Privacy Policy

1.1 Our core principles regarding user privacy and data protection

We operate our data protection in compliance with BS 10012:217: Specification for a personal information management system.

User privacy and data protection are inviolable human rights;
We have a duty of care to people contained within our database;
Data is a liability: it should only be collected and processed when absolutely necessary;
We despise spam in all its forms;
We will never sell, rent or otherwise distribute or make public any personal information.

1.2 Relevant legislation

Alongside our business and internal computer systems, this A Smarter Way to do Business website is designed to comply with the following national and international legislation with regards to data protection and user privacy:

EU General Data Protection Regulation 2018 (GDPR);

The Privacy and Electronic Communications Regulations 2003 (PECR).

This site’s compliance with the above legislation, all elements of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 10.0 below) for clarification.

2.0 Personal information that this website collects and why we collect it

A Smarter Way to do Business relies upon ‘consent’ as its lawful basis for the processing of personal data.

This website collects and uses personal information for the following reasons:

2.1 Site visitation tracking

Like most websites, this site uses Google Analytics (GA) to track user interaction.

We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to track their journey through the website.

Although GA records data such as your approximate geographical location, device, internet browser and operating system, none of this information personally identifies you to us.

GA also records your computer’s IP address which could be used to personally identify you, but Google do not grant us access to this.

We consider Google to be a third-party data processor (see section 6.0 below).

GA makes use of cookies, details of which can be found on Google’s developer guides.

For your information our website uses the Wix implementation of GA.

Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

2.2 Our Blog and Forum Modules

Should you choose to add a comment to any posts that we have published on our Blog or Forum modules any personal details you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment.

This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third-party data processors detailed below.

Only your name will be shown on the public-facing website.

Your comment and its associated personal data will remain on this site until we see fit to either:

remove the comment; or,
remove the blog post.

Should you wish to have the comment and its associated personal data deleted, please email us here using the email address that you used to comment.

If you are under 16 years of age you MUST obtain parental consent before posting a comment on our Blog or Forum modules.

NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this or any other website.

2.3 Contact forms and email links

Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be stored by this website or passed to/be processed only by any of the third-party data processors defined in section 6.0 below.

Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.

2.4 Email newsletter

If you choose to join our regular newsletter mailings (which is sent via email), the email address that you submit to us will be stored in our Wix website platform in the 'Shout Out' database, which we use for our email marketing. We consider Wix to be a third-party data processor (see section 6.0 below). The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.

Your email address will remain within the Wix 'Shout Out' database on our website for as long as we continue to use the Wix platform for email marketing or until you specifically request removal from the list.

You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

While your email address remains within the Wix 'Shout Out' database, you will receive occasional newsletter-style emails from us.

2.5 Event subscription

If you subscribe to one of our events, either a physical meet-up or a webcast meeting, the email address that you submit to us will be stored in our Wix website platform in the 'Shout Out' database, which we use for our email marketing. We consider Wix to be a third-party data processor (see section 6.0 below). The email address that you submit will be stored within this website’s own database but not in any of our internal computer systems.

If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.

While your email address remains within the Wix 'Shout Out' database, you will receive occasional newsletter-style emails from us.

3.0 How we store your personal information

As detailed in sections 2.2 to 2.5 above, if you submit a comment to a Blog or Forum post published on this website or subscribe to an email newsletter or an event, some personal information will be stored within this website’s database.

These are the only occasions where personal data will be stored on this website. This data is currently stored in an identifiable fashion: a limitation of the content management system that this website is built on (Wix).

Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.

4.0 Data retention period

We retain data for as long as it is required to enable the service that you receive.

4.1 Blog and Forum comments

Any blog or forum comment and its associated personal data will remain on this site until we see fit to either:

remove the comment; or,
remove the blog post.

Should you wish to have the comment and its associated personal data deleted, please email us here using the email address that you used to comment.

4.2 Marketing

5.0 Your rights in respect of processing

5.1 Your right to rectification

If you believe that information that we hold about you is incorrect or incomplete you may contact our DPO regarding the matter. We may ask you to provide identification and to provide further details concerning your query to allow us to investigate the matter.

5.2 Your right to access (Subject Access Report)

If you wish to obtain details of all of your personal information that we hold you may do so by requesting a Subject Access Report. Please email our DPO who will provide you with the information. We may ask you to provide identification and to provide further details concerning your query to allow us to investigate the matter.

5.3 Your right to object to or restrict processing

If you wish to object to or restrict the processing of your personal information, please email our DPO regarding the matter. We may ask you to provide identification and to provide further details concerning your query to allow us to investigate the matter.

5.4 Your right to erasure

If you wish to permanently erase your personal information, please email our DPO regarding the matter. We may ask you to provide identification and to provide further details concerning your query to allow us to investigate the matter.

5.5 Your right to data portability

As at 25th November 2019 we hold limited amounts of your personal data. As we process your data under the lawful processing basis of ‘consent’ we are not required to provide data portability.

5.6 Rights in relation to automated decision making and profiling

We do not undertake any form of automated decision making or profiling.

5.7 Right to be informed if we plan to use your personal data for a new purpose

If we plan to use personal data for a new purpose, we will update our privacy information and communicate the changes to individuals before starting any new processing.

6.0 About this website’s server

This website is hosted in data centers in the United States and Europe. From time to time, we may transfer hosting from one location to another. Notwithstanding the above, the Wix.com platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles. Wix.com guarantees that the platform will be compliant with the new regulation from May 2018.

All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

7.0 Our third-party data processors

We use third parties to process personal data on our behalf. The third parties we use are Wix, Mail Chimp and Google Analytics.

We or Wix will never ask for any sensitive information;
Wix provide the Customer Engagement platform we use to manage your relationship with us. What Wix do to ensure data protection to all our customers;
Wix employ full-time security consultants, dedicated to the security of our customer information;
Wix's signup and login services are completed through a secure server (HTTPS/SSL);
Wix uses cryptography hash functions to protect your information. Your password is stored as a hash digest and, in the event of a security breach, your original password cannot be recovered from ours or Wix servers;
Wix is certified under the EU-US Privacy Shield Framework and the Swiss-US privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, and therefore adheres to the Privacy Shield Principles.

8.0 Data breaches

We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.

9.0 Data controller

The data controller of this website is:

Carlos Wanderley

And whose operating office is situated at:

45 Plover Road, Stanway, Colchester CO3 8AF

10.0 Data protection officer

Although we are not required to do so by law we take data protection and your rights very seriously and have appointed a data protection officer:

Stuart Harle, 45 Plover Road, Colchester CO3 8AF

Email: @smarterway.biz

11.00 Information Commissioners’ Office

In the event that you wish to make a complaint our supervisory authority is the UK Information Commissioners’ Office. The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

Please visit the ICO’s website for further information:

https://ico.org.uk/for-the-public/

12.0 Changes to our privacy policy

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes.

Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the change log below.

12.1 Change log

25th November 2019 Policy instigated.