SMT Technology Privacy Policy

1. Introduction

In SMT TECHNOLOGY, LDA [(update company name, tax identification number, and full address of the registered office in Portugal)We value your trust and privacy.

This Privacy Policy explains, in a clear and accessible way, how we collect, use, store, share, and protect your personal data, in full compliance with the General Data Protection Law (LGPD – Law No. 13.709/2018, Brazil) and with the European Data Protection Regulations (namely the GDPR – Regulation (EU) 2016/679).

[When SMT Technology operates under European jurisdiction, replace references to LGPD with GDPR and adjust legal articles accordingly.]

By using our platform, contracting our services, or interacting with us (e.g., website, application, or email), you agree to the terms of this Policy. Our goal is to ensure you understand how we process your data and what your rights are.

 

2. Important Definitions

SMT Technology: We are the company that provides the platform and processes your data, acting as... responsible for the treatment (who decides what to do with the data) or subcontractor (who processes data for third parties), as the case may be.

Account Holder / User: The individual to whom the personal data belongs.

Personal Data: Any information that identifies or could identify the data subject, such as name, email, tax identification number, address, telephone number, etc.

Anonymized Data: Data that does not allow the identification of the data subject, used for statistical analysis or usage reports.

Data Protection Officer (DPO): Person responsible for compliance and point of contact with data subjects and the National Data Protection Commission (CNPD) [or ANPD, if still applicable in Brazil.].

Data Processing: Any operation performed on personal data, including collection, recording, storage, use, transmission, or deletion.

 

3. How We Collect Your Data

3.1 Data that you provide us

  • Filling out forms on the website or application (name, email, phone number, tax identification number, etc.);

  • Contact us via chat, email, WhatsApp, or phone;

  • Contracting for services or products (billing information, payment methods, etc.).

3.2 Data collected automatically

  • IP address, approximate location, date and time of access, device type, browser, and operating system;

  • Pages visited, clicks, and browsing time;

  • Access logs for security and technical diagnostics.

3.3 Cookies and similar technologies

We use cookies and analytics tools (such as Google Analytics) to:

  • Maintain active sessions;

  • Improve performance and browsing experience;

  • Personalize content and recommendations;

  • Detect suspicious behavior.

[When the SMT Technology website is implemented, include a direct link to the "Cookie Preferences Panel" with a detailed consent policy.]

PURPOSE

Provision and management of services

Service and platform improvements

Compliance with legal obligations

Communication and marketing

Security and fraud prevention

LEGAL BASIS (LGPD)

Contract execution

Legitimate interest

Legal obligation

Consent

Legitimate interest

EXAMPLE

Account creation, invoicing, technical support

Metrics analysis and navigation optimization

Issuing invoices and tax reports.

Sending newsletters, promotional campaigns

Monitoring access and attempted intrusions.

PURPOSE

LEGAL BASIS (LGPD)

EXAMPLE

Provision and management of services

Contract execution

Account creation, invoicing, technical support

Service and platform improvements

Legitimate interest

Metrics analysis and navigation optimization

Compliance with legal obligations

Legal obligation

Issuing invoices and tax reports.

Communication and marketing

Consent

Sending newsletters, promotional campaigns

Security and fraud prevention

Legitimate interest

Monitoring access and attempted intrusions.

We only process the data strictly necessary for each purpose, following the principles of purpose, adequacy, and necessity of the LGPD (Brazilian General Data Protection Law).

5. Data Sharing

Your data may be shared with:

  • Technology providers (e.g., AWS, Google Cloud, CRM or analytics tools);

  • Public authorities by legal obligation;

  • Business partners with prior consent;

  • Companies within the same corporate group [if SMT has subsidiaries or joint ventures in other countries].

SMT Technology We do not sell or rent personal data. Under no circumstances.

 

6. International Data Transfer

Some data may be stored on servers outside of Portugal or the European Union.
 We guarantee:

  • Adoption of Standard Contractual Clauses approved by the European Commission;

  • Robust certification and encryption mechanisms;

  • Prior notification to the data subject whenever there is a relevant change.

 

7. Data Retention

The data will only be kept for as long as necessary to:

  • To fulfill contractual and legal obligations;

  • Responding to complaints or audits;

  • To protect rights in administrative or judicial proceedings.

After the legal deadline, the data will be deleted or anonymized.
 The owner may request deletion at any time, and SMT Technology will respond within [timeframe]. 30 days.

 

8. Information Security

We have implemented safety measures that comply with the standard. ISO/IEC 27001, including:

  • TLS/SSL and AES-256 encryption;

  • Access control and multifactor authentication;

  • Continuous monitoring and internal audits;

  • Incident response plan with immediate communication to the CNPD (National Data Protection Commission).

 

9. Rights of Data Subjects

Under the GDPR, the data subject has the right to:

  • Access your personal data;

  • Correct or update incorrect information;

  • Request deletion (“right to be forgotten”);

  • To limit or oppose treatment;

  • Transfer the data to another responsible party;

  • Withdraw consent;

Complain to CNPD.

 

10. Data Protection Officer (DPO)

Name: [To be confirmed — it could be José Colmeal himself or a new local DPO.]
 E-mail: [dpo@smttechnology.pt (to be created)]
 Telephone: [To be defined after acquisition of the line in Portugal.]

 

11. Policy Updates

We may update this Policy periodically to reflect legal, technological, or organizational changes.
 The changes will be communicated via:

  • Email (to registered customers);

  • Notification on the website;

  • Publication on the new institutional page [www.smttechnology.pt].

Continuing to use the services after the update will imply acceptance of the new terms.

 

12. Contacts

General email: [info@smttechnology.pt (to be created)]
 Support email: [support@smttechnology.pt (to be created)]
 Telephone: [to be defined]
 Household: [Update with the address of the headquarters in Portugal.]
 Opening hours: Monday to Friday, from 9 am to 6 pm