Privacy Policy - Smarti's Club
This is the privacy policy for Smarti's Club and Smarti's Club Webshop.
This privacy policy explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Notice also sets out your rights in respect of our processing of your personal information.
This Privacy Notice will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.
This Privacy Notice is intended to assist you in making informed decisions when using our Services and/or to understand how your personal information may be processed by us as a result of providing the Services. Please take a moment to read and understand it.
We use your personal data for many reasons, from understanding how our users engage with our content to informing our marketing and advertising. Ultimately, this allows us to publish the classes, events and content that you engage with on our sites.
These are the main reasons why we collect and use data about our users:
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To show you content that is relevant to you and to improve your experience on our site
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To provide the services you sign up for, such as subscriptions
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To carry out marketing analysis and send you communications when we have your permission, or when permitted by law
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To enable us to show advertising on our sites
We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics:
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Information about your rights and our obligations
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Clarity about our dealings with you and transparency about how we collect and use your personal data
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Commitments on how we protect your personal data
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Commitments on how we will facilitate your rights and respond to your questions.
We will continue to examine how we can provide more clarity to our users about our use of data.
About this privacy policy
This privacy policy explains how we (Smarti's Club) collect, use, share and transfer your personal data when you use the services provided on Smarti's Club and Smarti's Club webshop (“our sites”).
Personal data is any information about you by which you can be identified. This can include information such as:
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your name, date of birth, email address, postal address, phone number, mobile number; size of your household; household income; hobbies; interests;
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debit or credit card details;
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information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and
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other information relating to your personal circumstances and how you use our sites, apps and services.
Sometimes our sites and apps may contain links to third party sites and services. These sites and services have their own privacy policies. If you follow a link to a third party, you should read the privacy policy shown on their site.
How to contact us
The data controller for our sites and apps is Smarti's Club 79a Brandreth Road, Cardiff CF23 5NW Cardiff.
This means that we are responsible for deciding how and why we hold and use your personal data. If you want to contact us you can email us on smartisclub@gmail.com or write to us at the above address.
What personal data we collect and how we use it
We collect personal data when you sign up for our services and when you browse our sites. This information is used to provide our clubs, events and other services, display advertising and analyse how visitors use our sites.
When you subscribe for an account we collect:
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Name:
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Age:
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Your address:
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Your Child/Children Age
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Gender
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Some information about your interests and hobbies
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some limited data from your social media profile (further information on this is below) if you have signed in using your social media details; and
When you register for an account, we assign you a unique ID that we use to recognise you when you are signed in to our services.
When you use our sites we may also use cookies or similar technology to collect extra data, including:
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your IP address – a numerical code to identify your device and which can provide information about the country, region or city where you are based;
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your browsing history of the content you have visited on our sites, including information on how you were referred to our sites via another website; and
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details of your devices, for example, the unique device ID, unique advertising ID and browsers used to access our content.
Some of our services, such as Professional Networks, may give you the option of providing more information about your preferences, so that we can tailor your experience. Signing up for membership or a subscription may also mean you need to provide other details such as your address details:
We will not collect special categories of data – such as information about your race, political opinions, religion, health or sexual orientation – unless you have chosen to provide that information to us.
Using your social media details to sign into your account
When you sign in to our sites using your Facebook login details, you give permission to Facebook to share with us your email address and certain aspects of your Facebook profile if you have made these public on your Facebook profile. This only includes your first and last name, age range, link to your Facebook profile and profile picture. We do not have access to updates on your Facebook profile.
If you use your Google login details, you give Google permission to share the information that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, your age range, a link to your Google profile and, if you have one, your profile picture.
We will then use this information to form a profile for your Smarti's Club account. If you remove Smarti's Club from your Facebook settings, or if you remove smartisclub@gmail.com from your Google settings, we will no longer have access to this data. However, we will still have the information that we received when you first set up your account using your Facebook or Google login.
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How we collect personal data
We collect personal data when you:
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register for an account on smartisclub.com;
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pay for a subscription or purchase any other products/services;
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attend our events;
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enter our competitions and surveys;
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sign up for marketing communications;
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use mobile devices to access our content;
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access our sites, through cookies and other similar technology; and
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when you contact us via email, social media, our apps or similar technologies or when you mention us on social media.
Why we use your personal data
We use personal data collected through our sites for a number of purposes, including the following:
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To provide the services you sign up for, such as sending out subscriptions. We also use the personal data for related internal administrative purposes – such as our accounting and records – and to make you aware of any changes to our services.
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To send marketing communications when we have your permission, or when permitted by law.
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To personalise our services (for example, so you can sign in), remembering your settings, displaying personalised advertising as well as measuring how effective our online adverts are, recognising you when you sign in on different devices and tailoring our marketing communications based on what you engage with on our sites.
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To carry out marketing analysis, for example we look at what you have viewed on our sites and apps and what products and services you have bought to better understand what your interests and preferences are, and to improve our marketing by making it more relevant to your interests and preferences. You can opt out from having your personal data used for marketing analysis by going into your account to the tab “Emails and marketing”.
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To improve our marketing communications, we use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email.
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To sell advertising space on our sites.
statistical purposes such as analysing the performance of our sites and apps and to understand how visitors use them. -
To respond to your queries and to resolve complaints.
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For security and fraud prevention, and to ensure that our sites and apps are safe and secure and used in line with our terms of use.
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To comply with applicable laws and regulations.
Access permissions that we ask from users of smartisclub.com
When you use smartisclub.com, we ask for the following permissions to access particular functions of your mobile device:
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For the Android version, we ask for permission to access your contact details/profile on your mobile device, so that we can add or find your smartisclub.com account on your phone. We also ask for permission to access the storage on your mobile device, so that you can store content and read when offline.
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For the iOS version, we ask for permission to save pictures to your photo library, so that you can save pictures that you find in our adventures on your mobile device.
Legal grounds for using your personal data
We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. In every case, the legal ground will be one of the following:
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Consent: For example, where you have provided your consent to receive marketing emails from us. You can withdraw your consent at any time. In the case of marketing emails you can withdraw your consent by clicking on the “unsubscribe” link at the bottom of the email or through your email preferences in the “emails and marketing” tab, when signed into your account.
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Our legitimate interests: Where it is necessary for us to understand our users, promote our services and operate our sites efficiently for the creation, publication and distribution of adventures, nuggets and events globally. For example, we will rely on our legitimate interest when we analyse what content has been viewed on our sites and apps, so that we can understand how they are used. It is also in our legitimate interest to carry out marketing analysis to determine what products and services may be relevant to the interests of our readers.
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Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a subscription from us and we need to use your contact details and payment information in order to process your order and deliver your subscription.
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Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
Updating your personal data
Personal data that we receive about you from other organisations
Adding to or combining the personal data you provide to us
When you sign up to our services we may add to the personal data you give us by combining it with information shared with us by other trusted organisations. This includes, for example, information about the region that you are located in, so that we can show you the prices for subscriptions or other products in your local currency. We may also add information to improve the accuracy of your delivery address when we send out mail. We may also obtain information from partners whose offers we include in some of our marketing communications and we use this information to ensure that we do not send you irrelevant marketing.
We also use information on the content you have viewed on our sites and apps and your interaction with the content to add you to groups with similar interests and preferences, so that we can make our online advertising more relevant. Sometimes we use data about your interests or demographics that third parties have collected from you online to add to these groups. Please refer to our cookie policy for more information on how we use cookies.
Information shared by event partners
When you register or book a ticket for a Smarti's Club event organised by an event partner, your registration data may be shared with us by the event partner.
Security of your personal data
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
Who we share your personal data with
If you are going to one of our events hosted by an event partner, we may share your personal data with that partner for event administration purposes.
We do not share your personal data with other people or organisations that are not directly linked to us except under the following circumstances:
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We may share your data with other organisations that provide services on our behalf such as dealing with online payments and other forms of payment processing, ie credit card transactions and preventing fraud.
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We may also share your data with our advertising partners, as set out in the section about Online Advertising below.
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We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
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We may reveal your personal data to any other organisation that buys, or to which we transfer all, or substantially all, of our assets and business. If this sale or transfer takes place, we will use reasonable efforts to try to make sure that the organisation we transfer your personal data to uses it in line with our privacy policy.
Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
International data transfers
Data we collect may be transferred to, stored and processed in any country or territory where one or more of our Smarti's Club service providers are based or have facilities. While other countries or territories may not have the same standards of data protection as those in your home country, we will continue to protect personal data that we transfer in line with this privacy policy.
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:
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We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
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We may also use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your personal data the same protection it has in the EEA .
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Where we use service providers in the United States, we may transfer personal data to them if they are part of the Privacy Shield scheme, which requires them to provide a similar level of protection of your personal data to what is required in the EEA.
If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the EEA.
How long we keep your personal data
We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries about a product or service and as a result may keep personal data while you are still using our product or services. We may also need to keep your personal data for accounting purposes, for example, where you have bought a subscription. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asked for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in future.
How we may contact you
Service communications
From time to time we may send you service emails, for example, telling you your subscription is coming to an end, that the subscription is changing, or thanking you when you place an order with us.
Marketing communications and editorial newsletters
If we have your permission, we may send you materials we think may interest you, such as new Smarti's Club offers and updates. Depending on your marketing preferences, this may be by email, phone, SMS or post.
You can decide not to receive these emails at any time and will be able to “unsubscribe” directly by clicking a link in the email
Market research
Sometimes we may contact you for market research purposes, for example about a survey.
Responding to your queries or complaints
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Online advertising
We use personalised online advertising on our sites. This allows us to deliver more relevant advertising to people who visit psmartisclub.com. It works by showing you adverts that are based on your viewing patterns and the way you have interacted with our sites. It then shows you adverts which we believe may interest you.
When you browse our sites, some of the cookies and similar technology we place on your device are advertising cookies, so we can understand what sort of pages you are interested in. We can then display advertising on your browser based on these interests.
We do not collect or use information such as your name, email address, postal address or phone number for personalised online advertising.
We may also share online data collected through cookies and similar technology with our advertising partners. This means that when you are on another website, you may be shown advertising based on your browsing patterns on smartisclub.com.
We may also show you advertising on smartisclub.com website based on your browsing patterns on other sites that we have obtained from our advertising partners.
Online retargeting is another form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with a site away from our sites.
For example, if you have visited the website of an online toy/board game shop, you may start seeing adverts from that same shopping site displaying special offers or showing you the products you were browsing. This allows companies to advertise to you if you leave their website without making a purchase.
Advertising that we place on our site or on other sites
We also use personalised online advertising to promote our own products and services. This means that you may see advertising for our products and services on our sites and when you are on other, third party websites, including social media platforms.
Your rights with regard to the personal data that we hold about you
You can contact us with regard to the following rights in relation to your personal data:
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If you would like to have a copy of the personal data we hold on you or if you think that we hold incorrect personal data about you, please write to Smarti's Club, 79A Brandreth Road, Cardiff CF23 5NW or email smartisclub@gmail.com. We will deal with requests for copies of your personal data or for correction of your personal data within one month. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
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Where you have provided us with consent to use your personal data, you can withdraw this at any time.
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Where applicable, you may also have a right to receive a machine-readable copy of your personal data.
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You also have the right to ask us to delete your personal data or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request. Where applicable, you have the right to object to processing of your personal data for certain purposes.
If you want to make any of these requests, please contact smartisclub@gmail.com.
We may need to request specific information from you to help us confirm your identity.
Contact us for information about how we use your personal data
If you have any questions about how we use your personal data or if you have a concern about how your personal data is used, please contact the Data Protection Officer at Smarti's Club, 79A Brandreth Road, Cardiff, CF23 5NW or email smartisclub@gmail.com.
Complaints will be dealt with by the Data Protection Manager, and will be responded to within 30 days.
If you are not satisfied with the way your concern has been handled, you can refer your complaint to the Information Commissioner’s Office.
Changes to the Privacy Policy
If we decide to change our privacy policy we will post the changes here. If the changes are significant, we may also choose to email all our registered users with the new details. If required by law, we will get your permission or give you the opportunity to opt out of any new uses of your data.