1. Introduction
This Privacy Policy explains how Smart Player Systems OÜ ("Profichat", "we", "us", or "our") collects, uses, and protects personal data when you use the services provided through Profichat.net (the "Platform"). We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Estonian law. By using the Platform you confirm that you have read and understood this Policy.
2. Data Controller and Contact
Data controller: Smart Player Systems OÜ
Registered address: Narva mnt 5, Kesklinna linnaosa, Tallinn, Harju maakond, 10117, Estonia
Registry code: 17050841
Contact for privacy matters: [email protected]
For personal data that our business customers process about their own end-customers through the Platform, the business customer is the data controller and Profichat acts as a data processor on their behalf, under a data processing agreement.
3. Personal Data We Collect
- Account and contact data: name, business name, e-mail address, phone number, and login credentials you provide when registering.
- Billing data: subscription and transaction records, plan details, and billing contact information. Card payment details are handled by our payment processors and are not stored by us in full.
- Communications data: messages, support requests, and correspondence you send to us.
- Customer content: messages and contact details you route through the Platform to communicate with your own customers (processed on your behalf).
- Technical and usage data: IP address, browser type and language, device information, access times, and pages viewed, collected automatically when you use the Platform.
- Cookie data: information collected through cookies and similar technologies (see Section 9).
4. Purposes and Legal Bases for Processing
We process personal data only where we have a lawful basis under the GDPR:
- To provide the Services and perform our contract with you (Art. 6(1)(b)) — creating and managing your account, delivering the features you subscribe to, and providing support.
- To process payments and prevent fraud (Art. 6(1)(b) and (f)) — billing, chargeback handling, and detecting misuse.
- To comply with legal obligations (Art. 6(1)(c)) — accounting, tax, and record-keeping requirements.
- For our legitimate interests (Art. 6(1)(f)) — securing and improving the Platform, analytics, and communicating with you about your account; we balance these interests against your rights.
- With your consent (Art. 6(1)(a)) — optional marketing communications and non-essential cookies. You may withdraw consent at any time.
5. Marketing Communications
We may send you service-related messages (such as security, billing, and policy notices) as part of providing the Services. We will send promotional messages only where permitted, and you can opt out at any time using the unsubscribe link in those messages or by contacting us. Opting out of marketing does not stop essential service notices.
6. Who We Share Data With
We do not sell or rent your personal data. We share it only with the following categories of recipients, under appropriate contracts:
- Payment processors — Mollie and Stripe, to process transactions securely.
- Infrastructure and service providers — hosting, e-mail delivery, and analytics providers who process data on our behalf as processors.
- Messaging-channel providers — where you use integrated channels (for example WhatsApp, Telegram, Facebook, Instagram), data is exchanged with those providers to deliver your messages.
- Authorities or advisers — where required by law, to comply with a legal obligation, or to establish, exercise, or defend legal claims.
Our processors are bound by contract to process personal data only on our instructions and to keep it secure.
7. International Data Transfers
Where personal data is transferred outside the European Economic Area (for example to a third-party service provider), we ensure an appropriate safeguard is in place, such as an adequacy decision of the European Commission or the EU Standard Contractual Clauses.
8. Data Retention
We keep personal data only as long as necessary for the purposes described in this Policy: for the life of your account and thereafter as required for legal, accounting, and fraud-prevention purposes (for example, invoicing records are kept for the period required by applicable law). When data is no longer needed, we delete or anonymise it. Some information may remain in secure backups for a limited period before being overwritten.
9. Cookies and Tracking Technologies
We use cookies and similar technologies to operate the Platform, remember your preferences, keep you signed in, and measure usage. Non-essential cookies (such as analytics and advertising cookies) are used only with your consent, which you can manage or withdraw through our cookie settings or your browser. Blocking some cookies may affect how the Platform functions. We use analytics tools such as Google Analytics to understand and improve performance.
10. Your Rights
Subject to applicable law, you have the right to:
- access the personal data we hold about you;
- request correction of inaccurate or incomplete data;
- request erasure of your data ("right to be forgotten");
- request restriction of, or object to, certain processing;
- receive your data in a portable format (data portability);
- withdraw consent at any time where processing is based on consent;
- lodge a complaint with a supervisory authority.
To exercise any of these rights, contact us at [email protected]. You also have the right to complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee) or the supervisory authority in your country of residence.
11. How We Protect Your Data
We use appropriate administrative, physical, and technical measures to protect personal data against unauthorised access, loss, or misuse. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we work to protect your data and will notify you and the relevant authority of a personal data breach where required by law.
12. Children's Privacy
The Platform is intended for business users and is not directed at children. We do not knowingly collect personal data from anyone under 18. If we learn that we have collected such data, we will delete it. If you believe a minor has provided us data, contact us at [email protected].
13. Third-Party Websites
The Platform may contain links to third-party websites. We are not responsible for the privacy practices of those sites, and this Policy does not apply to them. We encourage you to review their privacy policies.
14. Business Transfers
If we are involved in a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction. We will notify you of any such change and of any choices you may have.
15. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version takes effect when published on this page, and the "last updated" date will be revised. We encourage you to review it periodically. Continued use of the Platform after changes take effect constitutes acceptance of the updated Policy.
16. Contact Us
If you have any questions about this Privacy Policy or how we handle your personal data, contact us at [email protected].