Privacy Policy

1. Who we are

Smart Ad Management ("SAM", "we", "us", "our") — offices at 1211 Liberty Ave, Brooklyn, NY 11208, USA and Mr van Houtenstraat 54, 6535 XP Nijmegen, The Netherlands.

We are the controller of the personal data described in this policy. You can contact us at contact@smartadmanagement.com.

This policy explains what personal data we collect through smartadmanagement.com (the "Website"), why we use it, who we share it with and what rights you have. It is written to meet the requirements of the EU General Data Protection Regulation (GDPR) and, where relevant, applicable US state privacy laws.

2. Data we collect

We collect only the data needed to run the Website and respond to you:

• Enquiry data — name, company, email, phone number (optional), service of interest, budget range (optional) and the message you write, when you use our contact form.
• Email correspondence — the content of emails you send us and our replies.
• Technical data — IP address, browser type and request details processed by our hosting provider and by Google Fonts when pages load (see section 6).
• Cookie preference — a single value stored in your browser remembering whether you accepted or declined optional cookies.

We do not knowingly collect data from children, and we do not ask for sensitive personal data.

3. How the contact form works

When you click “Send message”, the form opens your own email application with the details you entered pre-filled in a new message addressed to us. Nothing is sent until you send that email yourself. We receive your data only when you send it, and the Website does not store form entries on a server.

4. Why we use your data and our legal basis

• To reply to your enquiry and prepare a proposal — steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR) and our legitimate interest in running our business (Art. 6(1)(f)).
• To operate, secure and improve the Website — legitimate interest (Art. 6(1)(f)).
• Optional analytics or marketing cookies, if ever enabled — your consent (Art. 6(1)(a)), which you can withdraw at any time.
• To comply with legal obligations such as accounting and tax rules (Art. 6(1)(c)).

We do not sell your personal data and we do not use it for automated decision-making or profiling that produces legal effects.

5. Who we share data with

We share data only where necessary:

• Service providers such as website hosting, email and IT support providers, acting on our instructions.
• Our technology partner GAITS Solutions (GAITS ADTECH, S.L.), only when your enquiry concerns IT services delivered by them, and only so they can respond to you.
• Professional advisers, authorities or courts where required by law.

We require our providers to protect your data and use it only for the agreed purpose.

6. Third-party content and international transfers

The Website loads fonts from Google Fonts. When a page loads, your browser connects to Google servers and your IP address may be transmitted to Google. Links to external sites (for example gait.solutions or LinkedIn) are governed by those sites’ own policies.

Our offices are in the United States and the Netherlands, so your data may be processed in both. Where data is transferred outside the European Economic Area, we rely on safeguards recognised under the GDPR, such as Standard Contractual Clauses or an adequacy decision.

7. How long we keep data

Enquiry emails: for as long as needed to handle your request and, if no business relationship follows, up to 24 months.

Client records and invoices: for the period required by tax and accounting law (generally 7 years).

Cookie preference: stored in your browser until you clear it.

8. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased, in the cases provided by law;
• restrict or object to certain processing, including processing based on legitimate interest;
• receive your data in a portable format;
• withdraw consent at any time, without affecting earlier processing.

To exercise a right, email contact@smartadmanagement.com. We will respond within one month. You also have the right to lodge a complaint with a supervisory authority — in the Netherlands, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl) — or with the authority in your own country.

California and other US state residents: depending on your state you may have rights to know, access, correct and delete personal information and to opt out of its sale or sharing. We do not sell or share personal information for cross-context behavioural advertising. Contact us to exercise these rights; we will not discriminate against you for doing so.

9. Security

We use reasonable technical and organisational measures to protect personal data, including encrypted connections (HTTPS) and restricted access. No system is completely secure, so please avoid sending sensitive information by email.

10. Changes to this policy

We may update this policy from time to time. The “Last updated” date below shows the latest version; material changes will be highlighted on the Website.

11. Contact

Questions about this policy or your data: contact@smartadmanagement.com.

Last updated: 18 October 2026