LAST UPDATED: 03/05/2018
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the applicable data protection legislation, we are the data controller. We will treat your personal data in accordance with our obligations under data protection law and implement adequate security measures. Our aim is to be clear and transparent about the way we use your personal data and not do anything you would not reasonably expect.
1. Information We May Collect From You
1.1. Information you give us (submitted information):
a)this includes information that you provide to us:
(i) when you call us;
(ii) by filling in forms and submitting them to us;
(iii) by e-mail, or through our App Services, Website, App Services and App;
(iv) when you register to use our services, subscribe to any one of our services, through surveys, or by requesting further services;
(v) you download, install (or uninstall), update, register or use our App [available from on our any AppStore specified by us Website] to use our services; or
(vi) when you enter any promotion sponsored by us;
b) the information you give us may include:
(i) your company’s name, field of business and your position in the company;
(ii) your name, address, e-mail address, username, password and other registration information, financial information or your phone number; or
(iii) information you submit in order to sign up for one of our events, give a testimonial or tell us your story;
c) if you contact us, whether through our App Sservices, Website, App Services, App or otherwise we may keep a record of that correspondence. For example, if you submit a query, a complaint, report a problem with our App Sservices, Website, App or otherwise liaise with our customer service, technical support or any other department in our company we may keep a record; and
d) we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
1.2. Each time you visit or use our App Sservices, Website or App we may collect the following information:
a) details of your use of our App and your visits to our Website including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise (“Log Information”);
b) your contact details such us your e-mail address, forename and surname (“Contact Details Information”);
c) information we receive from other sources (“Third Party Information”). We are working closely with third parties (including, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies);
d) you might give us permission to access some information about you when using some social media sites such as Twitter, WhatsApp Facebook depending on the privacy settings you have and the privacy policies of such companies. (“Social Media Information”);
e) technical information, including [the type of mobile device you use,] [a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device),] [mobile network information,] [your mobile operating system,] [the type of mobile browser you use,] [time zone setting,] [OTHER INFORMATION] (“Device Information”);
f) location information. We also use GPS and other geo location technology to determine your current or past location (e.g. to verify your location necessary for the supply of our services) (“Location Information”). Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by sending us an e-mail or by writing to us at Smart Bureau Limited of 11-71-75 Shelton Street, Covent Garden, London WC2H 9JQ (Attn: Customer Service); and
g) we may combine the information we have about you with other information available from other external sources such as information available in the UK electoral roll, or published articles or news, etc.
1.3. We may check some of the information that you provide against third party databases to confirm that it is accurate.
1.5. We may have access to your billing address and payment history in order to assist with customer service enquiries. Under no circumstances are these details disclosed to any third parties other than those who need to know this information for the performance of the services requested by you.
2. How We May Use the Information Collected From You
2.1. We will only use your personal information where the law allows us to. Most commonly, we will use your personal data in the following circumstances, each known as a “lawful basis”:
- Where we need to perform a contract with you, for example selling and supplying to you the Services;
- Where it is necessary for our legitimate business interests, provided that your fundamental rights are not overridden by our interests;
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on your consent to process data, other than in relation to sending certain direct marketing messages. Where we rely upon your consent, you have the right to withdraw your consent at any time by contacting us at firstname.lastname@example.org.
2.2. We will only use your personal information in line with the purposes for which you provided it to us (or for compatible purposes) in connection with the following activities below. We have also indicated which lawful basis we are relying upon for each activity.
2.3. We may process this information for the purpose of:
a) administering registration records (including reminders, e.g. to update your payment details) (lawful basis: performance of a contract);
b) providing and personalising our products and services (lawful basis: performance of a contract, legitimate interests);
c) remembering your preferences about how you would like us to use your personal data and interact with you (lawful basis: legitimate interests);
d) conducting statistical analyses, reporting and drafting analysis reports (lawful basis: legitimate interests);
e )measuring or understanding the effectiveness of advertising we serve to you and others (lawful basis: legitimate interests);
f) providing you access to all parts or features of our App Sservices, Website, App Services and App (lawful basis: performance of a contract, legitimate interests);
g) dealing with your enquiries and requests, including contacting you where necessary and providing you with information you ask from us (lawful basis: consent, performance of a contract);
h) carrying out our obligations arising from any contracts entered into between you and us (including, but not limited to, the provision of services, billing and monitoring of payment) (lawful basis: performance of a contract, legitimate interests);
i) keeping our App Services, Website, App Services and App safe and secure, including to prevent, detect and investigate potentially prohibited or illegal activities as well as checking the information that you provide against third party database to confirm that it is accurate (lawful basis: lawful obligation);
j) contacting you for your views on our services and notifying you occasionally about important changes or developments to our App Sservices, Website, App Services and App (lawful basis: legitimate interests);
k) managing your rights as a data subject (lawful basis: lawful obligation);
l) carrying out market research campaigns (lawful basis: legitimate interests);
m) improving and developing our App Sservices, Website and App (lawful basis: legitimate interests);
n) carrying out internal operations (including but not limited to troubleshooting, data analysis, testing, research, statistical and survey purposes, transferring your anonymised data to Google in order to improve our services) (lawful basis: legitimate interests);
o) ensuring that content from our App Services, Website, App services and App is presented in the most effective manner for you and for your computer or mobile device (lawful basis: performance of a contract, legitimate interests); and
p) debt recovery or debt tracing, crime, fraud and money laundering compliance (lawful basis: lawful obligation, legitimate interests).
2.4. We may also use your personal information to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by e-mail or text. If you are a new customer, we will contact you by electronic means only if you have consented to this (lawful basis: consent).
2.5. If you are an existing customer, and you have not opted out of this, we will only contact you by electronic means (e-mail, SMS or InMail) with information about goods and services similar to those which were the subject of a previous sale to you. You will be entitled to opt out from this by contacting us or by clicking “unsubscribe” in the electronic communication you receive (lawful basis: legitimate interests).
2.6. If you do not want us to use your information in this way, please specify your preferences by ticking or not ticking the relevant box (or boxes) situated on the Registration Form on which we collect your data (e.g. the registration form) or email us to withdraw your consent.
2.7. We may contact you by phone when you submit a form to us or when you send us a written enquiry about our services (e.g. by email) (lawful basis: performance of a contract, legitimate interests).
2.8. We may contact you by phone in connection with services and activities we promote (i.e. this would typically consist of a very small number of calls to you per year and follow up calls only if the first call yields positive interest) (lawful basis: performance of a contract, legitimate interests).
2.9. We may also gather information and statistics for the purposes of monitoring the usage of our App Sservices, Website, App Services and App and may provide such anonymized information to third parties. These statistics will not include information that can be used to identify you (lawful basis: legitimate interests).
2.10. We may use screening and profiling methods to enable us to determine your behavior, interests and habits and to analyze demographic, geographic, and other information relating to you, to allow us to send you information relevant to you and to improve your experience. When doing so, we may gather information about you from other suitable and lawful third party sources such as publicly available data or data from social networks as specified in paragraph 2.1.4 above (lawful basis: legitimate interests).
2.11. You may ask us to provide you with information about our services or services offered jointly with or on behalf of other organizations by sending us an e-mail.
2.12. If you choose to post messages on any online forum or other message platforms that we may make available for this purpose on the App Services, Website, App Services and App, we may collect that information you provide to us, on or via those forums and platforms. We may retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems, as permitted by law (lawful basis: lawful obligation, performance of a contract, legitimate interests).
2.14. We may contract out part of our services plus other ancillary services such as hosting, credit checking, billing, and verification of sales. We may disclose your personal information to other organizations so that they can provide you with the services that we have contracted out (lawful basis: performance of a contract, legitimate interests).
3. Information Security
3.2. Where relevant, with respect to online payments, all your payment details will be passed from your browser for processing using encryption. All information you provide to us is stored on our secured servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or other suitable encryption technology.
3.3. Where you have been allocated a user admin area (an “Account”), this area is protected by your user name and password, which you should never divulge to anyone else. You are responsible for keeping this password confidential. We ask you not to share a password with anyone.
3.4. Please be aware that communications over the Internet, such as e-mails/webmail are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered – this is the nature of the World Wide Web/Internet.
3.5. We cannot accept responsibility for any unauthorized access or loss of personal information that is beyond our control.
3.6. We believe that we have appropriate policies, rules and technical measures to protect the personal data that we have under our control (having regard to the type and amount of that data) from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss.
3.7. All of our employees and data processors that have access to, and are associated with, the processing of your personal information are obliged to respect the confidentiality of our users’ information.
3.8. We ensure that your information will not be disclosed to government institutions or authorities except if required by law or when lawfully requested to by courts of law, regulatory bodies or law enforcement organizations.
3.9. If we use external suppliers to collect or process personal data on our behalf. We will check such companies first and ensure that we place contractual obligations on them so they manage your personal data in line with our instructions and expectations and with data protections laws.
4. To Whom Will Your Information Be Disclosed?
4.1. We do not sell your data to any third parties, but we may share some of your data with our trusted service providers and suppliers for the purpose of providing you with the information or services you request:
a) if such service providers or suppliers are acting on our behalf they cannot use your data for any other purpose than that, which is prescribed by us, and we only use those service providers and suppliers who undertake to protect your details with the same degree of care as we do; or
a) our employees;
b) our affiliates and their employees;
c) any member of our group companies and their employees, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006;
d) successors in title to our business;
e) a prospective seller or buyer in the event that we sell or buy any business or assets, in which case we will disclose your personal data to such business or assets;
f) a buyer, if Smart Bureau Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
g) as required by our event organizers in respect to any event you are taking part in or have applied for;
h) third party consultants, contractors or other service providers who may access your personal information when providing services (including but not limited to IT support services) to us;
i) government bodies and law enforcement agencies and in response to other legal and regulatory requests, if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
j) auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes or processes;
k) any third party where such disclosure is required in order to enforce or apply our Terms, and/or other agreements; or to protect the rights, property, or safety of our company, our customers, or others; and
l) protect the rights, property or safety of Smart Bureau Limited, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud prevention and credit risk reduction; and.
5. Your Contact Information
You can change your contact details at any time by updating your profile in your customer account and update your contact preferences (if any) by changing your settings related to your notification choices.
6. Your Rights In Relation To Your Information
6.1. You can write to us at any time to obtain a copy of your information and to have any inaccuracies corrected.
6.2. Where appropriate, you may object to our processing your personal data under certain circumstances or write to us to have your personal information erased, restricted, rectified, amended or completed.
6.3. If you wish to do this, please write to Smart Bureau Limited of 71-75 Shelton Street, Covent Garden, London WC2H 9JQ (Attn: Customer Service) or send an e-mail. Please quote your name and address in any such correspondence. Please also provide brief details of the information of which you would like a copy or which you would like to be corrected, if possible (this helps us to more readily locate your data).
6.4. We will require proof of your identity before providing you with details of any personal information we may hold about you. We may charge a reasonable fee from you when a request is manifestly unfounded or excessive or repetitive or we receive a request to provide further copies of the same information.
8. Where We Store and Process Your Information
9.3. In the event the purposes for which we process personal information changes, then we will contact you as soon as practicable and seek your consent, where such notification relates to a new additional purpose for processing which is not compatible or similar to the originally specified purposes.
10. Use Of Your Personal Information Submitted To Other Apps or Websites
10.1. If you disclose your information to third parties, such as other websites throughout the Internet (including the ones we link to), different rules may apply to their use or disclosure of the information you disclose to them.
10.2. We are not responsible for the privacy policies and practices of other apps or websites even if you accessed the third-party app or website using links from our App Services, Website, App Services and App or by means of our services.
10.3. We recommend that you check the policy of each app and website you visit and contact the owner or operator of such app or website if you have concerns or questions.
11. Data Retention
11.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
11.3. In some circumstances you can ask us to delete your data.
11.4. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
12. Further Information
12.1. For complaints or for requesting further information from us on data protection and privacy or any requests concerning your personal information please write to Smart Bureau Limited of 71-75 Shelton Street, Covent Garden, London WC2H 9JQ (Attn: Customer Service) or e-mail us.
12.2. You can also contact the Information Commissioner's Office if you have a complaint regarding your personal data that we cannot resolve. Their website address is:
13. Your Duty to Inform Us of Changes
13.1. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
13.2. If your personal details change, please help us to keep your information up to date by notifying us.