SmartGuide® turns a smartphone into a personal, self-guided tour companion. Delivering that experience means we handle some information about you — most importantly, your device's location — so we can point you to the right stop at the right time. This policy explains what we collect, why, and what choices you have.
Who We Are
This policy applies to this website, the SmartGuide® mobile application, and the SmartGuide® content management system ("CMS") used to build and publish tour content.
What We Collect
This website. When you browse this site, we collect standard technical information — your device and browser type, approximate location from your IP address, pages visited, and how you interact with the page — through analytics tools such as Google Analytics. If you submit the demo request form, we collect what you provide: your name, title, hotel or portfolio, email, phone number, and any message.
The SmartGuide® app. You can listen to a tour without creating an account. If you do create one, we collect basic profile details such as your name and email. To guide you along a route, the app tracks your device's location and your path through a tour; we also log general usage such as which stops you open and how you interact with the app. We only collect photos, videos, or comments you choose to share within the app.
The CMS. Partners who build tour content create an account with a name and email address, and may submit additional details as part of publishing a guide. Content submitted through the CMS — including your name as the contributor — is typically made public through the app as part of that guide.
How We Use It
- To operate the app's core function — guiding you to points of interest based on your location.
- To respond to demo requests and communicate with hotel partners about the program.
- To maintain, secure, and improve our website, app, and CMS.
- To understand usage patterns and analyze how our services are used.
- To meet legal obligations, or to establish, exercise, or defend legal claims.
- To send service updates, and — only where you've agreed — marketing communications, which you can opt out of at any time.
How We Share It
We do not sell personal information. We share it only in limited circumstances: with employees, contractors, and service providers (such as analytics vendors) who help us operate our services and who are bound by confidentiality obligations; when required by law, court order, or to protect our legal rights; in aggregated, de-identified form (for example, reporting how many tours were completed in a given city); in connection with a merger or sale of the business, with notice to affected users; or with your consent.
Where personal data is transferred outside a jurisdiction with an equivalent level of protection, we use appropriate safeguards, such as the European Commission's standard contractual clauses.
Your Choices & Data Retention
You can stop the app from collecting information about you at any time by uninstalling it, or by deleting your CMS account. We keep personal information for as long as you use our services and for a reasonable period afterward, unless law requires us to retain it longer. To request deletion of your data, contact us using the details below.
Your Rights
Depending on where you live, you may have the right to access the personal data we hold about you, correct inaccurate data, request erasure, restrict or object to certain processing, request that your data be provided in a portable format, and lodge a complaint with your local data protection authority. Where processing is based on your consent, you can withdraw it at any time.
Children
Our services are not directed at children under 16. If you are under 16, please only use SmartGuide® with the consent of a parent or legal guardian. If a parent or guardian believes their child has provided us with personal information without that consent, please contact us and we will remove it.
Changes to This Policy
We may update this policy from time to time. Material changes will be reflected on this page with an updated effective date below.
Contact Us
For questions about the hotel partnership program on this website: bburns@winterisland.com.
Effective as of July 2026.