This policy applies to the handling of the personal data which MySmartestBuy.com AS (“MySmartestBuy” or “we”) gathers about you that may, for example, come to us via our websites (including social networks belonging to third parties), electronic mail, SMS, telephone, stores, registration forms and in other contacts with us, camera surveillance, from third parties and from generally available information.
We are attentive to your personal privacy concerns. This policy governs how we gather, use and protect information about you and how you can exercise your rights. Kindly contact us if you have any questions or viewpoints with regard to this personal data policy.
With reference to the law, we refer below to the General Data Protection Regulation, GDPR) and other applicable Swedish data protection regulations.
1. What information do we gather about you?
By “personal data”, we mean information that pertains to you and which can identify you.
In this personal data policy, the terms “personal data” and “information about you” are used synonymously and interchangeably.
Normally, you can make use of our web page without providing us with any information except technical information. On some pages, you will be requested to provide information, for example, in connection with purchasing and service requests, or if you register to receive electronic newsletters. Furthermore, we can make use of information about you that we gathered from other sources provided by third parties, e.g., marketing and sales companies.
The personal data about you that are collected can be:
Personal and contact information - such as your name, address, e-mail and telephone number, demographic information (such as date of birth, age, sex, geographical location, favourite products and leisure interests) and, when it is clearly justified with regard to the purpose of the handling or importance of a secure identification, also personal ID numbers.
Economic information - information needed to complete an order or which you use to make a purchase, e.g., debit or credit card details.
Technical details about your device or internet-connection - e.g., IP addresses, cookies, geographical locations and log-in details.
Information about your user behaviour - such as your searching patterns and activities on your web page, your response time for pages and how you use our services.
User-generated information - the content that you personally register, submit or publish, e.g., in connection with calls made to customer service (which may be recorded), competitions, subscriptions to newsletters and content that you share with us by uploading to our web site or on social networks (where you allow the network to share with us), such things as texts, video clips and photographs.
Information from other sources - Generally available information or information from our cooperative partners that e.g., we gather in order to keep our information about you updated or in order, for example, to secure payment.
2. Purpose and legal basis
In order for our handling of your personal data to be legal, it necessary for there to be a legal basis for it, i.e., that it be necessary in order to fulfil a contract with you or that there be a legal obligation incumbent upon us, or that the handling of the data needs to be done after weighing interests, or after you have given your consent to a particular action. What follows are some examples of the purposes for which we handle your personal data and the legal basis on which this is done.
MySmartestBuy.com handles your personal data for a variety of purposes. Principally, MySmartestBuy.com handles your data for the following purposes and pursuant to the following legal bases for it:
One of our primary purposes with the collection of personal data is to fulfil our obligations toward you, the customer, by processing and delivering your orders, invoicing and in providing customer services and other measures connected with your purchase of our products. For example, we may need to answer your questions via our customer service associated with your purchases, as well as send information to you for product-safety purposes, e.g., whether any of our products need to be recalled, and otherwise ensure that legal requirements are being satisfied (e.g., the Norwegian Accounting Act).
Legal basis: Fulfilment of contracts (sales terms and conditions) or legal obligation
Another main purpose is to be able to offer you good products and services by customising services and in providing better services with more relevant content. We use the information we gather in order to be able to provide you with information about products you demand, but also to get to understand our customers better. In order to achieve this, we conduct inter alia customer surveys. Furthermore, we analyse the information about our customer’s demographic and geographical circumstances, interests and behaviours based on the information we obtain from our website or other services; this process is known as profiling. Customer and market analyses, as well as processing for statistical purposes, are conducted on an aggregate level and are not intended to identify individual customers.
Legal basis: Legitimate interest
We may use information about you in order by means of postal mail, e-mail, SMS/MMS or by telephone to send you newsletters, inform you of new products, campaigns, offers, competitions and other information about our products and activities that we offer and which we believe can be of interest to you. Thus, we may use the information about you for direct marketing purposes, including profiling, provided that you have not instructed us not to do so. However, to the extent that you do not have a customer relationship with us or have not had one in the past twelve months, we will only use your information for electronic direct marketing if you have consented to such. Your personal data can also be used for interest-based advertising on the internet via us or via the digital advertising networks with whom we cooperate, and which in certain cases can be customised to your personal interests based on the information we have collected by means of profiling.
You may at any time object to us using your personal data for direct marketing purposes by contacting us in the manner described in Section 10, or directly in our electronic dispatches.
Legal basis: Legitimate interest or consent (provided that nothing else has been expressly stated in connection with the collection of your personal data).
MySmartestBuy.com `s legitimate interest in handling the aforementioned personal data is in being able to offer you a better purchasing and customer experience, and to provide you with personally customised offers and other relevant information.
3. Information about cookies
When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address and email address.
When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
Email marketing (if applicable): With your permission, we may send you emails about our store, new products and other updates.
SECTION 2 - CONSENT
How do you get my consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us by sending us an a mail at: email@example.com
4. To whom do we submit your data?
We handle your data with the greatest care, and your data are only used by us and selected third parties.
Third parties that we engage to help us in conducting our activities (e.g., customer surveys and dispatches) are only permitted to use your personal data on our behalf and for the particular tasks we give them according to our instructions, and to act as personal data advisers for us. They are obligated to keep your personal data confidential and safe. If required by law, you are entitled to obtain a list of any personal data advisers handling your personal data on our behalf.
In order to be able to offer better services, and for marketing purposes, we can also forward your personal information to third parties, most often independent personal data managers, in order for them to be able to perform a service for us or for you, e.g., for address updates, a postal or shipping service company that will deliver products, insurance companies, banks/credit review companies or digital advertising networks with which we cooperate.
In other special cases, we can also submit personal information, e.g., when we have reason to believe that it is necessary to identify, contact or take action against someone who may have made an unauthorised access to the web site or in some other way have violated or breached our rights or property or our customer's or other visitor’s rights.
The transfer of personal data to countries outside the EU/EEA requires the country in question having an agreement with the EU/EEA, that the country is considered to have sufficient data protection legislation, or that we have entered into a contract with the third party in question that stipulates that they be compelled to apply EU-commission-approved clauses with regard to the protection of personal privacy. You will find a list of approved third countries and standard clauses on the EU-commission home page and on the Swedish Data Protection Authority about the transfer of data to third countries.
5. Your rights
According to the law, you are entitled to request information about the personal data we have about you once you have identified yourself and have clearly indicated what information you wish to receive. Such a request shall be made in writing, be signed by one’s own hand and be sent to the address as indicated below in Section 10. We will as soon as possible and within one month address your request. In those cases where we cannot fulfil your request, we will notify you about this and indicate the reasons why.
If you find that the information about you is incorrect or incomplete, in a manner limited to what is prescribed by law, you are entitled to turn to us with a request for a correction. We will correct or update the information about you as soon as it is reasonably possible.
As set out by law, you also have a right to request to receive information about you or to request that we limit the handling of your personal data, and to revoke any consent. As set out by law, you also have a right to have the personal data you provided us transferred (ported).
Please note that it may be required that we maintain the necessary personal data in connection with erasure, revocation of consent or porting in order to fulfil our responsibilities as set out in law or by contract. We may also be permitted by law to maintain certain personal data in order to provide for our business needs.
You have a right to raise objections to such handling of your personal data that we conduct pursuant to a weighing of interests, including profiling. In that case, after you have specified the process to which you object, we must demonstrate that there are interests that outweigh the reasons for your objection. Similarly, you are entitled at any time to object to the handling of your personal information done for direct marketing.
6. How long do we save your personal data?
We save your personal data only as long as is necessary for the purposes pursuant to this personal data policy or as long as it is required according to law or contract. Your personal data are deleted or rendered anonymous when they are no longer relevant to the purposes for which they have been collected or no longer required by law or contract.
7. What we do to protect your information?
In order to prevent unauthorised access, use, modification, destruction or disclosure, we have implemented suitable and reasonable standards to protect and secure the information about you that we handle.
The measures are taken in order to prevent unauthorised or illegal handling of the information about you, as well as the unintentional loss or destruction of, or damage to, this information. smartestbuy.com makes use inter alia of SSL (Secure Socket Layer), which means that the orders you place are encrypted. We are also part of Trygg E-handel, which is a certification from Svensk Distanshandel with regard to safety and security for web stores.
If a personal data incident is discovered, this must be reported to the Irish Data Protection Authority and to you according to law.
8. Link to other web sites
Please note that this web site may feature links to other web sites. This means that if you follow such a link, you will be visiting other web sites that are subject to other regulations concerning privacy protection than those set out in this personal data policy.
9. Changes to the personal data policy
This personal data policy may be updated by us. If substantial changes to this personal data policy are made, we will notify you by placing a clear message on the web site or in some other required manner. We encourage you to read through this personal data policy in order to remain informed of how we handle your personal data.
10. Complaints and claims
If you feel that the handling of your personal data has been conducted in an incorrect manner, we ask you to contact us as soon as possible. You also have an opportunity to submit your complaint to the Swedish Data Protection Authority with regard to our personal data handling process.
If you feel that you have suffered damages pursuant to our handling of your personal information having been in violation of the law, you may be entitled to claim damages. You can then demand compensation from us or bring a case against us in the courts.
smartestbuy.com, is the party responsible for the handling of your personal information according to the above, unless otherwise expressly stated in connection with the collection of your information. Smartestbuy.com abides by Swedish data protection legislation. If you have any questions regarding the policy or our personal data handling, please contact us via the details below.
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at firstname.lastname@example.org or by sending us an a mail at: email@example.com
Head Of Customers Service.