This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the “Data Subject”) who is not already in the public domain.
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR), which is EU-wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.
Who we are
Smart Numbers Ltd is a UK based telecommunications reseller principally involved in the B2B sector.
Smart Numbers Ltd uses the information collected from you to provide services and marketing information that Smart Numbers Ltd believes may be of interest to you and your business. In having made your initial contact with Smart Numbers Ltd, you consent to Smart Numbers Ltd maintaining a marketing dialogue with you until either you opt out (which you can do at any stage) or we decide to discontinue promoting our services. Smart Numbers Ltd also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Smart Numbers Ltd will be acting on the instruction of its client and will aim to ensure that the client is fully GDPR compliant.
Some personal data may be collected about you from forms and surveys that you complete; from records of our correspondence and phone calls; and from details of your visits to our website, including but not limited to personally identifying information such as Internet Protocol (IP) addresses. Smart Numbers Ltd may from time to time use such information to identify its visitors. Smart Numbers Ltd may also collect statistics about the behaviour of visitors to its website along with transaction information collected in the process of performing its business.
Any information Smart Numbers Ltd holds about you and your business encompasses all the details we hold about you and any sales transactions, including any third-party information, we have obtained about you from public sources and our own suppliers, such as credit referencing agencies.
Smart Numbers Ltd will only collect the information needed so that it can provide you with its services. Smart Numbers Ltd does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that Smart Numbers Ltd has purchased from a third-party list broker, on behalf of a client.
Legal basis for processing any personal data
To meet Smart Numbers Ltd.’s contractual obligations to clients and to conform to relevant legal obligations they have.
Legitimate interests pursued by Smart Numbers Ltd and/or its clients
To promote the services offered by Smart Numbers Ltd and/or to market the services and/or products offered by Smart Numbers Ltd.’s existing clients.
Through agreeing to this privacy notice you are consenting to Smart Numbers Ltd processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing email@example.com; by phoning +44 (0) 3450178179; or by writing to us. See last section for full contact details.
Smart Numbers Ltd may, on occasion, pass your Personal Information to third parties exclusively to process work on its behalf. Smart Numbers Ltd requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Smart Numbers Ltd does not broker or pass on information gained from your engagement without your consent. However, Smart Numbers Ltd may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests. Smart Numbers Ltd may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions, to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property, or safety of Smart Numbers Ltd, its clients and/or the wider community.
Smart Numbers Ltd will process personal data during the duration of any contract and will continue to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. After seven years any personal data not needed will be deleted.
Data is held on multiple servers within the United Kingdom. Smart Numbers Ltd does not store personal data outside the EEA.
Although Smart Numbers Ltd does not store personal data outside of the EEA, in certain circumstances we may need to transfer personal data outside of the EEA in order to provide our services (e.g. when processing transactions for international numbers). In such cases, Smart Numbers Ltd is committed to ensuring that third party data processors, who may themselves store personal data outside of the EEA, adhere to the highest possible level of data privacy, and, wherever practically possible, will endeavour to impose legally binding obligations on said third parties. This may include, but is not limited to, relying on EU adequacy decisions and/or PCI compliance regulations, and/or enforcing standard contractual provisions.
At any point whilst Smart Numbers Ltd is in possession of or processing your personal data, all data subjects have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Smart Numbers Ltd refuses your request under rights of access, we shall provide you with a reason, which you have the right to challenge legally. Smart Numbers Ltd can, at your request, confirm what information it holds about you and how it is processed.
Identity and the contact details of the person or organisation (Smart Numbers Ltd) that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of Smart Numbers Ltd or a third party such as one of its clients, information about those interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to. How long the data will be stored.
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (ICO).
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it was not collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access details of what personal data is held, identification will be required. Smart Numbers Ltd will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence; passport; birth certificate; and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Smart Numbers Ltd is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to firstname.lastname@example.org or by phoning +44 (0) 345 017 8179 or by writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by Smart Numbers Ltd or its partners, you have the right to complain to Smart Numbers Ltd directors. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Smart Numbers Ltd Limited, attention of the Operations Director
26-27 Shamrock Way, Hythe Marina Village, Hythe, Southampton SO45 6DY
Telephone +44 (0) 345 017 8179 or email email@example.com
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