Privacy & Cookies Notice
This Privacy & Cookies Notice was updated on 13th September 2017.
This Notice explains how information about you is used when you contact us, or use our products and services through our website, Smartfocus.com (the "Website") or otherwise. SmartFocus UK Limited is the data controller (referred to in this policy as “we” or “us”) responsible for how your personal information is collected and used.
We are committed to protecting and respecting your privacy.
This Notice provides you with information about:
1. Information We Collect From You
We may collect and process information about you:
(a) When you interact with us directly by:
Visiting our Website;
Contacting us via our Website to find out more information (by email, phone or direct mail) about any of our products or services highlighted on our Website, or previously to enable access to content hosted on our Website such as webinars, videos, eBooks or whitepapers;
- Taking part in customer surveys and questionnaires hosted on our Website or via third party survey tools; and
- Contacting us either in writing, or by calling our customers services number, or via our live chat functionality on our Website.
(b) From third parties:
When you interact with a third party to access their products or services which may be sponsored by us and they tell you that your information may be shared with us; and
We may also confirm your professional details which are publicly available on your professional social media profile (for example, LinkedIn) or your business website.
The information you provide to us may include: name, email address, phone number (including mobile number), job title, company name, country, state, your communications and marketing preferences and information about products and services you’ve bought, enquired about or shown an interest in.
Information we collect about you may include: 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 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
2. How and Why We Use Your Information
We use your information to:
Provide you with the product or service requested by you and to fulfil our contractual obligations to you.
- Allow you to participate in interactive features of our services, when you choose to do so.
- If you are a customer, to provide you with customer services and service messages relating to our products and services.
- Personalize our electronic communications to you and our content based on your language or location.
- Provide you with information about our products and services or thought leadership content that we believe will be of interest to you, via email, phone or direct mail if you sign up with us or choose to do so. At any time you may withdraw your consent by clicking the unsubscribe link on any of our emails, or change your communication preferences by emailing us at firstname.lastname@example.org.
- Analyse, manage and improve our Website and products and services.
- Tell you about important changes to the Website via email.
- Manage customer requests, inquiries, surveys and questionnaires.
- Carry out customer and marketing research.
- To ensure business polcies are adhered to.
- For operational reasons, such as recording transactions, training or control.
- If you apply to work with us, to process that application.
- To comply with any legal, regulatory ort corporate governance obigations and good practice or in connection with legal proceedings or investigations.
Sharing Your Personal Information
We may share your personal information across our 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 information with third parties, including to meet national security or law enforcement requirements.
We may share your 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 data 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.
You may also request limitations on how SmartFocus uses or discloses personal data about you. Under the Privacy Shield Framework and this Notice, you have the right to request limitations on how SmartFocus uses or discloses personal data 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.
3. Information security
We take appropriate technical and organisational measures– to safeguard your personal data, and 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.
Enables us to store a unique identifier for your session
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.
Enables other websites to know that you have visited our website (using DoubleClick)
Enables us to track non-personal visitor information such as number of visits, visit length and referrer (using Google Analytics)
Enables us to present you with retargeting advertising on other websites (using AdRoll)
Enables us to predict your location and display content in the appropriate language
- Google AdWords Conversion
Enables us to track leads and other conversions from our advertising (using Google AdWords)
Enables us to store your preferred content language
Enables us to track who has visited our website (using Lead Forensics)
5. Marketing and Customer Research
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.
6. Your rights
Please contact us at firstname.lastname@example.org if you would like to request to access the personal information we hold on you. In the event of any inaccuracies, you may ask to have this information corrected. We may need to ask for proof of identity before we share any personal information with you and to charge you a small fee for providing you with your personal data, as permitted by applicable law.
7. Changes to Our Privacy Notice
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.
8. How to contact us
For questions, comments, requests or complaints regarding this privacy Notice or about how we collect store or use your personal data please contact us at email@example.com.
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 2017