We take the privacy of all our users
seriously.
This Privacy Policy outlines how we treat your personal information, and
forms part of the Terms and Conditions of this Site. This Privacy Policy
applies only to this Site, and not to the collection and use of personal
information by any third party via any website to which there are links on
this Site. We are not responsible for the privacy policies of other
websites, and encourage you to be aware when you leave our Site, and to
read all applicable terms, conditions and privacy policies when using
other websites.
Consent
Your use of this Site signifies your consent to us collecting and using
personal information about you in accordance with this Privacy Policy.
What information do we collect?
You may access this Site's home page without disclosing any personal data.
Only details of your vehicle(s) are stored and you have editorial control
over that content. To ensure that we maintain the accuracy of this register
for you and any other smart car enthusiast, we ask that you keep the data
content up-to-date whilst you own the vehicle. Your contact details used
during Registration for this service will only be used by thesmartclub ltd
to contact you as required.
How do we use your information?
Any personal data relating to you will be used and recorded by us in
accordance with current data protection legislation and this Privacy
Policy. Except as expressly stated in this Privacy Policy, we will not sell,
share, trade or licence your personal information to others without your
express consent.
We reserve the right to disclose your personal information to anyone
who may take over the running of the Site or who may purchase any or all
of our assets including your personal information. We reserve the right to
disclose your personal information to any law enforcement agency
requesting it in connection with the commission of any offence, once we
are reasonably satisfied as to the circumstances surrounding the request.
We also reserve the right to access and disclose your personal information
in order to comply with applicable laws a lawful government requests, to
operate our systems properly or to protect our users and ourselves.
Security
We take every precaution to protect your personal information. In
addition, we have strict security protocols in place to protect our
customer database from unauthorised access, improper use or disclosure,
unauthorised modification, and unlawful destruction or accidental loss. We
only allow access to the customer database when absolutely necessary, and
then under strict guidelines as to what use may be made of such details.
We may ask you for proof of identity before disclosing any personal
information to you.
Note that your VIN(s) and vehicle registration number(s) are encrypted for additional security.
Surveys
We always aim to improve the services we offer. As a result we may
occasionally canvass our visitors, members and users by means of
online surveys. Participation in surveys is voluntary, and you are under
no obligation to reply to any survey you might receive from us. Should you
choose to do so, we will treat the information you provide with the same
high standard of care as all other customer information.
Cookies
When you first visit one of our Sites, upon entering your details,
we may send you a cookie. Usage of cookies is in no way linked to
any personally identifiable information while on our Site. A cookie is a
small file that can be placed on your computer's hard drive for record
keeping purposes, and we may use them to do a number of things. For
example, cookies may be used to compile anonymous statistics related to
the take up or use of services, or to patterns of browsing. When used in
this manner, you are not individually identified, and information
collected in this manner is only used in aggregate.
Some of our business partners (for example, advertisers) may use cookies
on our Site or their own sites. We have no access to, or control over
these cookies. You are not obliged to accept a cookie from us, or any
other website, and you may modify your browser so that it will not accept
cookies, although some features on the Site may not function if you do.
Unsubscribe
We hope that you will enjoy using this Site and the services we offer.
However, you may request that your personal information is not used in the
ways outlined above. This is called unsubscribing, and may be achieved by
following all of these steps:
1. Click on your display name in the top right-hand corner of the page.
2. Click the 'Manage Services' link.
3. Click the 'unsubscribe' link.
Alternatively, you can contact us using the Contact Us option from the menu
that is visible when you log in and ask us to remove you from the mailing list.
Please include the word Unsubscribe in the subject and include your username.
Unsubscribing does not delete your personal or vehicle details from the system.
Unsubscribing simply removes you from the mailing list.
Correcting and Updating Personal Information
If your personal information changes, or if you believe that the personal
data we hold about you is incorrect, you may correct or update
the personal information held by us by following all of these steps:
1. Click on your display name in the top right-hand corner of the page.
2. Click the 'Manage Profile' link.
3. Modify any details you wish to correct or update.
4. Click 'Update' to save your changes.
5. Modify any details on the main details screen.
6. Click 'Update' to save the changes you have made.
Alternatively you may ask us to correct or update
the personal information held by us by sending us an email using the
'Contact Us' page available from the menu while you are logged in.
Should you wish your vehicle details to be removed from the Register,
simply use the Contact Us option from the menu visible when you log in.
Please include the words Vehicle Removal in the subject and include your
username in the detail of the message.
Site and Service Updates
We may send you Site and service announcements or updates. You cannot
unsubscribe from service announcements, as they will contain important
information about the services provided on the Site.
Notification of Changes
We may occasionally modify our Privacy Policy, and when this happens, we
will notify you via our homepage.
Privacy Support
If you have any enquiry or concern about our Privacy Policy, please
contact us using any of the following methods:
Email us using the 'Contact Us' page available from the menu while you are logged in.
Data Protection Act 1998
We have registered thesmartclub with the Government's Information Commissioner
and duly notified that body of the manner in which we process data as detailed in
this statement. Our Data Protection Registration number is
Z8460645 and we operate under the eight guiding principles of that Act
as detailed below:
First principle
Personal data must be obtained and processed fairly and lawfully.
thesmartclub will ensure that the individual/organisation about whom we
are collecting data understands the purpose(s) for which their data will
be used. Further details are contained within this document, referred to
as our ‘Privacy statement’ also known as the “Fair Processing Notice”.
Second principle
Personal Data may only be obtained or used for one or more
specified or lawful purposes and not be used in a way which would be
incompatible with those purposes.
thesmartclub will only gather data regarding individuals and/or
organisations relevant to Membership of thesmartclub, our associated
services, publications or promotions and/or Events relevant to the
business of thesmartclub.
At all times such data gathered will be in accordance with the First
principle stated above.
Third principle
Personal data must be adequate, relevant and not excessive.
thesmartclub is responsible for identifying the appropriate
personal data necessary for normal work processes and ensuring that only
this personal data is collected.
Fourth principle
Personal data must be accurate and kept up to date.
thesmartclub is responsible for ensuring data is processed
correctly. For example, where a Member, event participant or organisation
informs us of a change of address, we must ensure that the details are
changed correctly, in a timely manner and in accordance with procedures.
Fifth principle
Personal data must be held for no longer than is necessary for the purpose
or purposes which it is obtained.
thesmartclub will review the data held at regular intervals
and delete any that is no longer required, once other regulatory or
legislative retention periods have been met.
Sixth principle
Personal data must be processed in accordance with the rights of
individuals/organisations (i.e. data subjects).
The Data Protection Act 1998 bestows a number of rights on
data subjects including Right of Access. A data subject is entitled to
request a copy of the data we held on them and thesmartclub will charge a
fee of £10.00 (ten GBP) for such a request. Such a request is referred to
as a ‘Data Subject Access Request’ or ‘DSAR’.
Seventh principle
The data controller must ensure that personal data is kept safely and that
there is no unauthorised access to any data held and that data is
protected against accidental loss, destruction or damage.
thesmartclub has procedures and processes in place to
ensure that data is kept secure including data encryption and off site
secure storage facilities.
Eighth principle
Personal data must not be transferred outside the EEA
unless an adequate level of protection is in place.
The Data Protection Act 1998 does allow thesmartclub to process data
outside the EEA but only if the rights and freedoms of the data subjects
concerned are adequately protected. This is achieved through the
thesmartclub ensuring a written contract is in place with the data
processor (outsourcer firm), that the roles are clearly defined between
thesmartclub and data processor and that the data processor can only use
the data as instructed by thesmartclub. The data processor would be
expected to have IT and physical security at least equal to if not better
than thesmartclub’s own standards.