The Smartie Pants Platform ("the Platform") and the website ("the Website") both available on are owned and maintained by Smartie Pants Limited, (Smartie Pants, We, Us),  a company incorporated and existing under the laws of Bulgaria, company number 206763549, with registered office: Republic of Bulgaria, 1712 Sofia, Mladost 3 Residential area, block 325,entrance 2, floor 1, studio 1. All references to "Smartie Pants", "we", "us", or "our" in this Policy are references to Smartie Pants Ltd.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes Smartie Pants's policies and practices regarding our collection and use of your personal information and sets forth your privacy rights. We will from time to time update this Privacy Policy as we undertake to comply with regulatory changes, data protection and data privacy standards and industry best practices. We encourage you to check this policy regularly.


The Smartie Pants Platform is available on the Website. When you create your own account on the Website, we collect personal information, such as your name, your employer’s name, your work address (including your country location), and your email address. Depending on your role on the Platform, we may ask you to voluntarily provide additional information as needed through your account profile as described in the Terms and Conditions related to the services, we provide to you.

We use and hold your personal information for account administration and to deliver benefits to you as a registered user, which is our primary purpose for collection of your information. By using our services, you acknowledge why we collect, hold, use and disclose personal information about you and you consent to the collection, use and disclosure of your personal information for this purpose of providing our services to you.


When handling personal information, we will comply with the European Data Protection Regulation (GDPR) and other applicable laws and regulations (herein defined as applicable laws). Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply protections as described in this Privacy Policy.

Data protection principles are designed to ensure that individuals’ personal information is protected throughout the information lifecycle – that is, from the time the information is collected through to its destruction.

To the extent you are entitled under the GDPR and other applicable laws, you can exercise your rights as explained in this Policy by contacting us.


If you correspond with us by email, the postal service, through the Website or other form of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry; to notify you of any updates at the platform and/or in the services; or to keep a record of your complaint, accommodation request, and the like.


As explained above, Smartie Pants collects, holds, uses and discloses personal information to provide you with the services offered through the Smartie Pants Platform. We use this information to refine our services to better tailor them to your needs and to communicate with you about the services Smartie Pants offers and provides. Most of the time, Smartie Pants uses certain personal information to verify your credentials as a registered user and to help you achieve your goals on the Smartie Pants Platform (e.g. making changes in the waterfalls to reflect the deals which were concluded at the Smartie Pants Platform, etc.).

As a general rule, we do not disclose personal information to any third parties, except if it is otherwise required by the GDPR or any other law or to third parties engaged to provide services in connection with the purposes described in this Privacy Policy (e.g. cloud third party service providers, etc.).

Since we process your personal information only for account administration and for delivering benefits to you, we do not sell your personal data to third parties.


Upon registration on the Smartie Pants Platform, you accept our Terms of Service and enter into a contract with us. Performing our contractual obligations towards you is our legal basis for processing your personal data collected as at the moment of your registration. The same legal basis will be applicable for any additional information that you provide to us in your account profile during the term of our contract. If we use cookies requiring your consent as a legal basis for processing of your personal data, we will inform you in advance and ask about your consent (please see below sections).


We may change our business model from time to time. Therefore, in the future we may collect your personal data within the country you are located and then transfer and process it to another area. If we initiate transferring of personal data to countries not deemed adequate as per the applicable data protection law, we will inform you in advance and ensure appropriate safeguards in place, including technical and organisational measures to guarantee the security of your data.


You can enjoy some of our services without giving us your personal information. Some of the information will still be available even to those who are not registered users. However, your information is necessary so that Smartie Pants can provide you with the services you have indicated to request by registering as a Developer or an Advertising Partner and help you boost revenue, as well as to authenticate you so that we know it is you and not someone else.


As other sites, our Website and the Smartie Pants Platofrm may collect certain information automatically and store it in log files. This information can help us design our site to better suit our users’ needs and help us diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.


Smartie Pants makes available a comprehensive Cookie Notice that describes the cookies used on the website and provides information why we use cookies.


Smartie Pants does not track users to subsequent sites and does not serve targeted advertising to them.
Smartie Pants does not, therefore, respond to Do Not Track (DNT) signals.


This Privacy Policy is intended to serve as a notice and provide you with information about what personal information Smartie Pants collects, holds, uses and discloses, the purposes for these processing operations as well as the legal basis. If you have any questions, please contact us at

Should you like to have more information on how Smartie Pants is collecting, holding, using and disclosing personal information about you, or to have access to it, please contact us at

Depending on what the applicable law is, you may also request information about: the purpose of the collecting, holding, using and disclosing your information; the categories of information concerned; who else outside Smartie Pants might have received the data from Smartie Pants; what the source of the information was (if you didn’t provide it directly to Smartie Pants); and how long it will be stored. You have a right to correct (rectify) the record of your personal information maintained by Smartie Pants if it is inaccurate. You may request that Smartie Pants erases that data or cease using it, subject to certain exceptions, provided in the applicable laws. You may also request that Smartie Pants ceases using your data for direct marketing purposes (where applicable). When technically feasible, Smartie Pants will—at your request—provide your personal information to you or transmit it directly to another party (data portability). You have the right to request to obtain from Smartie Pants a restriction of the processing of your personal data when some of the applicable laws requirements are in place.

You may request to exercise any of your rights at Also, a reasonable access to your personal information will be provided at no cost to you upon request made at If access cannot be provided within a reasonable time frame, Smartie Pants will provide you with a date when the information will be provided. If for some reason access is denied, Smartie Pants will provide an explanation as to why access has been denied.


We understand the importance of protecting children's privacy. The Smartie Pants Platform is not designed for, or intentionally targeted at, children 13 years of age or younger, or consumers under the age of 16. It is not our policy to intentionally collect or store information about anyone under the age of 13. In case we become aware that any information for children under age of 13 has been provided to us, we will permanently delete it without undue delay.


Security has always been central for the protection of confidentiality, integrity and availability of personal information. To help protect the privacy of data and personally identifiable information you transmit through the use of our website, we maintain technical and organisational safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal information to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

Your personal information is stored by Smartie Pants on the servers of the cloud-based database management services Smartie Pants engages, most commonly located in the United States. Smartie Pants retains data for the duration of the customer’s business relationship with Smartie Pants and for a period of time thereafter to allow registered users to recover accounts if they decide to renew. For more information on where and how long your personal information is stored, and for more information on your rights of erasure and portability, please contact us at When sending information overseas, we make sure there are arrangements in place to protect your information.


If you have a concern or complaint about your privacy, let us know and we’ll try to fix it. If you’re not satisfied with how we handle your complaint, there are other things you can do. You can also contact the data protection authority in your jurisdiction.


As we wish to improve our services and your customer experience, this Privacy Policy, our Terms associated with the services we provide are expected to change as well. We reserve the right to amend the Privacy Policy, our Terms at any time and every 12 months as a minimum. We may e-mail periodic reminders of our notices and terms and conditions, but you should check our website frequently to see the current terms and conditions that are in effect and any changes that may have been made to them.