SMARTER PRIVACY NOTICE
Smartco Ltd, trading as Smarter (“Smarter”) holds some information about you. Below we outline how that information is used, who we may share that information with and how we keep it secure. This notice does not provide exhaustive detail. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to Smarter. We keep our Privacy Notice under regular review. This Privacy Notice was last reviewed in May 2021.
1. What We Do
Smarter provides online booking of residential properties to individuals and companies.
2. How We Obtain Your Personal Data
You provide us with personal data in the following ways:
• By completing forms on our website, www.book-smarter.com. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask you for information when you enter a competition or promotion sponsored by Smarter, and when you report a problem with our site.
• By signing or otherwise agreeing to our terms of business;
• If you contact us, either via email, phone or letter; we may keep a record of that correspondence and personal data provided via such communications.
• If you complete surveys that we circulate for research purposes.
• By carrying out transactions through our website and through the fulfilment of your orders.
• By visiting our site, www.book-smarter.com, you provide us with information including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• As you access our site, we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
• By paying for transactions online.
The above may include the following information:
- basic details such as name, address, contact details
- dates of travel and purpose of your visit to London
- debit and credit card information
- details of contact we have had with you
We use this information in order to provide you with our services. This means that the legal basis of our holding your personal data is for legitimate interest.
Following completion of your course we retain your personal data for five years. This enables us to process any complaint you may make. In this case the legal basis of our holding your personal data is for contract administration.
Information we get from other sources
We may obtain information in the form of correspondence from other service providers. We use this information in order to provide you with our services. This means that the legal basis of our holding your personal data is for legitimate interest.
3. How we use your personal data
We act as a data controller for use of your personal data to provide you with our services. We also act as a controller and processor in regard to the processing of your data from third parties such as other goods and services providers. We act as a data controller and processor in regard to the processing of credit card and online payments.
We undertake at all times to protect your personal data, including any health and contact details, in a manner which is consistent with our duty of professional confidence and the requirements of the General Data Protection Regulation (GDPR) concerning data protection. We will also take reasonable security measures to protect your personal data storage.
We may use your personal data where there is an overriding public interest in using the information e.g. in order to safeguard an individual, or to prevent a serious crime. Also where there is a legal requirement such as a formal court order. We may use your data for marketing purposes such as newsletters but this would be subject to you giving us your express consent.
4. Do you share my information with other organisations?
We will keep information about you confidential. We will only disclose your information with other third parties with your express consent with the exception of the following categories of third parties:
- Any employees
- Our partnered host managers who service bookings, answer enquiries and manage the properties listed on our site
- Any contractors and/or advisors that provide a service to us or act as our agents on the understanding that they keep the information confidential
- Any goods and services providers who we need to liaise with in order to fulfil your booking request with us.
- Anyone to whom we may transfer our rights and duties under any agreement we have with you
- Any legal or crime prevention agencies and/or to satisfy any regulatory request if we have a duty to do so or if the law allows us to do so
We may share your information with a limited number of third parties as part of providing you with our services.
5. What are your rights?
Every individual has the right to see, amend, delete or have a copy, of data held that can identify you, with some exceptions. You do not need to give a reason to see your data. If you want to access your data you must make a subject access request in writing via the contact form on our site. Under special circumstances, some information may be withheld. We shall respond within 20 working days from the point of receiving the request and all necessary information from you. Our response will include the details of the personal data we hold on you including:
- Sources from which we acquired the information
- The purposes of processing the information
- Persons or entities with whom we are sharing the information
You have the right, subject to exemptions, to ask to:
• Have your information deleted
• Have your information corrected or updated where it is no longer accurate
• Ask us to stop processing information about you where we are not required to do so by law or regulation.
• Receive a copy of your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller, without hindrance from us.
• Object at any time to the processing of personal data concerning you
If you would like to invoke any of the above rights then please write to the Data Controller at Smarter via the contact form on our site.
6. What safeguards are in place to ensure data that identifies me is secure?
We only use information that may identify you in accordance with GDPR. This requires us to process personal data only if there is a legitimate basis for doing so and that any processing must be fair and lawful.
We also ensure the information we hold is kept in secure locations, restrict access to information to authorised personnel only, protect personal and confidential information held on equipment such as laptops with encryption (which masks data so that unauthorised users cannot see or make sense of it).
We ensure external data processors that support us are legally and contractually bound to operate and prove security arrangements are in place where data that could or does identify a person are processed.
7. How long do you hold confidential information for?
All records held by the Smarter will be kept for five years.
8. Website technical details
We do use electronic forms on our website making use of an available ‘forms module’ which has a number of built-in features to help ensure privacy. We also aim to use secure forms where appropriate.
In compliance with EU legislation, this document lists the cookies used on this website.
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
If you have a complaint regarding the use of your personal data then please contact us by writing to the Data Controller at Smarter and we will do our best to help you.