www.get-smart.com and www.fafcsa.org
Type of websites: Student loan relief through Cryptocurrency
Effective date: 7th day of August, 2022
www.get-smart.net and www.fafcsa.org (the “Sites”) are owned and operated by Digital Financial Aid Corporation (hereinafter “DFAC”), a non-profit corporation in the state of Florida, in the United States of America. DFAC is the data controller and can be contacted at:
7901 4th St. N Ste.
5593 Saint Petersburg, FL. 33702
- The personal data we will collect;
- Use of collected data;
- Who has access to the data collected;
- The rights of the Sites users; and
- The Sites’ cookie policies.
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.
By using our Sites, users agree that they consent to:
When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.
You can withdraw your consent by: Contacting the Data Controller.
Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal bases to collect and process the personal data of users in the EU:
- Users have provided their consent to the processing of their data for one or more specific purposes;
- Processing of user personal data is necessary for us to comply with a legal obligation. If a user does not provide the personal data necessary for us to perform a legal obligation the consequences are as follows: Without a user’s personal data, any related accounts will be suspended indefinitely;
- Processing of user personal data is necessary to protect the life of the user or another natural person; and
- Processing of user personal data is necessary to a task carried out in the public interest or in the exercise of our official authority.
Personal Data We Collect
Data Collected Automatically
When you visit and use our Sites, we may automatically collect and store the following information:
- IP address;
- Hardware and software details;
- Clicked links; and
- Content viewed.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Sites:
- First and last name;
- Date of birth;
- Email address;
- Phone number;
- Payment information;
- Auto fill data; and
- Blockchain address.
This data may be collected using the following methods:
- Creating a user account.
How We Use Personal Data
The data we collect automatically is used for the following purposes:
- The provision of accurate transactions.
The data we collect when the user performs certain functions may be used for the following purposes:
- The purchase, sale and other transfer of Get-Smart tokens to help people with student debt.
Who We Share Personal Data With
We will not sell or share your data with other third parties, except in the following cases:
- If the law requires it;
- If it is required for any legal proceeding;
- To prove or protect our legal rights; and
- To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our sites to another site, please note that we are not responsible for and have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved. You will be notified if your data is kept for longer than this period.
How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.
While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
International Data Transfers
We transfer user personal data to the following countries:
- United States.
If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:
- The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
- We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient..
Your Rights as a User
Under the GDPR, you have the following rights:
- Right to be informed;
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to restrict processing;
- Right to data portability; and
- Right to object.
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data, their parent or guardian may contact our Data Controller.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here:
DFAC privacy officer email address
DFAC privacy officer mailing address
Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not track the users of our Sites over time and across third party websites and therefore do not respond to browser-initiated DNT signals.
A cookie is a small file, stored on a user’s hard drive by a websites. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.
We use the following types of cookies on our Sites:
- Functional cookies
Functional cookies are used to remember the selections you make on our Sites so that your selections are saved for your next visits;
- Analytical cookies
Analytical cookies allow us to improve the design and functionality of our Sites by collecting data on how you access our Sites, for example data on the content you access, how long you stay on our Sites, etc;
- Targeting cookies
Targeting cookies collect data on how you use the Sites and your preferences. This allows us to personalize the information you see on our Sites for you; and
- Third-Party Cookies
Third-party cookies are created by a websites other than ours. We may use third-party cookies to achieve the following purposes:
- Monitor user preferences to tailor advertisements around their interests.
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office in the UK, Data Protection Commission in Ireland.
If you have any questions, concerns or complaints, you can contact our privacy officer, Dr. Angelika Zotter, at:
DFAC privacy officer email address