Smart Numbers Privacy Notice

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the 'Data Subject') who is not already in the public domain.

The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and the UK GDPR seek to protect and enhance the rights of data subjects. These rights cover safeguarding personal data, protection against unlawful processing and the free movement of personal data within the UK.

GDPR does not apply to information already in the public domain such as Companies House data.

SmartComms® (hereafter referenced as SmartComms® or Smart Numbers, Smart Numbers VoIP, Smart Websites) is a UK-based telecommunications reseller and media agency principally involved in the B2B sector.

SmartComms® Limited, 1–2 The Exchange, Beaulieu Road, Dibden Purlieu, Southampton, Hampshire, SO45 4PX. Company registered in England & Wales: 05457989. VAT registered: 887353085.

SmartComms® uses the information collected from you to provide services and marketing information that SmartComms® believes may be of interest to you and your business. After your initial contact we will maintain a marketing dialogue with you on the basis of legitimate interests until either you opt out (which you can do at any stage) or we decide to discontinue promoting our services.

SmartComms® also sometimes acts on behalf of its clients in the capacity of data processor. When working as a data processor, SmartComms® acts on the instruction of its client and aims to ensure that the client is fully UK GDPR compliant.

Some personal data may be collected from forms and surveys you complete; from records of our correspondence and phone calls; and from details of your visits to our website, including Internet Protocol (IP) addresses. SmartComms® may use such information to identify visitors and to compile statistics about visitor behaviour.

Any information we hold about you encompasses all the details we hold about you and any sales transactions, including third-party information obtained from public sources and our own suppliers such as credit referencing agencies. SmartComms® only collects the information needed to provide its services.

SmartComms® does not sell or broker your data, although coincidentally there may be times when your information could be contained in data we have purchased from a third-party UK list broker on behalf of a client.

We use a number of different legal bases to process personal data: legitimate interests to respond to sales enquiries and promote services; performance of a contract; compliance with a legal obligation; and consent (only where no other legal option is available).

If you have any concerns about the processing of your personal data you can contact us at privacy@smart-numbers.net, by phoning +44 (0) 345 0178 179, or by writing to us at the address above.

SmartComms® may, on occasion, pass your personal information to third parties exclusively to process work on its behalf. We require these parties to process the information based on our documented instructions and on requirements consistent with this Privacy Notice and the UK GDPR.

For legal obligations SmartComms® may be required to disclose your personal information to regulators, Government and statutory bodies. We may also enforce our Terms and Conditions, including investigating potential violations, detecting or preventing fraud, or protecting against harm to the rights, property or safety of SmartComms®, its clients and the wider community.

SmartComms® processes personal data during the duration of any contract and continues to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. For more detail, please ask for a copy of our Data Retention Schedule.

Telephone calls are recorded for staff training and security purposes. Any personal data collected will be retained for 30 days and then deleted, unless we need to retain it longer for contractual or legal purposes.

Personal data is mostly held on multiple servers within the United Kingdom. Where SmartComms® is required to hold personal data outside the UK, for example, processing transactions for international numbers, we rely on adequacy decisions and/or PCI-compliance regulations.

If we ever need to transfer personal data outside the UK we will put in place appropriate safeguards such as International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs) beforehand.

At any point during processing all data subjects have the following rights:

Right of access, request a copy of the information we hold about you.

Right of rectification, correct data we hold about you that is inaccurate or incomplete.

Right to be forgotten, in certain circumstances, ask for the data we hold about you to be erased.

Right to restriction of processing, where certain conditions apply, restrict processing.

Right of portability, have the data we hold about you transferred to another organisation.

Right to object, object to certain types of processing such as direct marketing.

Right to object to automated processing, including profiling, you have the right not to be subject to legal effects of automated processing or profiling.

In the event that SmartComms® refuses your request under rights of access, we shall provide you with a reason which you have the right to challenge legally. To access details of personal data held we require identification: a copy of a driving licence, passport or birth certificate, plus a supporting document (e.g. utility bill not older than three months). A minimum of one piece of photographic ID is required.

All requests should be made to privacy@smart-numbers.net, by phoning +44 (0) 345 0178 179, or by writing to us at the address above.

Our cookie policy is available at https://www.smart-numbers.net/terms/cookies/.

If you wish to make a complaint about how your personal data is being processed by SmartComms® or its partners, you have the right to complain to SmartComms®. If you do not get a response within 30 days you can complain to the Information Commissioner's Office (ICO).

SmartComms® Limited, attention of the Head of Customer Success, 1–2 The Exchange, Beaulieu Road, Dibden Purlieu, Southampton, Hampshire, SO45 4PX. Telephone +44 (0) 345 0178 179 or email privacy@smart-numbers.net.

The ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone +44 (0) 303 123 1113. Website: https://ico.org.uk/global/contact-us/email/.