Privacy Policy - Commericial Relationships
This policy covers our commercial relationships. This is for you if you are a client, supplier, partner, enquirer or if we have approached you regarding our services or if you have applied for a position with us.

Privacy Policy - Trading Personal Information
This policy relates to the data that we trade as part of our core business activity. Our clients task us with sourcing data from our suppliers and partners for their direct marketing activity and other legitimate activities that make use of personal information which might mean we process your details.

Privacy Policy – Commercial Relationships



Sales Smart Ltd are a provider of compliant business sales and marketing data which our clients access within our online prospecting and CRM tool for their own direct marketing activities.
This policy relates to you if you visit our website, you apply to work with us or if you are a client, supplier, partner or enquirer. It also applies to you if we have approached you regarding our services or if we have acquired your details through events, networking or a referral.

Contents


This Privacy Notice explains in detail the types of personal data we may collect directly from you, receive from or share with third parties about you. It also explains how we’ll store and handle that data and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how we use your data. We hope the following sections will answer any questions you have but if not, please do get in touch with us.

1. Legal basis for processing
2. When do we collect personal data
3. The data that we collect
4. How we use your details
5. How are your details protected
6. Website users
7. The information we hold
8. How long will we keep your details
9. Who might we share your details with
10. International transfers
11. Automated decision making
12. Your rights
13. Opting out
14. Our contact details
15. The regulator

1. Legal basis for processing


Data protection law states there are several legal reasons why a company may collect and process personal data. We work on the following bases for certain situations:
Contract – We will process your personal data to fulfil an order, deliver a service, essentially comply with our contractual obligations. An example might be, if you order a service for email delivery, we’ll collect your email address to deliver your purchase or pass them to the delivery company.
Legal Compliance – If the law or government requires us to, we may need to collect and process your data. An example might be passing on details of fraud to law enforcement.
Legitimate Interest – In some cases, we require personal data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business. This does not impact your freedom or rights. Examples might be using postal or email details to send direct marketing information by post telling you about products and services that we think might interest you. We may also use your purchase history to send or make available personalised offers.
We do not share the data that we collect directly from you with third parties for their own sales and marketing activity.

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2. When do we collect personal data


  • When you visit any of our websites or speak to an account manager on the phone.
  • When you create a credit account with us.
  • When you purchase a product or service by phone but don’t have (or don’t use) an account.
  • When you engage with us on social media.
  • When you contact us by any means with queries, complaints etc.
  • When you enter prize draws or competitions.
  • When you book any kind of appointment with us or book to attend an event, for example a meeting to discuss an opportunity.
  • When you choose to complete any surveys we send you.
  • When you comment on or review our products and services.
    Any individual may access personal data related to them, including opinions. So, if your comment or review includes information about the Partner who provided that service, it may be passed on to them if requested.
  • When you’ve given a third-party permission to share with us the information they hold about you.
  • Details that you provide us at networking events directly or where you have confirmed to the event organiser or other referring party that you are happy for your details to be shared.
  • From publicly available sources such as Companies House, websites, industry specific directories, press releases and so on.

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3. The data we collect


  • Details of your interactions with us through phone contact, email or online. An example might be notes from conversations with you, complaint details, comments, purchase details and web visits.
  • Copies of documents you provide to prove marketing compliance This will include details of your full name, work address, telephone number, ICO number, data protection contact name.
  • Details of your visits to our websites, and which site you came from to ours.
  • Information gathered by the use of cookies in your web browser.
  • Payment card information. This is not stored for longer than it takes to transact.
  • Your comments and product reviews.
  • To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
  • Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

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4. How we use your details


We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘Your rights’ which can be found in section 12.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Here’s how we’ll use your personal data and why:
  • To process any orders that you make by using our sales team. If we don’t collect your personal data during ordering, we won’t be able to process your order and comply with our legal obligations. An example may be that your details are passed to a third-party, so they can deliver your purchased product or service that you ordered. We would then keep those details for reasonable period afterwards in order to fulfil obligations such as refunds, guarantees etc.
  • To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
  • To protect our business and your account from fraud and other illegal activities. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
  • To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
  • We will use your personal data, preferences and details of your transactions to keep you informed by post, email or telephone about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
  • To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, marketing data misuse issues, and contractually required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email or text message.
  • To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
  • To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
  • To comply with our contractual or legal obligations to share data with law enforcement.
  • To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message.

Of course, you are free to opt out of receiving these requests or marketing from us at any time by updating your preferences with us.
Please visit our contact us page

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5. How are your details protected


We will treat your data with the utmost care and take all appropriate steps to protect it.
Access to personal data is limited to authorised personnel, password-protected and encrypted.
We regularly monitor our systems to identify ways to further strengthen security.
Physical access is limited to our premises and areas and equipment used for the storage or processing of data is further restricted to specific employees.
We make use of the latest firewall technology and systems and software updates.

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6. Website users


What specific information is obtained?
Our website does not collect specific, detailed information about you as a visitor to our site. Where information is gathered, we will inform you of this along with the explanation of why it is required.

Are any payment details stored?
Payment card details are used solely for individual transactions to which they have been provided for.

What information is retained?
Cookies and tracking software are used on a temporary basis and expire when the site has been left. These are used for purposes such as website improvement. Google Analytics is also used for the same reason of website improvement and understanding how you use it. This information is not shared with anyone.
By using the website, you are consenting to the use of cookies to retain session information for the purposes listed above. This information is held in your web browser and is removed at the end of your session.

The personal information we collect and hold via Tracking software is the following:
  • Browser used (Bing, Chrome, Internet Explorer etc.)
  • Location (based on IP address)
  • Gender
  • Age group
  • Site searches
  • Device(s) used
  • Frequency on Site
  • Session duration (time spent on the site)
  • Page(s) visited
  • Page session duration (time spent on specific page)
  • Web Surfing Behaviours

We currently use the following companies that may process your personal data through website usage. Facebook, Twitter, LinkedIn, Google, Infusionsoft.
If you need to contact us, you can find the relevant details here

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7. The information we hold


We hold information about people and the businesses they work for necessary for us to conduct our business activities.
  • Full Name
  • Job title/function
  • Company Name
  • Company Address
  • Company Website Address
  • Email Address
  • Phone Number
  • Initial Requirement
  • Transaction history
  • Credit/finance history

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8. How long will we keep your details


For direct marketing purposes we will keep your details and contact you while you remain a client and for up to six years from your last transaction. If you are an enquirer or prospect, we will keep your details for as long as they remain accurate and up to date. You can opt-out of receiving offers from us at any time.
For accounting purposes, we will keep transactional data for at least six years and dependant upon the requirements of any applicable legislation and government agency guidance.

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9. Who might we share your details with


This information will not be shared with any organisation for their own benefit. We might share your details with contracted processors working on our behalf for example a company sending our own promotional material.
We may have a legal obligation to share your details with organisations such as HMRC and law enforcement agencies.
In this instance, we provide only the information required to perform the service. The data will only be used for that exact purpose.
Partners are required to protect and respect your privacy. If we stop using a partner’s service, your data will be deleted or anonymised.

Examples of third parties we work with are:
  • Direct marketing companies who help us manage electronic communications, social media platforms such as Google or Facebook to show products that might interest you. This is based on consent or your acceptance of cookies on our website.
  • Data Insight companies to ensure your details are up to date and accurate.
  • IT Companies who support our website and business systems.
  • Data Suppliers who would deliver your ordered product.

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10. International Transfers


We might transfer your details outside of the EEA for the purpose of data processing. Examples of this might include:
  • CRM sytems
  • Data cleansing and validation service providers
  • Credit reference agencies
  • Data management software solution providers
  • Online/virtual server/back-up service providers

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11. Automated decision making


We will not make use of your details for automated decision making.

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12. Your rights


  • The right to be informed. This obligates us to tell you when we collect your details what we will do with them, how we hold them and for how long for example within a data collection notice and this privacy policy.
  • The right of access. If you ask us, we are obliged to let you know what details we have about you.
  • The right to rectification. You can ask us to update or change the information we hold about you.
  • The right to erasure. You can ask us to delete or suppress your details which we will do unless there is an overriding reason that means we must keep all or part of them.
  • The right to restrict processing. You can ask to limit the way in which we use your details.
  • The right to data portability. You can ask us for a copy of your details in a format suitable for you to provide to another organisation.
  • The right to object. You can object to us holding your details, or the way in which we make use of them.
  • Rights in relation to automated decision making and profiling.

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13. Opting out


You can opt out of receiving direct marketing from us by a number of different means:
If we email you, click the unsubscribe link within the footer of the email.
If we call you, ask our member of staff to suppress your details.
If we write to you, call us, email us or write to us :
Call our Compliance Officer on 01245 397 570
Write to us The Compliance Officer, Sales Smart Ltd, 1 Buckingham Court, Dairy Road, Chelmsford, Essex. CM2 6XW
Email : salessmart-support@dbsdata.co.uk

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14. Our contact details


Sales Smart Ltd
Registered in England & Wales 08566812
Registered with the ICO ZA020185
Registered Office: 1 Buckingham Court, Dairy Road, Chelmsford, Essex, CM2 6XW

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15. The Information Commissioner’s Office


Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Helpline number: 0303 123 1113
www.ico.org.uk
If you are based outside the UK, please contact the relevant data protection regulator in your country.

Updated 27th March 2019

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Privacy Policy – Trading Personal Information



Who are we?


Our business compiles business information which we make available for our clients for their own sales and direct marketing activities. We undertake appropriate due diligence on our suppliers to ensure that they collect, share and process personal data in a fully compliant manner. Should you wish to object to us processing your details for this purpose you can opt-out by contacting us and we will add you to our suppression file.
In the course of our business, we buy business sales and marketing data on behalf of our clients which we purchase from our preferred suppliers whose data and processes we monitor to ensure compliance with the GDPR, The Data Protection Act 2018 and PECR.

Topics


1. What do we use your data for?
2. Legal Basis for Processing: Legitimate Interest & Consent
3. What types of personal data do we source, collect and share?
4. Who may we share your data with?
5. Do we transfer your data to other countries?
6. How long will we keep your data for?
7. What are your rights?
8. Do we collect data from other sources?
9. When might we have to share your data?
10. Cookie Policy
11. Our Contact Details
12. The Information Commissioner’s Office
13. Changes to our privacy policy

1. What do we use your data for?


The data that we buy from our suppliers for our clients is for marketing, market research, analysis, data cleansing and profiling.
This means we share your details with reputable companies who may want to contact you by post, telephone or email to offer you goods and services that may be of benefit to you. You can ask us to stop sharing your details at any time now or in the future.
They may also profile your information. This means that they might use some of your information to help them segment data and select target audiences where analysis indicates that you may be more interested in their communications. We do not make automated decisions about you which may have a negative impact on your rights.
If we receive your details from more than one supplier, we may combine the information that they provide about you to create a single view of your details to help our clients personalise the communications they send you and make them more relevant and interesting for you. It will also help to ensure that they keep your details accurate and up to date.

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2. Legal Basis for Processing


When supplying your information to our clients for direct marketing we will rely upon legitimate interests as our legal basis for processing your data.
Direct marketing has been recognised explicitly as a legitimate interest in the GDPR (recital 47). We and our clients can rely on legitimate interest as a legal basis to process your information where our commercial interest does not override that of the data subject.
We and our clients will make decisions to ensure we are only processing your data when it’s been collected fairly and lawfully and that you would have a reasonable expectation of the data processing activities.

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3. What types of personal data do we source and collect?


The information we collect includes your name and contact information such as your job title, job function, company details, telephone number, email address, mobile number and postal address.

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4. Who may we share your data with?


Businesses & Organisations:
These are our clients who wish to promote their products and services to decision makers like you, within businesses or organisations.

Marketing Service Providers:
Such as marketing and advertising agencies who have approached us to help them source data on behalf of their clients. The marketing services providers we work with are strictly limited to only those organisations who we have completed checks on and who will process your data in strict compliance with all laws, regulations and guidance with regard to data protection.
We will share your data under strict licence terms which dictate their responsibilities and how their clients may make use of your details.

Our Group of Companies:
We might also share your details within our group of companies:
  • DBS Datamarketing Ltd
  • DBS Data
  • Sales Smart Ltd

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5. Do we transfer your data to other countries?


In the main we store your data in the UK and our clients also operate in the UK. From time to time we or our suppliers might use data processors who are, or whose software services are, cloud based outside of the EEA, primarily in the United States but under strict contract rules that ensure your personal details are only processed under the same laws that we operate under here in the UK.

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6. How long will we keep your data for?


We will only keep your personal details for as long as is necessary. Usually this means that following each delivery of data to us from a supplier we will retain and process the data for up to three months. We will retain any data that we collect from publicly available sources for up to 18 months. You can opt-out and have your details removed any time.

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7. What are your rights?


You have a number of important data protection rights which include:

1. Right to be informed –
We do this by informing you throughout this privacy policy.

2. Right of access –
You have the right to contact us to request details of the information we hold about you.

3. Right of rectification –
You have the right to ask us to rectify information that we hold about you if it is inaccurate or incomplete

4.Right to erasure –
This is also known as the right to be forgotten and gives you the right to request your information be removed if there is no compelling reason for its continued processing. Under these circumstances we will suggest to you that we add limited details about you to our suppression list which we will use to remove your details from any data that any suppliers deliver to us in the future.

5. Right to restrict processing –
This is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.

6. Right to data portability –
This gives you the right to ask a holder of your information to transfer that information to another business.

7. Right to object –
You have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. You also have the right to ask us to cease processing based on our legitimate interests, where there is no overriding justification for the processing of your data. Your rights and freedoms override our interests.

8. Rights related to automated decision-making including profiling –
We do not use automated decision-making processes which would have a potentially damaging effect on you. But if we did, you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.

9. Right to withdraw consent at any time where relevant –
You have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information to need to do so, at the time we collect your data and each time we contact you. You can withdraw consent in the following ways:
If we email you, click the unsubscribe link within the footer of the email.
You can call our Compliance Officer on 01245 397 570
Write to us: The Compliance Officer, Sales Smart Ltd, 1 Buckingham Court Dairy Road, Chelmsford, Essex CM2 6XW
Contact us here
Email us: salessmart-support@dbsdata.co.uk

10. Right to lodge a complaint with a supervisory authority –
If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include:
  • The Information Commissioners Office
  • The Direct Marketing Association

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8. Do we collect data from other sources?


We buy and receive personal information from third party suppliers as part of our data broking activities. When we do so we check that they have collected your details fairly and lawfully and that they comply with all applicable data protect regulations. Our suppliers include organisations that compile specialist business databases on a commercial basis, credit reference companies and public sources such as Companies House and research companies.

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9. When else might we have to share your data?


On rare occasions we may be asked to share your information for the prevention of crime, on legal grounds or with regulatory bodies who are investigating complaint made by a consumer or for any other reason as required by law.

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10. Cookie policy


We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate.

COOKIE NAME PURPOSE
ASP.NET_Sessionid
(Identifies users session on server)
_aidcookie Contains Affiliate ID
_contact_num Contact number of current person filling in the survey
_cookie checking of input if valid
_ega age of user
_qahash Question answer hash
_qt Value to determine what part of the survey they are currently in
_vh Unique identifier for the person who filled in the survey on the site
Google Analytics
(uses cookies to provide meaningful reports about site visitors. They do not collect the user’s personal data)
_utma Identifies users and sessions e.g.amount of visits (for each visitor), the time of the first visit, the previous visit and the current visit
_utmb Identifies new sessions/visits e.g. page views
_utmz Stores entry point into the site – the traffic source of campaign that explains how the user reached your site. E.g search engine, search keyword, link from another site etc
_utmx Used for A/B or multivariate testing using Google web optimiser

Please note that our advertisers may also use cookies, over which we have no control. You can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies.
However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our site.

Other Websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

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11. Our contact details


Sales Smart Ltd
Registered in England & Wales 08566812
Registered with the ICO ZA020185
Registered Office: 1 Buckingham Court, Dairy Road, Chelmsford, Essex, CM2 6XW

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12. The Information Commissioner’s Office


Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Helpline number: 0303 123 1113
www.ico.org.uk
If you are based outside the UK, please contact the relevant data protection regulator in your country.

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13. Changes to our privacy policy


We keep our privacy policy under regular review and we will place any updates on this web page.

Updated 27th March 2019

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