Last Updated: 18/04/2019
We are Smarter Business Ltd, registered in England & Wales
Our Company number is 7076039
VAT registration number 275941861
Our trademark is Smarter Business Ltd
Your right to privacy is important to us:
We are keen to strike a fair balance between your personal and company privacy and ensuring that you obtain full value from our services that we may be able to market to you.
Our Commitment to Being GDPR Compliant
The General Data Protection Regulation (GDPR) is a regulation within EU law on data protection and privacy for all individuals within the European Union and the European Economic Area (EEA).
Smarter Business processes personal data both as a Data Controller and Data Processor.
We, Smarter Business, shall comply with all applicable Data Protection Laws in the processing of personal data.
We, Smarter Business, adhere to Article 28 GDPR (Processor Terms) in relation to Processor Transfers of Personal Data from the EEA to a Third Country.
Smarter Business satisfies the Adequacy decision (establishing that a legal framework is in place outside of the EEA – that provides adequate protection for individual’s rights & freedoms re. their personal data) and ensures an adequate level of privacy protection, allowing the secure transfer of personal data outside of the EEA.
Smarter Business will transfer and store the personal data we collect about you in countries other than the country in which the data was originally collected, outside of the EEA.
Smarter Business will only transfer your personal data if:
- The country to which the personal data satisfies the European Commission’s adequacy decision requirement.
- Smarter Business have put in place the appropriate safeguards in respect of the transfer, ensuring that the recipient is subject to binding corporate rules.
Smarter Business’ Data Protection Officer & Dispute Resolution
Smarter Business has a designated Data Protection Officer (DPO), who is responsible for matters regarding privacy and data protection. Should you wish to contact the DPO, refer to the following contact information:
Attention: Data Protection Officer
John De Mierre House,
20 Bridge Road,
Haywards Heath, West Sussex, RH16 1UA
We will endeavour to respond to all queries and/or complaints received within a full calendar month thereof.
Note, if you remain dissatisfied with the resolution received from our designated DPO, you have the right to directly contact the relevant Data Protection Authority within your jurisdiction. We do however request that you attempt to resolve any issues with us first although you have a right to contact the Data Protection Authority at any chosen time.
Data Subject’s Eight Individual Rights
Smarter Business recognises the following:
Right to be informed – adhering to transparency requirements, whereby providing individuals with clear and concise information about what we do with your personal data.
Right of access – allowing individuals the right to obtain a copy of their personal data as well as other supplementary information, demonstrating that data is being used lawfully.
Right to rectification – allowing individuals the right to have their inaccurate personal data rectified and/or personal data completed.
Right to erasure/to be forgotten – depending on the circumstances, Smarter Business will erase a customer’s personal data.
Right to restrict processing – dependent on the circumstances, Smarter Business will restrict the processing of a customer’s personal data. An individual is entitled to limit the way that an organisation uses their data.
Right to data portability – allows the individual the right to receive personal data which they have provided to a Controller in a structured, machine readable format. It also gives them the right to request that a Controller transmits this data directly to another Controller.
Right to object – again, dependent on the circumstances, individuals have the right to object to the processing of their personal data.
Rights in relation to automated decision-making and profiling – by adhering to this, care is taken to not base decision-making solely on an automated means, which could have a legal and/or similarly significant effect(s) on the individual.
Types of Personal Data that We Process
If you register as a customer of any of our services, we will ask you for the following personal information.
Personal Data you provide to Smarter Business:
- First and last names
- Business title
- Billing/site address
- Telephone numbers
- Mobile number
- Business email address
- We may also ask you for other information that would be relevant for customer surveys or marketing offers.
If you subscribe to one of our services, your credit or debit card information will be taken by one of our partner companies. We or our partners do not store your credit or debit card details.
We will never sell any of your information.
How do we collect personal information from you?
We do not collect any personal information from you when you browse our website unless you sign up for information or send us an inquiry. That said, the individual has given us clear consent to process their personal data for a specific purpose.
What is our legal basis for processing your personal data?
Smarter Business will only process an individual’s personal data if we have obtained their explicit consent to do so.
Contractually, we will need to process your personal data in order to fulfil your contract requirements.
- Provision of Smarter Business’ services – required to enter into (or) perform a contract with you;
- Marketing and Promotional Offers and/or surveys
- Customer Services/Support
What do we use your personal information for?
If you are a registered customer we may use your personal information to:
- Confirm acceptance of your registration
- Communicate with you about our services
- Check that you are a registered customer if you call us
- Collect payment from you
- Let you know by email about any changes to our services and website
- Market our products and services to you
- Improve our understanding of the type of customers we are attracting to our services and how they use the services.
- To provide you with better service
Smarter Business will keep your personal data for as long as reasonably necessary for the purpose of our business activities –namely for the provision of our services (in line with any contracts we have in place) marketing of our services and providing customer support. As an exception, Smarter Business will retain your data as required for our legitimate business purposes and/or to comply with our legal obligations – this would include record keeping, accounting/auditing purposes, fraud prevention and other business administrative purposes. In the instance whereby we no longer have a legitimate business purpose to retain it, we will anonymize or delete such personal data immediately.
Note, that for accounting/auditing purposes, we will maintain your personal information for a period of five years. This would enable us to resolve and/or defend a claim.
Note, Smarter Business endeavours to refresh consent annually of all existing customers: If at this point we are informed that a customer no longer wishes to be assisted by us, we will remove your data from our system. Alternatively, should a customer contact us, requesting their right to erasure, we will gladly respect your wishes. In this instance, we will immediately remove your information from our system and formally notify the customer thereof.
Do we share your personal information with anyone else?
We sometimes need to share your personal information with the partner companies which we use to provide some of our services. We do not allow these companies to use your personal information for any purposes beyond providing our services to you.
If we receive a Court Order requiring us to reveal your identity, we will do so.
If there is a change in the ownership of Smarter Business Group or any of its assets, we may have to disclose personal information to the new owner.
Types of Third Parties with whom we may share your personal data
We will not pass your personal data to third parties except as necessary to perform our services to you or as required by the processes of the law.
In order to operate our business (provided it is in our legitimate interests for our business’ needs) we share data with third parties from the following categories:
|Third Party Category||Type of Personal Data Shared||Objective of Sharing Personal Data||Retention Period|
|Energy Suppliers (Gas and Electricity)|
First & Last Names,
Business Email Address,
Business landline number,
Billing/Business Site address
For the purpose of your utilities requirements:
Disclosure of personal information for the fulfilment of the contract. This would include credit checks; payments and maintenance of the site(s).
This is required when establishing the suitability of a potential customer prior to them enlisting our services.
|Utility Supplier dependent. Kindly inquire with the relevant supplier regarding their retention periods.|
|Systems Integrated Partners/analytics software services|
First & Last Names,
Business Email Address,
Business landline number,
Billing/Business Site address.
Any other personal information shared with us.
|To enable us to effectively monitor and optimise the delivery of our services.||We will retain your personal data for no longer than necessary. Consent refreshed annually (or) up until the time a customer wishes to have us remove their details from our systems.|
|Cloud Telephony Systems|
Phone numbers/Business landline number
|Cloud Telephony Platform to provide and record telephony services, embedded within Salesforce.||For audit purposes; retained indefinitely.|
|Law Enforcement/Government Authorities||In line with their information request/query.|
To comply with a legal obligation.
To safeguard our interests or someone else’s interests.
|In line with their internal procedures.|
Notice of New Services and Changes
Occasionally, we may also use the information we collect to notify you about important changes to our website, new services and special offers we think you will find valuable. As our customer, you will be given the opportunity to notify us of your desire not to receive these offers by sending us an email request at: email@example.com
Other information we collect
We also collect information from visitors to our website and registered customers to help us improve our website and services. This information tells us, for instance, how many visitors there were to our website, when they visited, for how long and which areas of our website they went to. This information helps us to assess which parts of our website are popular or need improving.
We may share this data in an aggregated form with our partners but only in ways that do not identify any living individuals.
How can I Inspect and Change the Personal Information Smarter Business Holds About Me?
You may request access to all your personally identifiable information that we collect online and maintain in our database. please send your request to: firstname.lastname@example.org
If the information we hold about you is inaccurate, please let us know and we will make the necessary amendments and confirm that these have been made.
How do we Protect your Personal information?
We use Salesforce, a secure external server to store the information you give us when you register. Salesforce.com’s services are certified as compliant with some of the most rigorous, industry-accepted security, privacy, and reliability standards. They are certified and audited to standards as a service provider with the ISO/IEC 27001:2005 standard (including ISO 27001), SAS 70 Type II (now SSAE No. 16), SysTrust, and the EU-US and Swiss-US Safe Harbor frameworks).
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