Privacy Policy

 

Thank you for reading our Privacy Policy.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data and tell you about your privacy rights.

1. Important Information

 

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how we collect and process your personal data, including any data you may provide to us directly via our website or otherwise.

It is important that you read this privacy notice together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Changes to the privacy notice and your duty to inform us of changes

This version of Privacy Policy was last updated on January 26, 2022.

It is important that the personal data we hold about you is accurate and up-to-date. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. What Information We Collect About You

 

Personal data, or personal information, stands for any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, and store different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, job title, company name and country.

  • Contact Data includes address, email address and telephone numbers.

  • Transaction Data includes details about payments to you if you are a supplier, and from you if you have purchased products and services from us, together with other details of your purchase.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

  • Profile Data includes work we have done, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

In addition, we use third party services such as Google Analytics that collect, monitor and analyse website’s usage data. For more details on how Google further uses information from websites like ours, please check https://policies.google.com/technologies/partner-sites

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3. How Your Personal Data is Collected

 

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

    • use our products or services;

    • register to access or download content on our website;

    • subscribe to our blog or publications;

    • request marketing to be sent to you;

    • enter a competition, promotion or survey;

    • give us some feedback; or

    • request a call-back or book a meeting.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

  • Technical Data from the following parties:

    • analytics providers;

    • advertising networks; and

    • search information providers.

  • Personal networking:

    • LinkedIn

    • workshops

    • networking events

    • contacts and colleagues

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

  • Identity and Contact Data from data brokers or aggregators.

 

4. How We Use Your Personal Data

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need 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

 

You have the right to withdraw consent to marketing communications at any time by contacting us at sasha.makarenko@sm-strategy.com

 

Marketing Communications and Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You may receive marketing communications from us if you have requested information from us or purchased goods or services from us or if your details are publicly available or registered to access or download content from our website and, in each case, you have not opted out of receiving that marketing communication.

You can always opt out of receiving regular newsletters and other regular marketing communications or promotional materials.

Where you opt out of receiving marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal 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 contact us at sasha.makarenko@sm-strategy.com

If we need to use your personal 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 personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

 

5. Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

Like many websites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

 

 

6. Data Security

The security of your Personal information is important to us but remember that no method of transmission over the internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal information, we cannot guarantee its absolute security.

 

 

7. Data Retention

We will only retain your personal 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 personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

By law we might have to keep basic information about our customers/clients (including Contact, Identity, Financial and Transaction Data) for a certain period after they cease being customers/clients for tax purposes.

In some circumstances you can ask us to delete your data and, in some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

 

8. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data

  • Request correction of your personal data

  • Request erasure of your personal data

  • Object to processing of your personal data

  • Request restriction of processing your personal data

  • Request transfer of your personal data

  • Right to withdraw consent

 

If you wish to exercise any of the rights set out above, please contact us at sasha.makarenko@sm-strategy.com

 

No fee usually required

You will not have to pay a fee to access your personal 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.

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 personal 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.

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 several requests. In this case, we will notify you and keep you updated.

 

 

9. Changes to This Privacy Policy

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy policy at any time and you should check this Privacy policy periodically. Your continued use of the Website after we post any modifications to the Privacy policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy policy.

If we make any material changes to this Privacy policy, we will notify you either through the e-mail address you have provided us, or by placing a prominent notice on our website.

 

 

10. Contact Us

If you have any questions about this Privacy policy, please contact us at sasha.makarenko@sm-strategy.com