SMOOTHMEDIA CONSULTING LIMITED
OPEN LINK http://smoothmedia.com/
Smoothmedia Consulting Limited (“Company”, “we” or “us” “our”) respects your privacy and is committed to protecting your personal data (Your Data). This policy will inform you as to how we look after Your Data when you visit our website http://smoothmedia.com (regardless of where you visit it from) and your privacy rights and how the law protects you. Please note that this policy is specific to Your Data sent by you to our website and does not apply more generally to any personal data provided to us by other means.
You can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this policy.
- IMPORTANT INFORMATION ABOUT WHO WE ARE
This policy aims to give you information on how we collect and process Your Data through your use of this website, including any data you may provide through this website when you submit an enquiry to us.
This website is not intended for children and we do not knowingly collect data relating to children.
The Company is the controller and responsible for this website. We have appointed a data protection leader (DPL) who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise Your Legal Rights, please contact the DPL using the details set out below:
Full name of legal entity:
Smoothmedia Consulting Limited
Name or title of DPL:
41 Great Portland Street, London, W1W 7LA
+44 (0) 7968 755 450
If you have any queries, concerns or complaints about the use of Your Data by us, please raise them with the DPL. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated in May 2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if Your Data changes during your relationship with us.
Third party links
- THE DATA WE COLLECT ABOUT YOU
Personal data or personal information, means any information about an individual from which that person can be identified which includes not only individuals in their personal or private capacity but also directors and owners of bodies corporate. It does not include data where a person’s identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Recruitment Data includes data about you in your CV and covering letter.
- Contact Data includes billing address, home address, email address and telephone numbers.
We do not collect any special categories of data (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 for example; finger prints including information about criminal convictions and offences) or aggregated data such as statistical or demographic data though our website.
- IF YOU FAIL TO PROVIDE DATA
If you choose not to send Your Data through the website, you will need to contact us by other means as we will not be able to identify who you are through any website interaction.
- HOW IS YOUR DATA COLLECTED?
We use different methods to collect data from and about you through direct interactions. You may give us your Identity and Contact Data by filling in forms, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you subscribe to our services or apply for a job with us.
- HOW WE USE YOUR DATA
We will only use Your Data when the law allows us to. Most commonly, we will use Your Data in the following circumstances:
- To perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
See “Purposes for which we use Your Data” below to find out more about the types of lawful basis that we will rely on to process your personal data.
- PURPOSES FOR WHICH WE WILL USE YOUR DATA
We have set out below a description of all the ways we wish to use Your Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please contact firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process Your Data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing
To register you as a new client
Performance of a Contract with you
For recruitment purposes
(a) Performance of a Contract with you
(b) Necessary to comply with a legal obligation
(c) necessary and in our legitimate interests
To administer and protect our business and this website where you submit an online enquiry email
(a) Performance of a Contract with you
(b) Necessary to comply with a legal obligation
- CHANGE OF PURPOSE
We will only use Your 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email email@example.com. Should we need to use Your Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process Your Data without your knowledge or Consent, in compliance with the above rules, where this is required or permitted by law.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout
- DISCLOSURES OF YOUR DATA
We may have to share Your Data with the parties set out below for the purposes set out in the table in “Purposes for which we will use your data” above.
- Information sent using the contact emails on the “Contact Us” page are received by staff of the Company.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use Your Data in the same way as set out in this policy.
We require all third parties to respect the security of Your Data and to treat it in accordance with the law. We do not allow our third-party service providers to use Your Data for their own purposes and only permit them to process Your Data for specified purposes and in accordance with our instructions.
10. INTERNATIONAL TRANSFERS
In addition to the disclosures set out in “Disclosures of Your Data” above, some of service providers are based outside the EEA so their processing of Your Data will involve a transfer of data outside the EEA.
Whenever we transfer Your Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer Your Data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield Framework which requires them to provide similar protection to personal data shared between the Europe and the US.
Please email firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring Your Data out of the EEA.
11. DATA SECURITY
We have put in place appropriate security measures to prevent Your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to Your Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your Data on our instructions and they are subject to a duty of confidentiality.
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.
12. DATA RETENTION
We will only retain Your Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Your Data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your Data, the purposes for which we process Your Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Your data will only be retained as long as necessary for the provision of our Services, being 6 years from the provision of our Services. You may. You may request access, erasure and rectification of your data during this period, after which we will securely destroy your data in accordance with applicable laws and regulations.
Where we collect Your Data via the website (where you do not become our client), we will keep Your Data for a period of 6 months. We will take all reasonable steps to destroy or erase Your Data after this period.
13. YOUR LEGAL RIGHTS
In certain circumstances, you have the following rights under data protection laws in relation to Your Data. You have the right to:
Request access to Your Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Your Data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of Your Data. This enables you to ask us to delete or remove Your Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove Your Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase Your Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of Your Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing Your Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of Your Data. This enables you to ask us to suspend the processing of Your Data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it; or
- you have objected to our use of Your Data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of Your Data to you or to a third party. We will provide to you, or a third party you have chosen, Your Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process Your Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please email email@example.com or telephone +44 (0) 7968755450 and ask to speak to the DPL.
14. NO FEE USUALLY REQUIRED
You will not have to pay a fee to access Your Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
15. WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access Your 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.
16. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest: means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process Your Data for our legitimate interests. We do not use Your Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by emailing firstname.lastname@example.org.
Performance of Contract: means processing Your Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation: means processing Your Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent: means processing Your Data where you have given us clear consent to do so for a specific purpose.