Smart Comms Privacy Notice

Introduction

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. SmartComms® is pleased to provide the following GDPR information:

Who we are

SmartComms® (hereafter referenced as SmartComms® or Smart Numbers, Smart VoIP, Smart Websites ) is a UK-based telecommunications reseller and media agency principally involved in the B2B sector.

Personal data

SmartComms® uses the information collected from you to provide services and marketing information that SmartComms® believes may be of interest to you and your business. In having made your initial contact with SmartComms®, we will maintain a marketing dialogue with you on the basis of legitimate interests until either you opt out (which you can do at any stage) or we decide to discontinue promoting our services. SmartComms® also sometimes acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, SmartComms® will be acting on the instruction of its client and will aim to ensure that the client is fully UK 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. SmartComms® may from time to time use such information to identify its visitors. SmartComms® 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 SmartComms® 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. SmartComms® will only collect the information needed so that it can provide you with its services. SmartComms® does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that SmartComms® has purchased from a third-party UK list broker, on behalf of a client. SmartComms® uses a number of different legal options to process:

• Legitimate Interests to respond to sales enquiries and to promote the services provided.
• Processing is necessary for the performance of a contract or service.
• Processing is necessary for compliance with a legal obligation.
• Consent but only where there is no other legal option for data processing.

If you have any concerns about the processing of your personal data you can contact us by emailing privacy@smart-numbers.net; by phoning +44 (0) 3450178179; or by writing to us. See the last section for full contact details.

Disclosure

SmartComms® may, on occasion, pass your Personal Information to third parties exclusively to process work on its behalf. SmartComms® requires these parties to agree to process this information based on our documented instructions and requirements consistent with this Privacy Notice and UK GDPR. For legal obligations, SmartComms® may be required to disclose your Personal Information to regulators, Government and statutory bodies. SmartComms® 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 SmartComms®, its clients and/or the wider community.

Retention policy

SmartComms® 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. For more details please ask for a copy of our Data Retention Schedule.

Phone recording

Telephone calls are recorded for staff training and security purposes. Any personal data collected will be retained for 30 days and then deleted, unless we need to retain it longer for contractual and/or legal purposes.

Data Storage and Transfers

Personal data is mostly held on multiple servers within the United Kingdom. Where SmartComms® is required to hold personal data outside the EEA, such as processing transactions for international numbers, we will rely on adequacy decisions and/or PCI compliance regulations. In the event of any compliance concerns, we will put in place appropriate safeguards such as IDTAs or SCCs before transferring any personal data.

Your rights as a data subject

At any point, whilst SmartComms® 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 SmartComms® refuses your request under rights of access, we shall provide you with a reason, which you have the right to challenge legally. SmartComms® can, at your request, confirm what information it holds about you and how it is processed.

You can request the following information:

• Identity and the contact details of the person or organisation (SmartComms®) 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 SmartComms® 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. SmartComms® 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 SmartComms® is dissatisfied with the quality, further information may be sought before personal data can be released. All requests should be made to privacy@smart-numbers.net or by phoning +44 (0) 345 0178 179 or by writing to us at the address further below.

Cookies

Our cookie policy: https://www.smart-numbers.net/terms/cookies

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by SmartComms® or its partners, you have the right to complain to SmartComms®. If you do not get a response within 30 days, you can complain to the ICO. The details for each of these contacts are: SmartComms® Limited, attention of the Head of Customer Success, 1-2 The Exchange Beaulieu Road, Southampton SO45 4PX. Telephone +44 (0) 345 0178 179 or email: privacy@smart-numbers.net The ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/