PRIVACY POLICY

At SMA Digital LTD, we understand the significance of your privacy and your concerns regarding the use of your personal data. We deeply respect and value the privacy of all individuals visiting our website, www.smadigital.co.uk (“Our Site”). We are committed to collecting and utilizing personal data only in ways that adhere to the principles set forth in this Privacy Policy, while ensuring alignment with our obligations and your rights under the law.

Kindly read this Privacy Policy attentively and ensure that you comprehend its content. We request your acknowledgment of this Privacy Policy when you visit our Site.

1. Information About Us

Our Site is owned and operated by SMA Digital, a limited company registered in England under company number 10047806, with a registered office at 7 Bell Yard, London, WC2A 2JR, United Kingdom.

2. What Does This Policy Cover?

This Privacy Policy exclusively pertains to your use of Our Site. Please note that Our Site may incorporate links to other websites. It’s important to recognize that we lack control over how your data is collected, stored, or used by these external websites. We urge you to review the privacy policies of such websites before sharing any data with them.

3. What Is Personal Data?

In accordance with the retained EU Law version of the General Data Protection Regulation (EU Regulation 2016/679) (the “UK GDPR”) and the Data Protection Act 2018 or any successor legislation (collectively, “the Data Protection Legislation”), personal data is defined as “any information related to an identifiable individual who can be directly or indirectly identified, especially through reference to an identifier.”

Put simply, personal data encompasses any information about you that enables your identification. It encompasses not only evident details like your name and contact information but also more subtle information, including identification numbers, electronic location data, and other online identifiers.

4. What Are My Rights?

Pursuant to the Data Protection Legislation, you possess several rights that we are committed to upholding:

a) The right to be informed about the collection and utilization of your personal data. While this Privacy Policy aims to provide you with comprehensive information, you can always contact us to gain further insights or ask questions using the details in Part 12.

b) The right to access the personal data we have on you. The process for this is detailed in Part 11.

c) The right to have inaccuracies or incompleteness in your personal data corrected. Please reach out to us via the details in Part 12 for more information.

d) The right to request the deletion or disposal of any of your personal data that we hold, a right often referred to as “the right to be forgotten.” For additional details, please contact us using the information in Part 12.

e) The right to limit the processing of your personal data.

f) The right to object to the utilization of your personal data for particular purposes.

g) The right to withdraw consent. This means that if we are using your consent as the legal basis for using your personal data, you can withdraw that consent at any time.

h) The right to data portability. If you’ve provided us with personal data directly, we are using it with your consent or for contractual purposes, and the data is processed through automated means, you can request a copy of that data for reuse with other services or businesses in many cases.

i) Rights related to automated decision-making and profiling. We do not employ your personal data in such a manner.

To acquire more information regarding the usage of your personal data or to exercise the rights as detailed above, please reach out to us using the information provided in Part 12.

It is essential to maintain the accuracy and currency of your personal data. If any of the personal data we possess about you changes, kindly keep us informed.

For additional information regarding your rights, you can refer to the Information Commissioner’s Office or your local Citizens Advice Bureau.

In case you have concerns or complaints about our handling of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. You can contact them through the details found at https://ico.org.uk/make-a-complaint or by phone at 0303 123 1113. However, we encourage you to first contact us using the information in Part 12, giving us the opportunity to address your concerns.

5. What Data Do You Collect and How?

Depending on your interactions with Our Site, we may gather and store various categories of personal data, as outlined in the table below, using the methods described therein. We do not collect any ‘special category’ or ‘sensitive’ personal data, data pertaining to children, or data concerning criminal convictions or offenses.

We may collect, use, store, and transfer different types of personal data about you, which are categorized as follows:

(a) Identity Data, including first names, last names, or usernames.

(b) Contact Data, including billing addresses, delivery addresses, email addresses, and telephone numbers.

(c) Financial Data, encompassing bank account and payment card details.

(d) Transaction Data, containing information about payments to and from you, along with additional particulars about products and services you have acquired from us.

(e) Technical Data, which includes your internet protocol (IP) address, login data, browser type and version, time zone configuration and location, plug-in types and versions, operating systems, and device technologies used to access this website.

(f) Profile Data, encompassing your username and password, records of purchases or orders placed by you, your interests, preferences, feedback, and responses to surveys.

(g) Usage Data, comprising details on how you utilize our website, products, and services.

(h) Marketing and Communications Data, which encompasses your preferences regarding receiving marketing materials from us or our affiliates, as well as your communication preferences.

6. How Do You Use My Personal Data?

According to the Data Protection Legislation, we are obligated to have a lawful basis for processing personal data. The subsequent table elucidates how we employ your personal data, alongside the lawful grounds that justify our actions:

7. How Long Will We Retain Your Personal Data?

We are committed to retaining your personal data for no longer than is essential, considering the purpose(s) for which it was initially collected. Consequently, your personal data will be retained for the following time frames (or, if there is no specific duration, the subsequent factors will be employed to ascertain the retention period):

With your approval and/or when permissible by law, we may also employ your personal data for marketing purposes, which could encompass reaching out to you via email, telephone, text message, or postal mail with information, updates, and offers about our products and services. We assure you that you will not receive any unauthorized marketing or unsolicited communications. We are unwavering in our commitment to safeguard your rights and adhere to our responsibilities under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003. Additionally, you will always have the option to opt-out. We will unfailingly secure your explicit opt-in consent before divulging your personal data to third parties for marketing objectives, and you will be able to opt-out at any time.

We will solely utilize your personal data for the purpose(s) for which it was initially obtained unless we reasonably determine that another purpose is consistent with the original one(s) and necessitate the use of your personal data for that purpose. If we do employ your personal data in such a manner and you wish us to elucidate how the new purpose is congruent with the original purpose, kindly reach out to us using the details in Part 12.

In cases where we need to employ your personal data for a purpose that is unrelated to or incompatible with the original purpose(s) for which it was initially collected, we will apprise you of this and elucidate the legal basis permitting us to do so.

Under certain circumstances, within the boundaries of the Data Protection Legislation and your legal rights, we may process your personal data without your awareness or explicit consent when it is permitted or mandated by law.

These include:

8. Storage and Transfer of Your Personal Data

In situations where any personal data is transferred outside of the United Kingdom and/or the European Economic Area (EEA), we will take appropriate measures to ensure that your personal data is handled with the same degree of safety and security as it would be within the UK, in accordance with the Data Protection Legislation, as detailed below.

We may store or transfer some or all of your personal data to countries that are not within the United Kingdom and/or EEA, referred to as “third countries,” which may lack data protection laws as robust as those in the UK and/or EEA. To ensure that your personal data is treated with the same level of safety and security as within the UK and EEA, we adopt the following measures under the Data Protection Legislation:

We employ specific contracts with external third parties approved by the European Commission for the transfer of personal data to third countries. These contracts demand the same degree of personal data protection required under the Data Protection Legislation. Further information can be obtained from the European Commission and the Information Commissioner’s Office in the UK.

Safeguarding your personal data is of utmost importance to us. To ensure its protection, we implement several essential measures, including:

• Restricting access to your personal data to only those employees, agents, contractors, and other third parties who genuinely need to access it, ensuring they are bound by confidentiality obligations.
• Establishing procedures for addressing data breaches, including notifying you and/or the Information Commissioner’s Office if legally required.

9. Do We Share Your Personal Data?

We will not disclose any of your personal data to third parties for any purposes, with the following exceptions:

If we sell, transfer, or merge portions of our business or assets, your personal data may be transferred to a third party. Any new owner of our business will continue to use your personal data as outlined in this Privacy Policy.

In certain limited circumstances, we may be legally obligated to share specific personal data, including yours, when we are involved in legal proceedings, complying with legal obligations, a court order, or government authority instructions.

We may share your personal data with our third-party service providers who offer various services to us that involve data processing (e.g., supporting the delivery of Our Site, enhancing its security, providing marketing or hosting services) or who process personal data for the purposes outlined in this Privacy Policy or as notified to you when we collect your personal data.

If any of your personal data is shared with a third party as described above, we will ensure that your personal data is handled securely, safely, and in compliance with your rights, our obligations, and the third party’s legal obligations, as described in Part 8.

In cases of selling, transferring, or merging parts of our business or assets, your personal data may be passed to a third party. A new owner of our business will adhere to using your personal data in a manner consistent with how we have used it, as specified in this Privacy Policy.

In some limited scenarios, we may be legally required to share specific personal data, including yours, if we are engaged in legal proceedings, complying with legal obligations, a court order, or the directives of a government authority.

10. Cookies and Similar Technologies

We utilize cookies and similar technologies on Our Site for various purposes, including enhancing your experience when using Our Site.

11. Can You Withhold Information?

Certain sections of Our Site may be accessible without providing any personal data. However, to utilize all the features and functions available on Our Site, you might be required to provide or consent to the collection of specific data.

12. How Can You Access Your Personal Data?

Should you wish to ascertain the personal data we hold about you or obtain a copy of such data (where it is stored), you can submit a “subject access request.” All subject access requests should be made in writing and sent to the email or postal addresses provided in Part 12. Generally, there is no charge for a subject access request. However, if your request is considered “manifestly unfounded or excessive” (e.g., due to repetitive requests), we may impose a fee to cover administrative costs. We will respond to your subject access request within one month and, in any event, within one month of receipt. While our goal is to provide a comprehensive response, including a copy of your personal data, within that time frame, more time may be necessary in complex cases, up to a maximum of three months from the date of receiving your request. We will keep you informed of our progress.

13. How to Contact Us

If you have any concerns or inquiries related to your personal data and data protection, including making a subject access request, please use the following contact details:

Email address: support@smadigital.co.uk Postal Address: SMA Digital LTD, 7 Bell Yard, London, WC2A 2JR, United Kingdom.

14. Changes to this Privacy Policy

This Privacy Notice may be subject to periodic changes, as may be necessitated by alterations in the law or modifications in our business affecting personal data protection. Any changes will be promptly posted on Our Site, and your acceptance of the terms of this Privacy Policy will be presumed upon your initial use of Our Site following such revisions. We recommend that you check this page regularly to stay up-to-date.