of normal operation, some personal data, the transmission of which is implicit in the web communication protocols or it’s useful for better mamagement and optimization of the system used to send data and e-mails. This acquisition, which occurs for statistical purposes only or to track the correct functioning of the Site, is not in any way aimed at identifying users. The web contact data is not, in any case, retained after being processed, except when required to ascertain responsibility in the case of any electronic crimes which damage the website.

5. Area of publication and circulation of data.

The appointed employees of Datasmart LLC will have access to the data and, with prior explicite consent of the user, the Sponsors and the third parties belonging to the categories contained in section 9, as well as collaborators and external managers of the Responsable assigned to data processing, the Trading Partners of the latter as Autonomous Responsable of data. Excluding instances above mentioned, User’s data will not be shared in any way by the Responsable.

6. Data Retention Period

The data collected will be processed exclusively for the time required for the purposes set out for which the User has expressed explicit consent:

  • for the purposes referred to in letters a) and b) in section 2 for the required time necessary for the processing of these and for the time set by laws, regulations or community legislations, especially in administrative and fiscal matters.
  • for the purposes referred to in letters c) d) and e) in section 2, the data will be retained for the required time to keep a constant the relationship esteblished wit the User, allowing Datasmart LLC to continue, lawfully, their marketing activities and direct sales until the User is interested in our products and services. Of course the retention period will be interrupted as soon as the User will reveal the desire to not receive further information and offers, by communicating it using the methods given in this Privacy Policy. Datasmart LLC take appropriate technical and organisational measures to not contact the User anymore.

Subsequently, the data will be anonimised for statistical purposes and then deleted, unless expressly provided otherwise by control authorities, law enforcement and Judiciary. Therefore can be retained for longer periods in cases of dispute, for the purpose to defend or assert a right, in a court of law, both on the part of the Responsable and the User.

7. Data transferred to third countries

Currently data will not be transfered to non-EU countries. The database mamagement is entrusted to Datasmart LTD and the processing if this data is bound to the purposes for which they were collected and occur in full compliance with the confidentiality and security standards provided by the laws on personal data protection applicable.

Whenever the Users personal data were to be subject of an international transfer outside EU territory, the Responsible will take every contratual measure suitable and necessary, in order to ensure appropriate level of the Users personal data protection in accordance with what is stated in this Privacy Policy, including, among others, standard contractual clauses approved by the European Commission. Whenever the adequacy of requirements or the Standard contractual clauses fails to be present, we will request againg consent to transfer to non-EU countries.

8. Sponsors List

Write to to receive the list of sponsors.

9. Categories of autonomous third party controllers

Personal data provided by Users (name, surname, address, email, phone, …) may be disclosed and/or transferred to the following categories of third party companies: (i) fixed and mobile telephone network companies; (ii) companies active in the publishing world (printed media, internet, television and new media); (iii) companies active in the e-commerce sector of products and services; (iv) companies operating in the energy sector; (v) travel and leisure operating companies; (vi) companies providing professional and/or scholastic education; (vii) advertising agencies, media and contact centers; (viii) companies operating in the food industry; (ix) NGOs and No-Profit Organizations (ONLUS); (x) companies operating in the insurance and finantial sector (xi) companies operating in the marketing and web communication sector, as well as business partners of these companies, operating in the e-commerce sector, appartenenti ai settori dell'e-commerce, mail-order businesses, publishing sector, utilities, turistic sector, sport sector, communication sector, entertainment, finantial sector, insurance sector, automotive sector, consumer sector, for the dispatch od advertising material and other promotional and commercial purposes by post or telephone and/or with automated calling systems orcall communication without the intervention of an operator and/or electronic communications such as e-mail, fax, messages like Mms or Sms or other types.

10. User Rights

Users can exercise the rights guaranteed by the Applicable Legislation, by contacting the Responsable via e-mail to:, or writing a letter to: 6 AKSAKOV STREET, ZIP / City: 1000 SOFIA (Bulgary) . Withing the meaning of the Applicable Legislation, the Responsable informs that Users have the right to obtain indication (i) of the source of the personal data; (ii) the purposes and methods of their processing; (iii) the logic applied in case of processing carried out with the aid of electronic instruments; (iv) information about the data holder and responsable parties; (v) of the entities or categories of entity to which the personal data may be disclosed or which may learn them as in their role as data processors or handlers.

Furthermore, the Users have the right to obtain:

  1. the access, the updating, the correction, or whenever interested, the integration of data;
  2. the cancellation, the transformation into anonymous form or blocking of data which have been processed unlawfully, including the data which doesn't need to be stored if related to the purposes they have been collected or subsequently processed for;
  3. the certification that the operations referred to in letters a) and b) have been disclosed, including also their content, of those to whom such data has been communicated or distributed with the exception of the cases the prove to be impossible or requires the use of manifestly disproportionate effort compared to the right to be protected.

Furthermore, Users have:

  1. the right to revoke consent at any time, where the processing is based on their consent;
  2. the right to data portability(right to receive the personal data concerning them in a structured format, commonly used and machine-readable format), the right to restriction of processing of their personal data and the right to erasure (“right to oblivion”);
  3. the right to object: i) in whole or in part, for legitimate reasons to the treatment of personal data concerning them, although pertinent to the purpose for which it was collected; ii) in whole or in part, to the processing of personal data used for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication; iii) whenever the personal data is processed for direct marketing purposes, at any time, to the processing of their personal data for these purposes, including profiling to the extent that it is related to direct marketing;
  4. whenever they considered that the processing which concerns them violates the legislation, the right to lodge a complaint with a supervisory authority (in the Member State in which they are ordinarily resident, in the Member State they are employed in or otherwise in the Member State where the alleged violation has occured). The Supervisory Authority is Bulgaria Commission for Protection of Personal Data (CDPD).

The Data Controller is not responsible for the updating of any link viewable in this Policy, therefor everytime a link is not functioning and/or updated, the Users reconize and accept that they will always refer to the document and/or section of the websites recalled by this link.

11. Update and changes to the Privacy Policy

Datasmart LLC reserves the right to modify this Policy and the conditions of use highlighting the changes made on the Site in the section “Privacy Policy”, therefore we reccomend the Users to periodically visit this page in order to view any changes or updates. Any legal dispute will be exclusively under the jurisdiction of Sofia, Bulgary.

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