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SmartBrands

Privacy Policy

Pending document. This text is an outline, not a privacy policy. It describes no commitment SmartBrands has made and must not be published as is. Counsel should draft or review it before this goes live.

What the site collects today

This inventory is accurate: it is taken from the site’s own code, and is meant as the starting point for drafting the policy.

  • Contact form. Collects first name, last name, phone (optional), email address and whatever message the visitor writes. It is sent to a third-party form service; which one, and where it stores the data, still has to be named.
  • No first-party cookies. The site writes no cookies and uses no browser storage.
  • No analytics or trackers. There is no Google Analytics, Meta Pixel or any other third-party tag installed.
  • Self-hosted fonts. Served from this domain rather than a CDN, so loading a page does not expose the visitor’s IP address to a third party.
  • Outbound links. WhatsApp and the social networks. Following one takes the visitor to a third-party service with its own policy.
  • Home page video. Rests as a poster frame served from this domain and makes no request to Google. Clicking it loads a YouTube player from youtube-nocookie.com, which at that point receives the visitor’s IP address; that domain does not write YouTube’s advertising cookies, but it does use browser storage for playback.

If analytics, an advertising pixel or an embedded chat is added later, this section and the cookie notice stop being accurate.

Sections the document has to cover

  1. Data controller. Legal name, registered address and contact details. The site lists offices in Peru and the United States, which determines which law applies.
  2. What data is collected and why each item is needed.
  3. Purpose and legal basis for processing.
  4. Processors and third parties the data is shared with, including the form service, and whether it crosses borders.
  5. Retention period.
  6. The individual’s rights and how to exercise them.
  7. Security measures.
  8. Changes to the policy and how they are communicated.