Privacy and Cookie Policy

(a) Privacy Policy

BACKGROUND:

Smarttdigital understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this site, www.Smarttdigital.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of our Site, and you will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1.Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2.Information About Us

Our Site is owned and operated by Interclubz Limited (Trading as Smarttdigital), a limited Company registered in England under company number 10050083

Registered address: 121 Albert Street, Fleet, Hampshire, GU51 3SR

Main trading address: Afon House, Worthing Road, Horsham, RH12 1TL

VAT number: 241 4993 00

Data Protection Officer: Paul Comyn

Email address: talktous@smarttdigital.co.uk

Telephone number:01403 788 244.

Postal Address. See main trading address above.

3.What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4.What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5.What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

1. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
2. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
3. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
4. The right to restrict (i.e. prevent) the processing of your personal data.
5. The right to object to us using your personal data for a particular purpose or purposes.
6. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6.What Data Do We Collect?

Depending upon your use of Our Site, we may collect some or all of the following personal and non-personal data (please also see Part 14 on our use of Cookies and similar technologies and our Cookie Policy below):

1. Name;
2. Address;
3. Email address;
4. Telephone number;
5. Business name;
6. Business Location
7. Business Web Site address
8. Business email address
9. Information about you
10. Information about your business
11. Details of content posted by you on our site (including blogs, photos, videos, Market Ads, Events, Links, Files, Recommended)
12. Information about your preferences and interests;
13. IP address;
14. Web browser type and version;
15. Operating system;
16. A list of URLs starting with a referring site, your activity on Our site, and the site you exit to;

7.How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one or more of the following purposes:

1. Providing and managing your Account;
2. Providing and managing your access to Our site;
3. Personalising and tailoring your experience on Our Site;
4. Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
5. Personalising and tailoring our services for you.
6. Communicating with you. This may include responding to emails or calls from you.
7. Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by unsubscribing in the email sent to you

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone and text message with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

8.How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept);

As long as you have an account on the site.

If you cease to hold an account, and both you and the site owner agree that your content should remain on the site.

9.How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.

10.Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11.How Can I Control My Personal Data?

In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our email us at the point of providing your details and by managing your Account).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12.Can I Withhold Information?

You may access certain areas of Our site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, our Cookie Policy below.

13.How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14.How Do You Use Cookies?

Our Site may place and access a first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services For more details, please refer to our Cookie Policy below

15.How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Paul Comyn

Email address: talktous@smarttdigital.co.uk

Telephone number:01403 788 244.

Postal Address: Afon House, Worthing Road, Horsham, RH12 1TL

16.Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

(b) Cookies

Cookies Background

This website www.Smarttdigital.com (“Our Site”) uses Cookies and similar technologies in order to distinguish you from other users. By using Cookies, We are able to provide you with a better experience and to improve Our Site by better understanding how you use it. Please read this Cookie Policy carefully and ensure that you understand it. Your acceptance of Our Cookie Policy is deemed to occur if you continue using Our Site.If you do not agree to Our Cookie Policy, please stop using Our Site immediately.

1.Definitions and Interpretations

In this Privacy and Cookie Policy, unless the context otherwise requires, the following expressions have the following meanings:

“Cookie” means a small file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site;

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and of EU Regulation 2016/679 General Data Protection Regulation (“GDPR”);

“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by the Data Protection Act 1998; and

“We/ Our/ Us” means Interclubz Limited, a limited company registered in England under company number10050083, whose registered address is 121 Albert Street, Fleet, Hampshire, GU51 3SR and whose main trading address is Afon House, Worthing Road, Horsham, RH12 1TL

2.Information about us

Our Site is owned operated by Interclubz Limited, a limited company registered in England under company number 10050083 whose registered address is 121 Albert Street, Fleet, Hampshire, GU51 3SR and whose main trading address isAfon House, Worthing Road, Horsham, RH12 1TL

Our VAT number is 241 4993 003

Our Data Protection Officer is Paul Comyn, and can be contacted by email at talktous@smarttdigital.co.uk, by telephone on 01252757134, or by post at Afon House, Worthing Road, Horsham, RH12 1TL

3.How does our Site use Cookies?

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law. We may use some or all of the following types of Cookie:

1. Strictly Necessary Cookies
2. A Cookie falls into this category if it is essential to the operation of Our Site, supporting functions such as logging in, your shopping basket, and payment transactions.
3. Analytics Cookies
4. It is important for Us to understand how you use Our Site, for example, how efficiently you are able to navigate around it, and what features you use. Analytics Cookies enable us to gather this information, helping Us to improve Our Site and your experience of it. n. From the point at which you visit Our Site until you close your browser. Session Cookies are deleted when you close your browser.
5. Cookies on Our Site are not permanent and will expire after 2 years from the date it was last refreshed.

For more details of the personal data that We collect and use, the measures we have in place to protect personal data, your legal rights, and our legal obligations, please refer to our Privacy Policy ( See above).

For more specific details of the Cookies that We use, please refer to the table below.

4.What Cookies does our site use?

The following first party Cookies may be placed on your computer or device:

Name of Cookie Purpose & Type Strictly Necessary

Google Analytics Google Analytics is a Web analytics service that provides statistics and basic analytical tools for search engine optimization (SEO) and marketing purposes

Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of

Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) analytics Cookies to gather the required information.

The analytics service(s) used by Our Site use(s) the following analytics Cookies:

Name of Cookie Purpose & Type Provider Strictly Necessary

Google Analytics Google Analytics is a Web analytics service that provides statistics and basic analytical tools for search engine optimization (SEO) and marketing purposes Google

5.Consent and Control

Before you open an account, you will have to agree to the Terms of use and Privacy/ Cookie terms. By giving your consent to these terms, you are agreeing to the placing of Cookies which will enable Us to provide the best possible experience and service to you.

In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

The links below provide instructions on how to control Cookies in all mainstream browsers:

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB

Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835

Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge(Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)

Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB

Safari (iOS): https://support.apple.com/en-gb/HT201265

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences

Android:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en(Please refer to your device’s documentation for manufacturers’ own browsers)

6.Changes to this Cookie Policy

We may alter this Cookie Policy at any time. Any such changes will become binding on you on your first use of Our Site after the changes have been made. You are therefore advised to check this page from time to time.

In the event of any conflict between the current version of this Cookie Policy and any previous version(s), the provisions current and in effect shall prevail unless it is expressly stated otherwise.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

7.Further Information

If you would like to know more about how We use Cookies, please contact Us at talktous@smarttdigital.co.uk, by telephone on 01403 788 244, or use our Contact us page.

For more information about privacy, data protection and our terms and conditions, please visit the following:

Privacy and Cookie Policy- See above;

Terms of Use- See the link alongside the Privacy/ Cookie terms .