About SMART Remote Management
SMART Remote Management (SRM) is a device management solution offered by SMART Technologies ULC and its subsidiaries (collectively, SMART). SRM enables authorized IT administrators to monitor, manage, and support SMART devices remotely. SRM is powered by technology provided by Radix Technologies Ltd. (Radix), which provides the platform functionality and infrastructure used to operate SRM.
Introduction
This Privacy Policy (Policy) explains how SMART collects, uses, stores, and discloses personal information when you use SRM. SMART is committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) and North American consumer privacy laws such as the California Consumer Privacy Act (CCPA) and similar state laws.
By using SRM, you agree to this Policy and consent to SMART’s collection and use of your personal information as described in this Policy.
SRM is designed for authorized IT administrators within business, government, and education organizations. Although SRM may be deployed in environments that serve students or minors, SRM is not intended for use by students or minors, and access is limited to administrative personnel.
Your organization is responsible for managing administrator access and ensuring that SRM is used only by authorized personnel.
SMART acts as the data controller for SRM. Radix processes personal information on SMART’s behalf as a service provider and data processor.
What data we collect
SMART Remote Management processes the limited information necessary to provide device management services. This includes:
| Device information | Device identifiers such as serial number, MAC address, operating system version, hardware attributes, and device configuration settings. IMEI may be collected for supported mobile devices, where applicable, and is not collected for SMART panels. |
| Application data | Information about installed applications and high‑level, anonymized usage statistics. SRM does not collect application content, credentials, or user‑specific viewing activity. |
| Account information | Administrator details provided by your organization such as name, email address, and assigned role. |
| Telemetry and logs | Device health metrics, audit logs, diagnostic data, and usage analytics to support performance, troubleshooting, and security. |
| Additional log categories | Timestamps, configuration change logs, device status updates, and operational records. |
| Location data | SRM does not collect GPS level or precise device geolocation. SRM may process IP derived regional location (country or region) for security, licensing, and service functionality purposes, but it does not track real time physical location of devices. On SMART Android devices, SRM does not have permission to access precise geolocation services. |
| Other device signals | SRM processes standard device‑management signals such as IP address, connectivity status, operating system state, and device reachability. SRM does not collect sensor data. Limited network or peripheral information may be processed only when initiated by an administrator (e.g., identifying a configured Wi‑Fi network for removal or showing currently connected Bluetooth devices, where supported). SRM does not perform continuous Wi‑Fi or Bluetooth scanning. |
SRM processes personal information relating only to administrator users designated by your organization. SMART does not use SRM data for marketing or for unrelated purposes.
SRM does not make any automatic decisions about people. All decisions involving user accounts or access require action by an authorized administrator.
How we use your data
SMART uses the information collected through SRM for the following purposes:
- To provide, operate, and maintain SRM
- To ensure device security, stability, and performance
- To respond to technical or customer support requests
- To improve overall service functionality and reliability
- To comply with legal, regulatory, and audit obligations
SMART does not sell personal information collected through SRM.
Sharing with service providers
SMART uses service providers to support the operation of SRM. These service providers assist with hosting, infrastructure, device‑management functionality, analytics, diagnostics, and related technical operations. SMART may update or replace these service providers as needed to maintain or improve SRM.
Currently, SRM is supported by Radix, which provides core device‑management platform capabilities. Radix processes information strictly under SMART’s instructions and in accordance with applicable privacy and security requirements. For more information about Radix’s privacy practices, you may refer to the Radix Privacy Policy.
SMART does not maintain a general subprocessor list for SRM, as Radix is currently the primary data processor. SMART may update or replace service providers as necessary in accordance with applicable privacy laws, and will take reasonable steps to ensure continuity of privacy and security protections. When purchasing SRM, SMART may collect customer data as described at: https://www.smarttech.com/legal/privacy-policies/data-collection
Service providers are not permitted to use SRM data for their own independent purposes.
Legal bases for processing
Under GDPR, SMART processes personal data based on:
- Contractual necessity to provide SRM
- Legal obligations
- Legitimate interests such as service improvement, system security, and fraud prevention
Your rights
Depending on the laws in your jurisdiction, you may have the right to:
- Access the personal information we hold about you
- Request correction or deletion of your personal information
- Request data portability
- Opt out of certain data uses permitted under the CCPA and similar laws
- Object to or restrict specific processing activities where applicable
To exercise these rights, contact SMART at privacy@smarttech.com. For enterprise deployments, some requests may need to be coordinated through your organization’s administrator or Data Protection Officer.
Data security and transfers
SMART and its service providers implement industry standard technical and organizational security measures, including encryption in transit and at rest, access controls, secure hosting environments, monitoring, and incident response procedures. While no method of data transmission or storage is completely secure, SMART evaluates and updates its security measures regularly to reduce risks to personal information.
However, SMART is not responsible for issues arising from how your organization chooses to configure or use SRM, including errors made by administrators or unauthorized access resulting from credentials being shared or mismanaged.
Data may be processed in regions where SMART or its service providers operate, including Canada, the United States, Israel, and other jurisdictions permitted under applicable data protection laws.
If personal data is transferred outside your region, SMART uses appropriate legal safeguards such as Standard Contractual Clauses (SCCs) for GDPR compliance or other approved mechanisms.
Retention
SMART retains personal data for only as long as needed to provide SRM, meet contractual or legal obligations, or support legitimate business purposes such as security, auditing, and fraud prevention. When an organization’s SRM subscription ends, SMART removes personal data from active systems within a defined administrative offboarding window, and backup copies are purged according to SMART’s secure backup‑retention and deletion schedules. SMART applies consistent, risk‑based retention periods for different categories of data and deletes or anonymizes personal information when no longer required.
Breach notification
If SMART becomes aware of a personal data breach affecting SRM, SMART will notify affected customers and regulatory authorities as required by applicable law, including obligations under GDPR Articles 33 and 34 where applicable.
Children's privacy
SRM is not intended for children under 16, and SMART does not knowingly collect personal information from minors through SRM.
Changes to this policy
We may update this Policy from time to time to reflect changes to our operations, or to meet new legal and regulatory requirements. Any material amendments will be communicated to you 30 days in advance and become binding once posted on SMART’s website.
Contactez-nous
N'hésitez surtout pas à nous contacter :
SMART Technologies ULC
Attention: Legal Department
Suite 600, 214-11 Ave SW
Calgary, AB T2R 0K1
CANADAA
+1 403 245 0333
legal@smarttech.com
privacy@smarttech.com
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