PRIVACY POLICY

SMART WAY GLOBAL LOGISTICS

Last updated: 2026

1. GENERAL PROVISIONS

This Privacy Policy explains how SMART WAY GLOBAL LOGISTICS, operating under the trademark “SMART WAY GLOBAL LOGISTICS”, processes and protects personal data.

The service provider and data controller is:

Daleth Brok LLC

Registered in Ukraine

Registration code: Z9Z80576

EORI: EE65730151

Email: support@smartway.global

This Privacy Policy is an integral part of the Terms and Conditions of Use and applies to all Users of the Website and Mobile Application.

In case of any discrepancy, the English version of the Policy shall prevail.

2. APPLICABLE LEGISLATION

Personal data is processed in accordance with:

The Law of Ukraine "On Personal Data Protection" , and
General Data Protection Regulation (GDPR) (EU Regulation 2016/679), if applicable.

3. ROLE OF THE DATA CONTROLLER

SMART WAY GLOBAL LOGISTICS acts as the data controller, determining the purposes and methods of processing personal data.

Certain data processing operations may be performed by verified third-party processors on the basis of contracts and in compliance with confidentiality requirements.

4. CATEGORIES OF PERSONAL DATA

We may process the following categories of personal data:

4.1. Account data and identification data

Full name
Phone number
Email address
Tax number / personal code
Identifiers in messengers
Photos

4.2. Professional and transport data

Driver's license data and image
Vehicle registration documents
Photos of vehicles
License numbers
Company data (for legal entities)

4.3. Customs and service data

Customs declarations
Logistics and transport documentation
Uploaded files and documents
Orders and service history
Correspondence with support service

4.4. Technical and usage data

IP address
Device and browser data
Application usage data
Date and time of access
Logs and diagnostic data

4.5. Location data

GPS coordinates collected through the mobile application in cases necessary for the provision of services

4.6. Payment details

Transaction information

⚠️ Payment card data is not stored by SMART WAY GLOBAL LOGISTICS and is processed exclusively by payment providers (e.g. LiqPay ).

5. PURPOSES OF DATA PROCESSING

Personal data is processed for the purpose of:

provision of customs and logistics services online;
execution and administration of Orders;
compliance with customs, transport and regulatory requirements;
communication with Users (technical, administrative, operational);
account management and security;
fraud prevention and risk management;
compliance with the law and dispute resolution;
improving the quality of services and platform functionality;
analytics and system performance monitoring.

6. LEGAL GROUNDS FOR PROCESSING

We process personal data on the basis of:

contract execution;
compliance with legal obligations;
legitimate business interests;
the User's consent (in cases provided for by law).

7. COOKIES AND SIMILAR TECHNOLOGIES

The Website and the Application use cookies and similar technologies to:

support user sessions;
saving settings;
fraud prevention;
performance and usage analysis.

The user can manage cookie settings through browser or device settings.

8. COMMUNICATION

Throughout the entire period of account activity, SMART WAY GLOBAL LOGISTICS may send Users technical, operational and administrative messages.

Such notifications are necessary to provide services and cannot be completely disabled, except when the functionality allows it.

9. DATA TRANSFER AND DISCLOSURE

Personal data may be transferred only in the following cases:

9.1. Service providers

Verified third parties that provide:

hosting services;
CRM systems;
analytics (e.g. Google Analytics, Meta);
payment processing (e.g. LiqPay);
messaging and email services.

Such parties process data solely on our instructions and in compliance with confidentiality.

9.2. To other Users

If necessary for the performance of services and with the explicit consent of the User, certain business data may be transferred to other registered Users.

9.3. Legal Disclosure

In cases where it is necessary for:

compliance with the law;
responses to legitimate requests from authorities;
prevent fraud or illegal activity;
protection of the rights and safety of Users and the Company.

10. INTERNATIONAL DATA TRANSFER

Personal data may be transferred outside Ukraine and the EU if necessary to provide services in compliance with the appropriate guarantees provided for by the GDPR and the legislation of Ukraine.