Privacy Policy

Smartshave Limited | smartshave.co.uk

Last updated: 24 October 2019

1. Who we are

Smartshave Limited (“we”, “us”, “our”) is a company registered in England and Wales under company number 12184698, with its registered office at 4th Floor, 14 Museum Place, City Centre, Cardiff, CF10 3BH. We operate the website smartshave.co.uk (the “Website”).

We are the “data controller” of your personal data, which means we decide how and why it is used.

If you have any questions about this policy or how we use your data, contact us at contactus@smartshave.co.uk or by post at the address above.

2. What this policy covers

This policy explains what personal data we collect when you visit the Website, buy from us, contact us or subscribe to our marketing, how we use it, who we share it with, and the rights you have. We handle your data in line with the UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR).

3. Personal data we collect

Information you give us

  • Identity and contact details: name, email address, telephone number, delivery and billing addresses.
  • Account details: username, password and order history, if you create an account.
  • Order details: products purchased, delivery preferences and returns.
  • Payment details: we do not store full card numbers. Payments are processed securely by our payment providers (see section 6), who give us confirmation of payment and limited details such as the last four digits of your card.
  • Communications: messages, reviews, survey responses and enquiries you send us.
  • Marketing preferences: whether you have opted in or out of our emails.

Information we collect automatically

  • Technical data: IP address, browser type and version, device type, operating system, time zone and language settings.
  • Usage data: pages viewed, links clicked, how you arrived at the Website and how you move around it.
  • Cookie data: see section 9 and our cookie notice.

Information from third parties

We may receive limited information from payment providers, delivery partners, analytics providers and advertising networks, and from fraud-prevention services.

We do not knowingly collect personal data from children under 13, and the Website is not aimed at them. We do not intentionally collect special category data (such as health information).

4. How and why we use your data

We only use your data where the law allows. The table below sets out our purposes and the legal basis for each.

Purpose Legal basis
To process and deliver your orders, take payment and handle returns or refunds Performance of a contract with you
To create and manage your account Performance of a contract
To respond to your enquiries and provide customer support Performance of a contract / legitimate interests (running our business)
To send you service messages such as order confirmations and delivery updates Performance of a contract
To send you marketing emails about our products and offers Consent, or the “soft opt-in” for existing customers (you can opt out at any time)
To improve our Website, products and services, and understand how customers use them Legitimate interests (developing our business)
To use non-essential cookies and similar technologies Consent
To prevent fraud and keep the Website secure Legitimate interests / legal obligation
To keep accounting and tax records and comply with the law Legal obligation
To establish, exercise or defend legal claims Legitimate interests / legal obligation

Where we rely on legitimate interests, we balance our interests against your rights and freedoms. You can ask us for details of that assessment.

5. Marketing

We will only send you marketing emails if you have opted in, or if you have bought from us before and we are marketing similar products (and you have not opted out). You can unsubscribe at any time by clicking the link in any marketing email or by contacting us at contactus@smartshave.co.uk. We will never sell your personal data to third parties for their own marketing.

6. Who we share your data with

We share personal data only where necessary and with appropriate safeguards in place. Recipients may include:

  • Payment processors, such as Square (Squareup Europe Ltd), to take and secure payments.
  • Delivery and courier companies, such as Evri, to deliver your orders.
  • Website, e-commerce platform and hosting providers, such as WooCommerce.
  • Email and marketing service providers, such as Mailchimp.
  • Analytics and advertising providers, such as Google Analytics, where you have consented to the relevant cookies.
  • Professional advisers, including accountants, lawyers, insurers and bankers.
  • Fraud-prevention agencies, regulators, law enforcement and other authorities where required by law.
  • A buyer or successor, if we sell or restructure our business, who may use your data in line with this policy.

Our service providers act on our instructions and are bound by contracts requiring them to protect your data.

7. International transfers

Some of our service providers are based outside the UK. Where we transfer your personal data abroad, we make sure it is protected by an appropriate safeguard, such as a UK adequacy regulation, the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Contact us if you would like more information about these safeguards.

8. How long we keep your data

We keep personal data only for as long as we need it for the purposes above. As a guide:

  • Order and accounting records: 6 years after the end of the financial year, to meet tax and legal requirements.
  • Account information: for as long as your account is open, and for a reasonable period afterwards unless you ask us to delete it.
  • Marketing data: until you unsubscribe or withdraw consent, after which we keep a minimal suppression record so we do not email you again.
  • Enquiries and correspondence: up to 3 years after our last contact.
  • Website analytics data: as set by the relevant cookie or analytics settings.

When data is no longer needed, we delete or anonymise it.

9. Cookies

We use cookies and similar technologies on the Website. Some are essential (for example, to keep items in your basket and keep the Website secure). Others, such as analytics and advertising cookies, are used only if you give your consent through our cookie banner. You can change your choices at any time using the cookie settings on the Website, and you can also block or delete cookies in your browser settings, although some parts of the Website may then not work properly.

For a full list of the cookies we use and their purposes, see our Cookie Policy at [LINK TO COOKIE POLICY].

10. Keeping your data secure

We use appropriate technical and organisational measures to protect your personal data, including encryption of data in transit (HTTPS), access controls and secure hosting. No method of transmission over the internet is completely secure, so we cannot guarantee absolute security. If a data breach is likely to put your rights at risk, we will notify you and the ICO as the law requires.

11. Your rights

Under data protection law you have the right to:

  • Access a copy of the personal data we hold about you.
  • Rectification of inaccurate or incomplete data.
  • Erasure of your data in certain circumstances (the “right to be forgotten”).
  • Restriction of how we use your data in certain circumstances.
  • Object to processing based on legitimate interests, and to direct marketing at any time.
  • Data portability, meaning to receive your data in a structured, commonly used format, or have it passed to another provider, where we process it by consent or contract.
  • Withdraw consent at any time where we rely on consent, without affecting the lawfulness of earlier processing.
  • Not be subject to solely automated decisions with legal or similarly significant effects. We do not make decisions of this kind.

To exercise any of these rights, contact us at contactus@smartshave.co.uk. We may need to verify your identity first. We will respond within one month, and we will not normally charge a fee, unless a request is clearly unfounded or excessive.

12. Complaints

We would like the chance to put things right, so please contact us first. You also have the right to complain to the Information Commissioner’s Office (ICO):

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Website: ico.org.uk | Telephone: 0303 123 1113

The Website may contain links to third-party websites. We are not responsible for their privacy practices, and we encourage you to read their privacy policies.

14. Changes to this policy

We may update this policy from time to time. The latest version will always be on the Website with the “last updated” date at the top. If we make significant changes, we will let you know, for example by email or a notice on the Website.

15. Contact us

Smartshave Limited 4th Floor, 14 Museum Place, City Centre, Cardiff, CF10 3BH Email: contactus@smartshave.co.uk Website: smartshave.co.uk