Privacy Policy

UK GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS

Introduction

SMPV Limited ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of website use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The rules on processing of personal data are set out in the UK General Data Protection Regulation (the “UK GDPR”). 

1.  Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person.

Data protection legislation – Means the data protection legislation enforce in the UK from time to time and includes the Data Protection 2018 (as amended) and the UK General Data Protection Regulation (UK GDPR).

Categories of data: Personal data and special categories of personal data

Personal data - The UK GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of UK GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The UK GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of UK GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2.  Who are we? 

SMPV Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Registered Address: 241 Mitcham Road, Tooting, London, England, SW17 9JQ. For all data matters contact us at dpo@smpvlimited.com.

3.  The purpose(s) of processing your personal data

We use your personal data for the following purposes:

·  To correspond with you

·  To offer our services

·  To register you as a new client or a new supplier

·  To enter into contract negociations

·  For the performance of a contract with you

·  To pay suppliers invoices

·  To send invoices to clients 

·  To adhere to legal requirements

4. The categories of personal data concerned

With reference to the categories of personal data described in the definitions section, we process the following categories of your data: 

- Personal data: First Name, Last Name

-Contact details: Business Address, Telephone Number, Email Address

- Bank details: Bank Name and address, Account number

We have obtained your personal data from our potential and current clients and suppliers or through direct or indirect contact via a third party, referrer, participation in external organisation activities or social media.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

5. What is our legal basis for processing your personal data? 

Personal data (article 6 of UK GDPR)

Our lawful basis for processing your general personal data:

Existing/prospective clients and suppliers:

-  Name, contact details for the performance of a contract or to take steps to enter into a contract and for the preparation and storage of invoices 

-  Bank details for payments of invoices.

Prospective clients and other contacts:

- Name and contact details for the legitimate interest of promoting and growing our business, improving our services, and business conduct.

More information on lawful processing can be found on the ICO website.  

6.  Sharing your personal data 

Your personal data will be treated as strictly confidential, and will be shared only with professional advisors. 

External Third Parties Service:

- Professional advisers including lawyers, bankers, accountants, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. 

- HM Revenue & Customs (HMRC), regulators and other authorities.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7.  How long do we keep your personal data? 

We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data:

-  Legal requirements (e.g. HMRC purposes)  

-  Performance of a contract or entering into a contract

-  Legitimate use for business conduct

8.  Providing us with your personal data

You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:

-  We will not be able to work with you, offer our services or conduct business 

-  We will not be able to offer work or pay you for your services. 

We require your personal data as it is a statutory, a contractual requirement, or a requirement necessary to enter into a contract. 

9.  Your rights and your personal data

Unless subject to an exemption under the UK GDPR, you have the following rights with respect to your personal data: 

- The right to request a copy of the personal data which we hold about you;

-  The right to request that we correct any personal data if it is found to be inaccurate or out of date;

- The right to request your personal data is erased where it is no longer necessary to retain such data;

- The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data;

- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means); 

- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

- The right to object to the processing of personal data, where applicable i.e. where processing is based on legitimate interests 

10. Transfer of Data Abroad

Some personal data may be transferred outside the UK and the European Economic Area.  

11. Automated Decision Making

We do not use any form of automated decision making in our business.

12. Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. 

13. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact us at dpo@smpvlimited.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.