Privacy Policy

SMYTH TECH LTD

Website Privacy Policy                                                                                                                                                     1st April 2020

BACKGROUND: 

You are here because you want to learn more about what we do with your personal information and who controls that information. Within this policy we hope to give you a clear understanding of how your data is handled and what options you have as a valued customer.SMYTH TECH LTD (referred to as we or us in this policy), a company incorporated in England and Wales with registered number 12542967 whose registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.References to us in this privacy notice are also made in respect of the network of franchisees who operate under the SMYTH TECH brand. We may need to share your personal information between us so that we can provide our services to you, but we will ensure that your information is only shared between the parties who need to know it and is never generally available within the network.

HOW DO WE COLLECT YOUR DATA:

We collect most of this personal information directly from you – in person, by telephone, text, or email or via our website and apps. We only ask for the information that is relevant to help us build an account with you.We may also collect information:

  • from a third party with your consent, e.g. your bank or building society;
  • from cookies on our website—for more information on our use of cookies, please see the section on cookies, below; and
  • via our IT systems, e.g. door entry systems and reception logs, automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems.

Our websites are not intended for children under the age of 13 and we do not knowingly capture their data without parental consent.This is applicable to the following in the UK Region:

This is also applicable to when you download our SMYTH TECH Mobile application or use any other services in relation to trade in and repairs in store or online.To help us provide superior service, SMYTH TECH LTD may share your information within the SMYTH TECH Group. The SMYTH TECH Group includes SMYTH TECH LTD, our franchisees, our subsidiaries and our affiliates who will take steps to safeguard it in accordance with SMYTH TECH LTD privacy policy. This also includes data analysis projects where we look to review our business direction and keep SMYTH TECH competitive.At times we may be required by law or litigation to disclose your personal information. We may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary.Our stores use CCTV to record images for the protection of staff and customers and the prevention and detection of crime. Our CCTV can also be used for staff training where relevant.For online transactions to ensure that your credit, debit or charge card is not being used without your consent, we will validate name, address and other personal information supplied by you during the order process against appropriate third-party databases. By accepting these terms and conditions you consent to such checks being made. All information provided by you will be treated securely and strictly in accordance with the Data Protection Act 2018 and other Data Protection laws applicable at the time.

OUR USE OF PERSONAL INFORMATION:

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.We will use your personal information for the following reasons:

  • Informing you about the services we offer,
  • entering into a contract with you and delivering the services you ask for;
  • taking direct debit and/or debit and credit card payments; and
  • recording transactions.

DO WE SHARE YOUR INFORMATION?

We will not share any of your data without your consent. Please see below exceptions to this rule:

  • We will, from time to time use external auditors to try and continuously improve our systems and the integrity of your data.
  • In relation to our online service, we provide your contact details to third party groups that will contact you in relation to the quality of the service we provide.
  • To work alongside Law enforcement for their investigations.

COOKIES:

As is standard practice on many corporate websites, the SMYTH TECH website uses “cookies” and other technologies to collect information. The cookies policy can be found here.

DEVICE PERMISSIONS FOR PERSONAL DATA ACCESS:

Our application requests certain permissions from users that allow it to access the user’s device data as described below.By default, these permissions must be granted by the user before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the owner for support at the contact details provided in the present document.The exact procedure for controlling app permissions may be dependent on the user’s device and software.Please note that the revoking of such permissions might impact the proper functioning of this Application.If user grants any of the permissions listed below, these respective Personal Data may be processed (i.e. accessed to, modified or removed) by this application.Approximate location permission (non-continuous)Used for accessing the User’s approximate device location. Our application may collect, use, and share User location Data in order to provide location-based services. The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for our application to derive the approximate position of the User on a continuous basis.

  • Camera permission
  • Used for scanning the product barcode
  • Microphone permission
  • Used for in app voice search
  • Precise location permission (non-continuous)

Used for accessing the User’s precise device location. Our application may collect, use, and share User location Data in order to provide location-based services. The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for our application to derive the exact position of the User on a continuous basis.

THIRD PARTY:

SMYTH TECH does not broker or pass or sell any information of their customers to any external agency.However, SMYTH TECH may from time to time include links to third-party websites, plug-ins and applications. Please be advised that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the sites privacy policy.

MARKETING:

When you sign up to our online memberships, we give you the opportunity to opt into our SMS/Email communication to keep you up to date with news and competitions. Of course, you have the option at any time to change these preferences by going online into your account and we will honor your choices.If you have a store account then please pop in store and we can make the necessary changes to reflect your preference.

WHAT RIGHTS DO YOU HAVE?

You have the following rights, which you can exercise free of charge:

  • Access:
    The right to be provided with a copy of your personal information (the right of access)
  • Rectification:
    The right to require us to correct any mistakes in your personal information
  • To be forgotten:
    The right to require us to delete your personal information—in certain situations
  • Restriction of processing:
    The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
  • Data portability:
    The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
  • To object: The right to object:
    • at any time to your personal information being processed for direct marketing (including profiling);
    • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
  • Not to be subject to automated individual decision-making:
    The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.If you would like to exercise any of those rights, please:

  • email our Administration Department – see below: ‘Contact Information’; and
  • let us have enough information to identify you (e.g. your full name, address and customer or account number);
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know what right you want to exercise and the information to which your request relates.

HOW LONG WILL MY INFORMATION BE RETAINED FOR?

We will only keep hold of your data for as long as it is required by SMYTH TECH to continue both a relationship with yourself and to fall in line with Legal requirements which include but not limited to Law Enforcement partnerships and warranty periods.

WHERE YOUR PERSONAL INFORMATION IS HELD?

Information may be held at our offices and those of our group companies, franchisees, third party agencies, service providers, representatives and agents as described above.Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA:

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • with our offices outside the EEA;
  • with your and our service providers located outside the EEA;
  • if you are based outside the EEA;
  • where there is an international dimension to the services, we are providing to you.

These transfers are subject to special rules under European and UK data protection law.
Some non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses please contact our Data Protection Officer (see ‘How to contact us’ below).

CONTACT INFORMATION:

SMYTH TECH has put into place a Data Protection team within our Administration Department to deal with your enquiries on a daily basis. If you have any questions then please get in contact with us either by email privacy@smythtech.co.uk or alternatively you can contact us via post:Compliance Manager/Data Controller
SMYTH TECH LTD
71-75 Shelton Street
Covent Garden
WC1H 9JQ
United Kingdom

We want to be your first contact option in relation to anything you are unhappy about in relation to your query, but you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you continue to be dissatisfied with our service. (www.ico.org.uk/concerns) This policy can be updated from time to time to fall in line with changes that are required. By reading this policy you agree to continue your relationship with SMYTH TECH. If you wish to withdraw consent then please see the ‘What rights do I have’ section for your options.