Privacy Policy

Jan 01, 2023


Smartifai FZ-LLC is responsible for processing your personal data to provide the services identified in section 4 of this privacy policy (the” Website “).

Smartifai FZ-LLC is a company domiciled at #C7-10, 10th Floor, IRISE TOWER TECOM, Dubai, United Arab Emirates, with license number (“Smartifai FZ-LLC”).

At Smartifai FZ-LLC, we are committed to the fundamental right to protect your personal data. This privacy policy is intended to inform you about your rights under the General Data Protection Regulation (” RGPD “).

Essential points of our policy

In this privacy policy, we explain each of the services offered by Smartifai FZ-LLC that require the processing of your personal data.

Therefore, you will be informed of:

The purposes of processing your personal data or what Smartifai FZ-LLC treats your personal data for.

The legal basis that justifies said treatment for each purpose.

If there is any communication of your data to third parties or an international transfer of the same. In this sense, we inform you that we do not transfer your data to third parties and we could only transfer them unless there is a legal obligation (derived from a request from the State Security Forces or Bodies or Courts and Tribunals) or unless it is essential to provide you a service, in which case, we will ask for your express consent.

The term of conservation of your data that is necessary to maintain the relationship or to provide the service or function that you have requested. Therefore, if we do not need your data to provide you with any service, these will be blocked and will only be accessible by Public Authorities in the event that there are legal, administrative, or fiscal claims in accordance with the deadlines established by each regulation for this. Once the blocking period has elapsed, the data will be completely deleted.

Disclosure: ADDEX platform under Smartifai uses Google's "Reporting" and "Audience Management" APIs [Explained in detail in the following YouTube video]. The use and transfer of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

What information will we collect from you?

You should know that there are different ways to collect personal data:


We collect information about you when you contact us through the channels enabled for this, such as the contact form, or when you provide us with your resume to work with us.

When you contact us through these channels, we will request your express consent to collect your email, your name and surname, your country of residence, date of birth, gender, NIF, and other information about your professional profile and academic training in case of that you are applying to work with us.

All the fields that appear marked with an asterisk (*) in the forms that are provided to you in the channels will be required to be completed, in such a way that the omission of any of them could imply the impossibility of being able to provide the requested services. You must provide truthful information, being forbidden the impersonation or the use of aliases or anonymous names.

When providing any information that may be requested on the channels, you will not be able to choose abusive expressions, coinciding with brands, commercial names, names or pseudonyms of people of public importance or celebrities for whose use you are not authorized. It is essential that you protect your reference data, passwords and access codes that you generate at all times. You will be solely responsible for the use of your personal account, and in this sense you agree to make diligent use of said information, not to make it available to third parties, and to notify us, without delay, of its loss or theft. So that the information provided is always up-to-date and does not contain errors, you must notify Smartifai FZ-LLC, as soon as possible, of any changes to your personal data that may occur through an email to the address listed here.

Likewise, by clicking on the “I accept” button (or equivalent) incorporated in the aforementioned forms, you declare that the information and data that you have provided are accurate and truthful.


When you browse, different cookies and other tracking devices can be installed on your device, as we explain in our cookie policy.

Smartifai FZ-LLC is a technology dedicated to providing online advertising services through the analysis of the content of the URLs through which the user browses in order to understand the context of each of the images that are published on a website. Once Smartifai FZ-LLC detects the context, it offers to advertise integrated into the images of the Website itself, related to the content previously analyzed.

When you visit a Website that uses our technology, we collect and process certain information that, although it does not directly identify you (such as a first or last name), may detect other relevant information about you or the devices you use to navigate.:

Information about your browser: Like the browser you use or its version.
Information about your device: About the type of device used (computer, mobile, tablet) and its operating system.

Information about your location: Coarse location (country, city) based on your IP
Information about your interaction with the ads: About the ads seen, and your interactions with them, if you view them, click on them, etc.

Information about your internet service: Like the IP.
We inform you that, through our advertising technology, we do not store any type of personal information that can directly identify you, such as your name, surname, address, date and place of birth, ID, email, etc. Nor do we process information of a sensitive or specially protected nature, such as data related to health, union membership, sexual orientation, religious identity, etc.

How will we use your personal information? What services do we provide you?

Smartifai FZ-LLC acts as the person responsible for the processing of personal data for the following purposes:

  1. Keep you informed about Smartifai FZ-LLC products and services, as well as send you news, notify you of events and other activities that are of interest to you.
  2. To provide you with the services that you have requested and to attend to your requests for information, as well as to facilitate the exercise of your rights.
  3. Assess the résumés received, and manage the selection processes.

On the other hand, Smartifai FZ-LLC acts as the person in charge of the processing of personal data to the extent that data is processed that allows the user to be identified or identifiable, for the provision of the services offered through its In-Image advertising technology, with the following purposes:

  1. Install a technical cookie in order to allow the cookie syncing process with third parties to allow programmatic advertising.
  2. Customize advertising campaigns, and display ads that are tailored to user preferences.
  3. Analyze and measure the delivery and effectiveness of the content sent, processing information about what content has been shown, how often, how, for how long or if any action was taken with respect to said content, for example by clicking on it.

Explicit User Consent

  1. Are users explicitly informed about the use of AI models and the potential data sharing involved?

    Yes, users who opt-in to share their personal information are informed in detail about how their data will be used and whether it will be shared. No data is collected, stored, or shared if users revoke their consent. Additionally, data is stored in their respective countries in accordance with personal data privacy laws, ensuring there is no breach or misuse of their data. Respecting users' privacy is our top priority.

  2. Does the app obtain explicit consent from users before sharing their data with any third-party AI models?

    Users' data is not shared with any third-party AI models. Their data is analyzed using our in-house technology, and the results are shared with the respective ad manager accounts in a fully hashed and encrypted manner using the SHA hashing method; in this case, with Google Ads.

  3. How is this consent obtained (e.g., clear opt-in checkbox, detailed explanation)?

    Users receive an option via promotional mail or message to opt-in to which includes a simple checkbox option for users to specify what information they are comfortable sharing with us, thus giving them full control. After selecting the parameters they wish to share, we provide a detailed explanation of how this data will be used, how it will be stored, and whether it will be shared. This allows users to make an informed decision.

What is the legal legitimacy for the processing of your data?

Smartifai FZ-LLC will treat your personal data in accordance with the following legitimating bases, depending on the type of data that is provided, as well as the interactions that, as a user, you establish with Smartifai FZ-LLC:

  1. The processing of your data for the purposes related to the contact form, candidate management, or commercial or advertising communications related to Smartifai FZ-LLC's products and services are based on the management and processing of the legal relationship established between both parties, that is, in the management of your own request, in maintaining contact, in the provision of the service that you have requested and, where appropriate, in the legitimate interest of Smartifai FZ-LLC.
  2. The processing of your data for the purposes related to In-Image advertising services is based on your explicit, free and unequivocal consent, which is collected by the editors who make use of our services.

Transfer of data and international transfers.

At Smartifai FZ-LLC we do not transfer your personal data to third parties for their treatment for the purposes described. However, if necessary, they will always be transferred based on a legal basis that legitimizes this treatment.

Notwithstanding the foregoing, on some occasions for the provision of our In-Image advertising services, we share data with some of our business partners:

AWS – as the provider of the server infrastructure.
SmartyAds – as an ad-server service provider.

At Smartifai FZ-LLC, we only work with suppliers who guarantee full compliance with the obligations required in the RGPD, and we sign treatment order contracts in accordance with the requirements of the regulations. The treatments carried out by the aforementioned providers are governed by the privacy policies of each provider that can be accessed directly from their websites.

Exercise of your rights.

We inform you that you can exercise the following rights:

  1. Right of access to your personal data to know which ones are being processed and the processing operations carried out with them.
  2. Right to rectify any inaccurate personal data.
  3. Right to delete your personal data, when this is possible.
  4. Right to request the limitation of the processing of your personal data when the accuracy, legality or need to process the data is doubtful, in which case, we may keep the data for the exercise or defense of claims.
  5. Right to object to automated decision making.
  6. Right to object to the processing of your personal data when the legal basis that enables us to process it, in accordance with section 4 above, is legitimate interest.
  7. Right to the portability of your data, when the legal basis that enables us to process it from those indicated in section 4 above is the existence of a contractual or consent relationship.
  8. Right to revoke the consent granted to Smartifai FZ-LLC.

You can exercise your rights at any time and for free in the following ways:

  1. By sending an email to the address listed here indicating the right you wish to exercise and your identifying data.
  2. By directing a written request to the address , indicating the right you wish to exercise and your personal data.
  3. In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you can unsubscribe from all previously accepted commercial communications shipments.

Likewise, we inform you that you have the right to file a claim with the Spanish Data Protection Agency if you consider that we have committed an infringement of data protection legislation regarding the processing of your personal data.

Retention periods and Cookies.

We will only keep your data for as long as it is necessary to offer you these services. Any of the data that you provide us through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available in the event that there is a legal obligation (derived from a request from the Security Forces of the State or Courts and Tribunals) as well as when you exercise your rights here.

In relation to your personal data obtained through the channels, Smartifai FZ-LLC uses Cookies according to the Cookies Policy that you can consult here.

Security and confidentiality.

We are committed to the security of your information. In order to prevent unauthorized access or the unauthorized disclosure of personal data, we have taken the appropriate technical and physical measures, as well as the management processes to safeguard and secure the information we collect from you.


Minors under 14 years of age may not use the services available through the Website without the prior authorization of their parents, guardians or legal representatives, who will be solely responsible for all acts carried out through the Website by minors in their charge. , including the completion of the forms with the personal data of said minors and the marking, where appropriate, of the boxes that accompany them. In this sense, and to the extent that Smartifai FZ-LLC does not have the capacity to control whether or not users are minors, it must be parents and guardians who enable the necessary mechanisms to prevent minors from accessing the Website and / or facilitating personal data without your supervision, not admitting Smartifai FZ-LLC any responsibility in this regard.

Update of the privacy policy.

We do our best to keep our privacy policy fully updated on a monthly basis. If we make changes, these will be clearly identifiable in a clear and specific way, as allowed in the relationship we have established with you (for example: we can communicate the changes to you by email).

This privacy policy has been reviewed and published as of Jan 01, 2023.