Privacy Notice


Last revised: July 15th, 2019

Welcome to our website.

SMC International Expansion Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website https://smcinternationalexpansion.com and we are committed to safeguarding personal data that you share with us. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Notice carefully and ensure that you understand it. Your acceptance of this Privacy Notice is deemed to occur upon your first use of our website. If you do not accept this Privacy Notice, you must stop using our Site immediately.

This Privacy Notice is provided in a layered format so you can easily find specific areas of interest click on the headings below to find out more. Please also refer to the Glossary for clarity on the terms used in this privacy notice.

1. Who we are and important notices

1.1. We are a controller of your personal data for the purposes of relevant data protection legislation. As a Controller, we use the personal data we hold about you in accordance with this Privacy Notice. We welcome any questions or comments you may have about this Privacy Notice or our processing or your personal data. 

If you do have any questions , including any requests to exercise your legal rights (see section 6. below for more details), please email us at: privacy@smcinternationalexpansion.com.

You may also write to us at: Data Protection Team, SMC International Expansion Ltd, Elm Barn, Stert Road, Kingston Blount, Oxfordshire, OX39 4SB, United Kingdom or call us on +44 (0) 1844 355899

Important Notices about this Privacy Notice:

1.2. This Privacy Notice applies only to your use of our website and relates to personal information that identifies "you" meaning individuals who visit our website.

1.3. A separate Privacy Notice applies for: Our clients, vendors/suppliers, employees, contractors and employment candidates. our clients, vendors/suppliers, employees, contractors and employment candidates.

1.4. Third-party links – Our Site may contain links to third-party websites, plugins and applications. Please note that we have no control over how your data is collected, stored, or used by other websites, plugins and applications and are not responsible for how your data is protected by third-parties. When you leave our website, we encourage you to check the privacy policies of any third-party websites before providing any data to them.

1.5. Changes to this Privacy Notice – This Privacy Notice may vary from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection. Any changes will be immediately posted on our website and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our website following the alterations. Please read this Privacy Notice periodically to ensure you understand how we may currently be collecting and processing your personal data to keep up-to-date. This Privacy Policy was last updated on July 15th, 2019.

1.6. Your duty to inform us of changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. What type of information we have

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, process, store and transfer different kinds of personal data about you which we have grouped together as follows:

2.a.  Identity

Data that identifies an individual.

Data includes: First Name, Last Name, any identity documents you provide to us as part of our KYC/AML obligations.

2.b.  Contact

Data that allows us to contact an individual

Data includes: Email address, Telephone Number(s).

2.c.  Professional

Data that indicates an individual's current or previous professional career and education.

Data includes: Job title, job function, LinkedIn profile.

2.d.  Professional knowledge, opinion and preferences

Data that indicates an individual's professional knowledge, professional opinions and professional preferences which allows us to tailor our contact and service.

Data includes: How an individual would like to be contacted, what an individual knows and doesn't know (e.g. about international expansion in a particular country), an individual's thoughts and opinions (e.g. about their international expansion plans in a particular country), an individuals preferences and intentions (e.g. how their international expansion plans should be executed), etc.

2.e.  Marketing and Communications

Data that records your marketing preferences and any communications to or from you.

Data includes: Your preferences in receiving marketing from us and your communication preferences, messages you send via this website, notes of telephone calls, voice mail, email, other written communication.

2.f.   Technical

Data of a technical nature

Data includes: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plugin types and versions, operating system and platform and other technology on the devices you use to access this website.

2.g.  Aggregated

Data that is aggregated for internal purposes.

Data includes: Statistical or demographic data.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and bio-metric data.


If you fail to provide personal data when requested, where we need to collect personal data by law or under the terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you. In such cases we may have to cancel a service you have with us but we will notify you at the time if this is the case.

Cookies

a. What are cookies?

Cookies are small pieces of data sent to a user's computer when they visit a website.

They are used by a website to send "state information" to a user's browser and for the browser to return the state information to the website. The state information can be used for authentication and identification purposes and to collect user preferences.

Cookies are stored in the cookie directory of your hard-drive, and do not necessarily expire at the end of your session. "Session cookies" are automatically deleted when you close your browser.

Cookies are used by most websites to enhance the user's experience, monitor how a user is using the website and analyse website traffic.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below.

b. Our use of cookies – Our website may use cookies to enable us to collect information about you so that we can provide you a better experience when visiting our website, e.g. to ensure the fastest speed based on your location. The cookies that we currently use to do this are listed in the table below.

Cookie

Description

Duration

Type

__cfduid

The cookie is set by CloudFare and is used to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.

11 months

Necessary

Social Media – We may also maintain pages on some of the largest social media networks (e.g. LinkedIn). Sharing your personal data with a social media network may result in that information being collected by the social network provider or result in that information being made publicly available. SMC International Expansion Ltd cannot control or endorse any policies or practices of external social media networks whose functionality you may access through our website. You should always read the privacy policy, and check your privacy settings, on any social media network through which you might share information over.

3. How we get the information and why we have it

We may collect data about you in different ways.

i. Information provided directly by you. Most of the personal information we process is provided to us directly by you. This might be in person, by phone, in writing (by email or other documents) or via our website (either by submitting am enquiry form or by sending a message).

ii. Information we collect about you. We may also create personal data about you, for example, if you contact us by telephone we may make a written record of key details of the conversation.

iii. Interacting with our website. Additionally, as you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies (see 2 above for more details), and other similar technologies.

We will only use your personal data when the law allows us to. Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:

i. We have a contractual obligation. Where we need to perform the contract we are about to enter into or have entered into with you. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

ii. We have a legal obligation. Where we need to comply with a legal or regulatory obligation. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

iii. We have a legitimate interest. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

iv. Your consent. We do not generally rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You are able to remove your consent at any time. You can do this by contacting Privacy@SMCInternationalExpansion.com.

4. What we do with the information we have

Below is a table which sets out the ways we may use your personal data and which of the legal bases we rely on to do so.

We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Note the numbered points below refer to the points in 2. (re Type of Data) and 3. (re Lawful Basis) above.

Purpose/Activity

Type of Data

Lawful Basis

To respond to an enquiry or message you left on our website or you sent by email or phone.

a. Identity

b. Contact

c. Professional

d. Professional knowledge, opinions and preferences

i. Contractual – Necessary for our performance of a contract with you.

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

a. Identity

b. Contact

f. Technical

iii. Legitimate Interest – Necessary for our legitimate interests (e.g. for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). 

ii. Legal Obligation – Necessary to comply with a legal obligation.

To use data analytics to improve our website, services, marketing, customer experience and relationship management.

a. Identity

b. Contact

f. Technical

g. Aggregate

iii. Legitimate Interest – Necessary for our legitimate interests (e.g. to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

To make suggestions and recommendations to you about services that may be of interest to you or necessary for you.

a. Identity

b. Contact

f. Technical

i. Contractual – Necessary for our performance of a contract with you (to alert you to a need to remain compliant).

iii. Legitimate Interest – Necessary for our legitimate interests (e.g. to develop our products/services and grow our business).

To assist our Local Service Providers and other professionals to provide their professional services to you.

a. Identity

b. Contact

c. Professional

d. Professional knowledge, opinions

f. Technical

i. Contractual – Necessary for our performance of our contract with you (e.g. to ensure our Local Service Providers have the information they need to provide their professional services to you).

To allow us to manage and maintain standards within our network of Local Service Providers.

a. Identity

b. Contact

c. Professional

d. Professional knowledge, opinions and preferences

i. Contractual – Necessary for our performance of our contract with you (e.g. ensuring you receive the highest level of service from our Local Service Providers).

iii. Legitimate Interest – Necessary for our legitimate interests in operating our network of Local Service Providers (and other professionals) and the legitimate interests of our Local Service Providers to assist them in delivering their professional services to you.

To comply with legal and regulatory requirements.

a. Identity

b. Contact

c. Professional

iii. Legitimate Interest – Necessary to comply with our legal and regulatory obligations, including our obligations under Anti-Money Laundering legislation.

To make suggestions and recommendations to you about our services that may be required by and/or of interest to you.

a. Identity

b. Contact

c. Professional

d. Professional knowledge, opinions and preferences

e. Marketing and Communications

i. Contractual – Necessary for our performance of our contract with you (e.g. highlighting areas where additional services may be required to keep you compliant in a particular location).

iv. Consent

Additional Notes:

We never sell any of your data and we do not share any of you data to third parties.

We do not perform any automated decision making and/or profiling with your data.

Marketing – We will only use your data for the purposes of marketing if you have given your express consent. We use this data to suggest services which we believe are relevant to you. You can ask us to stop sending you marketing messages at any time by emailing Privacy@SMCInternationalExpansion.com.

Change of purpose – We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. I f you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by emailing Privacy@SMCInternationalExpanion.com.

5. Who do we share your personal data with

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

5.1. Our third party Local Service Providers or other Professional Providers so that they can respond to your enquiry or provide professional services to you under the contract we are about to enter into or have entered into with you.

5.2. Other external providers that we may use in delivering our service to you, e.g. translation services, notarisation services, marketing services, hosting and data storage, etc.

5.2. Our external auditors.

5.3. Legal and other regulatory or statutory authorities with whom we have a legal obligation to share your data or to report any potential or actual breach of applicable law or regulation.

5.4. Law enforcement agencies, courts or other relevant parties, to the extent necessary for the establishment, exercise or defence of legal rights.

5.6. Law enforcement and regulatory agencies in connection with prevention, investigation, detection or prosecution of unlawful activity or aw otherwise required by law.

5.7 Third parties in the event of an actual or proposed sale, transfer, or merger of our business, parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

5.8. Others, where you have specifically agreed.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, ensuring that your personal data is handles safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law.

6. International Transfers (outside the EEA)

In order to deliver our services to you, we may have to transfer you personal data outside the European Economic Area (“EEA”). This may be because the services we are delivering relate to your operations outside of the EEA, you are based outside of the EEA and/or our Local Service Provider is based outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure the transfer complies with data protection law on the basis of:

6.1. A European Commission adequacy decision (transfers to a country which the European Commission has deemed has in place an adequate level of protection, similar to protection within the EEA).

6.2. The Privacy Shield (transfers to the US, where the recipient is registered under the Privacy Shield).

6.3. The use of standard data protection clauses (EU model clauses).

7. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for.

We may retain your data after we have finished providing a particular service to your or responding to a query from you, in order to comply with any legal, accounting or reporting requirements.

We will not retain your data for longer than necessary for the purposes described in this Privacy Notice. Different retention periods apply for different types of data (see section 2).

Please email Privacy@SMCInternationalExpansion.com for more information about the retention period for a specific type of data.

6. Your duties and data protection rights, making a request and how to complain

6.1 Your Duty to inform us of changes

Please notify us of any changes to your personal information to help us ensure that the personal data we hold about you remains current. Please do so by emailing Privacy@SMCInternationalExpansion.com.

6.2 Your Rights

Subject to applicable law including relevant data protection laws, you may have a number of rights in connection with the processing of your personal data, including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

6.3 Making a Request

If you wish to make a request to exercise any of the rights set out above, you can do so by emailing Privacy@SMCInternationalExpansion.com.

We will not charge you to exercise your rights. However, if your request for access is clearly unfounded, repetitive or excessive, we may charge a reasonable fee or may refuse to comply with the request.

If you make a request, we will usually respond to you within one month. If your request is more complex, we may need longer to respond to you and we will advise you of this as soon as possible. In this case, we will notify you and keep you updated.

We may need to request specific information from you to help us confirm your identity and verify your right to access the information.

6.4 Withdrawing Consent

In some circumstances, you may have previously provided your consent for us to collect, process, store and transfer you personal data for a specific purpose (e.g. opting in to email marketing). You may withdraw your consent at any time by emailing Privacy@SMCInternationalExpansion.com.

6.4 How to Complain

6.4.1 Contacting us

We will always do our best to address your concerns and appreciate you giving us the opportunity to do so.


If you have any concerns about this Privacy Notice or our processing or your personal data, please email us at Privacy@SMCInternationalExpansion.com.


You may also write to us at:


Data Protection

SMC International Expansion Ltd

Elm Barn

Stert Road

Kingston Blount

Oxfordshire

OX39 4SB


or call us on +44 (0) 1844 355899.


6.4.2 Contacting the ICO


However, you can also complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time.


The ICO’s contact details are:


Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF


You can find out more information:


on their website – ico.org.uk


by telephoning their helpline – +44 (0) 303 123 1113

SMC International Expansion Ltd

Registered Company in England and Wales | Company Number: 12080798

Registered Office Address: Elm Barn, Stert Rd, Kingston Blount, Oxfordshire, OX39 4SB, UK

Copyright © 2019 SMC International Expansion Ltd All rights reserved