Privacy Policy
How Smart Leads handles personal data about the people who use it.
Who is responsible
The reviewed text must cover:
- The controller for account data (legal name, address, contact for privacy questions) and a representative or data protection officer if required.
- For lead data inside workspaces, the workspace is the controller and Smart Leads the processor (02-design “Compliance”); that processing is described in the Data Processing Agreement.
Data about users
The reviewed text must cover:
- Account data: name, email, password (stored as a hash), two-factor settings and sessions.
- Security and audit records: sign-ins, IP addresses, and workspace actions such as member changes and exports (REQ-AUD-1).
- Billing data handled by Paddle; Google sign-in data when a user signs in with Google.
Purposes and legal bases
The reviewed text must cover:
- For each use (running the service, security, billing, emails about the account), its purpose and legal basis.
Recipients and processors
The reviewed text must cover:
- The hosting provider of the server (P10-05), the email provider for platform emails, Paddle, Google (sign-in), and Sentry when error tracking is on (P10-06: error reports exclude request bodies, cookies, headers and user data).
- Where they process data, and the safeguards for transfers outside the EEA if any.
Cookies
The reviewed text must cover:
- Only what the service needs: a secure, HttpOnly session cookie, and the light/dark preference and table settings kept in the browser. No advertising or analytics cookies.
Retention
The reviewed text must cover:
- How long account, audit and security records are kept.
- Daily database backups are kept 14 days (NFR-9); a deleted workspace is purged within 30 days (REQ-WS-6).
Rights
The reviewed text must cover:
- Access, correction, deletion, export, objection and complaint to a supervisory authority, and how to exercise them.