Smart Response Media Limited Privacy Notice – August 2018
How we use your personal and business information.
Under the new General Data Protection Regulation [GDPR] which forms part of the regulatory regime in the UK, together with the new Data Protection Act 2018, Smart Response Media Limited is obliged to announce the following Data Privacy Statement for all customers of our products and services.
Your information will be held by Smart Response Media Limited. This privacy notice is to let you know how our company look after your information. This includes what you tell us about yourself, what we learn by having you/the business as a customer, and your marketing choices. This notice also tells you about your privacy rights and how the law protects you.
This Privacy Notice covers both personal and business information, and for the purpose of this Privacy Notice the following words have the following meanings:
“You/your” means suppliers, clients and customers of our business who we have collected information about, in connection with the products and services provided to/by us.
“The business” means the business you are associated with and which is our customer or supplier, whether it is a company, limited liability partnership, partnership, sole trader, or other entity such as a special purpose vehicle, club, charity or trust.
Contacting us about data privacy
If you have any questions, or want more details about any of the topics in this Privacy notice or how we use your personal and business information you can contact the Managing Director at Smart Response Media Limited at email email@example.com
How the law protects you
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Smart Response Media Limited. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it.
When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.
The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:
- For reasons of substantial public interest, or
- To establish, exercise or defend legal claims.
We may collect both personal and business information from other any of these sources:
- Personal and business information we already retain
- When you supply, apply for or buy our products and services
- When you talk to us, for example, on the phone or in meetings
- When you use our websites
- In emails and letters
- If you take part in our competitions or promotions
- Personal and business information we collect when our services are used
- Profile and usage data
This section explains how long we may keep your personal information for and why
We will keep your personal information as long as you/the business is a customer of or supplier to Smart Response Media Limited.
After you/the business stops being a customer, we may keep your personal information for up to seven years.
We will only use your personal information for those purposes and will make sure that your privacy is protected.
We sometimes ask for information that is useful, but not required by law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won’t affect the products or services your business has with us.
This section contains information our Cookies Policy
Cookies are small computer files that get sent down to your PC, tablet or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again. Cookies store information about your visits to that website, such as your choices and other details. This is covered by our Privacy notice, even though it does not include personal details about you.
How to complain
This section gives details of how to contact us to make a complaint about data privacy. It also shows you where to get in touch with the government regulator.
Please let us know if you are unhappy with how we have used your information.
You can contact us using the details set out in this notice. You also have the right to complain to the regulator about the use of your personal information, and to lodge an appeal if you are not happy with the outcome of a complaint.
If you are not happy with our response, you can contact the Information Commissioner’s Office:
Cheshire, SK9 5AF
UK Calls – 0303 123 1113
Outside UK – +44 1625 545 700
This section explains what to do if you no longer want us to hold or use your information
You can withdraw your consent at any time. Please contact us using the details set out at the top of this notice if you want to do so.
If you withdraw your consent, we may not be able to provide certain products or services to you/thebusiness.
Letting us know if your information is incorrect.
Here you can find out how to contact us if you think the information we hold for you is wrong, incomplete or out of date.
You have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it.
If you want to do this, please contact us using the details set out at the top of this notice.
How to get a copy of your personal information
This section tells you where to write to us to get a copy of your personal information, and how to ask for a digital file you can use yourself or share easily with others. You can do this online or by writing to us.
You can get a copy of all the personal information we hold about you by contacting Smart Response Media at the following address or via email to the Managing Director @ firstname.lastname@example.org
Smart Response Media Limited, 2 Tallis Street, London, EC4Y 0AB
What if you want us to stop using your personal information? This section explains about your right to object and other data privacy rights you have – as well as how to contact us about them.
You can object to us keeping or using your personal information. This is known as the ‘right to object’.
You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights.
You can ask us to restrict the use of your personal information if:
- It is not accurate
- It has been used unlawfully but you don’t want us to delete it
- It is not relevant any more, but you want us to keep it for use in legal claims
- You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.
If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.
If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us using the details set out at the top of this notice.
Who we share your personal and business information with
We may share your personal and business information with outside organisations such as tax authorities. This is so that we can provide products and services, run our business, and obey rules that apply to us. Here we list all the types of organisation that we may share information with.
Authorities, this means official bodies that include:
- Central and local government
- HM Revenue & Customs, regulators and other tax authorities
- UK Financial Services Compensation Scheme and other deposit guarantee schemes
- Law enforcement and fraud prevention agencies
- Agents who help us to collect what is owed to us
- Credit reference agencies (such as Callcredit, Equifax and Experian)
- Someone linked with our provision of our product or service
- Companies you ask us to share your data with
We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may try to bring other businesses into Smart Response Media Limited.
This is sometimes called Mergers & Acquisitions or ‘company takeovers’.
- During any such process, we may share data with other parties involved. We’ll only do this if they agree to keep it confidential and secure.
- If the change to our Group happens, then other parties may use this data in the same way as set out in this notice.
We do not sell the information we have to any outside organisations.
We use marketing to let you and your business know about products, services and offers that may be of interest. This section describes how we decide what marketing to show or send. It also explains how we work out what may be interesting to you or your business.
We may use your personal or business information to make decisions about what products, services and offers we think you may be interested in. This is what we mean when we talk about ‘marketing’. We can only use your personal or business information to send marketing messages if we have consent or a ‘legitimate interest’. By ‘legitimate interests’ we mean that we have a business or commercial reason to use your or the business’s information, and it must not conflict unfairly with your interests.
The personal and business information we have is made up of what you tell us, and data we collect when you or your business use, buy or supply our products/services, or from outside organisations we work with. We study this to form a view on what we think you/the business may want or need, or what may be of interest. This is how we decide which products, services and offers may be relevant.
This is called profiling for marketing purposes. You can contact us at any time and ask us to stop using your personal or business information this way.
If allowed, we may show or send your business marketing material online (on our own and other websites including social media), or by email, mobile phone or post.
What you get will depend on marketing choices that you set. You can change these at any time and tell us to stop sending you marketing.
We may ask you/the business to confirm or update these choices, if you/your business takes out/buys any new products or services with us in future. We will also ask you/your business to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can contact us to update your choices at any time.
How we use your information to make automated decisions
Here we tell you how we use automated systems to make decisions relating to you and the business. We also explain the rights you have to challenge decisions using personal information made this way.
Approving credit: we use a system to decide whether to provide credit terms to the business.
Credit Insurance (CI)
This section explains how we work with outside companies to decide whether to grant your business credit. It explains what we do and why we do it.
We carry out credit checks via our outside Credit Insurance (C!) provider. If the business uses our services from time to time we may also search information that the CIs have, to help us manage those client accounts.
We will share your personal and business information with CIs and they will give us information about the business and you. The information we exchange can include:
- Business name and address and (where applicable) date and place of incorporation
- Financial situation and history
- Public information from Companies House
- We’ll use this data to assess whether you or your business is able to be offered credit by Smart Response Media Limited
Direct Selling Operations
SmartResponse sell their products directly to consumers via their online operations namely www.walkfit.tv but all of the customer data is ultimately kept and managed entirely by Amazon.co.uk who manage all aspects of SmartResponse’s fulfilment operations that are fully integrated into our online transactional website. SmartResponse never give or sell data to any other body.
Amazon.co.uk keeps data about SmartResponse customers who have purchased SmartResponse products from WalkFit.tv and/or Amazon.co.uk in a secure customer database. Amazon.co.uk keep your data as secure as possible and please review their policy via the following link –https://www.amazon.co.uk/gp/help/customer/display.html?nodeId=502584.