Introduction

SmartSpotter takes your privacy very seriously and shall handle your personal data with the utmost security and care. In this Privacy Statement you will learn how we handle your data as well as learn about your rights concerning our processing of your data. We advise that you read this Privacy Statement thoroughly. Should you have any questions or remarks, please contact us at privacy@smartspotter.com.

 

Who is SmartSpotter?

SmartSpotter is the besloten vennootschap SmartSpotter B.V., with registered office at (1411 DL) Naarden listed at the Traderegister of the Dutch Chamber of Commerce under 55334652.

SmartSpotter is as the controller ultimately responsible with regard to the processing of your personal data.

SmartSpotter has appointed a data protection officer. You may contact our data protection officer at privacy@smartspotter.com.

 

How does SmartSpotter use your personal data?

Underneath you will find an overview of the purposes for the processing of your personal data. You will also find a specification of which data SmartSpotter uses for that specific purpose, the legal justification, and the amount of time SmartSpotter keeps this data. For clarity’s sake, we have categorised the purposes.

 

Services, customer management and financial administration

Purpose:

Financial administration

Information:

Bank details, Outstanding balance

Legal basis:

Consent

Storage period:

As long as necessary for this purpose

 

 

Purpose:

Services

Information:

Home address, Email, Data necessary to provide the service, Data generated by the service

Legal basis:

Consent

Storage period:

As long as necessary for this purpose

 

 

Purpose:

Handling complaints

Information:

Home address, Email, Data necessary to provide the service, Data generated by the service

Legal basis:

Consent

Storage period:

As long as necessary for this purpose

 

 

Purpose:

Job application

Information:

Name, Username, Email, Phone

Legal basis:

Legitimate interests

importance:

Commercial interests

Storage period:

As long as necessary for this purpose

 

 

 
Marketing

Purpose:

Newsletter

Information:

Name, Email Legitimate interests

Legal basis:

Legitimate interests

Interest concerned:

Commercial interests

Storage period:

As long as necessary for this purpose

 

 

Purpose:

Social media marketing

Information:

Name, Email Legitimate interests

Legal basis:

Legitimate interests

Interest concerned:

Commercial interests

Storage period:

As long as necessary for this purpose

 

 

 
Business to Business Marketing

As a part of our marketing practice, we make unsolicited contact with companies, including individual employees of such company, by telephone or email to inform them of our services that could result in a mutual commercial interest. We obtain the contact details for such companies and its employees from public information including company websites, business and social media, sector news and industry conferences. We also may have obtained such contact details directly from you or your company if you or your company have previously contacted us using a corporate phone number or corporate email address. Any personal data collected and processed for our business to business marketing practice as detailed herein is done so pursuant to our legitimate interest to market our services to you.

 

If we contact you by email as part of our business to business marketing practice, we will inform you of who we are and will only use your corporate email address (e.g., firstname.lastname@org.co.uk). Any such email communications will include a link to opt out of receiving future marketing emails within the sender’s email signature. Any request to opt out of future marketing emails will be carried out as quickly as possible; however, you may continue to receive email communications for a short time that were scheduled prior to your opt out request, or that are sent before your request is able to be carried out.

 

We may contact you via telephone as part of our business to business marketing practice. If you do not wish to receive telephone calls for this purpose, you may say so during any such call.

 

We will hold your contact information securely as detailed in this policy for up to 5 years to take into account any changes of job role and company, and to maintain a supressed list of persons choosing to unsubscribe from email communications. When the 5-year time limit has been reached, and with no response from the individual, all data of that person will be deleted from our new business database.We hold your contact information on CRM Dynamics (Office 365) servers located in the United States with access strictly limited to allocated employees in the UK directly involved in new business opportunities. We do not share or sell your contact information with any other person or entity. As detailed below, we have safeguards in place to protect your information in connection with the transfer of data outside of the EEA.

 

Website

Purpose:

Website analytics

Information:

Online behaviour, Location

Legal basis:

Legitimate interests

Interest concerned:

Commercial interests

Storage period:

As long as necessary for this purpose

 

 

Purpose:

Account

Information:

Name, Address, Email, Username, Password

Legal basis:

Consent

Storage period:

As long as necessary for this purpose

 

 

 

SmartSpotter has obtained your data because you have provided this data to us.

 

What are your rights?

Under the European General Data Protection Regulation you have a number of rights with regard to your data and the processing thereof:

 

Access

You may access your personal information and make any necessary changes in your account. If you would like to see which personal data SmartSpotter has obtained about you, you may exercise your right of access by submitting a request to SmartSpotter.

 

Making changes

If you wish to make changes to the personal information that you have seen as a result of a request for access and you are unable to make the changes yourself in your account, you may request that SmartSpotter makes these changes for you. You may request that SmartSpotter modifies, corrects, supplements, erases or shields your information.

 

Restriction of processing of personal data

You also have the right, under certain conditions, to ask SmartSpotter to restrict the processing of your personal data.

 

Right to object

If processing of your data takes place on the grounds of 'legitimate interest' by SmartSpotter or a third party, you have the right to object to that processing.

 

Portability of data

You have the right to obtain your personal data from SmartSpotter. SmartSpotter will provide this in a structured and commonly used format, which can easily be opened using commonly used digital systems.

 

Withdrawing consent

When the legal basis for a particular processing is your explicit consent, you have the right to withdraw that consent. This does not affect past processing, but does mean that we will no longer be allowed to process this data in the future. It may also result in SmartSpotter no longer being able to provide you with certain services.

 

Response from SmartSpotter

A request can be sent to privacy@smartspotter.com. SmartSpotter will comply with your request as soon as possible and in any case no later than one (1) month after SmartSpotter has received such a request. If SmartSpotter rejects your request, we will indicate in our reply why the request was rejected.

 

Recipients of your personal data

Your data may be transmitted to:

•           True B.V., Hamilton Bright

It is possible that SmartSpotter is required to submit your data to a third party, for example to fulfil a legal obligation.

 

What are cookies and how does SmartSpotter use them?

Cookies are small pieces of (text) information that are sent to your browser when you visit the website of SmartSpotter and then stored on the hard disk or in the memory of your device. The cookies placed via SmartSpotter’s website cannot damage your device or the files stored on it. With 'cookies', we also mean comparable techniques collecting information, such as device fingerprinting.

 

Can changes be made to this Privacy Statement?

This Privacy Statement is subject to changes. We therefore advise you to regularly read the Privacy Statement for any such changes.

 

Questions, remarks, and complaints

If you have any questions regarding this Privacy Statement or the way in which SmartSpotter uses your data, you can send an e-mail to privacy@smartspotter.com. If you have a complaint about the way your data is processed, please send an e-mail to privacy@smartspotter.com. Furthermore, you always have the right to contact the competent national data protection authority. In The Netherlands, this is the Autoriteit Persoonsgegevens.

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