Privacy Policy
Effective date: October 22, 2026
This Privacy Policy explains how SmartBTN LLC (“Smartbtn”, “we”, “us”), a Wyoming limited liability company and part of the Baxet family of companies, collects, uses, discloses and protects personal information when you visit smartbtn.me, use our dashboard and apps, or interact with the Smartbtn chat widget on a website of one of our customers. It also describes your rights under US state privacy laws, including the California Consumer Privacy Act as amended by the CPRA (“CCPA”), and under the EU and UK GDPR.
Notice at collection. We collect the categories of personal information listed in Section 3 for the purposes in Section 4 and keep them for the periods in Section 9. We do not sell personal information for money. Analytics and advertising cookies on our own website may be considered “sharing” for cross-context behavioral advertising under California law; you can opt out at any time via Your Privacy Choices, and we honor the Global Privacy Control (GPC) signal, which turns off analytics and marketing technologies on our website.
1. Scope and our role
1.1. We are the business/controller for personal information about visitors of our own websites, our customers and their team members (account holders, operators), people who contact us, and prospects.
1.2. We are a service provider/processor for personal information that our customers process through the Service about their website visitors and contacts (“End Users”) — for example chat messages, contact details that a visitor leaves in the widget, and visitor activity collected by the widget on the customer’s site. Our customer decides why and how that data is processed; please read the privacy notice of the website you visited and send your requests to that company. If you contact us, we will forward your request to the relevant customer where we can identify it. See Section 7.
1.3. This policy does not cover third-party websites, messengers or services linked from or connected to the Service.
2. Sources of personal information
- From you — when you register, set up a project, pay, contact support, fill in forms or chat with us.
- Automatically — from your browser or device when you use our websites, dashboard, apps or the widget (cookies, local storage, logs, and, with your consent, analytics tags).
- From our customers — when they invite team members, import contacts, or connect messaging channels and other integrations.
- From third parties — payment providers (payment status, country, partial card details), sign-in and messaging platforms you connect, and fraud-prevention and security services.
3. Categories of personal information
| Category (CCPA) | Examples | Disclosed to |
|---|---|---|
| Identifiers | Name, email, phone, account and project IDs, IP address, visitor ID of the chat widget, messenger user IDs | Hosting, email, support, payment providers; customers (for their End Users) |
| Customer records | Billing name and address, company details, payment status | Payment providers, accountants and auditors |
| Commercial information | Plans, purchases, invoices, refund requests | Payment providers, professional advisers |
| Internet or network activity | Pages viewed, referrer, UTM and ad click IDs, device and browser data, time on page, scroll depth, interactions with the widget, logs | Hosting and analytics providers (analytics only with consent) |
| Approximate geolocation | Country, region and city derived from IP address and time zone | Hosting and geolocation providers |
| Audio, electronic and similar information | Chat messages, files, and call or voice messages if the customer enables these channels | Hosting, messaging and AI providers selected by the customer |
| Professional information | Company, job title, team role | Hosting and support providers |
| Inferences | Conversation topics, sentiment, lead scores or priorities that the customer’s AI assistant assigns to a conversation | The customer who controls the conversation |
| Sensitive personal information | Account login credentials (password stored only as a hash). We do not use sensitive personal information to infer characteristics about you. | Not disclosed |
We do not knowingly collect information from children under 13 — see Section 12.
4. How we use personal information
- to provide, operate and secure the Service, including chat routing, AI Features, notifications and integrations;
- to create and manage accounts, process payments, prevent fraud and enforce our Terms;
- to provide support and send service, billing and security messages;
- to measure and improve our websites and the Service, debug, and develop new features (using aggregated or de-identified data where possible);
- with your consent where required, to run analytics on our own website and measure our advertising;
- to send marketing emails about Smartbtn and other Baxet services, which you can opt out of at any time;
- to comply with law, respond to lawful requests, and establish or defend legal claims.
We do not use Customer Data, including End Users’ conversations, to train general-purpose AI models offered to others, and we do not sell End Users’ data.
5. Legal bases (EEA, UK and Switzerland)
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Providing the Service, accounts, billing, support | Performance of a contract (Art. 6(1)(b)) |
| Security, fraud prevention, service improvement, visit statistics of the chat widget on our website (to help visitors in the chat), B2B direct marketing to business contacts | Legitimate interests (Art. 6(1)(f)), balanced against your rights |
| Analytics and advertising cookies on our website, marketing emails where consent is required | Consent (Art. 6(1)(a)), which you can withdraw at any time in Cookie settings or via the unsubscribe link |
| Tax, accounting and other legal duties | Legal obligation (Art. 6(1)(c)) |
6. How we disclose personal information
We disclose personal information only as described here:
- Service providers acting on our behalf under contract: cloud hosting and data centers, content delivery, email and SMS delivery, customer support tools, error monitoring, and analytics (Google Analytics and Yandex Metrica, only with your consent on our website).
- Payment providers such as Stripe, PayPal, Payssion and Cryptomus, which process payments as independent controllers under their own privacy notices.
- AI model providers (for example OpenAI, Anthropic, Google, DeepSeek, Yandex or Sber) that process prompts and conversation context to generate replies when a customer enables AI Features. When a customer uses its own API key, the provider acts under the customer’s agreement with it.
- Messaging and integration platforms a customer connects (for example Telegram, WhatsApp, VK, MAX, Avito, email), to deliver messages to and from those channels.
- Our customers, for the End User data they control.
- Affiliates within the Baxet family, for hosting, support and administration, under this policy.
- Legal and safety — to comply with law or legal process, protect rights, safety and property, and investigate fraud or abuse.
- Business transfers — in a merger, acquisition, financing or sale of assets, subject to this policy.
Sale and sharing. We do not sell personal information for money and have not done so in the past 12 months. If you accept analytics or marketing cookies on our website, identifiers and website activity are made available to Google and Yandex, which may be a “sale” or “sharing” under some US state laws. You can opt out at any time (Section 10). We have no actual knowledge of selling or sharing personal information of consumers under 16.
7. Data we process for our customers
When a website uses the Smartbtn widget, the widget may collect a pseudonymous visitor ID (cookie SmartBtnClient), messages and files you send, the page address and title, referrer, language, screen size, time zone, approximate location derived from the IP address and, if the website owner enables visitor activity and you consent where consent is required, the pages you view, time on page and scroll depth. This data is processed on behalf of the website owner, who is responsible for informing you and for obtaining any consent. To exercise your rights, contact the website owner; we will assist our customers in responding.
8. International data transfers
We are based in the United States. Our servers and the service providers we use are located in several countries, including the Russian Federation (where our main application servers and databases are hosted), the European Union and the United States, and personal data may be processed in any of them. Analytics data collected with your consent is processed by Google (including in the United States) and Yandex (including in the Russian Federation). When we transfer personal data from the EEA, the UK or Switzerland to a country without an adequacy decision, we do so where the transfer is necessary to provide the Service you requested under our contract with you, or on another ground permitted by applicable law. Questions about transfers can be sent to info@smartbtn.me.
9. Retention
- Account and project data — for the life of the Account. When you ask us to close the Account and delete your data (email info@smartbtn.me), we complete the request within the time limits required by applicable law (for example, 45 days under the CCPA), except as below.
- End User data — as configured by the customer and per our agreement with the customer; deleted on the customer’s instruction.
- Billing and tax records — as long as tax and accounting laws require (generally up to 7 years).
- Security logs — typically up to 90 days, longer if needed to investigate an incident.
- Analytics cookies — as listed in the Cookie Policy; your consent choice is kept for 12 months.
Backups are overwritten on a rolling basis. We may keep data longer where required by law or to resolve disputes.
10. Your US state privacy rights
Depending on your state of residence (including California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon and other states with comprehensive privacy laws), you may have the right to:
- Know/access the categories and specific pieces of personal information we collected, the sources, purposes and the categories of recipients;
- Delete personal information we collected from you, subject to legal exceptions;
- Correct inaccurate personal information;
- Data portability — receive your data in a portable format;
- Opt out of sale or sharing of personal information and of targeted advertising — use Do Not Sell or Share My Personal Information or enable the Global Privacy Control in your browser; we treat a GPC signal as a valid opt-out for that browser;
- Limit the use of sensitive personal information — we use it only for purposes permitted without that right;
- Non-discrimination — we will not deny services, charge different prices or provide a different quality of service because you exercised your rights;
- Appeal — if we decline your request, you may appeal by replying to our decision; if the appeal is denied you may contact your state attorney general.
How to submit a request. Email info@smartbtn.me with the subject “Privacy request” from the email address associated with your account, or write to us at 30 N Gould St Ste R, Sheridan, WY 82801, USA. We will confirm receipt within 10 business days and respond within 45 days (extendable by 45 days where permitted, with notice). We verify requests by matching information you provide with information we hold; we may ask for additional details. An authorized agent may submit a request with your signed permission; we may ask you to verify your identity directly.
California “Shine the Light”. We do not disclose personal information to third parties for their own direct marketing purposes.
11. Your rights in the EEA, UK and Switzerland
You have the right to access, rectify and erase your personal data, to restrict or object to processing (including direct marketing at any time), to data portability, and to withdraw consent at any time without affecting the lawfulness of prior processing. You also have the right to lodge a complaint with your local data protection supervisory authority. Contact us at info@smartbtn.me; we respond within one month (extendable by two months for complex requests). We do not carry out decision-making based solely on automated processing that produces legal or similarly significant effects on you.
12. Children’s privacy
The Service is intended for businesses and is not directed to children under 13 (or under 16 in the EEA, where applicable). We do not knowingly collect personal information from children under 13 in compliance with the Children’s Online Privacy Protection Act (COPPA). If you believe a child has provided us personal information, contact us and we will delete it. Customers must not use the Service to collect personal information from children under 13 without verifiable parental consent.
13. Marketing communications
If we send you marketing emails, we do so in accordance with the CAN-SPAM Act and, where required, only with your consent: each such email identifies us, includes our postal address and contains a working unsubscribe link, and we honor opt-outs within 10 business days. You will still receive transactional and service messages about your account, billing and security.
14. Security
We use administrative, technical and physical safeguards appropriate to the risk, including encryption in transit (TLS), access controls and least-privilege access, password hashing, monitoring and backups. No system is perfectly secure; if a breach affects your personal information we will notify you and authorities as required by law.
15. Cookies and similar technologies
We use strictly necessary cookies to run our websites and the Service and, only with your consent, analytics and marketing technologies. The Smartbtn chat widget on our website reports visits to our team as part of the chat. Non-essential technologies stay off until you choose “Accept” or enable them in Cookie settings. Details are in our Cookie Policy.
16. Changes to this policy
We may update this Privacy Policy. The effective date above shows the latest version. If we make material changes, we will notify you by email or through the Service before they take effect.
17. Contact
SmartBTN LLC
Attn: Privacy
30 N Gould St Ste R, Sheridan, WY 82801, USA
Email: info@smartbtn.me (subject “Privacy request”)