Data Privacy

A Privacy Policy  –  SmithMartin LLP

GDPR Safe Data image

This Privacy Policy published May 25, 2018. (Last updated: June 4th 2018)

SmithMartin LLP makes significant efforts to preserve your privacy and to comply with the European GDPR regulations. (The European General Data Protection Regulation ).

We are  careful and sensitive to and about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.

We store personal information for only as long as we have a reason to keep it – only keeping data that is core to our business and minimum for our needs.

As a multi-faceted social business we do feature ‘advertorial’ or banner content for a range of Partnership services. We do not, however, track you or post web beacons, tracking pixels or cookies as part of our service reference process.

We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.

We aim for full transparency on how we gather, use, and share your personal information.

Who We Are and What This Policy Covers

This Privacy Policy applies to information that we collect about you when you use:

Our websites (including smithmartinpartnership.com, Changethinking.co.uk, Thirdsectorweb.co.uk, Mining the Seem, conversationsEAST.org, BookMonitor, BooksgoWalkabout.com, Enterprisingcommunities.org, Dolphinbooksellers.co.uk, CollectedWorks) and all other sites in our web family, or which are pending launch .

Our other products and services that are available on or through our websites, and other users’ websites that use our Services, while you are logged in to your account with us.

Throughout this Privacy Policy we’ll refer to our websites and services collectively as “Services.” Our Data Controller details are available below…

How we collect, use, and share information about you, along with the choices that you have with respect to that information.

Creative Commons Sharealike License

Creative Commons License
This work is licensed under a Creative Commons Attribution-ShareAlike 4.0 International License.

Much of our web content is published under a Creative Commons Sharealike license, like this privacy narrative. You’re more than welcome to copy it, adapt it, and repurpose it for your own use.

Make sure to revise the language so that your policy reflects your actual practices.

Information We Collect

We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.

We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources.

It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

Basic Account Information: If you are subscribing to a SmithMartin LLP account, for web hosting for example, we may ask for basic information from you in order to set up your service account.

Transaction and Billing Information: If you buy something from us– a subscription to a custom built and managed domain, or a book for example – you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.

Ecommerce Site Information: If you use our ecommerce Services to buy or to sell products or services to others through your own site. You may also provide us with information about your financial account to set up a payments integration, such as the email address for our Stripe payment portal. We regard confidentiality within our systems as an inviolate principle.

We never see or store your banking and transaction details anywhere in our company records., if your service is processed by Google, Plasso or Stripe for example.

Content Information: Depending on the Services you use, you may also provide us with information about you in draft and published content (such as for your website or an article for one of ours). For example, if you write a blog post that includes biographic information about you, we will have that information, and so will anyone with access to the Internet if you choose to publish the post publicly.

Credentials: Depending on the Services you use, you may provide us with credentials for your website (like SSH, FTP, and SFTP username and password). We now build almost exclusively in WordPress and your Jetpack and VaultPress users may provide us with these credentials in order to use our one-click restore feature if there is a problem with their site, or to allow us to troubleshoot problems on their site more quickly.

Communications With Us : You may also provide us information when you respond to surveys, communicate with our Partners and/or Associates about a support question, or post a question about your site in our message and client support panels.

Information We Collect Automatically

We also collect some information automatically:

Log Information: We do not automatically log personal information, although third party suppliers of our service elements may do so. For example, Google, Plasso and Stripe – who are themselves GDPR complaint.

Usage Information: We collect anonymous information about your usage of our Services. For example, we collect information about the number of site visits, page views etc. We use this anonymous data to map and plan our sites effectiveness for future users.

We do not explicitly seek to capture or store location information, of any kind, from the delivery of our services.

Information from Cookies & Other Technologies:

We never plant cookies or pixel tags etc., for example. However, third party suppliers across the globe regularly do so.

Information We Collect from Other Sources

We may also get information, such as a mailing address, from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services.

How And Why We Use Information

Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

To provide our Services–for example, to set up and maintain your account, host your website, backup and restore your website, or charge you for any of our paid Services;

To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to create and manage their websites more efficiently;

To monitor and analyse trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;

To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyse how many individuals purchased a service or product after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;

To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of SmithMartin LLP and others, which may result in us declining a transaction or the use of our Services;

To communicate with you, for example through an email, about offers and promotions offered by SmithMartin LLP, or one of its other web based services, if we think it will be of interest to you, solicit your feedback, or keep you up to date on SmithMartin and our products;

To personalise your experience using our Services, provide content recommendations (for example, through our book reviews, book articles or sales functions), in order to target our marketing messages to groups of our users (for example, those who have a particular subscription with us or have been our user for a certain length of time), and to serve relevant, non-tracking ‘internal’  advertisements.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfil our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account– for example, in order to enable access to our website on your device or charge you for a paid plan or product purchase; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or

Sharing Information

How We Share Information

We do not sell our users’ private personal information.

We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.

Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site.

This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyse fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, registrars, registries,  and your hosting provider if your site is not hosted by SmithMartin LLP or one of its subsidiaries), those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and companies that make products available on our websites (where, for example, we occasionally feature goods or services compatible with our ethical business stance.), who may need information about you in order to, especially, provide technical or other support services to you which we do not possess or offer.

We require 3rd Party vendors to subscribe to or be in agreement with our privacy commitments in order to share information with them.

Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.

To Protect Rights, Property, and Others:

We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of SmithMartin LLP, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.

With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorise us to do so, such as the social media services that you connect to. (We ethically use Twitter too, for example)

Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.

Published Support Requests: And if you send us a request (for example, via a support email or one of our feedback mechanisms), we reserve the right to share that request in order to help us clarify or respond to your request or to help us support other users, with your permission.

Information Shared Publicly

Information that you choose to make public is –’you guessed it’–disclosed publicly.

That means, of course, that information like your public profile, posts, other content that you make public on your website, and your “Likes” and comments on other websites, are all available to others–and we hope you get a lot of views!

Please beware that public information may also be indexed by search engines or used by third parties.

How Long We Keep Information

We always discard information about you when we no longer need the information for the purposes for which we collect and use it.

We may keep the web server logs that record information about a visitor to one of SmithMartin’s websites, such as the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyse traffic to SmithMartin’s websites and investigate issues if something goes wrong on one of our websites, for example.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorised access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

To enhance the security of your account, we encourage you to enable our advanced security settings, like Two Step Authentication.

Choices

You have several choices available when it comes to information about you:

Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible to you.

Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.

Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services you can close your SmithMartin account. Please keep in mind that we may continue to retain your information after closing your account, for legal obligations such as law enforcement requests, or reasonably needed for our legitimate business/legislative/accounting interests.

Your Rights

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

Request access to your personal data;

Request correction or deletion of your personal data;

Object to our use and processing of your personal data;

Request that we limit our use and processing of your personal data; and

Request portability of your personal data.

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.

EU individuals also have the right to make a complaint to a government supervisory authority.

Controllers and Responsible Companies

SmithMartin Services are worldwide. Different SmithMartin companies and web entities are the controller (or co-controller) of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.

Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is SmithMartin LLP, the entity that entered into the contract with you under the Terms of Service for the the product or service you use.

To exercise your rights, please communicate with 

datacontroller@smithmartinpartnership.com

You can write to us:

Group Data Controller

Tim Smith MA FRSA

SmithMartin LLP

Carthouse 3

Copley Hill Business Park

Babraham, Cambridge, CB21 3G

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us.

Supporting projects with SmithMartin LLP
Our Partnership logo…

Working with schools, children's centres, charities and social business across the UK and beyond…