Privacy Policy

Privacy Policy

EASTRON EUROPE LTD

PRIVACY NOTICE

This Privacy Notice applies where we are acting as a data controller with respect to the personal data we collect when you “customer, buyer, representative, agent” use the Services supplied by Eastron Europe Ltd “Company, Seller, Services”. You can request a full copy of our Company Privacy Policy www.eastroneurope.com.

In this Privacy Notice we explain how we collect, use and share your personal information “Data” in accordance with the European Union General Data Protection Regulation (GDPR).

Your privacy is important to us, and this policy is intended to help you understand what information we collect about you when you provide it to us; when you use our Services; when we share it; and when other sources provide it to us, as further described below.

If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

1. Data We Collect

1.1 Account Information:

We collect information about you when you register for an account with us “account data” whether in writing, by telephone, by email or make purchases through our online Services. To create an account you need to provide information such as your full name, address (business/residential), contact number, email address and billing information (e.g. credit card details), and when you register for the online Services you will need to set up a password. We also keep track of your preferences when you select settings within the online options to carry out your service specification.

1.2 Your use of the Services:

We collect certain information about you when you set up an account and interact with our Services. This information includes the products you purchase, your name, contact number, email address, installation address and the source of the account data - you or your employer or agent. The account data may be processed for the purposes of operating our business, providing our Services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. We may use your data to authenticate access to your account.

1.3 Payment Information:

We collect payment and billing information when you register with Eastron Europe Ltd. Upon registration we ask you to designate a billing representative providing name, address and contact information, including payment information such as payment card details, which we collect via secure payment processing services. The payment information "transaction data" we process relating to transactions will also include; purchases of goods and services that you enter into with us direct and/or through our website. The transaction data will be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.

1.3.1 Financial transactions relating to our website and services:

Your transaction data may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. Where you have made a request for credit and instructed us to complete the credit processing on your behalf (e.g. credit form) such processing will be in accordance with this policy.

1.4 Information contained in or relating to any communication you send to us:

We use your contact information "correspondence data" to communicate with you about our Services, to send transactional communications via email and telephone including; providing quotations; confirming your purchases; reminding you of appointments; responding to your questions and requests; providing customer support; sending technical feedback; updates; security alerts; along with administrative messages.

We may also process the communication content and metadata associated with any communication we receive from you online. Using our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.

1.5 Information we receive from other sources:

We receive information about you from other third party services and from our business group and channel partners. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries). We may disclose specify personal information category or categories to our suppliers or subcontractors insofar as reasonably necessary for the purposes of delivering our services.

We may disclose your personal information to one or more of those selected third party suppliers of goods and services identified from our business group and channel partners for the purpose of enabling them to contact you so that they can

offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to

the personal data that we supply to them; and upon contacting you, each such third party will supply to you a copy of its own

privacy policy, which will govern that third party's use of your personal data.

1.6 Information we collect automatically when you use the Services:

We collect information about you when you use our Services, including browsing our website, use of our online Services and

taking certain actions within the Services. We log usage data “usage data” when you visit or otherwise use our Services,

including our site analytics or interact with ads (on or off our site), perform a search or share articles.

1.7 Cookies and Other Tracking Technologies:

We collect data through cookies and similar technologies (as described in our Cookie Policy). When you first visit our

website, we ask that you consent to our use of cookies and similar technologies in accordance with the terms of this policy.

You can also opt-out from these cookies through your browser settings and other tools. For further information please see

our Cookie Policy, which includes information on how to control or opt-out of cookies and tracking technologies.

2 How We Use Your Data

2.1 How we use the information we collect:

The information we use will depend in part on which Services you use, how you use them, and any preferences you have

communicated to us. Below are the specific purposes for which we use the information we collect about you.

We use your data “service data” to provide, support, customise and develop our Products and Services. The way we use your

personal information will depend on which Products/Services you purchase, your requirements and the purchase

specifications; including request for credit. We use the information that we have about you to operate and maintain the

Services, to provide and customise your purchases, provide customer support, manage sales and technical departments and

to tailor our Services so that they can be more relevant and useful to you and others.

2.2 Website support:

We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze

crash information, and to repair and improve the Services. Where you give us permission to do so, we share your information

with an Expert for the purpose of responding to support-related requests.

2.3 How we share your personal data:

We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence

of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In addition to the specific purposes for which we may process your personal data set out in this policy; we may also process

any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject,

or in order to protect your vital interests or the vital interests of another natural person.

2.4 To market, promote, and drive engagement with the Services:

We use your contact information and information about how you use the Services to send promotional communications that

may be of specific interest to you, including by email and by displaying ads on other companies' websites and applications.

These communications are aimed at driving engagement and maximizing what you get out of the Services, including

information about new products, features, articles and special offers we think may be of interest to you.

You may instruct us at any time not to process your personal information for marketing purposes. In practice, you will

usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide

you with an opportunity to opt-out of the use of your personal information for marketing purposes.

2.4.1 With your consent:

We use information about you where you have given us consent to do so for a specific purpose not

listed above. For example, we may publish testimonials or featured customer stories to promote the

Services, with your permission.

2.5 International transfers of information we collect:

We provide information about the circumstances in which your personal data may be transferred to countries outside the

European Economic Area (EEA). We and our partner group companies have suppliers/manufactures in China. The transfer

of your personal data will only be to the extent to meet service obligations in accordance with this policy. The European

Commission has made an adequacy decision with respect to the Data Protection Laws of these countries, that transfers to

these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or

approved by the European Union, a copy of which can be obtained here.

3 How We Store and The Retention of Your Data

3.1 How we store and secure information we collect:

We use suitable storage facilities for our internal record-keeping, with appropriate security measures used to protect such

data; including preventing unauthorised access, reckless alteration and theft. We also use website hosting service providers

to host the information we collect, and we use technical measures to secure your data.

While we implement safeguards designed to protect your information, no security system is impenetrable and due to the

inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on

our systems or otherwise in our care, is absolutely safe from intrusion by others.

3.2 Retention of information:

How long we keep information about you depends on the type of information, as described in further detail below. After such

time, we will either delete or archive for later deletion; if this is not possible, then we will securely store your information and

isolate it from any further use until deletion is possible.

Our retention period for processing personal data for any purpose or purposes shall not be kept for longer than is necessary.

We comply with our legal obligations in relation to the retention and deletion of personal data. We retain your online account

information until you delete your account. We also retain some of your personal information as necessary to comply with our

legal obligations, to resolve disputes, to enforce our agreements and to continue to develop and improve our Services.

4 Your Rights

There are certain rights available to you when it comes to your personal information. Below is a summary of those rights, how

to exercise them and any limitations. Accordingly, you should read the relevant laws and guidance from the regulatory

authorities for a full explanation of these rights at www.gov.uk/data-protection.

Your principal rights under Data Protection Laws are:

a) the right to access;

b) the right to rectification;

c) the right to erasure;

d) the right to restrict processing;

e) the right to object to processing;

f) the right to data portability;

g) the right to complain to a supervisory authority; and

h) the right to withdraw consent.

4.1 Access and updating your personal information:

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the

personal data, together with certain additional information. That additional information includes details of the purposes of

the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and

freedoms of others are not affected, we will supply to you a copy of your personal data. Upon this request your first copy is

free of charge; all subsequent copies may be subject to a reasonable fee £10. You can request access to your personal data

record for portability; to move, copy or transfer your personal data from one IT environment to another in a safe and secure

way, without hindrance to usability. You may make this request by visiting our website www.smartprocess.co.uk. We will

respond to any requests about this within one month.

4.1.1 Rectified inaccurate data:

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes

of the processing, to have any incomplete personal data about you completed.

4.2 Erasure of your information:

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances

include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise

processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable

Data Protection Laws; the processing is for direct marketing purposes; and the personal data has been unlawfully processed.

However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for

exercising the right of freedom of expression and information; to complete transactions; for compliance with a legal

obligation; or for the establishment, exercise or defence of legal claims. You may also request that we delete your online

account as provided in the terms of this policy.

4.3 You have the right to restrict the processing of your personal data:

You may contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the

personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of

legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been

restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: without

your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or

legal person; or for reasons of important public interest.

Our online Services give you the ability to access and update certain account information about you from within the Service.

For example; you can access your profile information from your dashboard and update your profile within your profile

settings or delete your account entirely.

4.4 Request that we stop using your information:

In some cases, you may ask us to stop processing your personal information where you gave us consent to use your

information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that

had already taken place at a previous time. You can also opt-out of our use of your information for marketing purposes by

contacting us. When you make such requests, we may need time to investigate and facilitate your request.

4.5 Object to our processing of your personal data:

You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only

to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried

out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests

pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we

can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the

processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for

direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at

your request prior to entering into a contract, and such processing is carried out by automated means. You have the right to

receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does

not apply where it would adversely affect the rights and freedoms of others.

You may exercise any of your rights in relation to your personal data by writing to us.

If you have unresolved concerns, you also have the right to complain to a data protection authority in the country where you

reside, where you work or where you feel your rights were infringed.

4.6 Opt out of communications:

You may opt-out of receiving promotional communications from us by using the unsubscribe link within each email, and

updating your email preferences within your Service online account settings menu, or by contacting us.

5 Changes

5.1 Changes to the Privacy Policy:

We may update this policy from time to time by publishing a new version on our website. We encourage you to review our

Privacy Policy whenever you use the Services, to stay informed about our information practices and to ensure you are happy

with any changes to the policy. We will notify you of changes to this policy by email or on our website.

 

Contact Us: If you have questions or concerns about how your information is handled, please contact us.

 

Eastron Europe Ltd

Eastron Europe Ltd

1 Ensign House,

Admirals Way,

London,

E14 9XQ

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