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1.1 The [www.smartbox.com/ie] website (the “Site") is operated by [Smartbox Group Limited of Joyce's Court, Block A, Talbot St, Dublin 1, D01 FV59, Ireland] (hereafter “we”, “us”, “our”, “Smartbox"). This Privacy Statement ("Statement") together with the Site Terms and Conditions of Use ("Terms") and Cookies Policy sets out the basis on which any information or personal data we collect from users, or that you provide to us, will be processed by the Site. This Statement applies to the Site and all services offered by Smartbox through the Site. The information provided by you will be held by us as a data controller.
1.2 The following discloses our information gathering and dissemination practices relating to the Site. In order to fully understand your rights, we encourage you to read this Statement and to consult our Terms. Each time you use the Site you will be bound by the then current Statement and you should review this each time you use the Site.
1.3 Smartbox reserves the right to amend this Statement at any time in full or in part in accordance with Section 10.
2.1 By using the Site, you signify acknowledgement of this Statement. If you do not agree with any aspect of the Statement, you must discontinue use of the Site. We reserve the right to modify this Statement at any time in accordance with Section 10 of this Statement.
3.1 We will collect and process the following personal data from you:
|Category of Data||Information collected and processed|
When using the Site or availing of services related to the Site, personal information will be collected from you by Google Analytics and by Smartbox This includes:
3.2 You can choose to provide us with the following personal data:
When you use the Site, we receive and collect certain information and personal data about you, known as “Personal Customer Information”. The Personal Customer Information we receive and collect depends on what you do when you visit the Site. We may collect and process the following Personal Customer Information about you:
|Category of Data||Information collected and processed|
|Information You Provide||
4.1 The following table details the legal basis for (the "Legal Basis") and the reasons why ("Purposes") we process your Personal Data:
It is necessary to process these personal data to enter into and perform our contract with you regarding your use of the Site as set out in the Terms
Access to the Website
Fulfilling your Orders and Requests
Data is processed on this basis where we have a legitimate interest to process the data which does not impact your rights and freedoms.
We will collect and process personal data for the purposes of improving and monitoring website efficiency and enhancing your use of the Site.
If you are purchasing from the site or redeeming a gift we will process your personal data to respond to any queries or requests submitted by you regarding the Site, and to send optional upgrades or reminders in relation to a product that you have purchased or redeemed or in relation to other similar products.
If you are using the site to apply for a position at Smartbox, we will process and respond to CVs and/or job applications submitted by you to Smartbox and send you information.
Improving Website Functionality & Efficiency
Responding to Queries and Complaints
Notify You of Changes
To send you marketing information by post provided you have not objected during the collection of your data (please note that you may refuse to receive such marketing information by contacting DPO@smartbox.com).
Email Marketing and Communication
Responding to Job Applications
5.1 We will disclose your personal data to other members of our group which means our subsidiaries, our ultimate holding company and its subsidiaries (the "Smartbox Group") who provide aspects of the services and products provided through the Site.
5.2 We will only disclose your personal information to third parties outside the Smartbox Group in the following circumstances:
|Smartbox Gift experience partners.||
[*IMPORTANT*- Please note that we share only your name, email address and phone number with these recipients and do not share your bank details, deposits or identification documentation. ]
|Smartbox subcontractors and service providers.||
|Regulatory Authorities, Law Enforcement Agencies, Public Bodies and Third Party Companies||
|Prospective Sellers or Buyers of Business Assets||
6.1 Your personal data may be stored and transferred inside or outside the European Economic Area ("EEA"). We only transfer your personal data outside the EEA where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards or there are appropriate safeguards in place to protect your Personal Data. If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your personal data you can contact us at [DPO@smartbox.com].
6.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your personal data, we cannot guarantee the security of any information you transmit to us; any transmission is at your own risk. Once we have received your information, we will endeavour to use strict procedures and security features to try to prevent unauthorised access.
7.1 The Site may contain links to other websites ("Linked Websites"). Smartbox is not responsible for the privacy statements or practices on the Linked Websites. This Statement governs only information collected on the Site. When accessing Linked Websites, you should read the privacy statement published on the relevant Linked Website. The terms of our Statement do not apply to Linked Websites. Please check these statements before you submit any personal data to Linked Websites.
7.2 The Site contains links to other sites and resources provided by third parties for your convenience and information only. We accept no liability in connection with any Linked Website, or any contract entered into or through a Linked Website. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.
8.1 In general, we expect to keep your personal data for a period of three years from the last date that we have contact with you or, where you enter into a contractual arrangement with us, for three years following the end of the performance of our contract or your termination as a Smartbox employee.
8.2 We do not store the payment information that you provide to pay for a gift or upgrade.
8.3 If you provide account information so that we can transfer money to you, we will store this data as part of your record, but it will only be used to send money to you.
8.4 Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data, or where we have a legitimate interest in preserving your data this legitimate interest is not in conflict with your rights and freedoms.
9.1 The table below sets out the rights which you have to address any concerns or queries with us about our processing of your personal data:
|Right of Access||
You have the right to request a copy of the personal data held by us about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive.
|Right to Rectification||
You have the right to request that we amend any inaccurate personal data that we have about you.
|Right to Erasure||
You have the right to ask us to erase your personal data where:
We may not be able to comply with a request where we require your personal data for compliance with a legal obligation or in connection with legal proceedings or for exercising the right of freedom of expression and information.
|Right to Restriction of Processing||
You have the right to ask us to restrict processing your personal data in the following situations:
When you exercise this right we may only store your personal data. We may not further process the data unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest. We will inform you before the processing restriction is lifted.
|Right to Data Portability||
You may request us to provide you with your personal data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another data controller where this is technically feasible.
This right only arises where:
|Right to Object||
You have a right to object at any time to the processing of your personal data where we process your personal data on the legal basis of pursuing our legitimate interests.
You have a right to object at any time to the processing of your personal data for direct marketing purposes.
9.2 You can exercise any of these rights by submitting a request to DPO@smartbox.com.
You have the right to lodge a complaint with the office of the Irish Data Protection Commissioner with regards to us processing your personal. Full details on how to do this may be accessed on the complaints section of the Data Protection Commission's website: https://www.dataprotection.ie/docs/complaints/1592.htm and the contact details for submitting a complaint are as follows:
|Office of the Data Protection Commissioner
|Phone:+353 57 868 4800 / +353 761 104 800
LoCall: 1890 25 22 31
Fax: +353 57 868 4757
10.1 If we amend this Statement, in whole or part, any changes will be posted on this page and, where appropriate, notified to you by email or when you use the Site. The new Statement may be displayed on-screen and you may be required to read and accept it to continue your use of the Site.
10.2 If at any time we decide to use your personal data in a manner significantly different from that stated in this Statement, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail, and you will have a choice as to whether or not we use your personal data in the new manner.