Website & Cookies Policy

Website and Cookies Notice

Introduction

SmartComms SC Limited and its group companies  (collectively “Smart Communications”, “we”, “us” and “our”) respect your privacy and commit to protecting it through our compliance with the practices described in this Website and Cookies Notice (“Notice”)

This Notice 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/ or other digital properties, communications, or forms that link or refer to this notice our (“Website”). This Notice 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 Notice 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 Notice. This Notice 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 Notice periodically for updates.

1. Data we may collect about you

  • Personal data that we could reasonably use to directly or indirectly identify you, such as your name, postal address, email address, telephone number, user name or other similar identifier, and any other identifier we may use to contact you online or offline (“personal data”)
  • Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
  • Technical information, including the full/partial Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
  • non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Website (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

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.

2. 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 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 Notice 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, 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. 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.
  • 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.
  • 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.

Some of this information may be collected using Cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below

3. Cookies and similar tracking technology

Our Website uses Cookies or other automatic data collection technologies to distinguish you from other Website users. Collecting this information enables us to better understand the visitors who come to the Website, where they come from, and what content is of interest to them, in addition to detecting, preventing or otherwise addressing fraud, security or technical issues, to ensure network and information security and to host, maintain and improve our websites including data hosting, data security, system maintenance and testing and troubleshooting systems and data. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:

  • Estimate our audience size and usage patterns;
  • Store your preferences so we may customize our Website according to your individual interests;
  • Speed up your searches; and
  • Recognize you when you return to our Website.

Certain features of our Website may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies and browser cookies use different management tools and you must manage their settings separately.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

Third-party use of cookies and other tracking technologies

Those cookies are set by us and called first-party cookies. Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use our Website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Personal Data Use Choices

How long do cookies last for?

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are ‘session cookies’. These cookies exist only while your browser is open and are deleted automatically once you close your browser. Other cookies are ‘persistent cookies’. These cookies survive after your browser is closed until a defined expiration date. They can be used by websites to recognise your computer when you open your browser and browse the Internet again.

HWhat types of cookies do we use?

Below is a detailed list of the cookies we use on the Website. Our Website is scanned with our cookie scanning tool regularly to maintain a list as accurate as possible. We classify cookies in the following categories:

  • Strictly Necessary Cookies
  • Targeting Cookies
  • Performance Cookies
  • Functional Cookies

The specific types of Cookies served through the Website are described below:

  • Strictly Necessary Cookies: These Cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These Cookies do not store any personal data.
  • Targeting Cookies: These Cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal data, but are based on uniquely identifying your browser and internet device. If you do not allow these Cookies, you will experience less targeted advertising.
  • Performance Cookies: These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these Cookies collect is aggregated and therefore anonymous. If you do not allow these Cookies we will not know when you have visited our site, and will not be able to monitor its performance.
  • Functionality Cookies:These Cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these Cookies then some or all of these services may not function properly.

What other technologies are used to track my Website visits?

Social Media Cookies: On some pages of the Website, third parties that provide applications through the Website (such as LinkedIn, Google and Twitter) may collect your IP address and set their own cookies in order to track the success of their applications or customize applications for you. These services will also authenticate your identity and provide you the option to share certain personal data with us such as your name and email address to pre-populate our sign-up form or provide feedback. For example, when you follow the Smart Communications Group using a social media button on the website or Smart Communications Group social network (e.g. Facebook, Twitter or LinkedIn), the social network that has created the button will record that you have done this. Because of how Cookies work, we cannot access these Cookies, nor can the third parties access the data in cookies used by us. Some pages of the Website may also contain embedded content, such as video content from YouTube, and these sites may set their own Cookies. Your interactions with these features are governed by the privacy notice of the company providing them.

Analytics: This Website uses Google Analytics, a web-analysis service of a service of Google LLC (“Google”). Google Analytics uses cookies and similar technologies to analyse and improve our Website on the basis of your usage pattern. The data accrued in this context may be transmitted by Google for analysis to a server in the United States of America and stored there. Should personal data be transmitted to the United States of America, Google will comply with applicable data protection laws in respect of such transfer. Your IP address will be abbreviated prior to the analysis of usage statistics, however, so that no conclusions can be drawn about your identity. For this purpose, Google Analytics has been extended on our website to include the code “anonymizeIP”, in order to guarantee an anonymised capture of IP addresses. Google will process the information so gained in order to evaluate your use of the website, to assemble reports on the website activities for the website operators, and to supply further services connected with website use and internet use. You can configure your browser so that it rejects cookies, or you can prevent the capture of the data generated by cookies and relating to your use of our websites (including your IP-address) and the processing of this data by Google by downloading and installing the browser add-on provided by Google. Alternatively, you can opt out of processing by visiting our Cookies Preference Center by clicking the Customize button at the bottom of this Notice. This will prevent the data collection of Google Analytics within this website (the opt-out link will only work in this browser and only for this domain). If you delete your cookies in this browser, you have to click on the link again. You will find more detailed information on this matter in the Privacy Statement of Google Analytics.

Behavioral Retargeting: Smart Communications uses remarketing services to advertise on third party websites to advertise to you after you have visited the Website. We and our third party vendors use Cookies to inform, optimize and serve ads to you based on your past visits. These Cookies allow third party vendors to identify your personal data (such as demographic characteristics) in order to serve you personalized and relevant ads when you browse the internet. These third party vendors may use this information (and similar information collected from other websites) to provide you with more relevant advertisements when you visit non-Smart Communications related websites within their networks. These third parties include Google. Our website uses Google Remarketing, a service of Google. This services uses Cookies and similar technologies to display personalized advertising messages on websites that work with Google. Cookies and similar technologies are also used to perform the analysis of website usage as a basis for the creation of interest-based advertisements. If you use a Google Account, depending on the settings in your Google account, Google may link your Google web and app browsing history to your Google account to personalize ads. If you don’t want this association with your Google account you will need to log out of Google before you can access the Website. You can configure your browser to reject Cookies, or you can prevent the collection of data collected by cookies and related to your use of this website and the processing of this data by Google by accessing Google Advertising Settings and setting the personalization buttons to “Off”. Alternatively, you can opt out of processing by visiting our Cookies Preference Center by clicking the Customize button at the bottom of this Notice. Please refer to Google’s privacy policy for more information on dynamic Remarketing. If you select to reject all cookies, certain parts of our Website may become inaccessible and certain features may not work correctly.

4. How we use your personal data

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:

  • a. Present our Website and provide you with the information, products, services, and support that you request from us.
  • b. Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
  • c. Fulfil the purposes for which you provided the data or that were described when it was collected.
  • d. Notify you about changes to our Website, products, or services.
  • e. Ensure that we present our Website content in the most effective manner for you and for your computer.
  • f. Administer our Website and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
  • g. Improve our Website, products or services, marketing, or customer relationships and experiences.
  • h. Enable your participation in our Website’s interactive, social media, or other similar features.
  • i. Protect our Website, employees, or operations.
  • j. Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
  • k. Make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.
  • i. Direct Marketing

Personal data that you provide via the Website, may be used to for 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), and to inform you about important developments within Smart Communications. 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.

We may use non-personal data for any business purpose.

5. Disclosure of Your Personal Data
We may share your personal data with:

  1. Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates.
  2. 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.
  3. 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.
  4. Advertisers and advertising networks that require the data to select and serve relevant ads to you and others.
  5. To fulfil the purpose for which you provide it.
  6. For any other purposes that we disclose in writing when you provide the data.
  7. With your consent.

We may also disclose your personal data to third parties:

  1. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  2. 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.
  3. To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  4. 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.

6. Consent to Personal Data Transfer

We are based in the United Kingdom. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own including the United States of America, Australia and the EEA.

By submitting your personal data or engaging with our Websites, you consent to this transfer, storing, or processing.

7. 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 Customize button at the bottom of this Notice. 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.

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

8. Your Data Privacy Rights

In accordance with the requirements under applicable law, you may have the following rights (subject to certain exceptions):

  • 1. 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.
  • 2. You can 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.
  • 3. 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.
  • 4. 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.
  • In the United States, states where you have one or more of the above rights include California, Colorado, Connecticut, Utah, and Virginia. For more information about your California specific privacy rights, see section 10 of this Notice. Some of these states allow you to appeal a decision we have made in response to your request to exercise a right under applicable privacy laws.Due to the nature of our services, we may also process personal data relating to individuals with whom we do not have a direct relationship. The transfer of personal data from our customers (acting as data controller) to Smart Communications (acting as data processor) is in compliance with applicable data protection laws. If you are an end user of one of our customers or in any other way connected to our customers’ use of the Smart Communication services, please contact the relevant customer directly who will then liaise with Smart Communications if legally required.

    Smart Communications will respond to your request within a reasonable time. Please note that we may ask you for further information in order to prove your identity before disclosing any personal data to you. We may also require proof of authorisation for anyone making a request on your behalf. These are security measure to ensure that any personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask for further information in relation to your request.

    If you are unhappy with the way that Smart Communications has handled your personal data, you have the right to make a complaint to the authority responsible for data protection in the country that you are based. Contact details should be available online or you may alternatively ask us for assistance.

    9. Jurisdiction Specific Rights – CCPA

    In addition to other applicable privacy laws as detailed herein, this Notice is intended to comply with our obligations pursuant to the CCPA, which provides specific privacy rights to residents of California in relation to businesses that do “business” in California.

    If you are a resident of California, we may process your Personal Information (as defined under California law) because we receive it from one of our customers, for whom we act as a “Service Provider” (as defined under CCPA), from you directly or indirectly, or from third party cookies. For purposes of this Notice, personal data includes Personal Information of California residents.

    Under the CCPA, “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:

    • 1. identifiers such as a real name, alias, unique personal identifier, online identifier, internet protocol address, email address, account name;
    • 2. characteristics of protected classifications under California or federal law specifically restricted to age (18+) and sex;
    • 3. commercial information, including records of products or services purchased;
    • 4. internet or other electronic network activity information, including, but not limited to, browser type and device type;
    • 5. geolocation data specifically continent, country and city/state;
    • 6. professional or employment-related information;
    • 7. inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.

    We sell and share (both as defined under the CCPA) your Personal Information to third parties as detailed in this Notice.

    CCPA Your Privacy Rights

    Certain jurisdictions allow you certain rights concerning your personal data. Applicable laws in the United States include the California Consumer Privacy Act of 2018 and its regulations, as amended by the California Privacy Rights Acts and its regulations (“CCPA”), the Virginia Consumer Data Protection Act of 2021 (“CDPA”), the Colorado Privacy Act of 2021 (“CPA”), the Connecticut Data Privacy Act of 2022 (“CTDPA”), and the Utah Consumer Privacy Act of 2022 (“UCPA”) and (“State Privacy Laws”) you have the following rights concerning your personal data.

    • a. The right to request information on how we process your personal data. This includes the right to request information about (1) the categories of personal data we collect about you, (2) the categories of sources from which we collect your personal data, (3) the purpose for which we collect or sell your personal data, (4) the categories of third parties to whom we disclose your personal data, and (5) the specific pieces of personal data we collect about you.
    • b. You may request we delete personal information that we have collected about you, subject to certain exceptions. Only you, or a person authorised by you, may request that we delete your Personal Information. We may deny your request if retaining your Personal Information is necessary for us or our service providers to perform certain actions as set forth under the State Privacy Laws. We may further retain aggregate and deidentified information.
    • c. You may direct us to correct inaccuracies in the personal information we hold about you.
    • d. You have the right to data portability, and to obtain a copy of the personal information we hold about you in a readily readable format that allows you to transfer your personal information to another business.
    • e. You may direct us not to sell your personal information or share it for the purposes of cross-context behavioral advertising. Nevada Residents may request to opt-out of selling their personal data by sending an email with the subject line “Nevada Do Not Sell Request.”
    • f. We will not discriminate against you for exercising your rights under the State Privacy Laws.
    • g. California’s “Shine The Light law” allows customers in California to request certain details about how certain types of personal data is shared with third parties, as well as in some cases affiliates, for marketing purposes. Under the law, we are required to provide this information or allow you to opt out of such disclosures. You may contact us to exercise your rights under this law.

    You, or anyone you designate as an authorised agent to act on your behalf, may exercise your privacy rights by contacting us by one or more methods as listed in section 14 of this Notice. We will respond to your request within a reasonable time. Please note that we may ask you for further information in order to prove your identity before disclosing any personal data to you or responding to a request made by you to exercise your privacy rights. We may also require proof of authorisation for anyone making a request on your behalf. Any business entity claiming to be an authorised agent of yours must be registered with the California Secretary of State. These are security measures to ensure that any personal data is not disclosed to a person who has no right to receive it. We may also contact you to ask for further information in relation to your request. Some jurisdictions allow you to appeal a decision we have made in response to your request to exercise a right under applicable privacy laws. We will inform you of our reasons for denying any request to exercise your privacy rights, and, if applicable, provide you with information on how to appeal the decision. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any actions taken or not taken in response to your appeal.

    If you are unhappy with the way that Smart Communications has handled your personal data, you have the right to make a complaint to the authority responsible for data protection in the country that you are based.

    10. 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:

    • a) The use of https for this Website;
    • b) Access controls to our systems;
    • c) Physical access controls to sites where we process your personal data;
    • d) Employee policies, procedures and training for our staff who handle personal data;
    • e) Prospect information obtained from GDPR compliant suppliers;
    • f) Website encryption.

    11. Childrens 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].

    12. Changes to the Notice

    This Notice was last updated 25 April 2023. A Notice will be posted on our Website home page for 30 days whenever this Notice is changed in a material way. By continuing to use the Website you confirm your continuing acceptance of this Notice.

    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.

    13. How to Contact Us

    Please contact Smart Communications using the below contact details if you have any questions about this Notice or Smart Communications practices relating to privacy or if you wish to exercise any of your rights as detailed under this Notice or otherwise granted under applicable laws.

    Attention: Data Protection Officer
    Email: [email protected]
    Telephone: 020 8232 7400 (UK) or 1-800-986-6810 (US)
    Address: Catalyst House, 720 Centennial Court, Centennial Park, Elstree, Hertfordshire, WD6 3SY, 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.