Privacy Policy

Last Updated: May 30, 2026 | Effective Date: May 30, 2026

This Privacy Policy describes how Smarba Consulting, Inc. ("Smarba Consulting," "we," "us," or "our") collects, uses, processes, and shares your personal information when you visit our website at www.smarbaconsulting.com (the "Site"), interact with our services, or communicate with us.

We are committed to protecting your privacy and handling your personal information responsibly. Please read this policy carefully to understand our practices regarding your information.

1. Information We Collect

1.1 Information You Provide Directly

We collect information you voluntarily provide to us when you:

• Contact us via our website contact form, email, or phone — including your name, email address, phone number, company name, job title, and any details you include in your message.
• Request a consultation or proposal — including project requirements, technical specifications, timeline expectations, and budget parameters.
• Subscribe to communications — such as your email address and communication preferences.
• Engage our services — we may collect additional business and technical information necessary to perform our consulting engagements under separate agreements.

1.2 Information Collected Automatically

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

• Device and browser information: IP address, browser type and version, operating system, device type, screen resolution, and language preferences.
• Usage data: Pages viewed, links clicked, time spent on pages, referring URLs, search terms, and navigation patterns.
• Cookies and similar technologies: We use cookies, web beacons, and similar tracking technologies as described in Section 5 below.

2. How We Use Your Information

We use the information we collect for the following purposes:

• Service Delivery: To respond to your inquiries, provide proposals, deliver consulting services, and manage our client relationships.
• Communication: To communicate with you about your requests, our services, project updates, and administrative matters.
• Site Improvement: To analyze usage patterns, improve our website functionality, enhance user experience, and develop new features.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, and enforceable governmental requests.
• Protection of Rights: To protect our rights, property, and safety, and the rights, property, and safety of our clients and third parties.
• Business Operations: For internal business purposes such as auditing, data analysis, research, and quality assurance.

3. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom, our processing of your personal information is based on the following legal grounds:

• Consent: Where you have given us explicit consent to process your information for specific purposes.
• Contractual Necessity: Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided those interests do not override your fundamental rights and freedoms.
• Legal Obligation: Where processing is necessary to comply with a legal obligation to which we are subject.

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

• Service Providers: We may share information with trusted third-party service providers who assist us in operating our website, conducting our business, or serving our clients (e.g., hosting providers, analytics services, email delivery services), provided they agree to maintain the confidentiality and security of your information.
• Professional Advisors: We may disclose information to our legal counsel, accountants, insurers, and other professional advisors where necessary in the course of our business operations.
• Business Transfers: In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred as part of that transaction.
• Legal Requirements: We may disclose information if required to do so by law or in response to valid legal process, such as a court order, subpoena, or government investigation.
• Protection of Rights: We may disclose information to enforce our terms of service, protect our rights or property, or protect the safety of our users or others.

5. Cookies and Tracking Technologies

Our Site uses cookies and similar tracking technologies to enhance your browsing experience, analyze site traffic, and understand where our visitors come from.

What are Cookies? Cookies are small text files that are stored on your device when you visit a website. They help websites remember your preferences and improve your experience.

Types of Cookies We Use:

• Essential Cookies: Required for the basic functionality of our Site. These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our Site by collecting and reporting information anonymously.
• Preference Cookies: Remember your settings and preferences to enhance your experience.

Managing Cookies: You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our Site.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Contact information: Retained for the duration of our relationship and for a reasonable period thereafter (typically up to 3 years following our last communication or engagement).

Usage data: Retained for analytics purposes for up to 26 months.

Client engagement data: Retained in accordance with our professional record-keeping obligations, typically 7 years following the conclusion of an engagement.

When we no longer have a legitimate business need to process your information, we will delete or anonymize it.

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Secure data storage with access controls and authentication
• Regular security assessments and vulnerability testing
• Employee training on data protection and privacy practices
• Minimum necessary access principles for all personnel

While we strive to protect your personal information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

8.1 For All Users

• Access: Request a copy of the personal information we hold about you.
• Correction: Request that we correct inaccurate or incomplete information.
• Deletion: Request that we delete your personal information, subject to certain exceptions.
• Objection: Object to our processing of your personal information based on legitimate interests.
• Restriction: Request that we restrict the processing of your information under certain circumstances.
• Portability: Request a copy of your information in a structured, machine-readable format.

8.2 California Privacy Rights (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights regarding your personal information:

• Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to Opt-Out: Smarba Consulting does not sell your personal information. We do not and will not sell personal information of any individual.
• Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise your CCPA rights, please contact us using the information in Section 12. We will verify your request before processing it.

9. International Data Transfers

Smarba Consulting is based in the United States. If you are located outside the United States, please be aware that your information will be transferred to and processed in the United States, where our servers and central databases are operated.

When we transfer personal information from the EEA, UK, or Switzerland to the United States, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission, or other legally recognized transfer mechanisms.

10. Third-Party Links

Our Site may contain links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us. If we learn that we have collected personal information from a child without verification of parental consent, we will take steps to delete that information promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this policy and, where appropriate, by providing additional notice through our website or via email.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

13. Developer Information

14. Contact Us

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

Smarba Consulting, Inc.
3324 W 105TH St
Cleveland, OH 44111-1238
United States

Email: contact@smarbaconsulting.com
Phone: +1 (318) 768-5608

We will acknowledge receipt of your privacy-related request within 5 business days and respond substantively within 30 days.