This Privacy & Cookies Notice was updated on 16th May 2018.
This notice explains how personal information about you is collected and used when you contact us, or use our products and services through our website, Smartfocus.com (the "Website") or otherwise. SmartFocus UK Limited (and its affiliates and group companies) (referred to in this policy as “we” or “us”) are joint data controllers (as we operate as a group for operation and administrative purposes), as appropriate to the relationship between you and us. We are responsible for how your personal information is collected and used.
We are committed to protecting and respecting your privacy and this notice explains how we look after your personal information and about your privacy rights. We have a data protection officer who is responsible for data protection at SmartFocus and please see the contact us section for contact details for our data protection officer if you have any queries concerning this notice, how we use your personal information and or how to exercise your rights.
This Notice provides you with information about:
We may collect and process personal information about you:
(a) When you interact with us directly by:
(b) From third parties:
Personal information that you provide voluntarily to us may include: name, email address, phone number (including mobile number), job title, company name, country, state, your communications and marketing preferences, information about products and services you’ve bought, enquired about or shown an interest in and details provided to us as part of an application for employment.
Personal information that we automatically collect about you may include: Personal information about your business contact details and job title, if confirmed via your publicy available professional social media profile or business website. Information about your interaction with our Website collected using cookies stored on your device, your IP address, which is a number (which indicates the country you are in) that allows your device to communicate with websites and apps, your location or your online browsing activities.
Third Party Sites
We use your personal information to:
Sharing Your Personal Information
We may share your personal information within the SmartFocus Group so we can provide you with the relevant products and services, where we are required or permitted to do so by law or to any successors in title of our business.
We may be required by law or a court of competent jurisdiction to share your personal information with third parties, including to meet national security or law enforcement requirements.
We may share your personal information with third parties including our business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, for the above reasons or with your agreement.
Sharing your information internationally
The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Where we share your personal information in countries outside of the EEA, we will take appropriate measures to protect your privacy and your personal information, by obtaining assurances from the recipients (to the extent permitted by law) that they will safeguard your personal information in a manner that is consistent with this Notice. In addition, if we learn that a third party is using or disclosing your personal information in a manner that is contrary to this Notice, we will take reasonable steps to prevent or stop such use or disclosure.
SmartFocus US, Inc. Complies with the U.S.-EU Privacy Shield Framework and the US-Swiss Safe Harbor Framework
Where we share your personal information with SmartFocus, US Inc, we do so on the basis that SmartFocus US, Inc. complies with the U.S.-EU Privacy Shield Framework and the US-Swiss Safe Harbor Framework. These frameworks are established by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. SmartFocus US, Inc. has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, and to view SmartFocus US, Inc.’s certification, please visit https://www.privacyshield.gov. For more information on the US-Swiss Safe Harbor Framework, and to view SmartFocus US, Inc.’s certification, please visit http://2016.export.gov/safeharbor/swiss/index.asp
Additionally, we are subject to the investigatory and enforcement powers of the Federal Trade Commission.
SmartFocus may be liable for onward transfers of personal information to third parties in violation of this Notice and the Privacy Shield.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection and use of your personal information.
Under the Privacy Shield Framework and this Notice, you have the right to request limitations on how SmartFocus uses or discloses personal information about you. With our Privacy Shield certification, SmartFocus has committed to respect these rights. To exercise these rights, please contact us as indicated below. We will respond to such requests within a reasonable timeframe.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
In the event your complaint is not resolved by us or our U.S.-based third party dispute resolution provider you may have the option under Privacy Shield to binding arbitration. For more information please visit https://www.privacyshield.gov/article?id=G-Arbitration-Procedures.
We take appropriate technical and organisational measures to safeguard your personal information. Even though we take these measures, we cannot guarantee its security if you transfer information over the Internet to us.
What is a Cookie?
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device.
A list of all the cookies used on the Website by category is set out below.
These cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. If you have chosen to identify yourself to us, we use session cookies containing encrypted information to allow us to uniquely identify you.
These cookies remain on your computer after you close your browser or turn off your computer. They are activated each time that the user visits the website that created that particular cookie. When you purchase our services or provide us with personal information, a unique identifier is assigned to you. This unique identifier is associated with a persistent cookie that we place on your Web browser. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies.
We may contact you with information about our products or services or other marketing research, if you agree for us to do so. If you are a customer, we will assume that you expect us to keep you up to date with our latest products and services unless you tell us you prefer us not to. If you decide not to receive any further marketing information from us, please follow the unsubscribe instructions included in our emails or you can contact us at email@example.com to update your communication preferences.
Our business means that we perform marketing services for our clients, who will be the data controller for these communications. If you wish to exercise your rights in respect of these activities, please contact the sender of the marketing communication, as identified in the email that you receive.
Where you have a relationship direct with us – ie. if you are one of our clients, contacts, suppliers, job applicant, employees or contractors (or ex-employees or previous contractors), then we will be acting as data controller in respect of the information we hold on you. So, under certain circumstances, by law you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please complete the Data Subject Request form available here.
We may need to update and to change this Notice at any time and, where appropriate and possible, these changes will be notified to you by e-mail. Please check back frequently to see any updates or changes to our Notice.
For questions, comments, requests or complaints regarding this privacy Notice or about how we collect store or use your personal information please contact us at firstname.lastname@example.org.
If you wish to find out more about your rights or if you are not satisfied with our response and wish to make a complaint, please contact the Information Commissioners Office at http://ico.org.uk.
© SmartFocus 2018