Welcome to the SMB Partners Limited (SMB) privacy notice for the www.smb.co.uk website.
SMB respects your privacy and is committed to protecting your personal data in accordance with the UK Data Protection Act 2018 and any subsequent law mandating data protection within the UK. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW WE COLLECT YOUR PERSONAL DATA
4. DISCLOSURES OF YOUR PERSONAL DATA
5. INTERNATIONAL TRANSFERS
6. DATA SECURITY
7. DATA RETENTION
8. YOUR LEGAL RIGHTS
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how SMB collects and processes your personal data through your use of this website, including any data you may provide through this website.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: SMB Partners Ltd
Email address: firstname.lastname@example.org
Postal address: The Pinnacle, 170 Midsummer Blvd, Milton Keynes MK9 1BP
If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this policy, or the way your personal information is processed, please contact us by one of the following means;
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the so please contact us in the first instance. We would also recommend that you raise any complaint with your employer, who will be our customer: they may well be able to assist in the resolution of your complaint in their role as data controller.
Changes to the privacy notice
This version was last updated on 1st January 2021
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The data we collect is provided by you.
We use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not process Special Categories of Personal Data about you.
3. How we collect your personal data
The vast majority of data that we process originates from our visitors.
A small part of the data we collect is Usage Data, which results from users' interactions with our site. This informs us how long individual users spend on the site, and what they do whilst on it.
Change of purpose
We will only use your personal data for the purposes for which we collected it. If we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose then we may do so. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using our details above.
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.
4. Disclosures of your personal data
We will not share your personal data, other than the technical data.
5. International transfers
Other than data processed by Cookies we use the following processors that offer a service that might be hosted outside of the United Kingdom. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
|Purpose||Location||Provider||Mechanism for transfer|
|Customer Support||International (USA)||Zendesk||Binding Corporate Rules|
|Email marketing tool||International (USA)||Mailchimp||SCCs with DPA|
|Email/Cloud storage||International (USA)||Microsoft||SCCs|
|Customer Support Cloud Provider||International (USA)||Amazon Web Service||SCCs with DPA|
Please also note we are reviewing data transfers in light of the UK leaving the EU and will ensure with advice and guidance of our DPO, any transfers of data from the UK will be in compliance with the UK data protection law and European law and contractual arrangements will be in place where necessary to safeguard data at all times.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, or altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Personal data will be destroyed/deleted in line wit our retention policy/procedure.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please remember that in many cases we are the processor of your personal data, and our customer is the controller. Therefore it may be more appropriate for you to refer any request to the appropriate customer. However, we will always try to assist with a request, and where necessary will liaise with our customer to ensure that the request is facilitated.
In instances where we are the controller, e.g. when you complete a form on our website, you have the following rights.
Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the contact information provided above in paragraph 1.
External Third Parties
Service providers acting as processors or sub-processors who provide IT and system administration services. See section 5.
YOUR LEGAL RIGHTS
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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 below), 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.
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 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.