- 1. Advantage Smollan Ltd (a company registered in England and Wales with registration number 09506907 and registered address c/o Legalinx Ltd, 1 Fetter Lane, London EC4A 1BR) believes in protecting the personal data it collects from individuals (“users”) that access or use the website situated at www.advantagesmollan.com (“the website”) and it takes seriously its obligation to comply with its obligations under the General Data Protection Regulation (GDPR).
- 3. Advantage Smollan is a data controller of users’ personal data (as detailed below) which is collected through the website, such as when users submit queries through the “contact us” function on the website or as is otherwise described in this policy. As a data controller, Advantage Smollan maintains a notification of its data processing activities with the Information Commissioner’s Office (ICO) (www.ico.org.uk) and its registration number is ZA240709
- 4. Advantage Smollan reserves the right in its sole discretion to amend this policy from time to time. In this event, Advantage Smollan will post the revised policy on the website. Advantage Smollan encourages you to periodically view this policy so that you remain informed as to how it is protecting users’ personal data and about what cookies are used on the website. Advantage Smollan may, where necessary, notify users of any modified version of this policy that might materially affect the way it uses, discloses or otherwise processes users’ personal data or otherwise affect their privacy rights. Advantage Smollan may do this by posting an update on the website which users will see at their next visit.
- 5. Personal data
For the purposes of this policy, “personal data” is data which relates to a living individual who can be identified from the data or from that data and other information which is in the possession of, or likely to come into the possession of, Advantage Smollan.
Personal data Advantage Smollan collects about users through their use of the website may include, but is not limited to, a user’s name, contact details, personal views and preferences, and navigational data. The website also collects information gathered though using cookies (see further details below).
- 6. Active collection of personal data
The website actively collects personal data from users by asking users specific questions and by permitting users to communicate directly with Advantage Smollan, for example via e-mail, and feedback forms.
Some areas of this site may also require the user to submit information in order for the user to register for certain services or benefit from specified features (for example newsletter subscriptions,).
In these situations, Advantage Smollan will ask the user for particular information (including personal data), and inform the user at each information point what information is required and what information is optional.
- 7. Passive collection of personal information
Advantage Smollan passively collects (i.e. without the user actively providing the information) personal information about a user as the user accesses and navigates through the website using various technologies and means, such as navigational data collection and cookies.
Cookies are text files that are stored on users’ computers, smartphones or other electronic Internet-enabled devices when they first access the website and when they revisit certain pages of the website.
When users use the website they will be using a browser and this means that they can control, block or restrict cookies through their browser settings. Information on how to do this can be found within the Help section of the browser used. All cookies are browser specific. Therefore, if a user uses multiple browsers or devices to access websites, they will need to manage your cookie preferences across all of these elements. In addition when a user first visits our website they will see a cookies consent banner or pop-up which draws their attention to the fact that cookies are used and which links through to this policy.
There are also several online resources that can provide more information on cookies and how they can be controlled within a variety of different web browsers. Please visit either http://www.aboutcookies.org or http://www.allaboutcookies.org for more information.
If a user uses a mobile device to access the website, they will need to refer to their instruction manual or other help/settings resource in order to find out how to control cookies on the particular device.
Please note: if a user restricts or deletes cookies, they may experience a loss of functionality while accessing the website and they will be treated as a first time visitor the next time they visit the website.
The website uses session cookies (which expire once a user closes their web browser). The website may also use persistent cookies (these remain on a user’s computer or other device when they close their web browser – until such time as they expire or the user deletes them).
Advantage Smollan has grouped the cookies by the website into the following categories, to make it easier for you to understand why we use them:
- Strictly Necessary: these cookies are strictly necessary for the website to work properly and for Advantage Smollan to keep to seek it secure. They are needed to allow users to use the website and its features and to move between pages of the website.
- Functionality: these cookies enable technical performance of the website and allow Advantage Smollan to ‘remember’ the choices users make and their preferences. They allow Advantage Smollan to give a better online experience. They also help Advantage Smollan to track performance of the website.
- Performance/Analytical: these cookies allow Advantage Smollan to collect certain information about how a user navigates the Website. They help Advantage Smollan to understand which parts of the website are interesting to users and which are not as well as what it can do to improve the website. They also help Advantage Smollan to identify when lots of people give up on an application process at a particular step – so we can try to make that step easier to use.
Cookie is set by:
Web analytics service offered by Google that tracks and reports website traffic.
You might notice that some cookies on the website are not related to Advantage Smollan (i.e. the company which operates the website). This is because some of the pages on the website contain embedded content from third party websites – such as video from YouTube for example. Because this content is from another website, Advantage Smollan does not control the cookies which relate to this. If a user wants to change their cookie preferences to block these third party cookies, they should check the third party websites for information on how to manage their cookies.
Advantage Smollan may also embed social sharing icons throughout the website. These sharing options are designed to enable users to easily share the website’s content with their friends using a variety of different social networks. These social sharing sites may set a cookie when a user is logged into their service. Please note that Advantage Smollan does not control the dissemination of these cookies and users should consult the relevant third party website for information on how these cookies are used and how the user can control them.
- 8. Advantage Smollan’s use of user’s personal data collected through the website
The personal data that Advantage Smollan may collect via the website, use and store is required for Advantage Smollan’s provision of the website, to manage and administer the website and for incidental purposes such as the prevention of fraud, in addition to the following more general purposes:
8.1 to improve the content of the website or any of the services provided by Advantage Smollan (“Advantage Smollan services”);
8.2 for marketing, product research and development purposes of Advantage Smollan.
This list is not intended to be exhaustive and may be updated from time to time as business needs and legal requirements dictate.
- 9. Disclosure of user’s personal information
Advantage Smollan will not disclose, for commercial gain or otherwise, users’ personal information other than as set out in this policy.
- 10. Accuracy of personal information and your rights to access your personal data
In order to ensure that a user’s personal information is accurate, current, and complete, the user may contact Advantage Smollan at the contact details below:
Advantage Smollan Ltd, 210 Wharfedale Road Winnersh Triangle, Berkshire RG41 5TP Telephone: +44 (0)118 927 1010 Email: firstname.lastname@example.org
If Advantage Smollan believes that the personal data held about the user is not accurate or complete, it will correct or update such personal data. Advantage Smollan will respond to the user’s request within a reasonable period after the request is made. If we do not consider the personal data we hold to be inaccurate or out of date, we will explain why.
In addition, individuals have the right to access the personal data that Advantage Smollan holds about them upon request. However there are some circumstances in which Advantage Smollan may refuse to provide access or only provide partial access to this personal data where that is permitted by law. A nominal fee may be charged (currently GBP 10) for dealing with these requests for access to personal data. To exercise your rights to access your personal data you would need to contact Advantage Smollan in writing. For this purpose please contact us at Advantage Smollan Limited, 210 Wharfedale Road, Winnersh Triangle, Berkshire RG41 5TP.
- 11. Security
In accordance with its obligations under the General Data Protection Regulation (GDPR), Advantage Smollan takes steps to put in place adequate technical and organisation security measures to –
- 11.1 to ensure the accuracy of;
- 11.2 to prevent unauthorised access to or disclosure of; and
- 11.3 to protect from misuse, loss, alteration or destruction users’ personal data.
- However, the user acknowledges that that Internet communications and transactions are not 100% secure or error free. In particular, information may not be secure in transit from the user to the website.
- 12. Linking to third party websites
- 13. Queries and complaints