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SmarterQueue (we/us/our/the Company) is committed to protecting and respecting your privacy.
This Site is owned and operated by SmarterQueue Ltd (Company No. 09981623) of registered address 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX (our Company Address). SmarterQueue processes personal data as a Data Controller, as defined in the Directive and the General Data Protection Regulation (GDPR).
Our Services should only be accessed by individuals 13 years old and above. The Services are not designed nor intended for use by children or anyone else under the age of 13.
1. Data We Collect About You
Our primary goals in collecting personal data are to provide you with the product and services made available through the Site, including - but not limited to - the Service, to communicate with you, and to manage your registered user account, if you have one. It’s important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect and process about you is explained in the sections below.
1.1 Data You Give Us
We collect personal data about you when you first register with SmarterQueue (or sign up for a free trial or for our mailing list), when you use our Services and when you communicate with us. We collect:
- Your full name, login details and email address
- Personal identification number(s), including a unique SmarterQueue user ID (a numeric string) which is assigned to you upon registration
- Other information you add to your account profile
- Information about your business and any other information submitted by you or your organizational representatives (via phone, email, online forms, surveys, in-person meetings, etc.)
- When making purchases through the Services, your purchase history, bank or credit card information, billing address and any other information necessary to complete the financial transaction (although financial information from users who subscribe to our paid plans is transmitted directly to our secure payment gateway and is not stored by us)
- User-generated content, such as messages, posts, comments, pages, profiles, images and feeds, or any other content or files you publish via our Services
- Information we receive relating to communications you send us, such as queries or comments concerning our Services
We process this data based on our contractual obligations to you and our legitimate interests in doing so.
1.2 Data We Automatically Collect
Each time you visit or use our Site or Applications, we automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, location, network data,browser plug-in types and versions, languages, operating system and platform.
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
We use this information as statistical data about your browsing actions and patterns, for system administration, and to evaluate, provide, protect or improve our Services (including by developing new products and services). Because we collect, use and share this information in the aggregate, it does not identify any individual.
1.3 Data We Receive From Third Parties
- We receive data about you from the following third parties for the following reasons.
- We use Amplitude, Google Analytics and Hotjar to collect behavioural information about you so we can gain insight into how we can improve our product and Site.
- We use Braintree to collect and process your payment information.
- We also receive information about your profile(s) on the social networks you use SmarterQueue to manage, including LinkedIn, Facebook, Twitter, Instagram, and Pinterest (as applicable depending on your use of SmarterQueue).
- You may opt-out from behavioural tracking from your Privacy Preferences once logged in.
For more information on how these companies handle your personal data, please refer to their privacy policies (links at the end of this document). We process this data based on our contractual obligations to you and our legitimate interests in doing so.
2. How We Use Your Data
We will never sell, share, or rent your personal information, such as your email address or other PII to any third party; or use your email address for unsolicited mail. Any emails sent by SmarterQueue will only be in connection with the provision of agreed services and products. We use your data to carry out our Site and Services in the following ways:
- To provide customer support by analysing your activity on our Site.
- To administer and manage your account, to provide you with information you request from us, and to carry out any other obligations arising from any contracts entered into between you and us.
- To ensure that content from our Site is presented in the most effective manner for you and for your device.
- To respond to communications from you and to provide you with information about our Services.
- To process payments.
We also use your data to make our Site and Services better in the following ways:
- To improve product functionality, by analysing low-performance within the product.
- To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.
- As part of our efforts to keep the Site safe and secure, e.g. by conducting analysis required to detect malicious data and understand how this may affect your IT system.
- To notify you about changes to our Site or Services.
- We use GeoLite2 (owned by MaxMind) to determine your country and present prices in the most appropriate currency.
We may use your contact information to market to you, and provide you with information about our products and services, including but not limited to our Service. We will not send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under applicable data protection laws. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which were the subject of a previous enquiry by you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have expressly consented to this.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please update your preferences, or notify us by email.
3. How We Secure Your Data
All of your personal information is protected and we have put in place appropriate physical, electronic, and management procedures to safeguard and secure the data we collect. Your information is stored on secure cloud databases, internal servers and third party servers (primarily Amazon Web Services, who provide our cloud storage system). Your information is only accessible by employees who have authorised access rights to such information. All of your payment information is encrypted using SSL technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we use strict procedures and the security features described above to try to prevent unauthorised access.
4. How Long We Store Your Data
We only keep your personal information for as long as it’s necessary for our original legitimate purpose for collecting the information and for as long as we have your permission to keep it. We will delete your personal information when you delete your account, or 12 months after your account becomes inactive.
5. Disclosure to Third Parties
We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, billing, customer relationship, database storage and management. We will share your personal data with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data. The following third parties have access to your personal data:
- We share behavioural information with Amplitude and Google Analytics so we can gain insight into how we can improve our product and Site.
- We share payment information with Braintree (owned by PayPal) so they can process your payment information.
- We provide access to your data to Amazon Web Services so they can provide us cloud storage.
As mentioned above, we also share information about your profile(s) on the social networks you use SmarterQueue to manage, including LinkedIn, Facebook, Twitter, Instagram, and Pinterest (as applicable depending on your use of SmarterQueue). SmarterQueue acts as a conduit between our users and our various supported platforms and third-party sites and applications. In several instances, the content published via SmarterQueue will not be in our custody or control, and any content that has been shared by you through any supported platform or third-party site or application via the Services may continue to be available to third parties and the public at large.
The only other circumstances under which we would share your personal data are:
- If the third party is a member of our group (which means any subsidiaries or ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If the Company or substantially all of its assets are acquired by a third party, in which case personal data will be one of the transferred assets and the purchaser will be permitted to use the data for the purposes for which it was originally collected by us.
- If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation, enforce or apply our Terms & Conditions and other agreements, or to protect the rights, property, or safety of the Company, our customers, or others (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
6. Third Party Websites
Our Site contains links to and from other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies—they may place their own cookies or other files on your computer, collect data or solicit personal information from you. We do not accept any responsibility or liability for these websites or their policies. We encourage you to read the privacy policies or statements of the other websites you visit.
7. International Transfers
Information that we collect is stored, transferred between, and processed in multiple countries, including countries outside the European Economic Area (EEA). These countries include countries where we operate, countries where our servers are located, and countries where the third-party services that we use are based. By submitting your personal data, you agree to this transfer, storing or processing.
We will take all steps reasonably necessary to ensure that your data is treated as securely as it would be within the EEA and under the GDPR. Such steps may include our entering into contracts with any third parties we engage and the use of Commission-approved Model Contractual Clauses. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
You can obtain more details of the protection given to your personal data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in the Contact paragraph below.
8. Your Rights
8.1 Legitimate Bases
We will ensure that your personal data is processed lawfully, fairly, and transparently and that it will only be processed if at least one of the following bases applies:
- You have given your clear consent to the processing of your personal data for a specific purpose.
- Processing is necessary for the performance of a contract to which you are a party (or for us to take steps at your request prior to entering into a contract with you).
- Processing is necessary for our compliance with the law.
- Processing is necessary to protect someone’s life.
- Processing is necessary for us to perform a task in the public interest or in the exercise of official authority and the task/function has a clear basis in law.
- Processing is necessary for our legitimate interests or the legitimate interests of a third party, except where there is a good reason to protect your personal data which overrides those legitimate interests, such as allowing us to effectively and efficiently manage and administer the operation of our business, maintaining compliance with internal policies and procedures, monitoring the use of our copyrighted materials, offering optimal, up-to-date security and obtaining further knowledge of current threats to network security in order to update our security.
8.2 Data Subject Rights
Under the GDPR, you have the right to:
- Withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
- Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
- Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
- Correct or supplement any information we hold about you that is incorrect or incomplete.
- Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
- Object to the processing of your data.
- Obtain your data in a portable manner and reuse the information we hold about you.
- Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
- Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).
You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us, or by unsubscribing using the links contained in the marketing emails.
We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.
Like many websites, we also use "cookie" technology to collect additional website usage data and to improve the Site and our Service.
Before any non-essential cookies are placed on your device, you will be shown a pop-up message requesting your consent to setting those cookies. By default, most internet browsers accept cookies, but you can choose to enable or disable some or all cookies via the settings on your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. For further details, please consult the help menu in your internet browser.
Please be aware that some of the cookies we use are essential for the Site to operate. If you use your browser settings to disable some or all cookies, it will turn off some of the features that make your experience more efficient, some of our Services may not function properly and you may not be able to access all or parts of our Site.
We use the following cookies:
- Strictly necessary cookies. These cookies are required to save your session and to carry out other activities that are strictly necessary for the operation of the Site. They include, by way of general example, cookies that enable you to log into secure areas of the Site, use a shopping cart, or make use of e-billing services. These cookies are session cookies, which means they’re temporary and will expire when you log out.
- Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around the Site when they’re using it. These cookies help us improve the way the Site works by, for example, ensuring that users are finding what they’re looking for easily.
- Functionality cookies. These cookies are used to recognise you when you return to the Site. They enable us to personalise our content for you, greet you by name and remember your preferences.
- Social Media cookies. These cookies work together with social media plug-ins. For example, when we embed photos, video and other content from social media websites, the embedded pages may contain cookies from these websites.
- Third Party cookies. We use third party cookies on the Site from Amplitude and Google Analytics for analytics and customer support. Please note that we do not control cookies placed by third parties and our Site does not block them. Please check the relevant third-party website for more information about these cookies.
10. Changes To Our Privacy & Cookie Policies
These policies may be updated from time to time for any reason. Each version will apply to the information collected while it was in place. Any changes we may make to our Privacy & Cookie Policies in the future will be posted on this page and, where appropriate, notified to you by email. You will be deemed to have accepted the terms of the updated Privacy & Cookie Policies on your first use of the Site following the alterations. Please check back frequently to see any updates or changes to our Privacy & Cookie Policies.
11. GDPR Compliance of Third Party Data Processors
All third party data processors that we use are GDPR compliant. You may use the links below to review their policies and documentation.
Last modified: 25th May 2018
CHANGES IN OUR POLICY
- 25/05/2018 - Increased privacy controls and clarification for GDPR compliance.