SMARTTIPSADAILY.COM PRIVACY POLICY
Last updated: June 22, 2018

Thank you for visiting our website. Your privacy is important to us, and we have adopted this Privacy Policy to memorialize our data collection, use and disclosure practices for our website located at the http://smarttipsdaily.com domain, along with its related tools and services (the “Website”). The Website is owned and operated by Morphing Solutions, LLC (“Morphing Solutions,” “we,” “us” or “our”). This Privacy Policy applies to anyone using or browsing our Website and to information provided to us via the Website by you or other visitors or users of our Website (“you” or “your” or “users”).

CONSENT

By using or accessing any part of the Website, including uploading or submitting any content such as comments, text, images, videos, contact information, and any other content or information (“Your Content”), you consent to this Privacy Policy. If you do not agree with any provision of this Privacy Policy, you may not use or access the Website.

Information collected through the Website may be transferred, used and stored in the United States and in foreign jurisdictions in which we, our users, or our service providers for the Website are located now or at any time in the future. If you access the Website, you consent to the capture, storage, transfer, use and processing of your Personal Data (as defined below) in and between all of those jurisdictions. The data protection and other laws in some countries and jurisdictions (such as the federal laws and some state laws in the United States) are not as comprehensive or stringent as the privacy laws in other countries and jurisdictions (such as the laws of the European Union). You agree that all transactions relating to our Website shall be deemed to have occurred in the United States, where we currently have all of our personnel and operations, though all applicable data protection laws, such as the GDPR (as defined below), shall govern the transactions relating to specific end user’s use of our Website, as applicable based on the end user’s country of residence.

COLLECTION OF INFORMATION; THIRD PARTY SITES

We may collect Personal Data in connection with our Website, such as through our contact pages and commenting features. You may always choose not to provide Personal Data, but this may prevent you from receiving certain services. When we use the term “Personal Data,” we mean information that can be used to identify an individual and may include your full or partial first and last name, business entity name and/or title with the applicable business entity, postal business or home address, electronic email address, user ID, password, telephone number, fax number, and Your Content, to the extent that it identifies you or a third party.

Our services may integrate with social media platforms, such as Facebook, Twitter, and Google, and if you choose to connect a social media account to our Website, then we will collect authentication information that permits us to connect to your social media account. We may also collect information from your social media account (such as your name, email address, demographic information from your profile, posting or other content, and your profile picture).

We may also collect certain Non-Personal Data about you including, without limitation, aggregated and anonymized information. Examples of the Non-Personal Data we may collect include, but are not limited to: your IP address; information about your operating system and browser (such as maker and version); information, content, or advertisements you view, hover over, or click on; referral information, click-stream data, device identifier, unique identifier, HTTP header, including URL, etc. and the city and state (but not precise geographic location) in which you are located. Unless otherwise required by applicable law, such as the GDPR, we treat this information as Non-Personal Data.

Information may be collected by us or by one of our service providers but in either case, this Privacy Policy will govern the collection, use, and sharing of the information.

Please note that we are not responsible for the privacy policies, practices, or content of websites owned by others that may link to or that may be linked from the Website (“Third-Party Sites”). In particular, some Third-Party Sites may collect information from you, such as information you provide in forms on those sites. For the sake of clarity, this information is not collected by the Website, and falls outside the scope of this Privacy Policy. Such collection practices are governed exclusively by the policies of those Third-Party Sites. Accordingly, we encourage you to review the privacy policies and terms of use of those Third-Party Sites so that you understand how those websites collect, use, and share your information.

USE OF INFORMATION

We may use Personal Data and Non-Personal Data to improve online operations; provide customer service; provide newsletters and/or other communications or services which you have signed up for or otherwise agreed to receive; display advertising and other content that is customized to your apparent interests or preferences; send account or transaction-related communications such as welcome letters and transaction confirmations; perform research and analysis aimed at improving our products, service and technologies; and manage our systems. We may also use this information for internal purposes to help us diagnose problems, monitor traffic patterns, and otherwise continually improve our Website and related services.

Please note that when you initially sign up or submit information on our Website, you may receive email messages or newsletters from us. You will be given the opportunity, in any commercial email that we send to you, to opt out of receiving such messages in the future by using the "unsubscribe" link at the bottom of each such communication. It may take up to 10 business days for us to fully process an unsubscribe request, and we may send you other types of transactional and relationship email communications, such as requests for additional information, confirmations, service updates or announcements, and administrative notices without offering you the opportunity to opt out of receiving them.

EUROPEAN UNION RESIDENTS

If you reside in a country in the European Economic Area or in Switzerland, then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) and the following additional information is provided for your benefit.

The controller of the personal data collected through the Website is:
Morphing Solutions, LLC
Attention: Office of the General Counsel
160 Greentree Drive, Suite 101
Dover, DE 19904
Email: [email protected]

If you use the Website, you acknowledge that your Personal Data is being processed on the basis of your consent as described in this Privacy Policy, and that information gathered through the Website may be transferred to, and used and stored in, the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You may withdraw your consent at any time by following the instructions in the Choice; Accessing and Updating Your Personal Data section below, but this will not affect the lawfulness of processing based on consent before its withdrawal. However, if you withdraw your consent or decline to provide Personal Data to us, you may be unable to use the Website. You have the right to file a complaint relating to the processing of personal data with a supervisory authority.

DISCLOSURE OF INFORMATION

We may disclose Personal Data and Non-Personal Data about you to companies, agents, contractors, service providers or others engaged to perform functions on our behalf (such as providing data storage, hosting the Website, processing payments, conducting audits and performing web analytics, and fulfilling orders or requests that you initiate), and to market our other products and services to you (for example, to send you messages concerning new Website features or special offers).

We may also disclose your Personal Data to third parties, in our sole discretion, as data subprocessors that handle and process your Personal Data for the following purposes: (a) to enforce or apply the Terms, including investigations of potential violations thereof; (b) to comply with legal or regulatory requirements or a governmental request; (c) to protect the rights, property or safety of Morphing Solutions, our users, or other third parties; (d) to comply with a request by any authority, such as a police department or regulatory authority; (e) to detect, prevent or otherwise address fraud, security or technical problems that may arise; (f) to handle the processing of payments; (g) to provide data storage and management; to assist in marketing Morphing Solutions’ products or services; (h) to conduct audits; (i) to provide web analytics and business intelligence; (j) to provide customer support; (k) to send email and platform alerts; and (l) to provide customer surveys and messaging services. We may also disclose Non-Personal Data to our clients, developers, business partners, merchants, advertisers, investors, potential buyers and other third parties for any reason in our sole discretion.

We reserve the right to transfer information (including your Personal Data and Non-Personal Data) to a third party in the event of a reorganization, spin-out, sale, merger, or transfer of some or all of the assets of our company, or in the unlikely event of a bankruptcy, liquidation or receivership of our business. However, we will provide you with advance written notice in the event any such transfer would subject your Personal Data to materially different privacy practices.

CHOICE; ACCESSING AND UPDATING PERSONAL DATA

When you use our Website, we make good faith efforts to provide you with access to your Personal Data and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. For information about your choices regarding targeted advertising from third-party advertising networks, please see the section below on “Cookies and Automatic Data Collection; Advertising Networks.”

Please email us at [email protected] or contact us at the address stated below with any questions if you need assistance accessing or changing your Personal Data or if you would like to have your Personal Data deleted from our servers. Please be aware that if you delete your Personal Data, you may not be able to continue to use the Website. If you ask us to delete your Personal Data, we may in our sole discretion retain certain information, including your Personal Data, to satisfy our legal, audit and/or dispute resolution requirements. Additionally, if your Personal Data is subject to the GDPR, you may have certain additional rights, including the right of restriction of processing of personal data, the right to object to processing of personal data, and the right to data portability. We may also retain your Non-Personal Data indefinitely.

If you do not request that we delete your Personal Data, we will retain it pursuant to our internal data retention and deletion practices as dictated by valid business and legal reasons for retaining such information. For example and without limitation, Personal Data provided to us by Website users will be retained as long as such Website users continue to communicate with us.

COOKIES AND AUTOMATIC DATA COLLECTION; ADVERTISING NETWORKS

Non-Personal Data (including aggregate, technical or demographic information) can also be collected through the standard operation of our internet servers and logs as well as other automatic data collection tools such as “cookies,” “web beacons” and other similar web technologies. A “cookie” is a small amount of data that is recorded either temporarily or persistently on your hard drive and that a website can use in order to recognize visitors who revisit the website so as to facilitate their ongoing access to and use of the website. Information we may collect through cookies and other similar technologies includes your browser type, language preference, operating system, referring website (if applicable), your IP address, the name and type of your computer or mobile device, the operating system of your device, your general geographic location, the date and time of each user visit or request, and the Website endpoints that you accessed or visited during your use of the Website. In addition to other uses as described in this Privacy Policy, we may gather the information we collect from each user and perform statistical analysis of the aggregated information, including analysis about the behavior of visitors to our Website on an aggregated, anonymous basis. Unless otherwise required by applicable law, such as the GDPR, we treat this information as non-Personal Data.

Any Non-Personal Data we collect from you through the use of our cookies, web beacons and other web technologies may also be used by us and shared with our affiliated companies to target advertising to you on the Website. We may also allow unaffiliated third-party companies such as advertising networks to serve ads and/or collect anonymous, Non-Personal Data when you visit our Website. These unaffiliated third-party companies may collect and use Non-Personal Data (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) in order to provide advertisements about goods and services likely to be of greater interest to you. This collection and use of Non-Personal Data would be governed by those unaffiliated third-party companies’ own privacy policies. These companies typically use a cookie or third-party web beacons to collect this information. To learn more about this behavioral advertising practice or to opt out of this type of advertising for participating companies, you can visit http://www.networkadvertising.org. Please note that if you delete your cookies or use a different browser, a different computer, or other device, you will need to opt out of this type of advertising again.

We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized “do not track” feature is released, we intend to adhere to the browser settings accordingly.

You may prevent our use of cookies to collect Non-Personal Data about you by adjusting the option that is available in most web browsers to deny or accept cookies. Recognize, however, that cookies may be necessary in order to provide certain features such as the customized delivery of certain information to you.

CHILDREN

We do not knowingly collect Personal Data from children less than 18 years of age. Nor do we authorize or permit children less than 18 years of age to use the Website. If we learn that we have inadvertently collected Personal Data from a child under the age of 18, upon receipt of notice from the child or the child’s parent or legal guardian, we will delete that child’s Personal Data and/or disable such information from being viewed or accessed by any other user or other third party.

INFORMATION SECURITY

We utilize a number of reasonable information security measures to safeguard your Personal Data. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we do not guarantee its security.

YOUR CALIFORNIA PRIVACY RIGHTS

A California resident who has provided Personal Data to a business with whom she or he has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed her or his Personal Data to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Data was disclosed in the preceding calendar year, as well as a list of the categories of Personal Data that were disclosed.

Currently, we do not intend to share your Personal Data with third parties for their own direct marketing purposes.

Please note that whenever you choose to share your Personal Data with a third party or to allow your Personal Data to be shared with a third party to communicate with you, your information will be subject to the third party’s privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as we have no control over how third parties use your Personal Data and other information. You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information.

California Customers may request further information about our compliance with California’s privacy law by emailing [email protected] or contacting us as stated below. Please note that we are only required to respond to one request per customer per year, and we are not required to respond to requests made by means other than through this email address.

YOUR CONTENT

Please note that when you choose to upload or submit Your Content, such as by posting comments, messages, and other content on the Website, Your Content will be viewable by third parties and other Website users and, in the case that Your Content consists of images, photographs, comments, and communications in public online forums, is publicly viewable. Accordingly, you should exercise discretion with regard to what Personal Data you post on the Website through any means, and should not post personal, highly confidential, or sensitive information (such as Your Content that is identifiable or embarrassing to you or others). We are not responsible for how third parties who view Your Content may use any Personal Data contained therein, such as to send you unsolicited messages.

CHANGES TO THIS PRIVACY POLICY

We may modify or update this Privacy Policy periodically by posting an updated policy on the Website, which modifications will become effective immediately upon posting. You can always check the “last updated” date at the top of this document to see when the Privacy Policy was last changed. We may also post a notice concerning changes to the Privacy Policy on our website if there are material changes. We encourage you to check this Privacy Policy regularly.

Your continued use of the Website following the effective date of an updated Privacy Policy constitutes your consent to the contents of such policy. However, we will not apply any material changes retroactively to any information we collected from you before such changes took effect, without your affirmative consent to do so. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE WEBSITE AFTER THE EFFECTIVE DATE OF SUCH CHANGES. Please note that upon you ceasing use of the Website, any Privacy Policy in effect immediately prior to your departure shall continue to be binding on you and applicable to the data (including any Personal Data) collected from you prior to such departure.

CONTACT US

To ask questions about our Privacy Policy, obtain more information, or to lodge a complaint, please contact us at:

Morphing Solutions, LLC
Attention: Office of the General Counsel
160 Greentree Drive, Suite 101
Dover, DE 19904
Email: [email protected]