We, OTC Limited, a limited company registered in England and Wales under company number 01353641 whose registered address is at Faulkner House, Victoria Street, St Albans, Hertfordshire AL1 3SE (“We”, “Us” and “Our”), understand that your privacy is important to you and that you care about how your personal data is used and shared online.
We respect and value the privacy of everyone who visits Our website, www.smartphone-manual.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation In this Policy, the term “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).
2. Information About Us
Our Site is owned and operated by Us.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 the right to be informed about Our collection and use of personal data;
4.1.2 the right of access to the personal data We hold about you (see section 12);
4.1.3 the right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 the right to be forgotten (meaning the right to ask Us to delete any personal data We hold about you). We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it, please contact Us using the details in section 13;
4.1.5 the right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 the right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 the right to object to Us using your personal data for particular purposes; and
4.1.8 rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
5.2 business/company name;
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences, and interests;
5.7 IP address.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7 below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.2 personalising and tailoring Our services for you;
6.2.3 replying to emails from you;
6.2.4 supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time).
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news, and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We are required by law to keep certain information about our customers (such as financial and transaction related data) for seven years after they cease being customers for tax purposes.
6.6 Our data retention periods vary depending on the context of the services that we provide to you, and our legal obligations. To determine the appropriate period for which we keep your data, we consider the amount, nature and sensitivity of your data, the potential risk or harm from unauthorised use or disclosure of your personal data, the purposes for which we process that data (and whether we can achieve those purposes through other means), and applicable legal requirements.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored in the UK.
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
11. Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com or using the contact details below in section 13.
13. Contacting Us
3.2 Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).