Privacy Policy

Last Updated: January 8, 2025

Smart Money Internet LLC ("we," "us," or "our") operates the website app-wall.co.com (the "Site"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our Site or use our services.

1. Data Controller

Organization Name: Smart Money Internet LLC

Address: 1252 N Havenhurst Dr W, Hollywood, CA 90046-4925, United States

Email: hello@app-wall.co.com

Phone: +1 (323) 555-1234

Data Protection Officer Contact

Email: privacy@app-wall.co.com

Address: 1252 N Havenhurst Dr W, Hollywood, CA 90046-4925, United States

For all inquiries regarding data protection, privacy rights, or security concerns, please contact our Data Protection Officer at the email address above.

2. Information We Collect

2.1 Information You Provide

We may collect the following information when you contact us or use our services:

• Name and contact information (email address, phone number)
• Company name and business information
• Project details and requirements
• Communication preferences
• Any other information you choose to provide

2.2 Automatically Collected Information

When you visit our Site, we automatically collect certain information, including:

• IP address and browser type
• Device information and operating system
• Pages visited and time spent on pages
• Referring website addresses
• Cookies and similar tracking technologies (see our Cookie Policy)

3. Legal Bases for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

3.1 Consent (Article 6(1)(a) GDPR)

We process data when you have given explicit consent for specific purposes, such as:

• Receiving marketing communications
• Non-essential cookies and tracking technologies
• Special categories of data (if applicable)

3.2 Contract Performance (Article 6(1)(b) GDPR)

Processing is necessary to:

• Enter into a contract with you for our services
• Fulfill our contractual obligations
• Provide requested services and support

3.3 Legal Obligation (Article 6(1)(c) GDPR)

We process data to comply with legal requirements, including:

• Tax and accounting obligations
• Responding to legal requests from authorities
• Compliance with employment and business laws

3.4 Legitimate Interests (Article 6(1)(f) GDPR)

We process data for our legitimate business interests, such as:

• Website security and fraud prevention
• Business analytics and improvements
• Internal administrative purposes
• Responding to inquiries and providing customer support

4. Purpose of Data Processing

We use your personal information for the following specific purposes:

• Service Delivery: To provide, maintain, and improve our Android app development services
• Communication: To respond to your inquiries, provide customer support, and send service-related updates
• Project Management: To manage development projects, timelines, and deliverables
• Business Operations: To process payments, maintain records, and fulfill contractual obligations
• Marketing: To send promotional materials (only with your consent)
• Legal Compliance: To comply with applicable laws and regulations
• Website Analytics: To understand how visitors use our Site and improve user experience
• Security: To protect against fraud, unauthorized access, and other security threats

5. Data Retention

We retain your personal data only as long as necessary for the stated purposes or as required by law. Specific retention periods include:

5.1 Category-Specific Retention Periods

• Contact Information: Retained for the duration of our business relationship plus 3 years after last contact for legitimate business purposes
• Project Data: Retained for the duration of the project plus 5 years for warranty, support, and legal purposes
• Financial Records: Retained for 7 years as required by tax and accounting regulations
• Marketing Communications Data: Retained until you withdraw consent or 2 years of inactivity
• Website Analytics Data: Retained for 26 months in anonymized form
• Support Communications: Retained for 3 years after resolution for quality assurance and legal purposes
• Security Logs: Retained for 12 months for security monitoring and incident response

General Principle: Data is retained only as long as necessary for the stated purposes or as required by applicable law. After the retention period expires, personal data is securely deleted or anonymized.

6. International Data Transfers

Your personal information may be transferred to and processed in countries outside the European Economic Area (EEA) and your country of residence. When we transfer data internationally, we ensure appropriate safeguards are in place:

6.1 Transfer Mechanisms

• Standard Contractual Clauses (SCCs): We use European Commission-approved Standard Contractual Clauses when transferring data to third countries
• Adequacy Decisions: We may transfer data to countries that have received an adequacy decision from the European Commission
• Binding Corporate Rules: Where applicable, we rely on approved Binding Corporate Rules

6.2 Third-Party Service Providers

We work with third-party service providers who may process data outside your jurisdiction. These providers are:

• Cloud hosting services (with data centers in the United States)
• Analytics providers
• Communication and email service providers
• Payment processors

All third-party processors are contractually obligated to implement appropriate technical and organizational measures to protect your data and comply with applicable data protection laws.

7. Data Sharing and Disclosure

We may share your information with:

• Service Providers: Third-party vendors who perform services on our behalf (hosting, analytics, payment processing)
• Business Partners: Partners involved in delivering services to you (only with necessary information)
• Legal Authorities: When required by law or to protect our rights and safety
• Business Transfers: In connection with any merger, acquisition, or sale of assets

8. Your Rights Under GDPR

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have the following rights under the GDPR:

8.1 Right of Access (Article 15 GDPR)

You have the right to obtain confirmation as to whether we process your personal data and, if so, to access your personal data along with certain information about the processing (purposes, categories, recipients, retention period).

8.2 Right to Rectification (Article 16 GDPR)

You have the right to obtain the rectification of inaccurate personal data and to have incomplete personal data completed.

8.3 Right to Erasure (Article 17 GDPR)

You have the right to request the deletion of your personal data when:

• The data is no longer necessary for the purposes for which it was collected
• You withdraw consent and there is no other legal ground for processing
• You object to processing and there are no overriding legitimate grounds
• The data has been unlawfully processed
• The data must be erased for compliance with a legal obligation

8.4 Right to Restriction of Processing (Article 18 GDPR)

You have the right to restrict processing of your personal data when:

• You contest the accuracy of the data
• The processing is unlawful and you oppose erasure
• We no longer need the data but you need it for legal claims
• You have objected to processing pending verification

8.5 Right to Data Portability (Article 20 GDPR)

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller when processing is based on consent or contract and carried out by automated means.

8.6 Right to Object (Article 21 GDPR)

You have the right to object to processing of your personal data based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will cease processing your data for such purposes.

8.7 Right to Withdraw Consent (Article 7(3) GDPR)

When processing is based on consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.8 Right to Lodge a Complaint (Article 77 GDPR)

You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement if you believe that the processing of your personal data violates the GDPR.

Exercising Your Rights

To exercise any of these rights, please contact us at privacy@app-wall.co.com. We will respond to your request within one month, or two months if the request is complex. We may ask you to verify your identity before processing your request.

9. Your Rights Under CCPA

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA):

9.1 Right to Know

You have the right to request disclosure of:

• Categories of personal information collected
• Categories of sources from which information is collected
• Business or commercial purposes for collecting information
• Categories of third parties with whom we share information
• Specific pieces of personal information we have collected

9.2 Right to Delete

You have the right to request deletion of your personal information, subject to certain exceptions.

9.3 Right to Opt-Out of Sale

We do not sell personal information as defined by the CCPA. We have not sold personal information in the preceding 12 months.

9.4 Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising your CCPA rights. We will not:

• Deny goods or services
• Charge different prices or rates
• Provide a different level or quality of services

9.5 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require written proof of authorization.

Exercising Your CCPA Rights

To exercise your CCPA rights, contact us at privacy@app-wall.co.com or call +1 (323) 555-1234. We will verify your identity and respond within 45 days.

10. Security

We implement appropriate technical and organizational security measures to protect your personal information, including:

• Encryption of data in transit and at rest using industry-standard protocols (SSL/TLS, AES-256)
• Access controls and authentication mechanisms
• Regular security assessments and vulnerability testing
• Employee training on data protection and security
• Secure data centers with physical security controls
• Firewall protection and intrusion detection systems
• Regular security updates and patch management
• Data backup and disaster recovery procedures

Important Disclaimer: While we strive to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

11. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at privacy@app-wall.co.com, and we will delete it.

12. Third-Party Links

Our Site may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to review their privacy policies before providing any information.

13. Changes to This Privacy Policy

We may update this Privacy Policy periodically. The "Last Updated" date at the top indicates when the policy was last revised. Material changes will be communicated through:

• Prominent notice on our website
• Email notification to registered users
• Update to the "Last Updated" date

Continued use of our services after changes constitutes acceptance of the updated policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

15. EU Representative

If you are located in the European Union and have concerns about our data processing practices that we have not adequately addressed, you may contact our EU representative (if applicable) or your local supervisory authority.

16. Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by Article 33 of the GDPR.