Smart.by ("Smart.by LLC," "we," "us," or "our") provides investment advisory, financial structuring, and strategic consulting services to investors and companies operating in Morocco and internationally. Given the confidential nature of our work, we treat the protection of personal and business information as central to our relationship with every client, partner, and visitor.

This Privacy Policy describes what information we collect, why we collect it, how it is used and protected, and the choices and rights available to you. It applies to our website, our client platform Smart Flow, and any other interaction you have with Smart.by, whether as a prospective client, an active client, or simply a visitor to our site.

Smart.by is a company registered in Tangier, Morocco, under ICE No. 002153351000062, with offices in Tangier, Casablanca, and Marrakech. Smart.by is the party responsible for determining how and why your personal data is processed in connection with our website and services.

For any question regarding this Policy or how your data is handled, you can reach our privacy team directly at [email protected].

We collect information in a few distinct ways, depending on how you interact with us:

• Information you provide directly: your name, email address, phone number, company name, and any details you share through contact forms, consultation requests, the investment simulator, or direct correspondence.
• Client and engagement data: where you become a client, information necessary to deliver our services, including financial, business, and project-related information you entrust to us for the purpose of our engagement.
• Technical and usage data: IP address, browser type, device information, pages visited, and time spent on our site, collected automatically through standard web analytics.
• Smart Flow platform data: where you use our client platform, information related to your projects, investments, and reporting activity within that platform.

We use the information we collect to:

• Respond to inquiries, schedule consultations, and provide the services you request
• Deliver, manage, and report on active client engagements, including through Smart Flow
• Send updates you have explicitly opted in to receive, such as our newsletter
• Understand how our website is used, so we can improve its content and performance
• Detect, investigate, and prevent fraudulent, unauthorized, or harmful activity
• Meet our own accounting, contractual, and administrative obligations

We only process personal data where we have a valid basis to do so. Depending on the context, this basis may be:

• Your consent, such as when you submit a contact form or subscribe to our newsletter
• The performance of a contract, when processing is necessary to deliver a service you have engaged us for
• Our legitimate interests, such as securing our website, understanding usage trends, or maintaining business records, provided these interests do not override your own rights
• A legal or regulatory obligation, where applicable to our business operations

Our website uses a limited set of cookies necessary for the site to function correctly, along with Google Analytics to help us understand how visitors use our site, such as which pages are viewed and for how long.

We use this analytics data in aggregate form to improve our website; we do not use it to build individual marketing profiles. You can control or disable cookies at any time through your browser settings, though some parts of our site may not function as intended if you do so.

We do not sell, rent, or trade your personal data, under any circumstance. Given the sensitivity of the financial and investment information our clients share with us, access is limited internally to those directly involved in your engagement.

We may share limited information with:

• Service providers who support our operations, such as hosting and website analytics providers, bound by confidentiality obligations and permitted to use data only to provide their service to us
• Professional advisors, such as legal or accounting counsel, where necessary to conduct our business
• Authorities, where disclosure is genuinely required to comply with an applicable legal obligation
• Business partners, only where you have given your explicit consent for a specific purpose

As we work with clients and partners across multiple countries, your information may occasionally be processed outside of the country where you are located, including in connection with hosting or IT infrastructure providers.

Where this occurs, we take reasonable steps to ensure that the receiving party maintains a level of protection consistent with the principles set out in this Policy, and we limit such transfers to what is genuinely necessary to deliver our services.

We retain personal data only for as long as necessary to fulfill the purpose it was collected for, including any period required to meet our legal, accounting, or contractual obligations.

Contact form submissions and general inquiries that do not result in an engagement are retained for a limited period and then deleted. Client engagement data is retained for the duration of our relationship and for a reasonable period afterward, consistent with standard professional and administrative practice, after which it is securely deleted or anonymized.

We apply technical and organizational safeguards appropriate to the sensitivity of the information we hold, including access controls, encryption where applicable, and restricted internal access to client and engagement data on a need-to-know basis.

Our Smart Flow platform, used to share project and investment information with clients, is built with the same standard of protection in mind. While we take data security seriously at every level, no method of transmission or storage over the internet can be guaranteed to be completely secure.

Depending on where you are located, you may have certain rights regarding the personal data we hold about you. Where applicable, these may include the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of your personal data, where we are not required to retain it
• Withdraw consent at any time, where processing is based on consent
• Object to or request that we restrict certain processing activities

We only send newsletter or marketing communications to individuals who have voluntarily subscribed to receive them. We do not purchase contact lists or send unsolicited marketing communications of any kind.

Every communication we send includes a simple way to unsubscribe, and doing so will not affect any existing client engagement or your ability to contact us directly.

Our website and services are directed at businesses and adult individuals in a professional or investment capacity. We do not knowingly collect personal data from minors, and our services are not intended for use by anyone under the age of majority in their jurisdiction.

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable expectations. Any changes will be posted on this page along with a revised "Last update" date. We encourage you to review this page periodically.

If you have any questions about this Privacy Policy or how your information is handled, please reach out to us directly:
📧 [email protected]
📍 Smart.by LLC, T106, Technopark, Tangier 90000, Morocco