Privacy Policy

Application and Scope

Stated below is the Privacy Policy (the "Privacy Policy") of WeSmartly ("Website, "Site", "we", "our" or "us").

The purpose of this Privacy Policy is to identify the personal information we may collect, describe how you can review and make changes to that personal information, describe how you can learn about changes to the Privacy Policy, and provide you with a mechanism to opt-out of certain marketing activities.

This privacy policy ("Privacy Policy" or "Policy") describes how WeSmartly treats your personal information obtained through the website and any subdomains [subsidiary websites] thereof, including those linked in the footer of the website (collectively "Website" and any mobile application ("App") owned and operated by WeSmartly (collectively referred to as "Platform") in this Privacy Policy. The Policy describes the kinds of personal information WeSmartly collects about you, why we collect it, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes the decisions you can make about your personal information. You may require us to change, amend or delete the personal information that you have provided to us at any time.

The Platform may contain links to third parties' websites or apps. We are not responsible for the privacy practices or the content of those websites. The Platform may also contain links to terms and conditions and privacy policies of third party providers who provide tools or services on a website. Therefore, please read carefully any privacy policies on those links or websites before either agreeing to their terms or using those tools, services or websites.


The terms "you", "User", "Service Seeker", “Student”, “Tutor” and "Service Provider" refer to individuals who use this Platform for the purposes of the Services offered.

In this Privacy Policy, "Personal Information" (also referred to as "Personal Data") means any information about an identifiable individual, such as your name, e-mail address, mailing addresses, gender, date of birth, any data about you that you elect to provide electronically through the Platform and any other information that identifies who you are. Registration Data (as defined in the Terms of Use and Personal Information will be used by WeSmartly solely in accordance with these 

Terms of Use

Unless we explain otherwise in this Policy, the words and phrases used in this Policy have the same meaning as in the Terms of Use


WeSmartly is responsible for Personal Information under its control, including the transfer of Personal Information to a third party service provider for processing on WeSmartly's behalf.

What Information Do We Gather?

When you sign up for a User Account through the Platform, you voluntarily give us certain personal information including your name, e-mail address, address, postal code/ZIP code, age and phone number. Use of the App may involve access to your location through your mobile device. You will be asked for permission before the App accesses and uses your location information. In addition, when you visit our Platform or contact us, we collect certain information about your activity on our Platform, as described below under the heading "Our Use of Cookies and Log Files".

Information We Collect From You

We automatically collect information about your internet connection, including but not limited to:

The name of the Internet domain you used to access the Internet

The IP address of the web site from which you linked directly to our Site

Your geo location to provide location-based services

The content you submit

The date and time you accessed our Site

The pages you visited

This information ("Non-Personal Information") does not identify you personally. We use this Non-Personal Information to monitor the effectiveness of the Site and Products, to identify areas of interest and to consider potential improvements to the Site, apps and products.

By using the Messaging Platform available through the Platform, you agree that a copy of your messages and any voice calls made through the Messaging Platform will be recorded and stored for the purposes of safety and protecting our Users from misuse of WeSmartly's Services. The recorded messages will only be stored for a period of time that is necessary to fulfil its purpose. The collection of information from the Messaging Platform is done so in accordance with the terms in this Policy.

How We Use Your Personal Information

We use the Personal Information we collect about you in order to provide you with the Services offered by WeSmartly and you agree that we may use your Personal Information for the following purposes:

For the Services offered by WeSmartly through the Platform

To support any requests or inquiries made by you

To contact you from time to time with user or Service updates

To assist you and the User(s) you have done (or have agreed to do) business with through WeSmartly's Services.

To customize, measure, report on and improve our services, content and advertising

To learn more about you and your product preferences by looking at the IP address of your computer and your activity on the Website (among other things)

To promote services related to the Website or those of the WeSmartly and/or our affiliates

To prevent, investigate or prosecute activity we think may be potentially illegal, unlawful or harmful

To enforce our Privacy Policy and/or our Terms or any other purpose referenced herein or therein.

How and Where is Personal Information Processed?

Personal Information will be collected, processed, stored and used by WeSmartly and may be passed to and processed by other companies under the instruction of WeSmartly. While WeSmartly undertakes measures to protect your Personal Information, when it is stored and/or processed in other jurisdictions, the laws of other countries may not provide the degree of protection for Personal Information that is available in Spain and/or Europe. If your Personal Information is transferred outside of Spain and/or Europe, it may be available to the foreign government of the country in which the information or entity controlling it is situated under a lawful order made in that country and used for purposes other than those described herein. 

WeSmartly may use Google Analytics to gather statistics on web traffic, Platform usage and information on User behavior. Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google utilizes the Data collected to track and examine Application use, to prepare reports on an Application's activities and share them with other Google services. WeSmartly may also use AdRoll, an advertising retargeting company, that enables WeSmartly to present you with retargeting advertising on other websites based on your previous interaction with the Website. In addition, WeSmartly and its Website allows for User interaction with social media networks and other external platforms directly from the Website. The interaction and information obtained is subject to the terms and conditions and privacy policies of Google, Adroll, and the social media and third-party platforms, respectively.

Sharing Your Personal Information

In accordance with this Policy, we may share your Personal Information including Financial Information, with our service providers, and third parties involved in providing Payroll Services to you. We may also share information with our financial, insurance, legal, accounting or other advisors that provide professional services to us.

We will not disclose, share, sell or rent your Personal Information in personally identifiable form with any third party, except if, and to the extent necessary, in our good faith judgment, doing so is required to: complete the Services offered by WeSmartly, comply with laws or regulations, respond to a valid subpoena, order, or government request; establish or exercise the Company’s legal rights or defend against legal claims; investigate, detect, suppress, prevent or take action regarding illegal or prohibited activities, suspected fraud, situations involving potential threats to the reputation or physical safety of any person; or as otherwise required by law.

We may remove personal identifiers from your information and maintain and use it in anonymous form that may later be combined with other information to generate aggregated information. Such anonymous and aggregated information may be sold, traded, rented, or shared.


We will retain your personal information only for a time and to the extent necessary for the purposes for which it was collected as described in this Policy and for reasonable backup, archival, audit, or other similar purposes.

Our Use of Cookies and Log Files

A cookie is a small information file that is sent to your computer, mobile or other device when you visit a website and it will recognise your device on future visits. These types of files do a number of different jobs such as remembering your preferences and chosen items, assisting you to improve your site experience as well as trying to ensure that the adverts or offers you see online are more relevant to you. These “cookies” can be divided into 4 types each of which is outlined below. 

Category 1: Strictly Necessary Cookies These cookies are essential in order to enable the site to provide services you have asked for such as remembering your shopping bag items. 

Category 2: Performance Cookies. This type collect anonymous information on how people use the site and the data is merged with other users to enable us to improve how the site operates. For example we utilise Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established. 

Category 3: Functionality Cookies. These remember choices you make such as language, deal interests or currency. These can then be used to provide you with an experience more appropriate with your selections and make the visits more tailored and pleasant. The information is also merged with other users on an anonymous basis to enable us to improve how the site operates. 

Category 4: Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising relevant to you and your interests. They remember the websites you have visited and that information is shared with other parties such as advertisers. 

You can change the settings on your browser to prevent cookies being stored on your computer or mobile device without your explicit consent. Your browser “help” section will normally provide details on how to manage the cookie settings. 

Protecting your security 

We may use personal information provided by you in order to conduct appropriate anti-fraud checks. Personal information that you provide may be disclosed to a credit reference or fraud prevention agency, which may keep a record of that information. This is done only to confirm your identity.

Accessing and Updating Your Personal Information

At any time you can contact us to: stop receiving e-mails from us; review the personal information held by the Company in connection with your account; withdraw your consent for our use and disclosure of your information; request a list of third parties to which WeSmartly may have provided your personal information; close your account; and amend your personal information, where possible, by logging into your User Account.

If you contact us to do any of the things listed above, we may require you to provide sufficient information to allow us to identify you and tell you about the existence, use and disclosure of your Personal Information and this Personal Information will only be used for this purpose. If you contact us about your Personal Information, we will respond to your request within a reasonable time and at no cost to you.

Links and Third-Party Websites

We provide links on our Platform to other, third party sites we think you will enjoy. These sites operate independently of us and have established their own privacy and security policies. Any personal information you provide on linked pages or other sites is provided directly to that third party and subject to that third party's privacy policy. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Data Integrity and Security

We aim to provide you with a safe experience. We have in place certain physical, electronic, technological, and organizational safeguards to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying use or modification. Please note, however, that while we try to create a secure and reliable Platform for users, the confidentiality of any communication or material transmitted to or from the Platform or via e-mail cannot be guaranteed.

We limit access to your personal information within WeSmartly to individuals on a need-to-know basis.

Children's Online Privacy Protection

The Platform is not intended for use by children under the age of 18 without the consent of their parent or legal guardian. WeSmartly does not knowingly collect or use any personal information from any children under the age of 13. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make commercially reasonably efforts to delete such personal information from our database.

Changes to the Privacy Policy

WeSmartly reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page, and by ensuring analogous protection of the Personal Information in all cases. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top of the page.

How to Access & Control Your Personal Data Reviewing, Correcting and Removing Your Personal Information

You have the following data protection rights:

You can request access, correction, updates or deletion of your personal information.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.

If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal information.

Acceptance Treatment of your data 

In the following link you will find our Data Protection Policy and we ask you to give your express consent to the use of your data to offer you services other than those you may have contracted by checking the box below. We inform you that if you decide not to accept, it could generate difficulties when providing services that could be of interest to you, such as promoting your establishment to our partners; or uploading the profile of your establishment on our website so that users can access your brand. In no case does this acceptance imply that we can transfer your data to a third party, which we will never do unless you expressly request it.

To exercise any of these rights, please contact us at or by mail to Digital Flow S.L  t/a WeSmartly. Company registration number B42930743 with registered offices in Avda Paseo Maritimo Rey De España 28, 29640, Málaga, Spain

Attention: Privacy Officer. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

Contacting us 

We are always pleased to hear from our customers (even if it is a complaint!). We are always grateful for any time you spend providing us with the knowledge we need to ensure our customers are completely satisfied - we want you to return to the site and to recommend us to your friends and family. If you have any questions or feedback about this statement, or if you would like us to stop processing your information, please do not hesitate to contact a customer service member of the WeSmartly team, who will be delighted to answer any questions you may have. 

You can either contact our customer care team at

If you continue to use our site without modifying its configuration, we understand that you consent to the use of the cookies created by it. You can revoke your consent at any time by deactivating the cookies on our website as indicated in the previous section. This revocation of consent may prevent the use of some services on our website.