Effective date: 31 October 2026
Who operates Smalee
Smalee is owned and operated by InMotion ICT Hub Limited, a company registered in Nigeria. Our address is KM 46 East West Road, Port Harcourt, Nigeria. For questions about personal data or to make a privacy request, email support@inmotionhub.com.
Worldwide scope
Smalee is available to users in different countries. This policy explains how we handle personal data about account holders, visitors to the Smalee website, and visitors to pages and links hosted through Smalee. Our company is based in Nigeria, but this policy is not limited to Nigerian users. Applicable privacy rights and obligations may also depend on your location and our activities there.
Information processed
Account information includes your name, email address, authentication information, timezone and preferences. Depending on the features you use, we also process profile content, uploaded files, destination URLs, custom domains, QR code content, billing details, support correspondence and information submitted through forms.
When someone visits a Smalee page or tracked link, the service can process an IP address, visit time, referring page, browser, device, language, campaign parameters and approximate location derived from the IP address. The information recorded depends on the page owner's settings, available features and tracking configuration. Approximate IP-based location is not a device's precise GPS location.
Why information is used
We use account and content information to provide the service you request, authenticate access, publish your content, generate links and QR codes, administer your plan and respond to support requests. We process technical and security information to operate the service, prevent misuse and investigate faults. Visit information supports reporting to the owner of the visited page or link.
Depending on the processing, the relevant legal basis may be performance of our agreement with you, compliance with a legal obligation, a legitimate interest assessed against your rights, or consent where required. Optional marketing or tracking that requires consent must be handled separately from acceptance of the Terms.
Our role and page owners' responsibilities
InMotion ICT Hub Limited is responsible for decisions about account administration, platform security and our own support records. A creator or business using Smalee to collect visitor information is responsible for deciding why they collect and use that information. Where we process that information on their instructions, the applicable processing arrangements must reflect those roles. A page owner's own privacy notice should explain their activities.
Public content and page owners
Publishing a page, link or uploaded asset can make its content accessible to anyone with the URL. Public content may be copied, indexed or shared by other services. Changing or removing content on Smalee does not remove copies held elsewhere.
When a page owner collects information through their page or enables an external embed, pixel or destination, their own notice and the relevant third party's terms may also apply. Contact the page owner about how they use information submitted to them. Contact Smalee about operation of the platform or suspected misuse.
Service providers and disclosures
Information may be processed by providers used for hosting, storage, transactional email, payments and other features you choose to enable. Payment providers process payment details under their own notices. External destinations and embedded services can receive information when you interact with them. We may disclose information when required by law or where necessary to investigate abuse or protect the service and its users.
Your personal data may be processed in Nigeria and in other countries where our service providers operate. Those countries may have different privacy laws. Where applicable law restricts international transfers, we must use a permitted transfer mechanism and appropriate safeguards, such as an applicable adequacy decision or approved contractual protections. Contact support@inmotionhub.com for information about the providers, locations and safeguards relevant to your data.
Security
We use access controls and technical and organisational measures intended to protect personal data. No internet service or transmission is completely secure. Please use a strong, unique password, protect your account credentials, and report suspected unauthorised access to support@inmotionhub.com. Where a personal data breach requires notification, we will follow applicable legal requirements.
Cookies and preferences
Smalee uses browser storage and cookies for functions such as authentication, security and interface preferences. Public pages can also use visit identifiers and integrations configured by their owners. Your browser can remove or block cookies; doing so may affect sign-in and other functions. Where optional cookies require consent, the available controls and actual loading behaviour must reflect your choice.
Retention and deletion
Analytics history is subject to the retention allowance of the applicable plan. Other information is retained for the purpose for which it was collected, including operating an active account, resolving support matters and meeting applicable record-keeping requirements. Contact us to request deletion or information about retention. Any information retained after a deletion request must have an identified reason and retention period.
Page owners are responsible for their own copies and exports. Deleting an account or record can affect published links and QR destinations; review the product's deletion warning before proceeding.
Your rights and complaints
Subject to applicable law, you may request information about processing, access, correction, deletion, portability, restriction or objection, and withdraw consent where processing relies on consent. Email support@inmotionhub.com with your request. We may need proportionate information to verify that a request concerns your data. Do not email passwords or API keys.
You may complain to the privacy regulator competent for your location or for the processing concerned. Our home regulator is the Nigeria Data Protection Commission. Nothing in this policy restricts your right to contact another competent regulator.
Additional rights depending on your location
If the GDPR or UK GDPR applies to our processing of your data, you may exercise the rights those laws provide, including access, correction, erasure, restriction, portability and objection, and withdrawal of consent where relevant. You may complain to the competent supervisory authority. Where another jurisdiction's law applies, you may have additional rights, including appeal of a privacy-request decision or choices concerning certain advertising or data disclosures. We will handle requests within the time limits and exceptions required by applicable law.
Where applicable US state privacy law grants rights to opt out of sale, sharing or targeted advertising, or to limit certain uses of sensitive information, those rights and any required preference-signal handling must be supported for the processing concerned. Contact support@inmotionhub.com to make a request. We will not unlawfully discriminate against you for exercising applicable privacy rights.
Younger users and required consent
Smalee is a general-audience service and does not set a fixed worldwide minimum account age. Applicable law may nevertheless require authorisation from a parent or legal guardian, including appropriate verification, before a younger person can agree to the service or before we collect, use or disclose their personal data. Those requirements apply even when the service itself does not contain age-restricted material.
If we learn that personal data has been collected without legally required parental authorisation, we will take appropriate steps to restrict the affected processing and obtain the required authorisation or delete the data, subject to applicable law. Contact support@inmotionhub.com about a younger person's data or to request review or deletion. We do not knowingly use children's personal data for targeted advertising. Public-page visitors and content about other people remain subject to applicable privacy protections, regardless of whether they have an account.
Decisions made by automated systems
Technical controls may detect suspicious traffic, enforce usage limits or restrict activity. If you believe a restriction affecting you is incorrect, contact support@inmotionhub.com to request review. We do not intend to make decisions producing legal or similarly significant effects about you solely by automated processing.
Updates
Changes to this notice will be published with an updated effective date. Material changes requiring additional notice or consent will be handled as required by applicable law.
Related terms
Please also read our Terms and Conditions.