What does this policy cover?

This policy describes the processing of your personal data in relation to your use of the website https://mysmartbar.co.uk by MySmartBar Limited (12640858 Suite 7 High Street House, 2 High Street, Yeadon, Leeds, England, LS19 7PP) ("we", "us" or "our"), as the owner and operator of the website.

For the purposes of applicable data protection law (including, the General Data Protection Regulation 2016/ 679 (the "GDPR"), we are a 'data controller' of your personal data. Where applicable, this policy should be read alongside MySmartBar's terms and conditions which tell you about the terms on which you may use the platform.

What personal data is collected?

  1. Personal data collected from you: The following categories of personal data may be collected about you in connection with your use of the platform and your interaction with us, including, but not limited to, when you fill in forms on the Platform or provide us with payment information:
    • Personal Identification Information: Your name
    • Contact Information: Your email address
    • Demographic Information: such as postcode and address of your venue;
    • Your marketing preferences, including any consents you have given us.
  2. In addition, if you contact us by phone, email or otherwise, we may keep a record of that correspondence.
    Please note that MySmartBar will not store credit or debit card information from payments made through our services other than where it is necessary for us to complete our obligations to you.
  3. Personal data collected about you:
    • From Others: Although we generally collect personal data directly from you, we also collect certain categories of personal data about you from other sources.
    • Automatically Collected Information: [such as, web browser type and version, operating system, the platform you came from and exit to, your IP (Internet Protocol) address, your browser settings, the date and time of your visits, and details regarding your interaction with the platform (including which pages or resources on the platform you access);]
    • Cookies Information: in accordance with the Cookies section below.
  4. This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy.
    Sometimes you will have given your consent for other websites, services or third parties to provide information to us.
    For example, this could include information we receive about you if you follow a Promoter's or Venue's page/website we operate or any other services we provide, in which case we will have informed you when we collected this data that it may be shared. We will also have told you for what purpose we will share your data.
    It could also include information from third parties that we work with to provide our products and services, such as payment processors, delivery companies, technical support companies and advertising companies. Whenever we receive information about you from these third parties, we will let you know what information we have received and how and why we intend to use it.

How is your personal data used, and what is the legal basis for this use?

We process your personal data for the following purposes:

  • Contractual Necessity: As required to establish and fulfil a contract with you, for example: if you make a purchase from us (this will include taking payments); communicating with you and providing customer services, and in order to administer our loyalty programme.
  • Legitimate Interests: As required by us to pursue our own legitimate interests, in particular:
    • facilitating the creation of, and securing online registered accounts
    • managing, operating and improving online registered services (incl. enabling you to manage your marketing preferences), and customer journeys on the platform;
    • monitoring any online feedback/reviews to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
    • we will use data in connection with legal claims which concern our company, group or partners, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
    • creating user/customer insights based on transactional behaviour segments to drive targeted direct marketing;
    • creating user/customer insights based on demographic segments to drive targeted email direct marketing and also carrying out market research and surveys;
    • communicating with you; and
    • investigating and handling any complaints received from you about our platform, or our services.
    • Cooperation with the UK Government Track and Trace service as and when requested

You can obtain further information on the legitimate interests balancing exercises which we have carried out by contacting us using the contact details provided below.

  • Legal Compliance: To ensure compliance with applicable laws and legal processes including, but not limited to, use in connection with legal claims, compliance, regulatory, tax, investigative purposes (including disclosure of such information in connection with legal process or litigation and to law enforcement agencies).
  • Consent: Subject to the following, we will send you direct marketing by email, SMS, push notifications, telephone, post, in-App and online about MySmartBar services which we think may be of interest to you. This will only be sent where you have given your consent to MySmartBar during the online sign-up process or verbally, or (where permissible) you have been given an opportunity to opt-out. You will be able to opt-out of electronic direct marketing by clicking the unsubscribe link contained in the email itself and, in all other cases, by updating your preferences on the MySmartBar platform.

Minors

Visitors under 18 years of age are not permitted to Subscribe to our services use and/or submit their personal information on any of our website or applications. We do not knowingly solicit or collect information from visitors under 18 years of age.

Who will your personal data be shared with, and where?

We will share your personal data with:

  • third party service providers, who will process it on our behalf for the purposes above. Such third parties include, but are not limited to, couriers for delivery of your orders, customer service operations, and marketing providers;
  • government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our own legitimate interests in compliance with applicable laws; and
  • purchasers or prospective purchasers of all or part of our assets or our business, and their professional advisers, in connection with the purchase.
  • MySmartBar partner venues for marketing campaigns providing the relevant consent has been given
  • We share the information that you provide to us with our staff so that we can provide our products and services to you.

Where we store your Personal Data

The data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing. MySmartBar will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, our terms of use and the applicable data protection legislation

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted (using SSL technology). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Where we act as a data processor

MySmartBar will be a Data Processor of this data and shall comply with its obligations as a Data Processor.
In addition to the above, there are certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:

  • required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings;
  • necessary to protect the safety of our employees, our property or the public;
  • necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction; and
  • proportionate as part of a merger, business or asset sale, in the event that this happens we will share your information with the prospective seller or buyer involved.
  • Sometimes, we share your information with our third-party providers, who help us provide and support our Services. Examples of third-party providers include payment processors, email marketing platforms, hosting services and content delivery services. We have contracts with each of these providers that specify that they will only use your data for the purposes of performing the services we have contracted them for. Anonymised data is also used for the purposes of website and app analytics.

Analytics

We may use analytics software to monitor how visitors use our platform, to compile reports and to help us improve the platform.

Changes to this policy

Any changes we may make to the policy in the future will be posted on the platform and, where appropriate, notified to you by email or otherwise.