- Introduction
- We are committed to safeguarding the privacy of our website visitors
and customers; in this policy we explain how we will handle your
personal data.
- By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
- How we use your personal data
- In this Section 2 we have set out:
- (a) The general categories of personal data that we may process;
- (b) The purposes for which we may process personal data; and
- (c) The legal bases of the processing.
- We may process [data about your use of our website and services] (“usage data“).
The usage data may include your IP address, geographical location,
browser type and version, operating system, referral source, length of
visit, page views and website navigation paths, as well as information
about the timing, frequency and pattern of your service use. The source
of the usage data is our analytics tracking system. This usage data may
be processed [for the purposes of analysing the use of the website and
services]. The legal basis for this processing is [consent] OR [our
legitimate interests], namely [monitoring and improving our website and
services].
- We may process your account data (“account data“).
The account data may include your name and email address. The source of
the account data is you or your employer. The account data may be
processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The legal basis
for this processing is consent or is necessary for a contract we have
with you, or because they have asked you to take specific steps before
entering into a contract.
- We may process information that you post for publication on our website or through our services (“publication data“).
The publication data may be processed for the purposes of enabling such
publication and administering our website and services. The legal basis
for this processing is consent or is necessary for a contract we have
with you, or because they have asked you to take specific steps before
entering into a contract.
- We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“).
The enquiry data may be processed for the purposes of offering,
marketing and selling relevant goods and/or services to you. The legal
basis for this processing is consent or is necessary for a contract we
have with you, or because they have asked you to take specific steps
before entering into a contract
- We may process information relating to transactions, including
purchases of goods and services that you enter into with us and/or
through our website (“transaction data“). The
transaction data may include your contact details, and the transaction
details. The transaction data may be processed for the purpose of
supplying the purchased goods and services and keeping proper records of
those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at
your request, to enter into such a contract and our legitimate
interests, namely our interest in the proper administration of our
website and business.
- We may process information that you provide to us for the purpose of
subscribing to our email notifications and/or newsletters (“notification data“).
The notification data may be processed for the purposes of sending you
the relevant notifications and/or newsletters. The legal basis for this
processing is consent or is necessary for a contract we have with you,
or because they have asked you to take specific steps before entering
into a contract.
- We may process information contained in or relating to any communication that you send to us (“correspondence data“).
The correspondence data may include the communication content and
metadata associated with the communication. Our website will generate
the metadata associated with communications made using the website
contact forms. The correspondence data may be processed for the purposes
of communicating with you and record-keeping. The legal basis for this
processing is our legitimate interests, namely the proper administration
of our website and business and communications with users.
- We may process any of your personal data identified in this policy
where necessary for the establishment, exercise or defence of legal
claims, whether in court proceedings or in an administrative or
out-of-court procedure. The legal basis for this processing is our
legitimate interests, namely the protection and assertion of our legal
rights, your legal rights and the legal rights of others.
- We may process any of your personal data identified in this policy
where necessary for obtaining professional advice. The legal basis for
this processing is our legitimate interests, namely the proper
protection of our business against risks.
- In addition to the specific purposes for which we may process your
personal data set out in this Section 2, we may also process [any of
your personal data] where such processing is necessary[ for compliance
with a legal obligation to which we are subject, or] in order to protect
your vital interests or the vital interests of another natural person.
- Providing your personal data to others
- We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding company and
all its subsidiaries) insofar as reasonably necessary for the purposes,
and on the legal bases, set out in this policy.
- We may disclose your personal data to our insurers and/or
professional advisers insofar as reasonably necessary for the purposes
of obtaining or maintaining insurance coverage, managing risks,
obtaining professional advice, or the establishment, exercise or defence
of legal claims, whether in court proceedings or in an administrative
or out-of-court procedure.
- We may disclose your persona data to our subcontractors insofar as reasonably necessary for the supply and goods/services requested by you.
- Financial transactions relating to www.iotsmartsolutions.com
are handled by our payment services providers, PayPal. We will share
transaction data with our payment services providers only to the extent
necessary for the purposes of processing your payments, refunding such
payments and dealing with complaints and queries relating to such
payments and refunds. You can find information about the payment
services providers’ privacy policies and practices at https://www.paypal.co.uk
- In addition to the specific disclosures of personal data set out in
this Section 3, we may disclose your personal data where such disclosure
is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the vital
interests of another natural person. We may also disclose your personal
data where such disclosure is necessary for the establishment, exercise
or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.
- Retaining and deleting personal data. Data Retention Policy Information: This
Section 4 sets out our data retention policies and procedure. Under ICO
guidelines, we only hold personal data for the following purposes and
retention periods:
- Necessary for Performance of Contract: 12 months
after the ceasing of our contract with the customer. For the personal
data of existing customers, held under the purpose of “Necessary for
Performance of Contract”, we hold the personal data of necessary
customer contacts for the lifespan of their products or service
contracts, plus an additional 12 months thereafter to ensure we are able
to contact any customer in the unlikely event of an emergency, such as a
product recall.
- Consent: 12 months after the ceasing of contract
with the customer OR 12 months after the last engagement with IoT Smart Solutions.
For the personal data of those who have given us consent to contact
them, held under the purpose of “Consent”, we hold personal data for 12
months after the person’s last engagement with IoT Smart Solutions or, should they
become a IoT Smart Solutions customer, for 12 months after the ceasing of our
customer contract, as stated above.
- Legitimate Interests: 12 months after last
engagement IoT Smart Solutions OR after six unanswered communications. For the
personal data of those we contact due to a legitimate interest in our
products and services, held under the purpose of “Legitimate Interests”,
we hold personal data for 12 months after the person’s last engagement
with IoT Smart Solutions, or following the person’s failure to engage with six
consecutive marketing communications – whichever is sooner.
- Anonymised Data: Indefinitely. For statistical
purposes, and to assist us in improving our products and services, we
hold customer review and feedback review indefinitely in an anonymised
form.
- Notwithstanding the other provisions of this Section 4, we may
retain your personal data where such retention is necessary for
compliance with a legal obligation to which we are subject, or in order
to protect your vital interests or the vital interests of another
natural person.
- We review this data every 12 months. Should you wish us to remove
any of your personal data held under these purposes, you have the right
to make requests regarding your data under the Data Rights of
Individuals. This policy does not apply to data exempt from GDPR, such
as publicly available information.
- Amendments
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- We may notify you of changes to this policy by email
- Your rights. IoT Smart Solutions Policy in Terms of Data Rights of Individuals: Under the GDPR, you have the stated rights regarding your personal data held by IoT Smart Solutions – as stated by the ICO: ICO Guide to Individual Data Rights. IoT Smart Solutions is committed to protecting your privacy, the
security of your data, and your right to access, amend or delete the
personal information held by us. Our commitment to your privacy, the
security of your personal information, and your right to access, change
or remove your personal information, extends fully to any data shared
with us by our clients in our role as an external vendor. If you have
any data requests, or queries about the data held by IoT Smart Solutions, please
contact our Data Protection Officer.
Under your individual data rights, we will provide your personal data
free of charge, in a structured, commonly used and machine-readable
format, such as CSV or XML files, within 1 month of your request. We
reserve the right to extend this period for a further 2 months if your
request(s) are complex or numerous. We will make every effort to ensure
all data is delivered securely.
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
- Third party websites
- Our website includes hyperlinks to, and details of, third party websites.
- We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Personal data of children
- Our website and services are targeted at persons over the age of 18.
- If we have reason to believe that we hold personal data of a person
under that age in our databases, we will delete that personal data.
- About cookies
- A cookie is a file containing an identifier (a string of letters and
numbers) that is sent by a web server to a web browser and is stored by
the browser. The identifier is then sent back to the server each time
the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid
until its set expiry date, unless deleted by the user before the expiry
date; a session cookie, on the other hand, will expire at the end of the
user session, when the web browser is closed.
- Cookies do not typically contain any information that personally
identifies a user, but personal information that we store about you may
be linked to the information stored in and obtained from cookies.
- We use cookies for the following purposes:
- authentication – we use cookies to identify you when you visit our website and as you navigate our website
- status – we use cookies to help us to determine if you are logged into our website
- shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website
- personalisation – we use cookies to store information about your preferences and to personalise our website for you
- security – we use cookies as an element of the security measures
used to protect user accounts, including preventing fraudulent use of
login credentials, and to protect our website and services generally
- analysis – we use cookies to help us to analyse the use and performance of our website and services
- advertising and re-marketing – we use these cookies for the purposes
of re-marketing our own services. We do not use these cookies to
collect information to sell to third parties
- Cookies used by our service providers
- Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
- We use Google Analytics to analyse the use of our website. Google
Analytics gathers information about website use by means of cookies. The
information gathered relating to our website is used to create reports
about the use of our website. Google’s privacy policy is available at:
https://www.google.com/policies/privacy
- Managing cookies
- Most browsers allow you to refuse to accept cookies and to delete
cookies. The methods for doing so vary from browser to browser, and from
version to version. You can however obtain up-to-date information about
blocking and deleting cookies via these links:
- (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- (e) https://support.apple.com/kb/PH21411 (Safari);
- (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
- Our details
- This website is owned and operated by IoT Smart Solutions.
- Our principal place of business is at Unit 8 Framlingham, Woodbridge, Suffolk, IP13 9HS
- You can contact us:
- (a) by post, to the postal address given above;
- (b) using our website contact form;
- (c) by telephone, on the contact number published on our website from time to time:
- (d) by email, using the email address published on our website from time to time.