Privacy policy

Effective date: June 2025

What this privacy notice covers

Welcome to SMG, a customer experience measurement and analysis platform.

This Privacy Notice sets out how we collect, store, transfer, share and use information that identifies, relates to, describes, is associated with, or could reasonably be linked to you (your "Personal Data") when you visit the smg.com website (our "Site").

Please read this Privacy Notice carefully before browsing the Site. If you have any questions about this Privacy Notice or how we use your Personal Data, please contact us using the contact details set out below.

Part 1 of this privacy notice sets out the following general information about how we collect and use Personal Data:

• Categories of Personal Data Processed
• How we use Personal Data
• Third-Party Recipients of Personal Data
• Retention of Personal Data
• Information Security
• Cookies
• Interest-based Advertising
• Control over your Personal Data

The Site uses cookies and similar tracking technologies to distinguish you from other users of the Site. Cookies are pieces of code that we transfer to your computer's hard disk to store or collect information. These technologies help us to provide certain functionalities of the Site and to monitor and improve these.

Please see our Cookie Notice for information about the cookies and similar trackers we use.

Other than cookies that are required to operate the Site, we will only place cookies on your device with your consent. You can also change your preferences in relation to the cookies you consent to receive by managing your Cookie Preferences.

You also have the ability to opt out of all cookies by disabling cookies in your browser or mobile settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of the Site. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

1. Cookie settings in Internet Explorer
2. Cookie settings in Firefox
3. Cookie settings in Chrome
4. Cookie settings in Safari web and iOS

Interest-based Advertising

We work with online advertising networks and advertising partners to tailor the ads played or displayed to you on other websites, apps, or services.

Online advertising

The ads you see online are tailored to your interests based on information collected about you, including information about your age, demographic, location, as well information about your internet usage over time, such as the websites you visit, the products and pages you view and the links you click on (including links in ads played or displayed to you).

Typically, this information is collected through cookies or similar tracking technologies. When you visit the Site, if you give us your consent to do so, we will place cookies and similar tracking technologies on your device to:

• Identify you and your device, and share this information with the relevant advertising networks, so that they can serve you advertising based on the information those advertising networks (or the partners they work with) have about your internet usage history
  
  
• Collect information about how you use the Site, so that when you visit another website that works with the same advertising network as us, we can play you adverts for the Site and our services which are tailored to the pages and features of our Site that you accessed

We may use certain forms of display advertising and other advanced features through third party service providers like Google Universal Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Site. You can opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners. You can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

Controlling the ads you see online

Please see our Cookie Notice for details of the third parties that collect information about your use of the Site for advertising purposes.

We will only collect and share information about your use of the Site for advertising purposes to the extent you have given us your consent to do so.

Withholding or withdrawing consent will mean that information about your use of the Site will not be shared with advertising networks to allow us to target advertising on other websites.

If you opt-out of advertising by withholding or withdrawing your consent to advertising cookies, you will still get ads when you browse the internet, and those ads may still be relevant to your interests. However, this will be based on target audiences (i.e. individuals sharing certain characteristics) rather than targeting based on your actual online activity. As a result, you may see advertising targeted to your location, demographic or other information on the websites you visit even if you reject cookies on the Site.

We support the self-regulatory principles for online behavioral advertising (the "Principles") published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at https://youradchoices.com/. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions:

• In the United States, please visit: https://youradchoices.com/, or https://optout.networkadvertising.org
  
• In the European Economic Area, please visit: http://www.youronlinechoices.com
  
• In Canada, please visit: https://youradchoices.ca

When you elect to opt-out through these sites, they will place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements.  Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.  Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Control over your Personal Data

You may control your information in the following ways:

• Email Communications Preferences. If you receive promotional email communications from us, you can stop receiving these by clicking on the “unsubscribe” link provided in such communications
  
  
• Cookies. Other than cookies that are required to operate the Site, we will only place cookies on your device with your consent.
  
  
• Modifying or Deleting Your Information.  If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacyofficer@smg.com. We may not be able to modify or delete your information in all circumstances
  
  
•   Your Rights
•   Children's Privacy
•   Updates

Part 2 of this privacy notice sets out additional information for users in the United States of America, and Part 3 of this privacy notice sets out additional information for users in the European Economic Area and the United Kingdom.

What this privacy notice does not cover

We use a number of web pages, applications and other tools to collect feedback and information from consumers about how they interact with our corporate partners. This Privacy Notice does not cover how we use Personal Data collected through those pages, applications and tools.

It also does not cover how we collect and use Personal Data about users of our customer experience reporting platform, SMG360.

Please refer to the privacy notices supplied with or published on those pages, applications and tools for information about how your Personal Data is used.

This Privacy Notice also does not cover our use of information that is not "personal information", "personal data" or similar terms under applicable law. This means that it does not cover our use of aggregated or anonymized information.

Where applicable law permits, it also does not cover deidentified information, meaning information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual (please note that this would not apply to Personal Data collected from you if you are in the UK, EEA or Switzerland).

Who we are and how to contact us

The Site is operated by Service Management Group LLC ("SMG", "we", "us" or "our").

If you have questions about privacy, need assistance with accessing or updating your Personal Data, or have complaints relating to the processing of your Personal Data, please contact our Data Protection Officer by email at privacyofficer@smg.com or by calling +1 800-764-0439 and asking to speak with SMG’s Data Protection Officer. 

If you are in the European Economic Area, you can also contact our EU representative, Data Protection Representative Limited:

• by email to datarequest@datarep.com, quoting "Service Management Group, LLC" in the subject line; or
  
  
• by completing the form at https://www.datarep.com/data-request

Please specify in your request that it relates to the smg.com website. 

Part 1 – How we collect and use Personal Data

Categories of Personal Data Processed

Personal data you provide to us

We collect Personal Data that you submit directly to us when you communicate with us about our Site or any of our other services. This can include information you provide to us when you contact us through the Site, by telephone, e-mail or any other means or when you sign up to receive marketing communications from us.

We will collect the following information in this way:

• Identifiers and professional / employment information, such as your name, company name, job title, business email address and department.
  
  
• Comments, questions and feedback that you submit to us when you contact us, such as if you request a demo of SMG’s offerings, ask to learn more about SMG or our services, express an interest in a career at SMG, or you have a question about the SMG services you currently use (such as issues or errors you experience when using such services or other support requests).
  
  
• Resources that you download from the Site. When you download reports, eBooks, best practice guides, presentations or case studies, we may collect your contact information as set out above and keep a record of the resources you have accessed or downloaded.
  
  
• Your marketing preferences, such as whether you have signed up to our newsletters or otherwise agreed to receive marketing emails from us.

We will indicate to you if the provision of certain Personal Data is mandatory or optional. If you choose not to provide any Personal Data marked as mandatory, we may not be able to respond to your queries, sign you up for our email alerts or respond to your other requests.

Personal Data we collect automatically through cookies and similar technologies

We automatically collect Personal Data about how you access and use the Site, including:

• Information about your device, such as IP address, type of device used to access the Site, browser type, browser window size and device model.
  
  
• Approximate location, such as general geographic location that we or our third-party providers may derive from your IP address.
  
  
• Information about how you interact with the Site, such as the pages you view and features you use on the Site, whether you have visited the Site before and any errors that occur on the Site while you are using it. 

For more information about how we collect this Personal Data, please refer to the "Cookies" section below.

Personal Data we collect from third parties or generate internally

We also collect certain Personal Data about you from third parties, or create certain Personal Data internally, namely:

• Identifiers and professional / employment information such as your name, company name, job title, business email address and department. We may collect this information from public sources, such as LinkedIn or other social media sites, or from lead generation partners. We may combine information from several sources, which means that we are not always able to identify the exact source of your Personal Data. If you would like to know more about where we obtained your Personal Data, please contact us using the details set out in the "Who we are and how to contact us" section above.
  
  
• Communications we send to you, such as the date, time and content of any promotional or other materials that we send to you by mail, email or other means. If we reach out to you by phone we will also keep a note of the date and time we called you and the content of the conversation.

How we use your Personal Data

We use the information that you provide to us or that we collect to:

• Communicate with you, including responding to your queries, comments or requests for further information about our services;
  
  
• Display the Site to you on your device, including to facilitate communication between your device and our systems, store your preferences, authenticate users and detect and prevent fraud;
  
  
• Improve our services, including assessing the performance of our Site; identifying usage trends to develop features, functionalities and content on our Site; diagnosing and remedying errors or performance-related issues;
  
  
• Send you promotional emails in accordance with your preferences, and customize the content of those emails based on information you have submitted to or requested from us;
  
  
• Measure the effectiveness of our marketing campaigns, such as assessing the extent to which any promotional activity that we engage in converts to customers signing up to our services;
  
  
• Comply with legal obligations or enforce our rights, including enforcing our rights under our Site terms and conditions, protecting SMG’s property or protecting the rights, property or safety of others, or, as needed, to support SMG’s external auditing, compliance, and corporate governance functions. 
  
  
• Serve you targeted advertising on the Site and other websites you visit, as further described in the "Targeted Advertising" section below.

Third-Party Recipients of Personal Data

• Third Party Service Providers Analyzing Usage of the Site: We may use third-party website analytics services to analyze how individuals use the Site.  We use information collected from these third-party services to help us better understand how our users find and use the Site, enhance our services, and to improve your user experience.
  
  
• Third Parties Assisting with Electronic Communications:  Your Personal Data will be used, as needed, to manage our relationship and communicate with you by mail, telephone, e-mail, mobile alerts, and SMS text messaging. We may share your Personal Data with service providers that assist us in communicating with you.
  
  
• Third Party Service Providers Assisting with Print Mail Direct Marketing: We also may share your Personal Data with direct mail service firms that assist us in printing, addressing and distributing printed materials and other physical marketing materials. Such firms may access name, title, company and company address information for the purpose of printing shipping and mailing labels. SMG uses this data to reach clients and prospects with non-digital marketing and product-related communications.
  
  
• Other Service Providers:  We may share your information, including your Personal Data, with other service providers we use to perform the functions for which we engage them, such as hosting, data storage, and security. 
  
  
• Law Enforcement and Other Public Authorities:  SMG may also share the information we collect from you, as needed, to enforce its rights, protect its property or protect the rights, property or safety of others, or, as needed, to support SMG’s external auditing, compliance, and corporate governance functions.  SMG will disclose Personal Data as it deems necessary to respond to a subpoena, binding order of a data protection authority or judge, legal process, governmental request or any other legal or regulatory obligation.  SMG may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.  SMG may also share Personal Data as required to pursue available legal remedies or limit damages it may sustain. 
  
  
• Third Parties in Connection with Business Reorganization: We may transfer information about you, including Personal Data, in connection with any actual or impending reorganization, merger, sale, joint venture, assignment, transfer, acquisition or other change in ownership or control by or of SMG or any affiliated company (in each case whether in whole or in part), including without limitation, in connection with any bankruptcy or similar proceeding.  Any such entity to which we transfer Personal Data will be required to provide you with notice of any purposes of processing not compatible with the purposes set forth in this Privacy Notice, as well as any privacy practices that are materially different than the practices set forth in the Privacy Notice.  Where required by law, such entity also will be required to obtain your consent.

Retention of Personal Data

We will retain your Personal Data in our records for no longer than is necessary for the purposes for which it was originally collected, and normally for no longer than the following periods:

• If you communicate with us or we communicate with you about our products and services, we will typically retain your Personal Data for up to one year from the date of the last communication between you and us.
  
  
• If you or the organization you work for sign up to our services, we will typically retain contact details, employment information and the content of our communications with you for the duration of our contract with you and for a period of 6 years after that contract terminates.
  
  
• If you or the organization you work for signs up to receive similar services to ours from another company, we will keep your contact details, employment information and the content of our communications with you for the duration of your or your organization's agreement with that other company (if known) and for a period of 3 years after it terminates. If we do not know the duration of your or your organization's agreement with our competitor, we will keep your Personal Data for a period of 3 years after our last communication with you.
  
  
• For information collected about how you use our Site, we retain data in accordance with the standard retention periods set by the service providers we use to collect such information.

When such information is no longer needed for the purposes for which it was originally collected, we will securely delete all of your electronic Personal Data, and securely dispose of any hard copy Personal Data, except for what is needed to comply with our legal obligations.  See section below under “Your Rights” for additional information pertaining to the right of erasure, as well as other data subject rights.

Information Security

SMG has an information security program that implements technical, physical, and organizational measures designed to assist in maintaining the security and confidentiality of Personal Data; safeguarding against anticipated threats to the confidentiality, integrity and availability of Personal Data; and protecting your Personal Data against loss, misuse, unauthorized alteration or destruction, and unauthorized access or disclosure. 

However, whenever Personal Data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party.  No system or online transmission of data is completely secure.  In addition to the technical, physical, and organizational measures that SMG has in place to protect your Personal Data, you should use appropriate security measures to protect your Personal Data.  If you believe that your account or any information you provided to us is no longer secure, notify our Data Protection Officer immediately by email at privacyofficer@smg.com or by calling 800-764-0439 and asking to speak with SMG’s Data Protection Officer. 

Cookies

The Site uses cookies and similar tracking technologies to distinguish you from other users of the Site. Cookies are pieces of code that we transfer to your computer's hard disk to store or collect information. These technologies help us to provide certain functionalities of the Site and to monitor and improve these.

Please see our Cookie Notice for information about the cookies and similar trackers we use. 

Other than cookies that are required to operate the Site, we will only place cookies on your device with your consent. You can also change your preferences in relation to the cookies you consent to receive by visiting Cookie Preferences.

You also have the ability to opt out of all cookies by disabling cookies in your browser or mobile settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of the Site. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

1. Cookie settings in Internet Explorer
2. Cookie settings in Firefox
3. Cookie settings in Chrome
4. Cookie settings in Safari web and iOS.

Interest-based Advertising

We work with online advertising networks and advertising partners to tailor the ads played or displayed to you on other websites, apps, or services.

Online advertising

The ads you see online are tailored to your interests based on information collected about you, including information about your age, demographic, location, as well information about your internet usage over time, such as the websites you visit, the products and pages you view and the links you click on (including links in ads played or displayed to you).

Typically, this information is collected through cookies or similar tracking technologies. When you visit the Site, if you give us your consent to do so, we will place cookies and similar tracking technologies on your device to:

• Identify you and your device, and share this information with the relevant advertising networks, so that they can serve you advertising based on the information those advertising networks (or the partners they work with) have about your internet usage history;
  
  
• Collect information about how you use the Site, so that when you visit another website that works with the same advertising network as us, we can play you adverts for the Site and our services which are tailored to the pages and features of our Site that you accessed.

We may use certain forms of display advertising and other advanced features through third party service providers like Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Site. You can opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://safety.google/privacy/ads-and-data/. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at https://policies.google.com/privacy. You can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

Controlling the ads you see online

Please see our Cookie Notice for details of the third parties that collect information about your use of the Site for advertising purposes.

We will only collect and share information about your use of the Site for advertising purposes to the extent you have given us your consent to do so. You can also customize your preferences by visiting Cookie Preferences.

Withholding or withdrawing consent will mean that information about your use of the Site will not be shared with advertising networks to allow us to target advertising on other websites.

If you opt-out of advertising by withholding or withdrawing your consent to advertising cookies, you will still get ads when you browse the internet, and those ads may still be relevant to your interests. However, this will be based on target audiences (i.e. individuals sharing certain characteristics) rather than targeting based on your actual online activity. As a result, you may see advertising targeted to your location, demographic or other information on the websites you visit even if you reject cookies on the Site.

We support the self-regulatory principles for online behavioral advertising (the "Principles") published by the Digital Advertising Alliance (DAA). This means that we allow you to exercise choice regarding the collection of information about your online activities over time and across third-party websites for online interest-based advertising purposes. More information about these Principles can be found at https://youradchoices.com. If you want to opt out of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in the DAA program and perform advertising-related services for us and our partners, please follow the instructions:

• In the United States, please visit: https://youradchoices.com/ , or https://optout.networkadvertising.org/
  
  
• In the European Economic Area, please visit: http://www.youronlinechoices.com/
  
  
• In Canada, please visit: https://youradchoices.ca/

When you elect to opt-out through these sites, they will place an opt-out cookie on your device indicating that you do not want to receive interest-based advertisements.  Opt-out cookies only work on the internet browser and device they are downloaded onto. If you want to opt out of interest-based advertisements across all your browsers and devices, you will need to opt out on each browser on each device you actively use. If you delete cookies on your device generally, you will need to opt out again.  Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Control over your Personal Data

You may control your information in the following ways:

• Email Communications Preferences. If you receive promotional email communications from us, you can stop receiving these by clicking on the “unsubscribe” link provided in such communications.
  
  
• Cookies. Other than cookies that are required to operate the Site, we will only place cookies on your device with your consent. You can also change your preferences in relation to the cookies you consent to receive by visiting Cookie Preferences.
  
  
• Modifying or Deleting Your Information.  If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at privacyofficer@smg.com. We may not be able to modify or delete your information in all circumstances.

Your Rights

Depending on where you access the Site from, you may have some or all of the following rights in respect of your Personal Data that we hold:

• Right of access. You have the right to obtain confirmation of whether, and where, we are processing your Personal Data, information about the purposes for which we process your Personal Data, information about how we determine applicable retention periods, and to obtain a copy of that Personal Data;
  
  
• Right of portability. You have the right, in certain circumstances, to receive a copy of the Personal Data you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Data to another person;
  
  
• Right to rectification or correction. You have the right to obtain rectification of any inaccurate or incomplete Personal Data we hold about you without undue delay;
  
  
• Right to deletion or erasure. You have the right, in some circumstances, to require us to erase your Personal Data without undue delay if the continued processing of that Personal Data is not justified; and
  
  
• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you.

You may also have the right to object (opt out) to our processing of your Personal Data where:

• we sell your Personal Data for monetary or other valuable consideration or use your Personal Data for targeted advertising; and
  
  
• we process your Personal Data based on our legitimate interests. If we receive an objection from you, there may be compelling reasons for continuing to process your Personal Data in this way, and we will assess and inform you if that is the case. 

If you wish to exercise one of these rights, please contact us by:

• email at privacyofficer@smg.com; or
  
  
• writing to Data Protection Officer, Service Management Group, LLC, 4049 Pennsylvania Avenue, Suite 203, PMB 1063, Kansas City, MO 64111

We will notify you if we are unable to action your request because your exercise of the above rights is restricted in any way under applicable law.

Children’s Privacy

The smg.com website is not directed to individuals under the age of 16, and we request that individuals under 16 not provide Personal Data to SMG.  If we learn that we have collected Personal Data from a child under 16, we will take steps to delete the information as soon as possible.

Updates

We will update this Privacy Notice from time to time when we make changes impacting the Privacy Notice, such as adding new services and applications, improving our services, and addressing changes in technologies and laws.  The Effective Date of this Privacy Notice, which is set forth on the first page of the Privacy Notice, reflects the date the Privacy Notice was last updated.  SMG will provide notice to you of any changes, and where required by applicable law, we will obtain your consent. 

Part 2 – Additional information for users in the USA

Your Privacy Choices

Depending on your state of residency, in addition to the rights set out in the "Your Rights" section above you may have the following rights in relation to the Personal Data that we hold about you (subject to certain limitations at law):

• The Right to Know. The right to confirm whether we are processing Personal Data about you and to obtain certain personalized details about the Personal Data we have collected about you in the last 12 months, including:

• the categories of Personal Data collected;
  
  
• the categories of sources of the Personal Data;
  
  
• the purposes for which the Personal Data was collected;
  
  
• the categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom the Personal Data were disclosed;
  
  
• the categories of Personal Data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the Personal Data were disclosed for those purposes; and
  
  
• the categories of Personal Data sold (if any), and the categories of third parties to whom the Personal Data was sold.
  
  
• The Right to Opt Out of Sales or Sharing for Targeted Advertising. The right to direct us not to "sell" Personal Data we have collected about you to third parties for monetary or other valuable consideration, or “share” your Personal Data to third parties for cross-context behavioral advertising purposes. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales. You may opt out of the sale of your Personal Data or the sharing to a third party for targeted advertising by updating your settings at Cookie Preferences.
  
  
• Non-Discrimination. The right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. Note, however, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
  
  
• The right to opt out of the sharing of your Personal Data to third parties for the third parties’ direct marketing purposes.

If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at privacyofficer@smg.com.

How To Exercise Your Privacy Rights

To submit a request to exercise one of the privacy rights identified above, please submit a request by: 

• Emailing privacyofficer@smg.com with the subject line “Data Subject Rights Request”; or
  
  
• Calling us at 1 (240) 376-2296; or
  
  
• Filling out our Individual Rights Request Form

All requests to exercise your rights will need to be verified by us. This process may require us to request additional Personal Data from you, including, but not limited to, your email address. In certain circumstances, we may decline a request to exercise a privacy right, particularly where we are unable to verify your identity. If we cannot verify your identity based on the information provided, a request for a copy of your data will be treated as a request for information and if we cannot verify your identity, a request to delete Personal Data may be treated as a request to opt-out of the sale of Personal Data.

If you wish to appeal a decision regarding your rights, please contact us at privacyofficer@smg.com.

Authorized Agents

You may designate an authorized agent to make a request on your behalf. An authorized agent must have written documentation of their authority to act on your behalf, such as receiving:

• a power of attorney; or
  
  
• receiving sufficient evidence to show that you have: (i) provided the authorized agent signed permission to act on your behalf, (ii) verified your own identity directly with us pursuant to the procedures above; and (iii) directly confirmed with us that you have provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of Personal Data "sales" or sharing for targeted advertising, the authorized agent must provide a signed permission demonstrating authorization to act on your behalf.

California Residents

If you are a resident of the State of California, these additional disclosures apply to you.

Collection of Personal Data. In the last 12 months, we may have collected all of the categories of Personal Data referred to in the "Categories of Personal Data Processed" section in Part 1 of this Privacy Notice above. For more information about how we use that Personal Data, please see the "How we use your Personal Data" section in Part 1 of this Privacy Notice above.

Disclosure of Personal Information. We may share and disclose Personal Data with third parties as described in the "Third-Party Recipients of Personal Data" section of Part 1 of our Privacy Notice. In the previous 12 months, we may have disclosed all of the categories of Personal Data we process to third parties for a business purpose. The categories of third parties to whom we may disclose your Personal Data for a business purpose include: (i) business partners; (ii) analytics providers and advertising networks; and (iv) our service providers, contractors and advisors. 

Sales of Personal Information.  In the previous 12 months, we may have sold the following information to third parties, subject to your settings and preferences and your right to opt out and in a manner consistent with your preferences or as permitted by law: information about how you use and access the Site, including information about your approximate location and the device you use to access the Site.

Privacy Rights of Minors. We do not sell the Personal Data and do not have actual knowledge that we sell the Personal Data of minors under 16 years of age. If we wish to do so in the future, we will first seek affirmative authorization from the minor who is between 13 and 16 years of age.

If you are under the age of 18 and you want to remove your name or comments from our website or publicly displayed content, please contact us directly at privacyofficer@smg.com. We may not be able to modify or delete your information in all circumstances.

Financial Incentives. We do not provide financial incentives to users for allowing us to collect and retain Personal Data through the Site.

Part 3 – Additional information for users in the UK and EEA

Service Management Group LLC will be the controller of the Personal Data that we collect about you when you access and use the Site. This means that this company determines and is responsible for how that Personal Data is used.

Uses of your Personal Data and lawful bases

We use the Personal Data we collect from you when you access and use the Site as follows:

• Identifiers and professional / employment information, such as your name, company name, job title, business email address and department