Privacy Policy - SmartXPO

Privacy Policy

SmartXpo Solutions Limited (“SmartXpo”, “we” or “us”) of 62-65 Chandos Place, London, WC2N 4HG takes user privacy very seriously. This Privacy Policy sets out how we will use your personal information and who it may be shared with.

SmartXpo reserves the right to alter and update this Privacy Policy from time to time. We urge visitors to our site to review the current version of the Privacy Policy each time they return to our site. The date of the most recent update is stated at the bottom of this Privacy Policy.

 

What information do we collect about you and how do we collect it?

We may collect and process data about you (“your information”) when:

  • you submit information online via our site (https://www.smartxpo.com) or send us any correspondence; 
  • you request information from SmartXpo or ask us to contact you; 
  • you submit information to us in connection with an employment application; 
  • you fill out a subscription form or consulting expertise inquiry; and
  • you opt-in to receive emails from us, or you agree to participate in surveys. 

 

The information we collect may include: your name, e-mail address, title, occupation, company or university affiliation, industry, region, relationship to SmartXpo, reason for contacting SmartXpo and any message you submit to us.

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Lawful basis for Processing

The basis for SmartXpo processing your information is either our legitimate business interests balanced with your interests, rights and freedoms or your consent.

How will we use your information?

We may use your information in the following ways:

to ensure that our site’s content is presented as effectively as possible for you;
for our internal purposes, such as quality control, site performance, system administration and to evaluate use of our site, so that we can provide you with enhanced services; 
to notify you about changes to our products and services; 
to provide you with information, products or services that you request from us, or which we feel may interest you (provided that you agree); and to create reports to assist with future marketing.
If you submit an employment application to us online through our site or otherwise, all of the information you submit may be used for any and all purposes ordinarily associated with processing an employment application.

Who has access to your information?

Our operations team and senior management have access your information.

As appropriate our marketing, support and accounts teams will access to people’s information appropriate to their functions and role.  We may provide your information to our professional advisors as appropriate. We may also disclose your personal information if required to do so by law, or if we believe that such action is necessary to:

(1) comply with legal requirements,

(2) protect and defend our rights or property or those of our users or

(3) protect the personal safety of our users or the public.

This may involve exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may also share your information with other organisations: if we sell or buy any business or assets, (as we may share your data with the prospective seller or buyer); if we or substantially all of our company assets are acquired by another party, in which case your information will be one of the transferred assets; or if we have to enforce or apply the terms and conditions of any agreements.

Marketing

We may collect the e-mail addresses of those who send us e-mail messages; however, we will not send unsolicited e-mail to any of the addresses we collect or share those addresses with any unaffiliated third party, except in the limited circumstances set forth below.

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Provided that you agree, we may use your information to provide you with marketing information that you request or that we feel may interest you by post and email.

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Where do we process your information?

We will not transfer your information to or store it at a location outside the European Economic Area (“EEA”) to countries which do not have as developed data protection laws.

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How do we keep your information secure?

SmartXpo has implemented measures meeting generally accepted standards of technology and operational security in order to protect your personally identifiable information from loss, misuse, alteration, or destruction. All your information is stored on our secure servers and we will protect your information in line with legal requirements.

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Despite these precautions, however, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted to our site or that unauthorized persons will not obtain access to your information.

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Our site may from time to time contain links to other websites. Please check the privacy policies on those sites before you submit your information to those sites. We do not accept any responsibility or liability for those sites or their privacy policies.

You should keep in mind that whenever you publicly disclose information about yourself online — for example, via message boards or chat rooms — that information could be collected and used by people whom you do not know. In addition, certain message boards and similar user forums may display IP addresses along with the message poster’s name and message. SmartXpo bears no responsibility for any action or policies of any third parties who collect any information users may disclose on the message boards, chat areas or other user forums, if any, on the site.

 

Data deletion

We only keep your information for as long as is necessary.  

In the event a client cancels their business with us, we are able to provide a copy of the data we hold to them. This data can be provided using a secure link, and upon confirmation that the data has been received, and in response to a request from the client, it will be deleted permanently from our systems within one year. In doing so all centrally held personal data is removed.

We retain your information if you were a client for up to year after termination or if you were an employee for up to seven years after the employee’s last day, since having records of previous employees can be necessary in continuing to provide our service effectively. Some examples include:

  • Updating a company IT policy that references “John Smith” as a contact – it would help to know John’s job title and department in order to find the person who has taken over John’s role.
  • When wiping an old computer for disposal, and we may find a user profile for “John Smith”. Knowing he is a previous employee and what department he was in can help in determining what should be done with that data.

In both of these cases, despite our reasonable efforts to remove everything, the nature of certain systems make it unfeasible or impossible to remove every trace of personal data. As such there may be personal data that remains on our systems which may include:

  • Historic invoices and billing statements may display the name of the person they were sent to. These are immutable and must be retained for audit and tax purposes.
  • Internal chat logs or message boards may reference a person’s name. There is no way to redact names from these logs or message boards.
  • Copies of deleted data may still exist on backups. Backups are maintained of our entire system: encrypted and stored as single files. Removing one person’s data is not possible.

Breach notification

Our incident management procedure includes notifying the tech and operational contacts at our clients within 72 hours of becoming aware of a breach, and its potential impact.

Your Rights

You have the right to access, rectify or erase your information and should direct any request on your information to us at info@SmartXpo.com

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SmartXpo would like to keep your personal information accurate. You have the right to correct, update or change your information by contacting us at info@SmartXpo.com

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You have the right to ask us not to process your information (or pass your information to other companies or organisations) for marketing purposes. You can tick the appropriate box on the forms when we collect your information or amend your choice at any time by contacting us at info@Smartxpo.com. You also have the right to unsubscribe from participating in our programs or have us erase your information at any time by contacting us at info@Smartxpo.com

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If you have any complaint about how we have used your information please do contacting us at info@Smartxpo.com, and you always have the right to complain to the Information Commissioner’s Office.

 

How to Contact Us

Questions, comments or requests concerning this Privacy Policy and your information are welcomed and should be addressed to us at info@Smartxpo.com. Alternatively, you can use the “Contact Us” page on our site.

Last updated: 19 June 2018