This Privacy Policy explains how we at SmartLock Europe Ltd obtain, use and disclose your personal data and how you can contact us if you have any questions or want to exercise any of your privacy rights. SmartLock takes its privacy responsibilities very seriously and has implemented measures designed to protect your personal data and ensure compliance with applicable laws.

1. Personal data we may collect about you
 

When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address and email address. When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.

Personal data we may collect about you:

Your contact details – such as name, address, email, telephone, mobile phone. We obtain this information directly from you (e.g. when you sign up to receive our newsletter, or become a registered user of our products or services).

Your registered user details and history – such as username, password, details of products or services purchased, device information, usage history, installation/support/service history, usage data, location data, IP address. We obtain this information directly from you (e.g. when you become a registered user) and from your use of our products and services.

Your preferences - such as whether or not you want to receive marketing communications.

Your activities on this and other websites – such as how many times you visit a site, which pages you go to, traffic data, location data and the originating domain name of your internet service provider (obtained through the use of cookies on this site – see further the paragraph 6, “How we use cookies”).

2. Purposes for which we may use your personal data
We may use your personal data for any of the following purposes:

providing products and services to you – including account administration and management, order fulfilment, facilitating with installation services, managing customer relations, billing and payment administration, fraud detection and prevention, providing customer support services, handling complaints and enquiries.

marketing and profiling – including managing our customers’ preferences and carrying out market research, statistical analysis and behavioural analysis to help improve our products and services, tailor our marketing communications and enhance customer satisfaction.

3. Disclosures of your personal data
We may sometimes appoint third party service providers (such as those providing installation services (e.g. locksmiths), providers of hosting and software as a service, delivery and logistics companies, and third party electronic payments provider) to carry out services on our behalf. This may involve sharing your personal data with such providers in connection with those services. We will ensure your personal data is properly protected and only used by our providers in accordance with this Privacy Policy.


4. How long we keep your personal data
We will normally keep your personal data for as long as you remain a customer of ours and thereafter for a period of seven years. If, after this point, we have not exchanged any communications, we will delete your data in accordance with our retention policy.

5. Legal basis for processing
SmartLock Europe Ltd is the controller of your personal data and responsible for complying with applicable data protection laws.

Where we collect and use your personal data for the purposes described above, we do so on the legal basis that either (a) the collection and use is necessary for the performance of a contract between us, or (b) you have given your consent to such use, or (c) it is in our legitimate interests to use your data for these purposes and this does not cause you unwarranted hard or prejudice.

6. How we use cookies
We use cookies when you visit our website. A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website.

We use the following types of cookies:

Site analytics cookies – these cookies allow us to measure and analyse how our customers use the site and to improve its functionality and your browsing experience

Targeting or advertising cookies – these cookies are used to deliver ads relevant to you. They also help us measures the effectiveness of our marketing campaigns.

We obtain your consent to the use cookies on this website via the cookie consent notice on our home page. If you use this website after the cookie consent notice has been displayed to you, we will take this as an indication that you consent to our use of cookies for the purposes described in this Privacy Policy.

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. More information about cookies, including how to block, delete or disable them, can be found at AboutCookies.org.

7. Shopify

Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall. We also use several Shopify plugins who may have access to your data.

Payment:

Payment processing is performed by Stripe via Bold Cashier or by Stripe via Xero. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

Fulfilment services:

Your order may be fulfilled by a 3rd party logistics company. We use mywarehouse and Amazon. Both providers have their own privacy policy.

CRM, Accounting & Shipping:

Your data may also be stored in our CRM, accounting and shipping software. We use Salesflare for CRM, Xero for accounting and Parcel2Go, Interparcel and Transglobal Express for shipping. Please refer to each company for details of their Privacy policy. We also use Mailchimp to manage customer lists. We do not store customer information on spreadsheets.

8. Marketing
If you provide us with your details and ask us to notify you of products and services that may be of interest to you, or sign up to a newsletter, or participate in any other promotional event, you consent to our contacting you by email, telephone, SMS and/or post for these purposes.

Similarly, when you become a registered user of our products and services, we make sure you are kept up to date with product and service related communications, including our newsletter.

In either case, you can opt out of receiving these messages at any time, including by clicking on the unsubscribe link included in our emails. This is managed by Mailchimp.


9. Your rights
You have the right to:

access your personal data – you have the right to receive a copy of the personal data we hold about you. We will require the request to be in writing, accompanied by proof of identity. This will ensure we only provide data to the correct person

withdraw your consent to direct marketing – you can exercise your right to withdraw consent to marketing at any time by contacting us or by clicking on the unsubscribe link in an email we have sent you

rectification – if you think any of the personal data we hold about you is inaccurate, you can ask us to correct it. Simply contact us and include your name, address and/or email address to help us ensure we accept amendments only from the correct person

restriction – in limited circumstances you may be able to require us to restrict our processing of your personal data. For example, if you consider what we hold is inaccurate and we disagree, the processing may be restricted until the accuracy has been verified

erasure – where we have no lawful basis for holding onto your personal data you are may ask us to delete it

portability – in limited circumstances you may be entitled to have the personal data you have provided to us sent electronically to you for you to provide to another organisation.

complain to the Data Commissioner’s Office – you can find data on how to do this at www.ico.org.uk

10. Security
We take the security of personal data very seriously. We employ security technology, including firewalls and encryption to safeguard personal data and have procedures in place to ensure that our paper and computer systems and databases are protected against unauthorised disclosure, use, loss and damage.

Personal data on our systems is only accessible by appropriately trained staff who need to access your personal data as part of their job. All access is tracked through individual login credentials and audit trails.

We only use third party service providers where we are satisfied that the security they provide for your personal data is at least as protective as the security we use ourselves.

11. smartCONNECT Portal
In some instances it may be necessary for you to give us access to your smartCONNECT portal account. You can grant permission and revoke permission at any time.

12. Transfers of your data out of the EU
We do not regularly transfer personal data outside of the United Kingdom or the European Economic Area (EEA). However, transfers may be made to our third party service providers (such as software as a service vendors and providers of delivery and logistics services) that are located outside the EEA. Where we transfer data out of the EEA, we will take proper steps to ensure that it is protected in accordance with this Privacy Policy and applicable privacy laws.

13. Links to other websites
Please note, this website contains links to other websites that are not controlled by us. These links are provided for your convenience. We are only responsible for our privacy practices and our security. We recommend you check the privacy policies for any other websites that you visit.

14. Changes to this Privacy Policy
Privacy laws and practice are constantly developing and we aim to meet industry standards. Our policies and procedures are, therefore, under regular review. We may, from time to time, update our security and privacy policies. We will ensure our website has our most up to date Privacy Policy and suggest check this page periodically to review our latest version.

15. Contact us
Contact Stuart Duncan data protection manager at: stuart@smartlock.co.uk

Business address: 305 Portland Road, Hove, East Sussex, UK, BN3 5SE

Telephone: 44 1273 930045