Welcome to the SmartR.Cards – UK Privacy Policy. This document elucidates the manner in which we collect, employ, and divulge information about you when you interact with our website, https://smartr.digital (“Website”), and engage with our customer loyalty program services (“Platform”), collectively referred to as “Services.” It is imperative that you carefully peruse this Privacy Policy and ensure that you comprehend it before commencing the use of our Services.
SmartR Cards, Inc. (“we,” “our,” or “us”) is the owner and operator of this Website and, consequently, the data controller concerning personal information belonging to our users located within the European Union.
By accessing and utilising our Services, you acknowledge that you have thoroughly reviewed and comprehended the content of this Privacy Policy. We retain the right to periodically update this Privacy Policy. Should changes occur, we will notify you by revising the date displayed at the top of the Privacy Policy, and in certain instances, we may provide additional notifications, such as an announcement on our homepage or a direct notification to you. We encourage you to periodically review this Privacy Policy to stay informed about our information practices and the methods available to safeguard your privacy.
**Information You Provide to Us Through the Services**
We gather and process information directly submitted to us through the Services. This includes personal data that you provide when creating an account, engaging in interactive features, making payments for purchase orders, communicating with us through third-party social media platforms, requesting customer support, or any other form of interaction with us. The information we collect may encompass your name, email address, company name, postal address, phone number, and any additional data you choose to provide. In cases where credit card information is furnished through the Services, this information is collected and processed by our third-party payment processor, Stripe, according to their Privacy Policy and practices, available at https://stripe.com/privacy.
**Information We Collect Automatically When You Use the Services**
When you access or utilise our Services, we automatically collect information about your interactions, including:
1. **Log Files:** We gather specific details about your Service usage, including your browser type, access times, viewed pages, IP address, and the page you visited before navigating to our Services. We do not monitor or log data from your servers while using the Services, although we may log or monitor your access information.
2. **Information Collected by Cookies and Other Tracking Technologies:** Various technologies, such as cookies and web beacons, are employed to collect information. For further information on cookies and how to disable them, please consult our Cookie Policy at https://smartr.digital/cookie-policy.
**Information We Collect From Other Sources**
We may also acquire information from external sources, which may be combined with data collected through our Services for purposes such as advertising and user authentication. For instance, if you create or log into your SmartR Cards account using Google Apps credentials via single sign-on, we may gain access to certain information, including your name and email address, as authorised in your Google Apps profile settings.
**Use of Information**
We employ the information we gather for various purposes, which encompass:
– Facilitating your complete access to the Services.
– Maintaining and enhancing the quality of our Services.
– Delivering products and services as requested, processing transactions, and providing related information such as confirmations and invoices.
– Sending technical updates, security alerts, support messages, and administrative notices.
– Addressing your inquiries, comments, and support requests.
– Creating and authenticating your SmartR Cards account.
– Communicating news, product offers, promotions, and events from SmartR Cards and other entities.
– Analysing trends, usage, and activities related to our Services.
– Detecting, investigating, and preventing fraud and illicit activities while protecting the rights and property of SmartR Cards and others.
– Enhancing and personalising our Services, offering content or features matching user profiles and interests.
– Notifying you about vital changes to the Services, including modifications to this Privacy Policy.
– Combining information with data from other sources to better understand your needs and provide improved service.
– Considering you for potential employment at SmartR Cards, linked to an application you’ve submitted.
– Executing any other purpose disclosed at the time of information collection.
**Sharing of Information**
We may share your personal information in the following ways or as otherwise delineated in this Privacy Policy:
– With approved vendors, consultants, and service providers who require access to the information to carry out specific tasks as part of a contract with you.
– In response to information requests if we believe disclosure is permissible, in accordance with, or required by applicable laws, regulations, or legal processes, such as complying with subpoenas or court orders.
– When disclosure is essential for enforcing our rights under this Privacy Policy or any agreement with you, or to safeguard the rights, property, and safety of SmartR Cards or third parties.
– In connection with, or during negotiations of, any merger, sale of SmartR Cards assets, financing, or acquisition of all or part of our business by another company.
– Among SmartR Cards and affiliated companies that may act on our behalf for purposes outlined in this Privacy Policy, including our parents, affiliates, subsidiaries, and other entities under common control and ownership.
– With analytics and search engine providers aiding in improving and optimising our Website, subject to our Cookies Policy.
– With your consent or at your direction.
We may also share aggregated or de-identified information that cannot reasonably identify you.
**Lawful Basis for Processing Your Information**
For EU users’ personal data, we must specify the lawful basis on which we process it. The following are the lawful bases for processing your personal information:
1. **Consent:** When necessary, we will obtain and rely on your consent for processing activities like direct marketing.
2. **Legal Obligation:** We will process your personal data only when required to comply with a legal obligation to which we are subject.
3. **Legitimate Interests:** We may process your data to pursue our legitimate interests, such as promoting our business, providing the Platform to our customers, ensuring the security and improvement of our Website and Platform, and developing new technology and services.
**External Links**
Our Website may occasionally feature links to external sites. Please note that these external websites maintain their own privacy policies, for which we bear no responsibility or liability. Prior to submitting any personal data to these external sites, please review their privacy policies to gain a comprehensive understanding of their practices.
**Log-in Features**
We may offer the option to sign up and log in using your Google account. Should you choose to do so, Google may request your permission to share specific information from your account with us, including your name, gender, location, timezone, and birthday. This information is collected by Google and provided to us as per Google’s privacy policy, accessible at https://policies.google.com/privacy?hl=en-US. You have control over the information shared with us through your Google account’s privacy settings.
**Advertising and Analytics Services Provided by Others**
We permit certain companies to serve advertisements on our behalf across the Internet and in applications. These entities, including Google AdWords, Google Analytics, and others, utilise email addresses and cookies for data collection. They employ technologies like cookies, web beacons, device identifiers, and other tools to gather information about your usage of our Services and other websites and applications. This data aids in analysing and tracking user behaviour, content popularity, targeted advertising, and a deeper understanding of online activities. For more information on cookies, please consult our Cookies Policy, and for details regarding interest-based ads or opting out of behavioural advertising, refer to SmartR Cards’s Cookie Policy at https://smartr.digital/cookie-policy.
**Information Collected on Behalf of Customers in Providing Our Platform**
Regarding personal information we handle or receive on behalf of a customer in connection with their usage of our Platform (“Customer PI”), we do not possess a direct relationship with the customer’s employees or other individuals interacting with the Platform. If you are such an employee or individual and seek access to or wish to amend or delete Customer PI, please direct your request to the relevant customer. We will promptly respond to a customer’s request to remove Customer PI, while EU individuals retain specific rights outlined in “Your Rights” below.
We will solely use Customer PI for the purpose of providing and supporting the Services for the respective customer. Customer PI will be retained for as long as necessary for this purpose and to adhere to our legal obligations, resolve disputes, and enforce our agreements.
**Marketing**
Subject to our legitimate interests or as required by law, we may use your personal information for marketing and providing promotional updates via email about our products and services. You can opt out of further marketing at any time by using the “unsubscribe” link included in all our marketing and promotional email communications or by contacting us through the provided contact details in the “Your Choices” and “Your Rights” sections of this Privacy Policy.
**Security**
We implement reasonable measures, including physical, technical, and organisational safeguards, to protect your personal information from unauthorised access, unlawful processing, accidental loss, destruction, and damage. It’s important to note that although we take measures to protect your information, internet transmission is not entirely secure. While we do our utmost to safeguard your data, we cannot guarantee the security of information submitted via the Internet.
Your personal information will be retained by SmartR Cards for the duration of your account and may be retained for a period afterwards, as needed for our legitimate interests, adherence to our terms of agreement with you, and in accordance with applicable legal obligations. This may include retention necessary for tax reporting and the enforcement of relevant terms or legal proceedings.
We may retain records of your stated objections to data processing, including objections to receiving marketing communications, for the sole purpose of respecting your preferences and refraining from further contact during the duration of your objection.
**Transfer of Information to the UK and Other Countries**
SmartR Cards is headquartered in the United Kingdom. By accessing or using our Services or providing information to us, you acknowledge that your information may be subject to processing, transfer, and storage in the UK, where local law may not provide the same rights and protections as you have under your own jurisdiction.
**Your Rights**
EU individuals possess rights pertaining to their personal data processed by SmartR Cards. If you are an EU data subject, you may exercise these rights by emailing us at [email protected]. Your rights include:
– Requesting access to your personal data.
– Requesting the rectification of any inaccurate personal data we hold about you.
– Requesting the erasure of your personal data.
– Withdrawing your consent, where applicable, for processing activities based on your prior consent.
– Filing a formal complaint with the Information Commissioner in Ireland (or your local EU supervisory authority if outside the UK) if you have concerns about the processing of your personal data by us.
If the requested EU Data pertains to Customer PI, please specify the relevant customer’s name in your request. We will direct the request to the customer for a direct response and provide support as necessary to address your request.
**Your Choices**
**Account Information**
Our customers may access, update, or modify the personal information they have provided by logging into the Services or contacting us at [email protected]. Customers may deactivate their accounts, subject to the terms of their agreements with us, by emailing us at [email protected]. Please note that we may retain certain personal information as required by legal obligations or for legitimate business purposes, such as dispute resolution or contract enforcement. Cached or archived copies of personal information may also be retained for a specified time.
If you are an individual with whom one of our customers interacts regarding the Services (e.g., an employee of a customer), kindly direct requests for access, modification, or deletion of personal information to the relevant customer.
**Cookies**
Most web browsers default to accepting cookies. You have the option to configure your browser to remove or reject browser cookies. Be aware that opting to remove or reject cookies may affect the availability and functionality of our Services. For more details, please consult SmartR Cards’s Cookie Policy at https://smartr.digital/cookie-policy.
**Promotional Communications**
You can opt out of receiving promotional emails from SmartR Cards by following the instructions within those emails or contacting us at [email protected]. Please note that we may still send non-promotional emails, such as those related to your account or ongoing business relations.
**Contact Us**
Should you have any questions or concerns regarding this Privacy Policy, please do not hesitate to reach out to us at:
SmartR Cards
42 Kennington Park Road
London
SE11 4RS
Email: [email protected]