This Policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit https://www.smartcommunications.com/, use our chatbot services, or other digital properties, communications, or forms that link or refer to this notice (our “Website“). This Policy applies to the personal data collected through our Website, regardless of the country where you are located.
The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.
Please read this Policy carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this Policy. This Policy may change from time to time. Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the Policy periodically for updates.
- Data we may collect about you
We collect and use different types of data from and about you including:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Any messages and interactions sent via our Chatbot (which may also include any of the above).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.
To the extent you interact with our Website Chatbot, where required by applicable law, we will gain consent to record and store your Website Chatbot messages.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- How we collect data about you
We use different methods to collect data from and about you including through:
- Direct interactions. Certain parts of our Website may ask you to provide personal data voluntarily: for example, we may ask you to provide your contact details in order to subscribe to marketing communications from us, register for events, webinars, surveys and/or to submit enquiries to us.
- Automated technologies or interactions. As you interact with our Website, we may collect certain information automatically via technology tools such as our Website Chatbot, cookies, service infrastructure (e.g. duration of session, use of webcams, connection information) and similar technologies from your device. We use the term “Cookies” in this Policy to refer to website cookies and similar technologies that may collect personal data automatically when you visit the Website (such as pixel tags, web beacons, Client IDs, device IDs and similar technologies). In some countries, including countries in the European Economic Area, this information may be considered personal data under applicable data protection laws. Specifically, the information we collect automatically may include your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. city and country – level location) and other technical information. We may also collect information about how your device has interacted with Website, including the pages accessed and links clicked. Where you register to use one of our sites by creating a user account, we may collect information which identifies your use of our site: for example, pages visited, and files downloaded. Please see our Cookies Notice for further details.
- Third parties or publicly available sources. We may receive information about you if you visit other websites employing our Cookies or from third parties including, for example, business partners, sub-contractors in advertising networks, analytics providers or search information providers. We may combine this data with information we already have about you. We may also receive information from Smart Communications group companies. This helps us to update, expand and analyse our records, identify new prospects for marketing and provide products and services that may be of interest to you.
- User Contributions. You also may provide information for us to publish or display (“post“) on public Website areas or transmit to other Website users or third parties (collectively, “User Contributions“). You submit User Contributions for posting and transmission to others at your own risk.
- How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Specifically, we use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:
- Present our Website and provide you with the information, products, services, and support that you request from us.
- Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
- Fulfil the purposes for which you provided the data or that were described when it was collected.
- Notify you about changes to our Website, products, or services.
- Ensure that we present our Website content in the most effective manner for you and for your computer.
- Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
- Improve our Website, products or services, marketing, or customer relationships and experiences.
- Enable your participation in our Website’s interactive, social media, or other similar features.
- Protect our Website, employees, or operations.
- Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
- Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
- Direct marketing, advertising and public relations purposes, in connection with Smart Communications’ business activities, products and services (including to make recommendations about our services, product updates, surveys, referral programmes, special offers, incentives, promotions, events and webinars). We may also send you marketing material about our third-party business partners where their services are used in conjunction with our products, for example, SMARTCOMM for Salesforce.
The respective consent you provide, collected in accordance with applicable data protection law for the specific jurisdiction in which you are located, may also be used to send you details of our products or services that we have identified as likely to be of interest to you, based on the preferences you selected. You may withdraw your consent for us to use your information in any of these ways at any time.
We may use personal data to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Please see our Cookies Notice for further details.
We do not use your personal data to make important automated decisions about you.
We may use non-personal data for any business purpose.
- Disclosures of your Personal Data
We may share your personal data with:
- Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
- Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization). We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
- Third parties to market their products or services to you if you have consented to/not opted out of these disclosures. We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
- Advertisers and advertising networks that require the data to select and serve relevant ads to you and others.
- To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
We may disclose your personal data to third parties:
- To fulfil the purpose for which you provide it.
- For any other purposes that we disclose in writing when you provide the data.
- With your consent.
- To comply with any court order, law, or legal process, including responding to any government or regulatory request.
- To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
We may share non-personal data without restriction.
- Retention of Personal data
We keep your personal data only as long as necessary for the purposes for which it was collected, to provide you with services, in accordance with our contract with you and where required or permitted under law. Generally, this means your personal data will be retained until the end of your contractual relationship with us and as long we have an ongoing legitimate business need to do so.
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.
In relation to direct marketing, we will retain personal data (only to the extent necessary) in order to ensure we respect you direct marketing opt out preferences.
Specifically, in respect of Cookies, personal data will not be retained for any longer than two years. Please see our Cookies Notice for further details.
- International Transfers
Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Smart Communications and our third-party service providers and partners operate around the world. This means that when we collect your personal data it may be processed in any of these countries.
Where we transfer your personal data to Smart Communications group companies, the transfer shall be in accordance with the 2021 Standard Contractual Clauses approved by the European Commission including supplementary measures, as applicable and appropriate. Transfers may also occur under Smart Communication’s intra group data transfer agreement which applies the same standard of adherence to applicable data protection law.
Where we transfer your personal data to third parties, we shall only do so in compliance with applicable data protection law. Where such transfer is made from the United Kingdom or EEA, such transfers are compliant with the transfer mechanisms approved by the European Commission under Article 46 of the General Data Protection Regulation (“GDPR”) and equivalent UK law.
Smart Communications is committed to processing and handling your personal data in accordance with applicable law, and we continue to monitor guidance on applicable data protection laws regarding appropriate safeguards for transfers of personal data.
- Your Personal Data Use Choices
We strive to provide you with choices regarding certain personal data uses in respect of the Website. We have established the following personal data control mechanisms:
Direct Marketing: If you do not want us to use your email address/contact information to promote our own products and services, or third parties’ products or services, you can opt-out by checking the relevant box located on the form where we collect your data or you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing, targeted, cross-context behavioral or telemarketing), please contact us using the contact details provided under the “How to contact us” heading below.
Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. In addition, you can opt-out of each cookie category (except strictly necessary cookies) by visiting our Cookies Preference Center by clicking the ‘Manage Cookie Preferences’ at the footer of this page. Please also note that if you choose to reject or remove cookies, doing so may prevent certain features or services of the Website from working properly and therefore affect your experience. Areas of the Website that can potentially incorporate content from third parties, and which therefore place third-party cookies, will not be available to you. If that is the case, you will be informed accordingly. Since your cookie opt-out preferences are also stored in a cookie in your website browser, please also note that if you delete all cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices. Please see our Cookies Notice for further details.
Some web browsers be configured to transmit “do-not-track” signals to the websites a user visits. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Except as required under applicable law, we do not change our practices in response to “do-not-track” signals. For more information on “do-not-track,” visit https://allaboutdnt.com.
- Your Data Privacy Rights
In accordance with the requirements under applicable law, you may have the following rights (subject to certain exceptions):
- To access, correct, delete, update or rectify your personal data; you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- To object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- To opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing, targeted, cross-context behavioral or telemarketing), please contact us using the contact details provided under the “How to contact us” heading below.
- If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- Website Data Security
We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data. Specific measures we use include:
- The use of https for this Website;
- Access controls to our systems;
- Physical access controls to sites where we process your personal data;
- Employee policies, procedures and training for our staff who handle personal data;
- Prospect information obtained from GDPR compliant suppliers; and
- Website encryption.
- Children’s Online Privacy
We do not direct our Website to minors and we do not knowingly collect personal data from children under 16 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at [email protected].
- Changes to the Policy
This Policy was last updated 22nd November 2023. A Policy will be posted on our Website home page for 30 days whenever this Policy is changed in a material way. By continuing to use the Website you confirm your continuing acceptance of this Policy.
Smart Communications is continuously improving our websites and products by using various third-party web analytics tools, which help us understand how visitors use our websites, desktop tools, and mobile applications, what they like and dislike, and where they may have problems. We maintain ownership of this data and do not share this type of data about individual users with third parties
- How to Contact Us
Please contact Smart Communications using the below contact details if you have any questions about this Policy or Smart Communications practices relating to privacy or if you wish to exercise any of your rights as detailed under this Policy or otherwise granted under applicable laws.
Attention: Data Protection Officer
Email: [email protected]
Telephone: 020 8238 7400 (UK)
Address: Suite 23, LCLB, 95 Mortimer Street, London, W1W 7GB UK
Group companies responsible for the processing of personal data
SmartComms Pty Limited – where there is a transfer of personal data is made from the United Kingdom or EEA to Australia (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law.
SmartComms LLC – where a transfer of personal data is made from the United Kingdom or EEA to the United States of America (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law.
SmartComms SC Limited – SmartComms SC Limited is registered with the UK Information Commissioner’s Office under registration number Z9698640 and is the parent company of the Smart Communications Group. It undertakes sales, marketing and product support for Smart Communications products and performs finance and billing functions for the entire group. As such it will be a controller of any customer data in relation to Smart Communications products and for billing purposes. Any transfer of personal data from the EEA to the UK (where this group company is located) will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law, as applicable and appropriate.
Intelledox Pty Limited – where there is a transfer of personal data is made from the United Kingdom or EEA to Australia (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law.
Intelledox Inc – where a transfer of personal data is made from the United Kingdom or EEA to the United States of America (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law.
Intelledox Asia PTE Limited –. where a transfer of personal data is made from the United Kingdom or EEA to Singapore (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law.
Intelledox Limited – located in Ireland
SmartComms Platinum AG – where a transfer of personal data is made to or from Switzerland (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law.
SmartComms GmbH – where a transfer of personal data is made to or from Germany (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law
Smart Communications CCM Austria GmbH – where a transfer of personal data is made to or from Austria (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law
SmartComms Platinum Pte Ltd – where a transfer of personal data is made from the United Kingdom or EEA to Singapore (where this group company is located) such transfer will be in compliance with the transfer mechanisms approved by the European Commission under Article 46 of GDPR and equivalent UK law.
Website Notice of Collection and Additional Information for Residents of Certain U.S. States
SmartComms SC Limited and its group companies (collectively “Smart Communications”, “we”, “us” and “our”) is collecting your personal information and sensitive personal information to support its business operations, including for the business purposes listed in the chart below.
Under the applicable state privacy laws, “Personal Information” is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household and includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
For purposes of applicable state data and privacy protection laws, we may share your Personal Information with third parties for cross-context behavioral advertising, as indicated in the chart below.
The Personal Information we sell is specific to website activities and internet identifiers. Categories of third parties to whom we sell your Personal Information include analytics and marketing firms. We do not knowingly sell the Personal Information of individuals under the age of sixteen. You may opt-out of sales of your Personal Information selecting ‘Manage Cookie Preferences’ the footer of this page.
We may collect the Personal Information categories listed in the table below. The table also lists, for each category, our expected retention period, use purposes, and whether we sell the information or share it with third parties for cross-context behavioral advertising.