PRIVACY & COOKIES POLICY
WHAT DATA DO WE COLLECT?
As part of providing you with our services, we collect your Personal Information upon visiting our website. “Personal Information” means any information from which you can be personally identified, such as your name, email address, phone number, etc.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together, as follows:
- Once you entered our website, we may collect information about the hardware from which you access the website, such as your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, website navigation.
- You can choose to provide us with additional information by filling out a form with the following details: full name, e-mail address, phone number, Skype address, etc.
We do not collect directly any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and/or genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, this information may be available to us via other third-party add-ons
HOW DO WE COLLECT YOUR DATA?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, skype or otherwise. This includes personal data you provide when you:
- apply for our products or services.
- subscribe to our services or publications.
- request marketing.
- enter a competition, promotion or survey.
- give us some feedback via the ‘contact us’ form on our website.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect such data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as Technical Data from analytics providers such as Google and or Facebook.
HOW WILL WE USE YOUR DATA?
We will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To email you with special offers on other products and services we think you might like.
- To analyze and improve the services offered on our Website.
- To do remarketing through Google Analytics and Facebook pixel.
HOW DO WE STORE YOUR DATA?
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 process your personal data on our instructions, and they are subject to a duty of confidentiality.
WHAT ARE YOUR DATA PROTECTION RIGHTS?
The right to access – You have the right to request Smart Broker Solutions for an access 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.
The right to rectification – You have the right to request that Smart Broker Solutions correct any personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you completed or corrected (accordingly), though we may need to verify the accuracy of the new data you provide us.
The right to erasure – You have the right to request that Smart Broker Solutions erase your personal data, under certain conditions. Thus, you are entitled to have your personal data erased if:
- the personal data is no longer necessary for the purpose which we originally collected or processed it for;
- we are relying on your consent as the lawful basis for us holding your data, and you withdraw your consent;
- we are relying on legitimate interests as our basis for processing your data, you object to the processing of your data, and there is no overriding legitimate interest for us to continue this processing;
- we are processing your personal data for direct marketing purposes and you object to that processing;
- we have processed your personal data unlawfully (i.e. in breach of the lawfulness requirement of us collecting and processing your personal data);
- we have to erase your data to comply with a legal obligation;
- we have processed your personal data to offer information or services to a child.
The right to restrict processing – You have the right to request that Smart Broker Solutions restrict the processing of your personal data, where there is no good reason for us to continue 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.
The right to object to processing – You have the right to object to Smart Broker Solutions ’s 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.
The right to data portability – You have the right to request that Smart Broker Solutions transfer the data that we have collected to another organization, or directly to you. We will provide 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.
The right to 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.
WHAT ARE COOKIES?
Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology in a way which enables the website browsed to save and identify the user’s browsing activity and individual preferences, for example: to collect information about the User’s activity in relation to the Services and it may serve to recall Personal Data previously indicated by a User, such as his/her user ID and password for access to the Service(s).
Do note that most browsers allow controlling cookies, including whether or not to accept them and how to remove them.
Cookies are downloaded by your browser whenever you access our website. The stored data is used to track your browsing path and the pages you visit most frequently. Cookies are commonly introduced to improve the efficiency of websites. By tracking our user’s behavior, we seek to make our website more user-friendly and tailored to your preferences and to get a better understanding of how you use our website. Cookies are also used to display remarketing advertisements, based upon the user’s previous visits to the website.
WHAT TYPES OF COOKIES DO WE USE?
Strictly necessary cookies: These cookies are essential for the running of our website. Without these cookies our websites would not function properly. These are saved temporarily as login information and expire once the browser is closed.
Preferences cookies: Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
Analytical cookies: The information provided by analytical cookies allows us to analyze patterns of visitor behavior and we use that information to enhance the overall experience or identify areas of the website which may require maintenance. The information is anonymous (i.e. it cannot be used to identify you and does not contain personal information such as your name and email address) and it is only used for statistical purposes. Behavioral cookies are similar to analytical and remember that you have visited a website and use that information to provide you with content which is tailored to your interests.
Promotional cookies: These cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
You can also deactivate the custom audiences remarketing feature in the Ads Settings section on Facebook at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
Google analytics: Our websites use the features of Google Analytics Remarketing. This feature makes it possible to link target audiences for promotional marketing created with Google Analytics Remarketing to the cross-device capabilities of Google AdWords and Google DoubleClick. This allows advertising to be displayed based on your personal interests, identified based on your previous usage and surfing behavior on one device (e.g. your mobile phone), on other devices (such as a tablet or computer). Google will associate your web and app browsing history with your Google Account for this purpose. That way, any device that signs in to your Google Account can use the same personalized promotional messaging.
You can permanently opt out of cross-device remarketing/targeting by turning off personalized advertising in your Google Account; follow this link: https://www.google.com/settings/ads/onweb/.
HOW TO MANAGE YOUR COOKIES
CHANGE OF PURPOSE
We will use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 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. 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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with third parties for the purpose of carrying out our services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
PRIVACY POLICIES OF OTHER WEBSITES (third-party links)
HOW TO CONTACT US
Any inquiries, questions or concerns regarding Smart Broker Solutions ’s privacy practices or this Policy, may be addressed to the following address: firstname.lastname@example.org.