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Smart Start® UK and EU Privacy Policy

Smart Start, LLC values you as a customer and respects your right to privacy. We know that you purchase our products and services because you trust that we will stand behind our promises. We pledge our commitment to treat your information responsibly. We created this Privacy Policy to show you that we are working hard to protect your privacy.

1A Smart Start, LLC and our affiliates (together, “our”, “us”, “we” or “Smart Start”) value you as a customer and respect your right to privacy. We know that you purchase our products and services because you trust that we will stand behind our promises.

Smart Start is the operator of the website available at https://www.smartstartinc.com (the “Website”). In the UK and EU countries, we provide data processing services to authorities responsible for monitoring users of our products (“Monitoring Authorities”) and hosted services for our distributors (the “Service”).

This Privacy Policy informs you of how we collect, use and disclose your personal data as a controller, including:

  • when you use the Website;
  • when you interact with us as a business representative of Monitoring Authorities, distributors, vendors or business partners;
  • when you opt to receive communications from us;
  • when we participate in conferences, seminars and other events; and
  • through other data collection points where we refer to this Privacy Policy.

Please read this Privacy Policy carefully. This Privacy Policy does not apply to any processing of personal data by or on behalf of Smart Start that is covered by a more specific privacy notice.

For the purposes of applicable UK and EU data protection laws (the “UK and EU Privacy Laws”), including Regulation (EU) 2016/679 (the “EU GDPR”), the UK equivalent of the EU GDPR (the “UK GDPR”) and the Data Protection Act 2018, 1A Smart Start LLC will be a controller of any personal data collected by us when you interact with us in the ways described above (i.e., when you use the Website, interact with us as a business representative, when you opt to receive communications from us, etc.). This Privacy Policy only applies where Smart Start acts as a controller of your personal data, and does not apply where we act as a processor which includes when we provide the Service. If you have any questions regarding our use of your personal data, or this Privacy Policy, please contact Toby Taylor, Vice President Regulatory Compliance, Smart Start, LLC, 500 East Dallas Rd, Grapevine, TX 76051 USA.

We rely on various legal bases under the UK and EU Privacy Laws in order to process your personal data (including basic contact and identifying information and IP addresses), including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business, conduct business with you and perform essential or legitimate business operations.

We do not collect special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.

Further information about the legal bases under which we process your personal data is included in the section headed “Why we use your personal data”.

You do not need to take any action as a result of this Privacy Policy, but you do have certain rights as described below in the section headed “Your rights”.

How We Collect Your Personal Data

We may collect your personal data in the ways set out in this section “How we collect your personal data”. We only collect the personal data necessary to carry out our business for the purposes set out in the next section headed “Why we use your personal data”.

Information you provide to us

We may ask you to provide us with certain personal data that can be used to contact or identify you.

We collect your personal data when you interact with us, including through the forms that you submit to us through the survey process and other transactions you may initiate through this Website or through mobile app, phone calls, e-mail and in-person verbal communication. Personal data may include, but is not limited to, your email address, name, phone number, postal address, date of birth and driving licence information.

We may also collect personal data about you that your browser sends through automated technologies whenever you visit our Website (the “Log Data”). This Log Data may include information such as your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics. Please see the section headed Cookies below for information about how we use such technologies.

Information provided by third parties or publicly available sources

We collect personal data from third parties, such as the name and contact information of attendees at conferences, seminars and other events in which Smart Start participates or intends to participate as a sponsor, exhibitor and/or who reflect or include a target audience or stakeholder in relation to any Smart Start product or Service.

If you represent one of our vendors, distributors or business partners, we may also collect your personal data (i.e., basic identifying and contact information, including your name, title, work email address, work postal address, job title and/or work telephone number, as appropriate) from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.

In some instances, we may provide software hosting services to independent distributors who may themselves collect personal data directly from individuals in the EEA or in the UK. Please see the section headed “Disclosure and transfer of personal data” below.

Why We Use Your Personal Data

We may use your personal data for the following purposes:

Purpose Legal Basis
To conduct business with you and to provide you with the Service Contractual necessity; and/or our legitimate interest in operating our business and providing the Service
For compliance monitoring and reporting purposes in cases where the use of our products is tied to a program administered by a Monitoring Authority Contractual necessity; and/or legal requirement in operating our business and providing the Service
To keep a record of your relationship with us Our legitimate interest in operating our business and providing the Service; and/or legal requirement
To protect against, identify and prevent, fraud, money-laundering, cyber attacks, theft of our property and other unlawful activity Legal requirement; and/or our legitimate interest in operating our business and providing the Service securely
To obtain advice from our professional advisors, including lawyers and accountants Our legitimate interest in operating our business
To administer and protect our business and this Website Our legitimate interest in operating our business
To make suggestions and recommendations to you, or to provide you with updates or other information, about our business and services that may be of interest to you Our legitimate interest in operating our business
For statistical analysis and market research Our legitimate interest in operating our business

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.

No solely automated decision-making, including profiling, is used when processing your personal data.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Sharing of Personal Data – Onward Transfers

Your personal data will be shared with and processed by our affiliates, our distributors and certain service providers as necessary to fulfil the purposes set out in this Privacy Policy. We do not transfer personal data subject to the UK and EU Privacy Laws to third parties other than our affiliates, distributors and certain service providers.

All distributors and affiliates enter into a contract with us which requires them to safeguard personal data consistent with this Privacy Policy and the UK and EU Privacy Laws. In the event that we become aware that a distributor, service provider or affiliate is using or disclosing personal data in a manner contrary to the UK and EU Privacy Laws, we will take reasonable steps to prevent or stop the use or disclosure.

Personal data, including monitoring data and other related information, will be shared with relevant Monitoring Authorities where required by contract or law in connection with the Service. Additionally, monitoring data may be shared with other third parties if permission has been given for such an arrangement.

We may engage third party companies to facilitate the provision of our Website, to provide the Website on our behalf, to perform Website-related services, to provide general business services and/or to assist us in analyzing how our Website is used, including IT and data security providers and data hosting providers. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. These third parties have access to your personal data only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.

We reserve the right to disclose your personal data where required to do so by law if we believe that such action is necessary to comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us, and/or to protect our rights, including rights to the security or integrity of our business and Website.

Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.

We may also disclose your personal data to research, actuarial, or other organizations for the purposes of conducting studies.

International Transfers

Your personal data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction, in order to fulfil the purposes described in this Privacy Policy and in accordance with applicable law, including where such transfer is a matter of contractual necessity to provide and administer the Website or operate our business.

To the extent your personal data is transferred to countries outside of the UK or the European Economic Area, such transfers will only be made in accordance with the UK and EU Privacy Laws. For further information about the safeguards used, please contact Toby Taylor, Vice President Regulatory Compliance, 500 E. Dallas Rd, Suite 100, Grapevine, TX 76051 USA (toby.taylor@smartstartinc.com; Tel +1 972 621 0252).

Cookies

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and transferred to your device. We use cookies to collect information to improve our services for you and for our business purposes.

Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this site, we will ask you to consent to their use.  The help feature on most browsers provides information on how to accept cookies, disable or refuse cookies or to notify you when receiving a new cookie.  You may also wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences. If you opt-out of certain cookies, you may not be able to use some features of our Website or Service.

On the Website, we use the following categories of cookies, for the following purposes:

Essential/Strictly Necessary: These cookies are strictly necessary for us to operate core functions of our Website and for you to browse our Website and use its features. We do not require your consent to use these cookies, and they are enabled by default. You may be able to block or delete these cookies yourself through your browser/device settings. However, blocking or deleting these cookies may have an impact on how our Website functions.

Preference/Functionality: These cookies allow our Website to remember choices you have made on past visits. We need your consent to set these cookies, and if you reject these cookies we will not collect this data. The functionality and appearance of our Website may be affected if you choose to reject these cookies.

Analytics/Performance/Statistics: These cookies collect information about how you use our Website (e.g., pages you have visited and links you have clicked on). These cookies are used by us for statistical analysis to help us to improve our Website. We need your consent to set these cookies, and if you reject these cookies we will not collect this data. The functionality and appearance of our Website to you will not be affected if you choose to reject these cookies, though the overall performance of our Website for all users may be affected.

Marketing: These cookies track your online activity to help advertisers deliver more relevant advertising and can share that information with other organizations or advertisers. We need your consent to set these cookies, and if you reject these cookies we will not collect this data. The performance of our Website will not be affected if you choose to reject these cookies.

Third Parties: We use third party technologies on our Website to improve functionality and user experience, such as Google Webfonts, Google Maps, Vimeo and YouTube. As an example, we use such technologies to enable you to watch videos on our Website. The providers of these technologies may deploy cookies to your browser when you visit the pages on our Website where we are using their technologies. We do not set these cookies and such cookies are subject to the third party providers’ own cookie policies.

Security and Retention

The security of your personal data is important to us. Unfortunately, no method of transmission over the Internet or method of electronic storage is completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our Website; any transmission of information or data by you to or through this Website is at your sole risk. Please note that e-mail communications sent over the Internet may be subject to viewing, alteration or copying by other parties. We are not responsible for the security of communications sent to us via the Internet and e-mail.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact Toby Taylor, Vice President Regulatory Compliance, 500 E. Dallas Rd, Suite 100, Grapevine, TX 76051 USA (toby.taylor@smartstartinc.com; Tel +1 972 621 0252).

Links to Other Sites

Our Website may contain links to other third-party websites, plug-ins and applications that are not operated by us. If you click on a third-party link, you will be directed to that third-party’s website and it may enable third parties to collect or share data about you. We strongly advise you to review the privacy policy of every website you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party websites or services.

Your Rights and Updating Your Preferences

You have the right to reasonable access to your personal data that we hold about you, as well as such other related rights as are provided by the UK and EU Privacy Laws.  There are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact Toby Taylor, Vice President Regulatory Compliance, 500 E. Dallas Rd, Suite 100, Grapevine, TX 76051 USA (toby.taylor@smartstartinc.com).

Access: You have the right to ask for a copy of the personal data that we hold and process about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested. Additionally, in accordance with the UK and EU Privacy Laws, we may limit or deny access to your personal data where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the legitimate rights of persons other than you would be violated. We reserve the right to take reasonable steps to authenticate the identity of any individual seeking access to personal data.

Correction: We take reasonable steps to make sure that the personal data that we collect, use, and disclose is accurate, complete, and up-to-date, but you may also contact us if the personal data that we hold and process about you is inaccurate or needs to be updated. We may provide web pages or other mechanisms on our Website through which you can correct or update your personal data, or elect to change your preferences regarding our future use or sharing of your personal data with third parties for marketing purposes. You can also contact us to update your personal or change your preferences via phone or by email via Toby Taylor, Vice President Regulatory Compliance, 500 E. Dallas Rd, Suite 100, Grapevine, TX 76051 USA (toby.taylor@smartstartinc.com; Tel +1 972 621 0252).

Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your personal data to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal data override your own rights.

Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.

If you receive a marketing communication from us by email, you may opt-out of receiving future email marketing communications by following the opt-out instructions provided in that e-mail. Please note that we reserve the right to send you certain communications relating to transactions you initiate, your customer account, your use of our Website, or other business matters, to the extent permitted under UK and EU Privacy Laws, and these communications may be unaffected if you choose to opt-out from marketing communications.

Portability: If you wish to transfer the personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Marketing Communications

We will only send you marketing newsletters, updates, alerts and similar marketing or promotional communications where you have requested information from us relating to our business or services which you might be interested in. If you receive a marketing communication from us by e-mail, you may opt out of receiving future e-mail marketing communications by following the opt-out instructions provided in that e-mail. Please see the section headed Your rights and updating your preferences above.

Children’s Privacy

Only persons aged 18 or older have permission to access our Service. Neither this Website nor our Service is intended for or addresses anyone under the age of 18 and we do not knowingly encourage or solicit visitors to this Website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and you learn that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a child under age 18 without verification of parental consent, we take steps to remove that information from our servers.

Contact Information

Questions or comments regarding this Privacy Policy should be submitted to us at:

1A Smart Start, LLC
500 E. Dallas Rd, Suite 100
Grapevine, TX  76051
USA

Attention: Toby Tayler, Vice President Regulatory Compliance
Email: toby.taylor@smartstartinc.com
Tel: 1-972-291-0252

Should you wish to lodge a complaint with regards to how your personal data has been processed by us under:

  1. the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us,
  2. the EU GDPR, please contact your local supervisory authority in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.

Notice of Changes or Revisions

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically.

If we make any material changes to this Privacy Policy, we will notify you either through the e-mail address you have provided us or by placing a prominent notice on our Website.

UK and EU Privacy Policy for www.smartstartinc.com

Updated on: 8 July 2022