Privacy Policy

Introduction

Your privacy and trust are important to us and this Privacy Policy (“Policy”) provides important information about how Smart Computers Limited (“Company” “we” or “us”) handle personal information. This Policy applies to personal information which we process in the course of doing business including information processed through the Company’s website and in the course of renting or supplying goods or services to you (collectively, our “Services”).

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.

It is important that you check back often for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Services and/or contact you using other methods such as email.

This Policy was last updated on 25th May 2018.

PURPOSE, LEGAL BASIS AND DURATION OF THE PROCESSING

We may process personal information about you in different ways depending on our relationship with you. Please click on the link below which most closely identifies your relationship with us:

You are customer.
You are a supplier.
You are a third party with whom we are in contact during the delivery of goods or services to our customers or the possible delivery of goods or services to prospective customers.
You are prospective customer or prospective supplier
You are an employee, former employee or a relative of either.
You are a prospective employee.
We have received your information from a third party.
Your relationship with us is not covered by any of the above

Customers and employees of our customers

We will collect and store personal information including contact details of our customers and their employees so that we can provide our Services in accordance with our contract with you. We will retain that information and any information relating to the contract between us in accordance with our retention policy following completion or termination of the contract(s) between us so that we can review our performance if any complaints or issues arise after completion or termination of the contract.

We have set out below the type of information which we hold, the lawful basis for holding it and the duration that we hold that information for depending on the type of goods and services which we provide:

Type of service	Personal information	Lawful basis for processing your data	How long we hold your data for
All services	The first name, surname, company address (if applicable) and contact details (email address, telephone number and postal address) of you and (where applicable) your employees involved in the delivery of the service	For the performance of the contract	7 years from completion of the contract
All services	Information about your transaction, including your payment card details and relevant forms of Identification	For the performance of the contract	For the duration of the contract
All services	The communications you exchange with us (for example, your emails, letters, calls, your messages on our online chat service or direct messages via social media)	For the performance of a contract	7 years from completion of the contract
Smart Repair Service	Personal information stored on your computer or device which we access while making the repair	For the performance of a contract	We do no hold or store this personal information
Smart Support Service	E-mail address, telephone number and user name of employees of customers to whom we are providing support	For the performance of a contract	For the duration of the support contract
Smart Rental Service	Personal information stored on your computer or device, including without limitation personal information relating to your employees, customers and suppliers.	For the performance of a contract	During the term of the rental period, you are in control of the information stored on the device and we will only access that information as part of any support service we provide to you. We delete all personal information stored on a device when it is returned to us at the end of the rental period.
Smart Cloud Service	E-mail address and user of employees of customers who are using the service	For the performance of a contract	For the duration of the contract
Smart Cloud Service	Personal information stored in the cloud, including without limitation personal information relating to your employees, customers and suppliers.	For the performance of a contract	During the term of the contract, you are in control of the information stored on the cloud and we will only access that information as part of any support service we provide to you. We do not store any of your personal information which we access through the cloud. We may use third party providers to provide your cloud services, whose terms of use may apply, as stated in your purchase order.
Smart Connect Services	Telephone numbers of customers who are using the service	For the performance of a contract	For the duration of the contract
Smart Protect Services	Telephone numbers of customers who are using the service	For the performance of a contract	For the duration of the contract
Smart Protect Services	Personal information accessed as part of the services and/or stored on any back up, including with limitation personal information relating to your employees, customers and suppliers.	For the performance of a contract	The Smart Protect Services are provided through our chosen partners as set out in any purchase order between us. Please refer to the relevant terms and conditions and privacy policy of the applicable partner.

We may use customer’s personal data for the following purposes.

To manage the products and services you hold with us and to comply with law. These communications are not for marketing purposes and as such, you will continue to receive them even if you opt-out from receiving marketing communications.

To provide our products and services to you – We will use your information to perform our services in relation to your IT, for example to manage a support related enquiry, provide you with rental equipment, to service your IT and to repair your IT. This list isn’t exhaustive.
To communicate with you and manage our relationship with you relating to the product and/or services you have with us – We may need to contact you by phone, email, post and/or SMS for administrative or operational reasons regarding the products and services you hold with us.
To provide you with a quotation – We will use the information you provide after you have sent us a request, filled in a web-form through our website or contacted us on social media to provide you with the response to your request.
To perform a credit check prior to releasing rental equipment – For some of our rental equipment, we may need to obtain a credit score in order for the quote to be accepted. You will be notified in advance of this happening. Refusal to allow us to do this may result in the quote not being accepted and the rental not going ahead.
To improve our services, fulfil our administrative purposes and protect our business interests – The business purposes for which we will use your information include accounting, billing and audit, credit or other payment card verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing, maintenance and development. To the extent any of these purposes are not necessary of the performance of our contract with you, they are in legitimate interests to develop and improve our products and services.
To gain feedback – at the end of a contract with Smart Computers and following a service desk call, you will automatically receive an email from Smart Computers to ask about that specific experience. This is to improve the services that we offer. Supplying feedback is optional and will not reflect the service you receive now or in the future. It is in our legitimate interests to develop and improve our products and services.
To improve our quality levels, help with staff training and to provide evidence in the event of complaint or dispute – We may record telephone conversations or other communications between you and us. We will use these recordings or transcripts of them to check your instructions to us, analyse, assess and improve our services to customers, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute or anticipated disputes between you and us. It is in our legitimate interests to develop, improve and monitor our products and services.

For marketing purposes.

To gain ad hoc feedback. Your opinion is very important to us, we may send you an email or call you to seek your feedback on the products and services we offer or regarding the any quotation you have received from us. This feedback will be used to improve our services and help us to understand buying processes of our customers and enquirers. We may use anonymous statistics in our marketing activity.
To inform you about news and offers that you may like – We may send you marketing communications, if you have indicated that you are happy to receive these, for example when you create an account or make an enquiry on our website or over the telephone. This will usually be in the form of a newsletter if we have your email address. Occasionally this will be done by telephone, SMS or by post. And will include: company news, new products and services, special offers and cost saving promotions that you may be interested in. We will also provide you with industry news relating to cyber security and useful tips to help you when it comes to IT. This is not an exhaustive list, and is subject to change. Of course, you can change the way you receive information from us at any time by emailing info@smart.uk.com.

You are a supplier or an employee of a supplier to us.

We will collect and store personal information including contact details of our suppliers and those employees of the supplier who are involved in the delivery of the contract so that we can receive your services in accordance with our contract with you. We will also retain that information and any information relating to the contract between us for a period of six years following completion or termination of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion or termination of the contract.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We are processing your personal information in this way because it is in our legitimate interests to grow our business and explore new business opportunities with you. We will only do this if we believe that you would reasonably expect us to contact you in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to being contacted in this way.

You are a third party with whom we are in contact during the delivery of services to our customers or the possible delivery of services to prospective customers.

We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of Services to our customers or discussions relating to Services to prospective customers. We may receive that information from you, a customer, a supplier, an introducer or otherwise as a result of an interaction between you and our supplier or customers. We process that information because it is in our legitimate interests to do so in order for us to be able to perform our contracts for our customers or pitch for work from prospective customers. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair.

Where your personal information is kept as part of a file relating to the performance of a contract with one of our customers, we will also retain that information and any information relating to that contract for a period of six years following completion or termination of that contract(s) so that we can review the file if any complaints or issues arise after completion or termination of the contract. Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every 3 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to being contacted in this way.

You are a prospective customer or a prospective supplier.

We will collect, store and use personal information including contact details of people who we might do business with as a supplier or a customer for the purpose of growing our business and exploring new business opportunities. We may collect this information from you, when you contact us (including through this website) or from a mutual contact. We will only collect contact information from your website or another third party website if we have identified you specifically as someone who may be interested in receiving a Service from us or delivering goods or services to us. We may contact you about new business opportunities for us to work together with you and to keep you informed of our activities.

We are processing your personal information in this way because it is in our legitimate interests to grow our business and explore new business opportunities with you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

When you enquire but do not purchase a product or service from us – we will follow up your enquiry by email and occasionally by phone for a 3 month period. If you have not opted in to receive marketing communications from Smart Computers, your personal data will be deleted from our systems after this 3 month period.

Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every 3 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to being contacted in this way.

You are an employee, former employee or a relative of either

Employees should refer to the Staff Handbook for further information about our privacy policy in respect of employees.

Where an employee has provided us with personal information about a spouse, civil partner or other family member/friend (where we have a legitimate interest to hold that information for example in relation to sharing a Company car, private medical insurance or other benefits or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it as an emergency contact in connection with the relevant benefit and/or policy in accordance with this privacy policy

You are a prospective employee or a referee of a prospective employee

If we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information because it is in our legitimate interests to do so in order for us to be able to make an informed decision about whether to interview you and, ultimately, recruit you. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair. Where your personal information is kept as part of a file relating to prospective employees of the Company, we will retain that information and any information relating to that matter. This is so that we can review the file if any complaints or issues arise after the recruitment process. The length of time that we keep prospective employee files is usually 6 months after conclusion of the relevant recruitment process.

Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example referees, this contact may be made by telephone, e-mail or post. We will only do this if we have your express permission to contact them in this way.

Where you have provided us with personal information about a referee or a previous employer, it is your responsibility to inform that person that you have provided us with their details and that we will be processing it in connection with your employment application. You should also give them our contact details (below) should they wish to discuss this with us.

We have received your information from a third party

If we have received your personal information from a third party, for example an introducer, your employer or service provider, that third party will be the controller in relation to that personal information and we will be processing it on their behalf. You should therefore contact that third party to review their privacy policy.

If you become a customer or a prospective customer as a result of an introduction, the Company will become a controller in relation to your personal information and the relevant sections of this policy will apply.

Your relationship with us is not covered by any of the above

We may hold your contact details and personal information as a result of an interaction between you and one of our employees or prospective employees. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our employee’s engagement with third parties. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair. We carry out a review of our contacts database every 3 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it safely.

WHERE YOU PROVIDE US WITH PERSONAL INFORMATION ABOUT ANOTHER PERSON

If you give us personal information about another person, you must ensure that:

(a) you are legally entitled to give us that information;

(b) the disclosure is in accordance with any applicable data protection or privacy laws; and

WHEN WE SHARE PERSONAL INFORMATION

We may share some of your personal data with, or obtain your personal data from, the following categories of third parties:

Suppliers providing services to us in order to help us run our business and improve our services. We may for example share your personal data with the companies who provide our antivirus and network cabling services.
Credit and debit card companies. We may share some of your personal data, which includes information about your method of payment, to the credit or debit Card Company that issued the card you used to pay for your products or services. In order to ensure the security of your transactions and prevent or detect fraudulent transactions, we may also share your information with fraud screening partners.
Credit Reference Agencies. To obtain a credit score and credit report in order to provide our rental service to you. You will be notified if this is a requirement to fulfil your rental request.
Fraud prevention agencies. To prevent crime and trace those responsible.
Your personal data may be disclosed to a third party who acquires us, or substantially all of our assets or if we sell or buy any business or assets.
We are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of Smart Computers Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

HOW WE SECURE PERSONAL INFORMATION

We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

As described in this Privacy Policy, we may in some instances disclose your personal data to third parties. Where we do this, we require that the third party has appropriate technical and organisational measures in place to protect your personal data. This will never be for marketing purposes, but only for the purposes of administering the products and services you have purchased through Smart Computers.

The information that you provide to us will be held in our secure servers, which are located on our premises in the UK. Your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, also referred to as the “EEA”) by staff operating outside the EEA who are employed by us. Where your personal data is accessed outside of the EEA, we require that appropriate safeguards are in place.

COOKIES OR OTHER TRACKING TECHNOLOGIES

In order to improve our services, to provide you with more relevant content and to analyse how visitors use our website, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies.

For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website in order to enhance the experience of the visitors to our website. This software does not enable us to collect any personal data. In addition, in order to understand how our customers interact with the emails and the content that we send, we use pixels that allow us to know if the emails we send are opened or if the content of our emails is displayed in text or html form.

We also use cookies in our website, and in some of our emails. Cookies are small pieces of information stored by your browser on your computer’s hard drive. They enable you to navigate on our website and allow us to provide features such as remembering aspects of your last search to make subsequent searches faster. You can delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our website, most of the features will be still accessible without cookies.

HOW LONG WE KEEP PERSONAL INFORMATION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

Where you have given your consent to us contacting you for marketing purposes, unless you withdraw your consent earlier we may continue to contact you for a period of 3 years. Prior to the end of the 3 year period, we will contact you to renew your consent to continue to receive this information. Of course, you can change the way you receive information from us at any time by emailing info@smart.uk.com.

Details of retention periods for different aspects of your personal data set out in the above Section: Purpose, legal basis and duration of the processing .

YOUR LEGAL RIGHTS

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or safely delete your personal information.

Access to personal information : You have the right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
Object to processing: of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request erasure: of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see above), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing: of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer: of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Correction of your data: You have the right to request that we correct your personal information if it is inaccurate or requires updating or complete your personal information if the information we hold is incomplete.
Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.
Filing a complaint: If you are not satisfied with how Smart manages your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to book some or all of your travel arrangements). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please let us know by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

THIRD-PARTY LINKS

This website has links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

HOW TO CONTACT US

Please contact us with any requests related to your personal information.

We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Email: info@smart.uk.com

Address:

Smart Computers Ltd
22 Enterprise Way
Cheltenham
Gloucestershire
GL51 8LZ

Attn: William Rendell

Telephone: 01242 580654