Last update: 30/9/2025

This Privacy Policy describes how Smartway S.r.l. (“Smartway”, “we”, “our”, or “us”) collects, uses, and protects the personal data of users (“you” or “users”) when using the Smartway App (“App”), in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

1. Data Controller

The Data Controller is:

Smartway S.r.l.
Registered office: Via dell’Opio nel Corso 11, 53045 Montepulciano (SI), Italy
VAT / Tax ID: 01522820529
Email: hello@smartwaywork.com

2. Types of Data Collected

We may collect and process the following categories of personal data:

  • Identification data: first name, last name, corporate email address, phone number, company name.

  • Technical data: IP address, device information, access and usage logs.

  • Additional data: profile picture, geolocation (if enabled by the user), country of residence.

We do not collect sensitive data beyond the information listed above.

3. Purposes of Processing

Your data will be processed for the following purposes:

  • Account management: profile creation, login, password recovery.

  • Provision of services: access to agenda, chat, internal social features, push notifications.

  • Marketing communications: newsletters, promotional materials, invitations to events (only with your explicit consent).

4. Legal Basis for Processing

The processing of personal data is based on:

  • Performance of a contract: to provide the App’s core services and allow participation in events/offsites organized through Smartway.

  • Legal obligations: to comply with applicable legal, accounting, or tax requirements.

  • User consent: for receiving marketing and promotional communications.

  • Legitimate interest: to ensure the security, functionality, and improvement of the App.

5. Data Sharing

Your personal data may be shared with:

  • Technical providers: Firebase, Django backend, Bunny.net (hosting and infrastructure services).

  • Communication and CRM services: Mailgun, HubSpot.

These providers act as Data Processors under Art. 28 GDPR and process data on our behalf.

6. International Data Transfers

Data is processed within the European Union.
Providers used (Firebase Europe, HubSpot EU, Bunny.net) comply with GDPR requirements.
No transfers to non-EU countries will occur without appropriate safeguards (such as EU Standard Contractual Clauses).

7. Data Retention

Personal data is stored for a maximum of 30 days from the user’s last activity.
After this period, data will be deleted or anonymized, unless longer retention is required by law.

8. User Rights

Under GDPR, users have the following rights:

  • Right of access, rectification, and update;

  • Right to erasure (“right to be forgotten”);

  • Right to restriction of processing;

  • Right to data portability;

  • Right to object to processing;

  • Right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) (www.garanteprivacy.it).

Requests to exercise these rights may be sent to: hello@smartwaywork.com

9. Cookies, SDKs and Tracking

The App does not use cookies or third-party tracking SDKs.
Technical data is collected only to ensure security and proper operation of the service.

10. Minors

The App is designed for corporate users (employees and business partners).
It does not contain content restricted to minors, but registration is intended for adults and/or employees authorized by their company.

This Privacy Policy may be updated in the future. Users will be notified through in-app messages or email in case of material changes.