We, SmartFluent, take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).
This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.
We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the contact information in section 15 of this privacy notice.
We collect your personal data for one of the following purposes:
To fulfil an order, or take steps linked to an order: in particular, in facilitating and processing transactions that take place on the site.
Where this is necessary for purposes which are in our, or third parties' legitimate interests. These interests include:
Where you give us consent:
For purposes which are required by law.
For the purposes of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:
We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. We may also collect your information from third-party sources and or partners from US or UK whereby we receive additional information about you, such as demographic data or fraud detection information; and combine it with information we have about you. For example, fraud warnings from service providers like the Kount fraud prevention system we use. The categories of personal information that we may collect, store and use about you include:
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please see "additional information", section 16 of this policy.
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.
We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see "additional information", section 16 of this policy.
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in section 15, so we can remove this information without any undue delay.
In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
You can exercise this right if:
We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
If you have any question about these rights, please see "additional information", section 16 of this policy.
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
When you visit our site, there are certain information recorded which are anonymous. If you are logged into your account, some of this information could be associated with your account. We are talking about the following kinds of details:
Occasionally, we will use third party advertising companies to serve ads based on prior visits to our sites.
Your personal data is not used in any automated decision making (a decision made solely by automated means without any human involvement) or profiling (automated processing of personal data to evaluate certain conditions about an individual).
Where we make an automated decision which has a legal or substantially similar effect, you have the right to speak to us and we may then review the decision, provide a more detailed explanation and assess if the automated decision was made correctly.
SmartFluent may disclose your personal data, listed in section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the UK.
We may share personal information to third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
For more information about transfers and safeguarding measures, please contact us using the information in section 16.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on [email protected].
Alternatively, you can make a complaint to the Information Commissioner's Office:
Your trust is important to us. That is why we are always available to talk with you at any time and answer any questions concerning how your data is processed. If you have any questions that could not be answered by this privacy policy or if you wish to receive more in-depth information about any topic within it, please contact our DPO and Compliance Team via email on [email protected].
We keep this Policy under regular review. This Policy was last updated on 01/01/2024.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.