Privacy Policy

Your privacy is very important to us. We designed our Privacy Policy to make important disclosures about how you can use SmartSession to share with others and how we collect and can use your content and information. We encourage you to read this Privacy Policy, and to use it to help make informed decisions. You should read the SmartSession Terms and Conditions of Use in conjunction with this SmartSession Privacy Policy.

 
GENERAL STATEMENT
1.
Your privacy is very important to us. Our Privacy Policy has been designed to reflect our commitment to ensuring the privacy of your information. The SmartSession Privacy Policy makes important disclosures about how you can use SmartSession to share your User Profile information with all Users of the SmartSession Platform and how we in turn collect and can use your content and information. We encourage you to read the Privacy Policy and to use it to help you, the User, make informed decisions. We will only collect, store and use your personal information for defined purposes which are outlined in our Privacy Policy and our Data Protection Policy. We use your information to provide you with our service, to support and enhance our relationship with you, for example, to provide service and support, and share product, services and SmartSession news and offerings with you. We do not sell your personal information to third parties. Periodically, we may send you information about SmartSession products and services we feel may be of interest to you. We have no desire or intent to infringe on your privacy while using our site. See our Data Protection Policy for full information on collection and use of personal information. We understand that as a registered User of the SmartSession Platform the privacy and the security of your information is very important to you. The purpose of our Privacy Statement is to outline SmartSessionís practices in this area.
 
CHANGES TO THE PRIVACY POLICY
2.
Please note that this Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent and we expect that the majority of such changes will be minor. Regardless, we will post any Privacy Policy changes on the SmartSession website and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us at any time through the SmartSession website or at: Data Protection Officer SmartSession Ltd, 5-7 Cranwood Street, London, EC1V 9EE, UK. PLEASE NOTE that this Privacy Statement is subject to the Terms and Conditions of Use of herein the SmartSession Website. We recommend that you read the Terms and Conditions of Use. If there is a conflict between the Terms and Conditions of Use and this Privacy Statement, the Terms and Conditions of Use shall prevail. Except as otherwise provided, terms used herein and defined in the Terms and Conditions of Use shall have the same meaning that is given to them in the Terms and Conditions of Use.
 
PROVIDING THE SERVICE FOR WHICH YOU HAVE APPLIED
3.
The information collected by SmartSession is used to facilitate the operation of the SmartSession Platform.
 
KEEPING YOU INFORMED
4.
There may be times when we feel that a service or product offered by us or a selected third party may benefit you. We may use information we obtain from your account transactions and your User Profile in this decision-making process. To make you aware of the service or product we may contact you by mail or other methods provided from your User Profile information to give you further details so that you can make an informed choice.
 
RESEARCH & STATISTICAL ANALYSIS
5.
We will use your details to assist us in understanding individual needs and business trends in order to improve the SmartSession products and services we offer.
 
THE DETAILS WE HOLD
6.
Under the Data Protection Acts 1988 and 2003 you have the right of access to information we hold about you on our records.
 
EMAIL/SMS
7.
If you email us, or give us your email address or SMS number, we will keep a record of it. With your explicit consent, we may use it to contact you occasionally about other SmartSession products and services which may interest you. We will not give your email address or SMS number to any unauthorised third parties. When emailing us, always use the email facility on the SmartSession website to make sure that the content of your email is secure. If you send us email in other ways, remember that it will be insecure and could be intercepted. If you do send us insecure email, please keep the amount of confidential information you include to a minimum.
 
THE INFORMATION WE COLLECT
8.
As you browse through our Website, our web server collects information about your visit, not about you personally. This information is anonymous and no attempt is or will be made to identify visitors. All information provided to us by you will be treated with the utmost confidentiality in accordance with all applicable legislative and regulatory standards. SmartSession will remove or amend the information as appropriate in accordance with applicable legislative and regulatory requirements.
 
USE OF 'COOKIES'
9.
What is a cookie? Cookies are small pieces of information, stored in simple text files, placed on your computer by a website. Cookies can be read by the website on your subsequent visits. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that the website can "remember" you on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have furnished such information to the website in your User Profile.
10.
How does SmartSession use cookies? When you visit SmartSession, we collect your browser type and IP address. This information is gathered for all SmartSession Users. In addition, we send cookies to your computer or other device that uniquely identifies your browser. We use session ID cookies to confirm that Users are logged in. These cookies terminate once the User closes the browser. By default, we use a persistent cookie that stores your login ID (but not your password) to make it easier for you to login when you come back to SmartSession. You can remove or block this cookie using the settings in your browser if you want to disable this convenience feature. We use cookies to collect information about visitors' use of the SmartSession website. The information collected by cookies enables SmartSession to understand the use of its site. This in turn helps to provide visitors with a better experience. SmartSession will not attempt to personally identify visitors from their IP addresses. We use cookies to improve the quality of our service. SmartSession also uses cookies in its advertising services to help advertisers and publishers serve and manage ads across the web. We may set one or more cookies in your browser when you visit a website, including SmartSession sites that use our advertising cookies and that view or click an ad supported by SmartSessionís advertising services. Cookies will not be used to contact you for marketing purposes other than by means of advertisements offered within the SmartSession website. Cookies do not in any way compromise the security of your computer.
 
RETENTION
11.
We will retain your data for as long as you have a User Profile on the SmartSession Platform. If you wish to remove your User Profile information you must delete the User Profile by going to your User Account Settings.
 
CONSENT
12.
By providing SmartSession with your information and by your use of this Website you consent to all of your information being used, accessible, available processed, disclosed and retained as set out above.
 
REPRESENTATION
13.
By your use of this Website you warrant and represent to us that in respect of any personal data of any data subject which you provide to us, you have the authority of that data subject to disclose such data to us on these Terms and Conditions of Use and for all the purposes herein set out and to give the consents set out above on behalf of each such data subject, and accordingly, all references in these documents to you shall be deemed to include any such data subject.
 
CONFIDENTIALITY & DISCLOSURE OF INFORMATION
14.
Outside of the SmartSession Platform we will treat all your personal information as private and confidential (even when you are no longer a SmartSession User). Nothing about your accounts (apart from what you upload to your User Profile) will be disclosed to anyone, other than in the exceptional cases permitted by law. These include:
 
(a) where we are legally compelled to do so;
 
(b) where there is a duty to the public to disclose;
 
(c) where disclosure is required to protect our interests (this will not be used as a reason for disclosing information about you or your information, including your name and address, to anyone else for marketing purposes);
 
(d) where disclosure is made at your request or with your consent;
 
(e) where disclosure is necessary for the performance of our legal agreements with you.
15.
From time to time we may employ agents and sub-contractors to process your information on our behalf to ensure that your online transactions are secure. The same duty of confidentiality and security will apply to our agents and sub-contractors and all processing will only be carried out under our instruction and will be supported by written contract. In instances where your information may also be shared by contracted third parties these third parties will similarly be under the same duty of confidentiality and security in respect of your data. SmartSession will not divulge customer information to a third party unless we have received customer authorisation or we are required to do so by law or you have selected to do so on your User Profile.
 
SECURITY OF INFORMATION
16.
At SmartSession, we understand how important the security and confidentiality of your information is to you. Keeping customer information secure is a top priority for SmartSession. Even so, SmartSession Ltd cannot and does not guarantee the privacy or confidentiality of information relating to you that passes over the Internet. In accessing this Website and in availing of any of the services/information available on or via this Website, you are deemed by the Terms and Conditions of Use to accept that electronic mail messaging and Internet communication may not be free from interference by third parties and may not remain confidential. In all circumstances the use by you of this Website is at your sole risk. You are solely responsible for maintaining your User Profile information. Please be careful and responsible whenever you are online. While we strive to protect your personal information, we cannot ensure or warrant that it will be at all times secure from unauthorised use and you transmit to us at your own risk. You can be assured that we have taken the necessary steps to protect your information by using some of the latest technologies available. This enables you to transact with us online in confidence.
 
DATA ENCRYPTION
17.
To help protect your credit card number and personal information, we encrypt transactions where necessary.
 
HYPERLINKS
18.
Some of the pages on this Website may contain hyperlinks to websites not maintained by SmartSession. You are reminded that different Terms and Conditions of Use will apply to you as a User of such websites. In addition such websites may not attain the same privacy standards that SmartSession maintains.
 
AMENDMENTS
19.
The contents of this Website, including these Terms and Conditions of Use, any information contained on this Website and our Privacy Statement are subject to change and to being updated without notice from time to time.
 
ATTEMPTED USE OF WEBSITE
20.
The SmartSession Terms and Conditions of Use shall also apply, subject to alteration as necessary, to attempted access of the Website and attempted use of information on it.
 
GENERAL
21.
In the event that any provision in the SmartSession Terms and Conditions of Use is held to be unenforceable or invalid, such provision shall be severed and the remaining provisions shall be enforceable to the fullest extent permitted by the laws of England.
22.
Clause headings in the SmartSession Terms and Conditions of Use are for reference purposes only and shall not be used to construe or determine the meaning of any or all of the SmartSession Terms and Conditions of Use.
 
SALE OF BUSINESS
23.
We reserve the right to transfer information (including your personal information) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company.
 
SECURITY
24.
Your personal information is held on secure servers hosted by our Internet Service Provider. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we will take all reasonable steps to protect your personal information, the nature of the Internet is such that we cannot and do not guarantee or warrant the security of any information you transmit to us via the Internet.
 
This policy was last revised on 25 January 2012