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. We may collect, 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 for any purpose. Aggregated Data is not considered personal data because it 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. If we combine Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data.
Where we need to collect personal data by law, or under the terms of a contractwe 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 provide you with products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you, including:
Direct interactions. You may give us your personal information by filling in forms or by corresponding with us by post, phone (we may record or monitor phone calls to make sure we are keeping to legal rules, codes of practice and internal policies, and for quality assurance purposes), email or otherwise. This includes personal data:
You provide when you:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
Below you can find a description of all ways intended to use personal data, and which of the legal bases we rely on to do so. Please note, that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Purpose/Activity
You can ask us to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a product purchase, product experience or other transactions.
Automated individual decision making is a decision made by automated means without any human involvement. Automated individual decision-making does not have to involve profiling (automated processing of your information to help us evaluate certain things about you), although it often will do. Sometimes we may use automation and profiling to evaluate information about you, which will enable us to:
By law, we must tell you about automated decision-making and profiling. This is because you have rights in relation to automated decision-making and profiling. If you want to know more about this, please contact us at email@example.com
We may have to share your personal data with the parties set out below for those purposes set out in table ‘Purposes for which we will use your personal data’:
Internal Third Parties
Other companies within Smile out of a Box acting as joint controllers or processors and who provide IT and system administration services and undertake leadership reporting.
External Third Parties
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
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 unauthorized 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org
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 several requests. In this case, we will notify you and keep you updated.
Data protection contacts
You have a right to make a complaint at any time to your local privacy supervisory authority.
However, we would appreciate the chance to address your concerns before you approach local privacy supervisory authority, so please contact us in the first instance.