GDPR Policy
Last updated: October 19, 2026
SmarterHealthAI, an Esprit Communities, Inc. subsidiary company
The https://smarterhealthai.com website (“site”), is owned and operated by Esprit Communities, Inc., a Texas corporation, through its subsidiary company SmarterHealthAI (“SmarterHealthAI”, “we”, and “us”). Its address is 8350 North Central Expressway, Tower 1, Suite 1900, Dallas, Texas 75206, USA.
SmarterHealthAI is dedicated to growing its presence in the EU and doing its best to provide superior customer service to its EU citizen members. As such, SmarterHealthAI takes the security and privacy of its EU citizen members very seriously. SmarterHealthAI is intent on complying with the European Union’s General Data Protection Regulation (GDPR) and has created the following policy and disclosures in accordance with GDPR.
1. GDPR Data Processing Policy
2. Entity/Data Controller
3. Lead Data Protection Authority
4. Data Processing Officer
5. Categories of Data Subjects and Data Collected
6. Basis for Processing
7. Cross-Border Transfer
8. Potential Recipients
9. Use of Data
10. Data Retention Period
11. Security Policies for Data
12. Withdrawal of Consent/Erasure
13. Right to Correct, Access and Portability of Data and Associated Procedure
14. Publish Date
1. GDPR Data Processing Policy
Esprit Communities, Inc. (“SmarterHealthAI”) recognizes that the European Economic Area (the “EEA”) has established strict protections regarding the handling of EEA personally identifiable information, in particular the EU General Data Protection Regulation (“GDPR”). In recognition of the importance of GDPR, SmarterHealthAI has adopted the following GDPR Data Processing Policy (the “Policy”).
This Policy is intended to ensure that you understand the following: (a) the entity that is collecting your personal data; (b) the purposes for which your personal data is collected; (c) how and why your personal data will be used; (d) the period during which your data will be retained; and (e) how you can contact SmarterHealthAI regarding your data.
This Policy supplements the SmarterHealthAI Privacy Policy and unless specifically defined in this Policy, defined terms in this Policy have the same meaning as they do in the Privacy Policy.
2. Entity/Data Controller
Any data collected through the https://smarterhealthai.com (the “SmarterHealthAI Website”) or any other website associated with, or related to, SmarterHealthAI Websites will be collected by Esprit Communities, Inc., a Texas corporation, with its principal place of business located at 8350 N. Central Expressway, Tower 1, Suite 1900, Dallas, TX 75206.
3. Lead Data Protection Authority
SmarterHealthAI Websites’ lead data protection authority is:
Attn: Data Protection Officer
Esprit Communities, Inc., a Texas corporation
8350 N. Central Expressway
Tower 1, Suite 1900
Dallas, Texas 75206 USA
You may lodge any complaints about SmarterHealthAI’s data processing with this Lead Data Protection Authority.
4. Data Processing Officer
You can contact SmarterHealthAI Data Processing Officer by emailing [email protected]
5. Categories of Data Subjects and Data Collected
SmarterHealthAI only collects data from users who either join or engage with SmarterHealthAI’s Website. SmarterHealthAI is committed to only collecting data that is necessary for SmarterHealthAI to provide the content and services on the SmarterHealthAI Website.
SmarterHealthAI’s Privacy Policy describes the categories of personally identifiable information that SmarterHealthAI may receive including: (a) name, (b) postal address, (c) e-mail address, (d) telephone number, or any other information that the SmarterHealthAI Website collects that is defined as personal or personally identifiable information under an applicable law or any other identifier by which you may be contacted online or offline.
Depending on which services you choose to use, SmarterHealthAI may require additional information, such as a shop name, billing information (including billing address, phone number, credit card information), a mobile telephone number, a physical mailing address, and/or payment information. As a Merchant, if you choose to enable SmarterHealthAI Payment processing, SmarterHealthAI may require information such as your social security number, or the equivalent, applicable tax ID, date of birth, bank account information and/or credit card information to verify your identity and provide this service to you.
You may also provide information to SmarterHealthAI such as the following: (a) information that you provide by filling in forms; (b) information provided at the time of registering to use SmarterHealthAI Websites; (c) information when you enter a promotion sponsored by SmarterHealthAI; (d) information when you report a problem with SmarterHealthAI Websites; (e) records and copies of your correspondence (including email addresses), if you contact SmarterHealthAI; (f) your responses to surveys that we might ask you to complete for research purposes; (g) details of transactions you carry out through SmarterHealthAI Websites and of the fulfillment of your orders; (h) financial information before placing an order through SmarterHealthAI Websites; and (i) your search queries on SmarterHealthAI Websites.
See SmarterHealthAI’s Terms and Conditions which prohibit the use of SmarterHealthAI’s Website by users under the age of 14. SmarterHealthAI does not intentionally solicit, collect or process information from anyone under the age of 14.
6. Basis for Processing
SmarterHealthAI processes data based on (a) consent of the user; and (b) the necessity of the data for providing the services that users are contracting for when they become members of the SmarterHealthAI Website. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR DATA IN ORDER TO ACCESS AND USE THE SMARTERHEALTHAI WEBSITE, PLEASE DO NOT USE, OR ENGAGE WITH, THE SMARTERHEALTHAI WEBSITE.
7. Cross-Border Transfer
Data centers hosting SmarterHealthAI’s data, including user data, are located globally and within the United States. Accordingly, as an EU citizen, in order to access the services and content provided by SmarterHealthAI, your data may be transferred outside of the EU. By using the SmarterHealthAI Website, you consent to the cross-border transfer of your data in order to receive access to the SmarterHealthAI Website.
8. Potential Recipients
SmarterHealthAI does not provide your data to third party recipients who are not necessary to the services and content provided on SmarterHealthAI’s Website without your permission. Third parties who may receive your data so that SmarterHealthAI can provide the services and content on SmarterHealthAI’s Website include SmarterHealthAI’s cloud infrastructure provider and SmarterHealthAI’s third party marketing cloud provider.
9. Use of Data
Please refer to SmarterHealthAI Privacy Policy for more information on how SmarterHealthAI uses your personal data.
10. Data Retention Period
SmarterHealthAI will retain your information for as long as your account is active or as needed to provide you services. If you no longer want SmarterHealthAI to use your information to provide you services, you may follow the “Withdrawal of Consent/Erasure” provision below. After closing your account, SmarterHealthAI will solely use your information as necessary to comply with any applicable legal obligations.
11. Security Policies for Data
SmarterHealthAI’s data security policy is detailed in the Privacy Policy. In summary, SmarterHealthAI has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to SmarterHealthAI is stored on secure servers behind firewalls. Any payment transactions and other sensitive information will be encrypted using secure socket layer (SSL) technology. SmarterHealthAI follows generally accepted industry standards to protect the personal information submitted, both during transmission and once SmarterHealthAI receives it.
The safety and security of your information also depends on you. Where SmarterHealthAI has given you (or where you have chosen) a password for access to certain parts of SmarterHealthAI’s Website, you are responsible for keeping this password confidential. SmarterHealthAI asks you not to share your password with anyone.
12. Withdrawal of Consent/Erasure
If, at any point, you no longer wish to have your personal data processed by SmarterHealthAI, wish to be forgotten, or wish to have your data erased, simply send an email to SmarterHealthAI’s Data Processing Officer at [email protected] with the phrase “consent withdrawn” or “erase” in the subject line. Your request should include your name, Merchant company name, email address and physical address. SmarterHealthAI will move expeditiously to stop the processing of your personal data and to remove your personal data from its systems. Please understand that, without access to your personal data, SmarterHealthAI may not be able to provide certain services. For example, SmarterHealthAI will not be able to send you communications, sales, offers, newsletters. Additionally, it may be impossible for SmarterHealthAI to fulfill purchases or sales without access to personal information.
13. Right to Correct, Access or Portability of Data and Associated Procedure
You have the right to have any inaccurate data corrected by a data controller. You also have the right to request access to your data or request that SmarterHealthAI make your data portable to another data controller. In order to make any such request, you should send the request to SmarterHealthAI’s Data Processing Officer [email protected]. Your request should include your name, Merchant company name, email address and physical address. SmarterHealthAI will endeavor to correct the data or to provide you your data in a simple and easily readable format as quickly as possible, but in no more than thirty (30) days.
14. Publish Date
This Policy was published on October 19, 2026.
Applicable Law and Disputes
The GDPR, and the data protection laws of the EEA country where you live, apply to our processing of your personal data as described in this Policy, and nothing in this Policy, the SmarterHealthAI Terms and Conditions of Use or any other SmarterHealthAI policy limits the rights those laws give you, including your right to lodge a complaint with your local data protection supervisory authority and to bring proceedings in the courts where you live. Subject to those mandatory rights, this Policy and its conditions, and all other disputes, claims and legal matters arising out of or relating to them, including any arbitration, are governed by the laws of the State of Texas, without regard to its conflict-of-laws rules.