I. About Smeester & Associates
Smeester & Associates is in the “CIO, CTO and IT executive” business. We provide assessments, consulting services and strategic advisory services to our clients to improve the overall sustainability and performance of technology in small and medium sized companies from a management and governance context (collectively, the “Services”).
II. How We Collect, Use, and Share Information
We Work for Our Clients
Smeester & Associates works as a consultant for our clients, and any Personal Information (defined below) we collect, use, and disclose through our Services is only processed on our clients’ behalf and as authorized and directed by those clients. It is the Smeester & Associates client’s responsibility to ensure that the data it collects or directs us to collect through Smeester & Associates’s Services can be legally collected. It is also the client’s responsibility to provide its employees and customers the appropriate level of notification that information, potentially including Personal Information, will be collected and maintained.
When we say “Personal Information,” we mean individually identifiable information that alone or when in combination with other information may be used to readily identify, contact, or locate a specific person, such as a name, address, phone number, username, email address, and password. We do not consider Personal Information to include information that has been anonymized or publicly available information that has not been combined with non-public Personal Information.
Information Collected through Our Services
Personal Information. We may collect Personal Information about users of a client’s IT systems in order to provide our Services and as authorized by that client. We may collect such Personal Information directly or indirectly, such as through a client or another service provider.
Device-related Information. We may also collect device related information from the user’s device, including information such as an IP address, the date and time of use of our Services, the date and time of an event on the client’s IT systems, system logs, and technical attributes about the device or a web browser.
Commercially Available Information. Smeester & Associates also collects information from commercially available sources. Such information may include names, addresses, email addresses, and demographic data. The information Smeester & Associates collects from these commercial sources may be combined and cross-referenced with information collected through the Smeester & Associates Services.
How We Use Information Collected through Our Services
To Serve Our Clients. We use the information we collect, including Personal Information, to provide our Services to the clients on whose behalf we are acting. For example, in order to provide technical support, we may contact a user of a Smeester & Associates client’s IT system using any contact information provided to us.
For Internal and Service-Related Purposes. We may use any information we collect through the Services for internal and service-related purposes, including providing it to third parties as necessary to allow us to facilitate provision of the Smeester & Associates Services.
Anonymized and Aggregate Data. We anonymize and aggregate data collected through our Services and may use it for any purpose.
How We May Disclose Information Collected through Our Services
We may share any information we collect, including Personal Information, with the client on whose behalf we are acting. We do not rent, sell, or share Personal Information collected through our Services with other people or nonaffiliated companies for their direct marketing purposes. We may otherwise share information we collect as follows:
Anonymized and Aggregate Data. We may share anonymous or aggregated data with our affiliates, agents, and current and prospective business partners for any purpose, subject to our agreements with our clients.
With Our Third Party Vendors and Service Providers. As appropriate, we may share any information we receive with vendors and service providers retained in connection with the provision of the Smeester & Associates Services. These third parties have access to Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any information is provided to them, and they are restricted from using the information for other purposes.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate: to comply with law enforcement requests and legal process, such as a court order or subpoena; to respond to your requests; to prevent or address fraud, security, or technical issues; or to protect our property or other legal rights or the rights or property of others.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, information collected through the Services may be sold or transferred as part of such a transaction, as permitted by law and/or contract. We cannot control how any other party to the transaction or any future entity created by the transaction may use or disclose such information.
Smeester & Associates Websites’ Information Practices
You can visit the Smeester & Associates Websites without revealing any Personal Information. However, in some instances, such as when you register for our Services or request additional information or contact from Smeester & Associates, you may be asked to provide certain Personal Information, which may include a name, company name, address, and email address.
In addition, if you choose to correspond with us via a web form or email, we may retain the content of your messages together with your email address and our responses. If you should enter into a client relationship with Smeester & Associates, you may obtain additional rights or agree to additional obligations associated with the collection, use, and disclosure of information.
From time to time, we may also ask our partners or clients to voluntarily provide us with the email addresses of friends or colleagues, so they too can benefit from the various products and services offered by Smeester & Associates and Smeester & Associates’s trusted affiliates.
If you have arrived at any Smeester & Associates Website by clicking on a banner ad for one of Smeester & Associates’s products or services, a session cookie may be used. This cookie contains an identification number for the advertisement that you clicked on, and it helps Smeester & Associates determine which of its ads attracts the most visitors. If you choose to request further information from us about Smeester & Associates’s products and services, the personal information that you provide in that request will be linked to the information in the session cookie.
In order to better understand how our sites are used, Smeester & Associates Websites may also use persistent cookies along with other information collected in our servers’ files (e.g., IP Address, referring URLs, etc.). Such information is not combined with information from any other cookie. Cookies may be delivered in a first-party or third-party context.
III. Access, Integrity, Retention, and Choices
Access & Correction
We collect information at the direction of our clients and generally do not have a direct relationship with the individual users of their IT systems whose information we may process. To request access to, correction, amendment, or deletion of Personal Information, a user of a Smeester & Associates client’s IT system should direct their query to that company.
If you wish to request access to, correction, or deletion of Personal Information you have submitted through the Smeester & Associates Websites, you can log into your account or contact Smeester & Associates at email@example.com.
Smeester & Associates will use Personal Information only in ways compatible with the purpose for which it was collected or authorized by our clients, or as requested in connection with Smeester & Associates Website user requests.
We keep information we need to provide our Services only so long as we have a valid business purpose, in accordance with applicable law and our client agreements. We may retain aggregate or anonymous information indefinitely.
We include an “unsubscribe” hyperlink in Smeester & Associates marketing emails for those users who wish to stop receiving email communication from Smeester & Associates. The hyperlink will connect to one of our websites, which will confirm the email address that has been automatically unsubscribed and will no longer receive emails from Smeester & Associates.
Smeester & Associates has adopted physical, technological, and administrative procedures to safeguard and secure the information we process.
By providing Personal Information to us or using the Smeester & Associates Websites, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services and the Smeester & Associates Websites.
V. International Use
Smeester & Associates is headquartered in the United States of America. We have developed data practices intended to assure information is appropriately protected. Personal Information may be accessed by us or transferred to us in the United States or to our affiliates, partners, merchants, or service providers elsewhere in the world.
VI. Children’s Privacy
We do not knowingly collect, store, or use information from children.
VIII. Contact Us