Smart Gate Innovations Privacy Notice

   Effective Date: November 18, 2024


Smart Gate Innovations Limited., (hereinafter referred to as “SGi”) and its worldwide affiliates and subsidiaries; (collectively “SGi”, “us”, “we”, “our”) is a global provider of cloud communications that offers various services. For our business and residential customers, we offer a complete and fully-configured unified communications solutions & products for the delivery of end-to-end communications via voice, video, text, mobile applications, and collaboration tools.

Smart Gate Innovations Limited. (“SGi”) welcomes you to this web site (“Site”). SGi respects your privacy and is committed to protecting the Personal Data (as hereinafter defined) that you share with us. This Privacy Policy describes how SGi collects and uses the Personal Data that you provide to us.


SGi is committed to complying with the EU-U.S. and the UK Extension to the EU-U.S. Data Privacy Framework Principles.


1. Collection of Personal Data 


When you browse SGI’s Site, we do not automatically collect Personal Data (as defined below) from you. We, however, do log your IP address (the Internet address of your computer) to give us an idea of which part(s) of the Site you visit and the amount of time that you spend there.

As you access and use SGi’s Site, SGi may request from you certain information, such as your name, e-mail address, company name, company address, and telephone number (“Personal Data”). This Personal Data is needed to provide to you a product or a service or to carry out a transaction that you have requested.


2. Cookies and Other Tracking Technologies 


This Site may use cookie and tracking technology. A “cookie” is a small data file that the Site places on your computer’s hard drive for identification purposes. These data files include information that allows our Site to remember important information that will make your use of our Site more efficient and useful to you.


3. How SGi Uses the Personal Data 


SGi uses Personal Data in several ways: to fulfill your requests for certain products and services; to personalize your experience on our Site; to keep you up-to-date on the latest product announcements; and to provide to you other information that we think you would like to hear about from us. We may also use your Personal Data to send to you direct marketing information or to contact you for market research.

By visiting this site and submitting your information to SGi you are granting consent to SGI to hold your information.


4. Disclosure to Third Parties 


If you request something from the Site (e.g., a product, a service, specific marketing materials, etc.), we may use your Personal Data to fulfill your request. To help us do this, we may share your Personal Data with third parties to provide certain services (e.g., marketing services) on our behalf. In such cases, however, the third parties are prohibited from using your Personal Data for any other purpose. It is SGi’s responsibility to ensure that data subject information is transferred to the third parties only as stated in this policy and through secure means. SGi requires all receiving third parties responsible to adhere to privacy policies, CCPA and GDPR requirements.

To describe our services to advertisers, vendors, and other reputable third parties and for other lawful purposes (including national security or law enforcement authorities), SGi may disclose aggregate statistics about our Site visitors, customers, and sales. But these statistics will not include Personal Data. SGi may disclose Personal Data if required to do so by law or if SGi believes that such action is necessary to protect and defend the rights, property, or personal safety of SGi, the Site, or its visitors. SGi may disclose your Personal Data in the event of any sale or transfer of its business or its assets.

SGi is responsible for ensuring onward transfer of protected personal data elements is done so only in accordance with Data Subject requests and in compliance with this policy. This includes but is not limited to ensuring 3rd parties have appropriate safeguards in place and are themselves in compliance with the EU-US DPF and the UK Extension to the EU-US DPF.


5. Changes to This Privacy Policy 


SGi reserves the right to amend the terms and provisions of this Privacy Policy from time to time. Your continued use of this Site after changes have been made will constitute your acceptance of any new or amended terms and provisions.

6. GDPR Compliance 

SGi complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, as set forth by the U.S. Department of Commerce. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF SGi commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. EU and UK individuals with inquiries or complaints regarding our EU-US DPF and the UK Extension to the EU-US DPF policy should first contact SGi with their name, email address, and country of origin at: GDPR@smartgatein.com

In compliance with GDPR, EU and UK individuals may request SGi copy of protected information by emailing GDPR@smartgatein.com with their name, email address, and country of origin.

EU and UK individuals may also request SGi to securely destroy all protected information attributed to them by emailing at GDPR@smartgatein.com with their name, email address, and country of origin. A response confirming the request and the deletion of collected data will be sent after the data has been deleted.

SGi will utilize EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) to address complaints and comply with the advice given by such authorities with regard to:


• Non-human resources data transferred from the EU and the UK.
• Human resources data transferred from the EU and the UK in the context of the

      employment relationship.
• Unresolved complaints concerning data transferred from the EU and the UK.


You have the right to access and correct your personal data SGi has collected based on your interaction with SGI or with its clients for which SGi is the data custodian. While SGi does not sell any personal data collected, you have the right to request SGI to limit the use and disclosure of your personal data. All such requests can be made by emailing at GDPR@smartgatein.com with your name, email address, and country of origin.