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SMARTBOX- WEBSITE PRIVACY STATEMENT

1. WHAT IS A PRIVACY STATEMENT


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. ACKNOWLEDGEMENT OF THIS STATEMENT


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. PERSONAL DATA SMARTBOX COLLECTS FROM YOU


3.1 We will collect and process the following personal data from you:

Category of Data Information collected and processed
Browsing Information

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:

  • Automatically Collected Information: Some personal and non-personal data is automatically received and sometimes collected from you/your device when you visit the Site. We receive and collect the name of the domain and host from which you access the Internet; the Internet protocol (IP) address of the computer you are using; the browser software you use and your operating system and the date and time you access the Site.
  • Information Collected via the Site (Cookies): For the same reason as we collect and process Automatically Collected Information, we use cookies to deliver a better and more personalised browsing and shopping experience on the Site. For more information, please see our [ Cookies Policy.
  • Other Information Collected via the SiteTo help us understand the effectiveness of certain of our email marketing efforts, Smartbox may use “message format” and “message open” sensing technologies. Both technologies require the use of certain technologies. For further information, please see our Cookies Policy.
  • If you’re browsing with Smartbox apps, you can decide to enable Smartbox to see your current location or grant access to your contact details – this helps us provide you with the best possible service and experience (for example, to see the nearest restaurants or attractions to your location or other recommendations).

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
  • • Information that you provide to us when creating a customer account and subsequently using the Site, availing of our services, purchasing our gift packs or verifying the validity of our gift packs. This information may include your name, birthdate, phone number, email address, billing address, shipping address, phone number, credit card information, and any preferences ( such as meal preference and any mobility restrictions) you might have for your trip.
  • • If you choose to correspond with us through the Site, we will keep a record of this correspondence for as long as is necessary to deal with this query. Please see our section on How Long We Keep Your Personal Data For, for further information on how long we retain this information.
  • • If you choose to purchase a gift pack or e-pack on the site for a third party beneficiary, you may need to provide us with information about the beneficiary during the ordering and/or reservation process. In such circumstances, it is your responsibility to make sure the beneficiary or beneficiaries would have no objection to you sharing their personal data for the purposes set out in this Statement.
  • • We may also ask you to complete surveys from time to time that we use for research purposes, although you do not have to respond to them and you may elect not to receive such surveys.
CV Information
  • • You may choose to give us additional information such as your name, gender, address, email address, university education, professional qualifications, previous employment, salary and other details when applying for vacancies advertised on the Site by submitting a job application through the Site.
  • • If you provide us with this information, we will keep a record of this information for as long as is necessary to process and handle your application (please see our section on How Long We Keep Your Personal Data For, for further information).

4. HOW & WHY WE USE YOUR PERSONAL DATA


4.1 The following table details the legal basis for (the "Legal Basis") and the reasons why ("Purposes") we process your Personal Data:

Legal Basis Purpose(s)

Contract

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

  • • To provide you with access to the Site and to allow you to use the Site.

Fulfilling your Orders and Requests

  • • To provide you with information, services and gift packs that you request from us and to fulfil orders placed through the Site.
  • • To register, process and complete your orders and/or reservations.
  • • To manage your customer account and/or beneficiary account.
  • • To prevent the fraudulent use of gift vouchers.
Consent

Marketing

  • • To provide you with information relating to Smartbox services which may be of interest to you where you have consented to receive such marketing or are an existing customer.
  • • For third parties/Smartbox to provide you with information relating to third party products and/or services where you have consented to receive such marketing.

Legitimate Interests

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

  • • To provide, improve, test and monitor the effectiveness of the Site.
  • • To monitor metrics such as total number of visitors, traffic data and demographic patterns.
  • • To ensure the content on the Site is presented in the most effective manner for you and to enhance your use of the Site.

Responding to Queries and Complaints

  • • To process and respond to any enquiries, requests and complaints you may submit to us via the Site or via our customer services .
  • • To respond and handle any requests you or your booked Partner have made.
  • • If you have not finalized a Stay Reservation online, we may contact you with a reminder to continue with your reservation.
  • • To seek your views on the Site and our services.

Notify You of Changes

  • • To notify you about changes to the Site and/or our services.

Postal Marketing

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

  • • To provide prizes for any draws you have entered and won
  • • To remind you about the expiry date of a gift you have registered
  • • To let you know about possible upgrades for a booking you have made
  • • To contact you some time after you purchase a gift, either to request feedback or to promote other gifts that might be of interest to you
  • • To send you questionnaire or invite you to provide a review about your experience with Smartbox or the Partner.

Call monitoring:

  • • When you make calls to our customer service team, Smartbox will use the number to connect to your customer record ,this can help save time for both you and our customer support staff. Our customer service may still ask for authentication, which ensures that your personal details are kept confidential.
  • • During calls with our customer service team, live listening may be done or calls may be recorded for quality control and training purposes which includes the usage of the recordings for the handling of claims and fraud detection purposes. Recordings are kept for a limited amount of time and automatically deleted, unless Smartbox has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.

Responding to Job Applications

  • • To process and respond to any job applications you submit to us via the Site.

Legal purposes:

  • • Finally, in certain cases, we may need to use your information to handle and resolve legal disputes, for regulatory investigations and compliance, to enforce the terms of use of the Smartbox online reservation service or to comply with lawful requests from law enforcement.

5. RECIPIENTS OF YOUR PERSONAL DATA


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:

Recipient(s) Purpose(s)
Smartbox Gift experience partners.
  • • To confirm your registration.
  • • Smartbox transfers relevant details you provide to the partner providing your experience, to enable them to provide that experience. This will be name and contact details as well as any preferences you express.
  • • In cases of reservation-related disputes, we may provide the Partner with information about the reservation process as needed. This may include a copy of your reservation confirmation as proof that a reservation was actually made.
  • • To provide you with appropriate and efficient support.
  • • To send you promotional or direct marketing material (in circumstances where you expressly consented to receiving any such material from third party partners).
  • • To verify the validity of any Smartbox gift packs purchased through the Site.

[*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.
  • • To assist Smartbox in providing the products, services and gift packs offered through the Site.
  • • For logistical and IT service purposes.
  • • To send you customer satisfaction surveys or polls which will be anonymised for statistical purposes to improve your Site experience.
Regulatory Authorities, Law Enforcement Agencies, Public Bodies and Third Party Companies
  • • To comply with any applicable legal obligation, court order, summons, search warrants, or any other legal or regulatory obligation or request to which Smartbox is subject.
  • • To protect the rights, property or safety of Smartbox, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • • To enforce or apply the Terms and other agreements or to investigate potential breaches.
Prospective Sellers or Buyers of Business Assets
  • • To facilitate the acquisition of Smartbox by a third party.
  • • To facilitate the acquisition of a significant portion or substantially all of Smartbox's assets by a third party

6. STORING OF AND TRANSFERS OF YOUR PERSONAL DATA


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. LINKS


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. HOW LONG WE KEEP YOUR PERSONAL DATA FOR


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. YOUR RIGHTS AND HOW TO EXERCISE THEM


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 Further Information
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:

  • 1. your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us;
  • 2. you withdraw your consent and no other legal ground permits us to process your personal data;
  • 3. you object to the processing and there are no overriding legitimate grounds for the processing;
  • 4. your personal data have been unlawfully processed; or
  • 5. your personal data must be erased in order to comply with a legal obligation.

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:

  • (1) where you contest the accuracy of your personal data;
  • (2) where the processing is unlawful and you do not want us to delete your personal data;
  • (3) where we no longer need your personal data for the purposes of processing but you require the data in relation to a legal claim; or
  • (4) where you have objected to our processing of your personal data pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms or in connection with legal proceedings.

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:

  • (1) we process your personal data on your consent or where it is necessary to perform our contract with you; and
  • (2) the processing is carried out by automated means.
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
Canal House
Station Road
Portarlington
County Laois
Phone:+353 57 868 4800 / +353 761 104 800
LoCall: 1890 25 22 31
Email: info@dataprotection.ie
Fax: +353 57 868 4757

10. CHANGES TO THIS STATEMENT


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.