Smart & Secure Centre Privacy Policy

Registration Information

The following information is collected during registration, and can be amended at any time from the account section of the website or prior to checkout:

• Your name and title
• Your username
• Your company name (optional)
• Your contact information, including:
• account email address
• billing email address
• billing telephone number
• Your geographic information (shipping and billing addresses)
• The following device information about the computer, tablet or smartphone used to register your account or log in:
• IP Address
• Last login date
• User Agent String

Your Registration Information is used to:

• Create your Smart & Secure Centre account / log in, which can be logged into again in future to make additional purchases.
• Your device information is used to:
• prevent spam and DDOS attempts by monitoring for a large amount of content (such as user accounts, orders, reviews or comments) created by the same device.
• attempt to determine if someone other than yourself has gained unauthorised access to your account.
• determine if your account is inactive if we decide to close any accounts (see "How long is this data retained?" column for Registration Information for more information);
• Allow us to contact you regarding any issues with your account, such as:
• password reset instructions;
• confirmation that your account has been created.
• Your Registration Information will be used solely for the above purposes, with the following exceptions, it will be used to:
• Allow us to contact you regarding any issues with your order (only if you order or attempt to order from us, see Order Details section for more information)
• To inform you of new products, offers and other promotions via email (only when opted into marketing communications)

Your Registration Information is stored on our website database indefinitely (in order to allow customers to order again with as little delay and hassle as possible) or until such a time that you ask us to remove your account. If you request removal of your Registration Information, it will be retained for up to seven additional days (after it is removed from our live / primary data source) in our regular backups. See the Backed up Data section for more information.

If at any time we choose to systematically delete Registration Information, customers will be contacted beforehand in good time if they meet our criteria for removal. We will provide customers with facilities to keep their account in our system if they so wish.

Notices will be posted on our website informing customers of the time of removal, as well as the criteria we used to determine which accounts will be removed (last order date, last login, etc.).

• Consent: By creating a Smart & Secure Centre account, you have given clear consent for us to process your personal data for a specific purpose.
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

• If you opt-in to marketing communications, your Registration Information will be passed onto our email marketing provider, SharpSpring (as detailed in the Marketing Data section). SharpSpring is operated by SharpSpring, Inc.
• If you opt-in to receive review invitations, a subset of your Registration Information will be passed onto our service reviews provider, TrustPilot (as detailed in the Review Invitation Details section). TrustPilot is operated by Trustpilot A/S (CVR no. 30 27 65 82).
• When attempting to pay for your goods, your Registration Information - in addition to your Order Details (see below for details) - are passed onto our Payment Provider WORLDPAY (UK) LIMITED (Company registration number 07316500). Additionally, if you choose to pay with PayPal, this data will be passed on to PayPal (Europe) S.à r.l. & Cie, S.C.A.

Cart Contents

When adding products to your cart while logged in, the following details are stored in our database and associated with your Registration Information:

• Items in cart
• Quantity of items in cart
• Prices to be paid for items, delivery and VAT
• The shipping and payment methods chosen
• Any information added to text fields on customisable products.
• Any information added to the optional "Order notes" field.

If you do not log into or sign up for an account when adding products to the cart, this information is not linked to any personally identifiable information.

This data is stored indefinitely for your convenience.

However, if at any time you would like this data to be removed, you can remove the items from your cart or contact us for assistance. If you remove items from your cart, they will be retained for up to seven additional days (after they are removed from our live / primary data source) in our regular backups. See the Backed up Data section for more information.

These details will never be passed onto a third party unless:

• you proceed to the checkout to attempt to complete your order (see Order Details section below); or
• are required to do so by law (see Introduction section).

Cart contents will be encrypted and transferred to another server operated by our backup provider on a regular basis, as outlined in the Backed up Data section.

Order Details

When you complete the checkout process, the following information is stored in our database, assigned an Order Number, and associated with your Registration Information:

• Items purchased
• Quantity of items purchased
• Prices paid for items, delivery and VAT
• The shipping and payment methods chosen
• Any information added to text fields on customisable products.
• Any information added to the optional "Order notes" field.

The above information is also stored in our database as a failed order if you are transferred to our payment provider (WorldPay), but your payment is not successful.

In addition to the above information, the following device information about the computer, tablet or smartphone used to make your order:

• IP Address
• User Agent String

If you do not log into or sign up for an account when adding products to the cart, this information is not linked to any personally identifiable information.

The Order Details we collect at checkout are used in combination with your Registration Information in order to:

• ensure your items reach you in a timely fashion;
• provide you with updates on the progress of your order, such as:
• if your order has been successfully taken;
• when your order has been dispatched;
• when your order has / will arrive (if this information is available for the shipping method chosen during checkout); and
• send you a copy of your invoice, tracking information, and any other important documents;
• allow us to contact you regarding any issues with your order, such as:
• if payment was not successful;
• if a product ordered is not available due stock shortages, discontinuation, or other issues with inventory;
• any recalls, updates to instructions or any other information that affects the safe operation of the products you have ordered.

The device information collected while checking out is used to:

• prevent spam and DDOS attempts by monitoring for a large amount of content (such as user accounts, orders, reviews or comments) created by the same device.
• attempt to determine if someone other than yourself has gained unauthorised access to your account.
• combat and investigate potential fraud

In order to comply with the Companies Act 2006, EasyGates Ltd keeps accounting records for 6 years from the end of the last company financial year they relate to, or longer if:

• they show a transaction that covers more than one of the company’s accounting periods; or
• we are otherwise required to by HMRC (for example for compliance check purposes).

• Consent: By completing the checkout process, you have given clear consent for us to process your personal data for a specific purpose.
• Contract: processing this data is necessary to fulfil our contractual obligations to you.
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

• When attempting to pay for your goods, your Order Details - in addition to your Registration Information (see above for details) - are passed onto our Payment Provider WORLDPAY (UK) LIMITED (Company registration number 07316500). Additionally, if you choose to pay with PayPal, this data will be passed on to PayPal (Europe) S.à r.l. & Cie, S.C.A.
• If you opt-in to marketing communications during checkout, your Registration Information and Order Details will be passed onto our email marketing provider, SharpSpring (as detailed in the Marketing Data section). SharpSpring is operated by SharpSpring, Inc.
• If you opt-in to receive review invitations, a subset of your Registration Information and Order Details will be passed onto our service reviews provider, TrustPilot (as detailed in the Review Invitation Details section). TrustPilot is operated by Trustpilot A/S (CVR no. 30 27 65 82).

Enquiry Details

When completing on of our contact forms, your Enquiry Details will be passed on to our CRM provider SharpSpring. The email will then be passed on to our internal technical or sales support teams

Contact Form

When completing our contact form, the following information is passed on to our internal technical or sales support teams:

• Name
• Telephone number (optional)
• Email address
• Enquiry type
• Any information inputted into the message field
• The page on which the contact form was filled out
• Whether or not you opted in to Email Marketing

Installer Enquiry Form

When completing our Installer Enquiry Form, the following information is passed on to our internal technical or sales support teams:

• Name
• Preferred contact method(s)
• Email address (if entered)
• Telephone number (if entered)
• Home address
• Home automation product interests
• Any information inputted into the "Extra info" field
• The page on which the Installer Enquiry Form was filled out
• Whether or not you opted in to Email Marketing

If you would like to email us without using the SharpSpring system, please email us directly using one of the email addresses listed on our contact page.

Our policies for email retention differ depending on the purpose of the email message, as well as the content of each particular message. Enquiries sent through this form will be kept at a minimum for as long as an enquiry or support case is still ongoing.

Emails may be archived for a longer period if we believe it necessary to keep the email as a record of fact (i.e. if we believe a dispute over the nature or timing of events may occur).

At most, email communications that do not need to be archived for any legal reasons (such as for accounting and VAT records, or if we believe an email may be relevant to any upcoming legal proceedings) will be kept for no longer than 2 years.

This data is shared with our CRM provider, SharpSpring. SharpSpring is operated by SharpSpring, Inc.

As well as Smart & Secure’s Privacy Policy, your data will also be subject to SharpSpring’s Privacy Policy.

These details will never be passed onto another third party unless:

• we have your express permission beforehand; or
• are required to do so by law (see Introduction section).

Review Invitation Details

If you opt-in to receiving review invitations, the following subset of your Registration Information and Order Details will be passed on to our review provider (Trustpilot):

• Your billing name
• Your billing email address
• Your order number

If you opt-in to receiving review invitations, EasyGates Ltd (via Trustpilot) will contact you via email to invite you to review any services and/or products you received from us in order to collect your feedback and improve our services and products.

By default, for each order you make while opted in, you will receive the following emails from Trustpilot:

• An initial review invitation 7 days after your purchase.
• An additional reminder email 7 days after your first invitation if you have not yet written a review.

EasyGates Ltd. may change the timing of these review invitations in the future.

EasyGates Ltd. may use such reviews in promotional material and media for advertising and promotional purposes.

If you did not opt-in to receiving review invitations during checkout, you can always leave us a review at any time after purchasing by visiting our Trustpilot profile.

The details provided to Trustpilot are held by ourselves for as long as detailed in the Registration Information and Order Details sections.

Please see Trustpilot’s US Privacy Policy or section 6 (Data retention) of Trustpilot’s UK Privacy Policy for details of how long Trustpilot holds your review data.

Trustpilot’s privacy policy can also be viewed in additional languages for other territories by using the language dropdown in the footer of the Trustpilot Legal website.

If you wish to opt-out of future review invitations from EasyGates Ltd, as well as other companies using Trustpilot, press the unsubscribe link in your review invitation email. If you have a Trustpilot account, please see their support page for instructions on unsubscribing from (or resubscribing to) future emails. If you opt-out via Trustpilot’s website, you will not be sent invitation requests for this order or future purchases, even if you opt-in again during checkout on smart-secure.co.uk.

If you wish to have your Review Invitation Details removed from Trustpilot’s service, please see the Your Data and Your Rights section for information on how to request that we remove it. Alternatively, please see this support page for instructions on how to contact Trustpilot directly.

We use an external company, Trustpilot A/S (CVR no. 30 27 65 82), to collect your feedback, which means that we will share your billing name, billing email address and order number with Trustpilot for this purpose if you opt-in to receiving review invitations.

If you want to read more about how Trustpilot processes your data, please review their Privacy Policy (US version, UK version).

Trustpilot’s privacy policy can also be viewed in additional languages for other territories by using the language dropdown in the top right of the Trustpilot Legal website.

Marketing Data

EasyGates Ltd uses a number of methods to keep previous and potential customers informed about our latest offerings and services.

Email Marketing

EasyGates Ltd maintains several email marketing lists across its various websites.

When you sign up for an email marketing list, we will always make it clear what information is being added to our marketing list.

Smart & Secure Centre Mailing List

If you opt-in to the Smart & Secure Mailing List, the following information will be collected and passed on to our email marketing provider SharpSpring:

• Your name
• Your email address
• The following information about your subscription:
• The IP address of the device you used to subscribe
• The time at which you subscribed
• The website or form you signed up on

Depending on how you interact with the Smart & Secure website, or where you opt in to marketing, the following additional data may be passed on to SharpSpring

• Your Enquiry Details (for example if you opt in while filling in an enquiry form)
• Your Registration Information, Cart Contents and / or Order Details (for example if you opt in while signing up for our store or checking out)

In the future, we may also allow you to select optional "interest categories", which allow you to further narrow down the subjects or products you are interested in.

After you subscribe, SharpSpring may store further information about your interaction with their service, including Device information and Usage data, including but not limited to:

• information about the email client and device you use to open emails
• how you interact with the emails you receive through the SharpSpring service such as which emails opened and whether you clicked any links within the email

You can read more about the data that SharpSpring collects in SharpSpring’s Privacy Policy

We use the Marketing Data you provide to give you regular updates about our latest products, services and offers via email.

The Marketing Data you provide to us for Email Marketing is stored for as long you stay subscribed to our marketing lists.

You can use the following links to opt-in or opt-out of our marketing list

• Subscribe
• Unsubscribe

Consent: If you opt-in to email marketing, you have given clear consent for us to process your personal data for a specific purpose.

This data is shared with our email marketing provider, SharpSpring. SharpSpring is operated by SharpSpring, Inc.

As well as Smart & Secure’s Privacy Policy, your data will also be subject to SharpSpring’s Privacy Policy.

Analytics Data (Performance Cookies)

EasyGates Ltd uses Google Analytics to analyse how visitors use our site. Please see the appropriate subsections below to see details for each service.

If you opt-in to Analytics, a cookie is stored on your computer that contains a unique, anonymised ID. This unique ID is a random collection of letters, numbers and symbols, and does not contain any other personally identifiable information which you may provide to us in another context. The client ID is used to differentiate you from other visitors, as well as determine whether you are a first time or returning visitor.

Google Analytics Data

EasyGates Ltd uses Google Analytics to analyse how visitors use our site.

When Google Analytics is enabled, various details about your computer, browser and visit behaviour are passed on to Google. This information may include, but is not limited to:

• Your IP Address
• An estimate of what browser and operating system you are using to visit our site
• What pages you visit and how long for

Your IP address is collected by the Google Analytics service purely for the purpose of determining the approximate geographic location of visits. Google does not share your IP address with us, and only provides us with an anonymous, approximated geographic location. EasyGates Ltd employs Google Analytics’ optional IP Anonymization feature. This feature removes the final set of digits from your IP address before transmitting it to Google, in order to provide a more anonymised and less accurate estimation of your location.

The techniques that Google employ do not collect personal information such as your name, email address, postal address, or telephone number.

We will not link, or seek to link, any of the above information with any personally identifiable information we hold about you.

Remarketing Data (Targeting / Advertising Cookies)

EasyGates Ltd. use a number of services to advertise our products and service to customers across the web. Among these are remarketing tools.

If you opt in to remarketing / targeting, these services will place cookies in your browser containing a unique, anonymised ID to help distinguish you from other users. As well as this cookie, we will also share details about how you interact with our site (such as what pages you visit, what products you add to your cart etc.) with our remarketing partners.

This allows us to group customers anonymously into "audiences" depending on their interests or actions and show more relevant adverts to them across the web or on smartphone and tablet apps. For example, we may show you ads containing accessories for products you are interested in or show you ads reminding you of products you’ve left in your cart but not purchased.

Facebook Pixel

As per Facebook’s documentation, if you opt-in to remarketing, the following information will be sent to Facebook:

• HTTP Headers – Anything present in HTTP headers. HTTP Headers are a standard web protocol sent between any browser request and any server on the internet. HTTP Headers include IP addresses, information about the web browser, page location, document, referrer and person using the website.
• Pixel-specific Data – Includes Pixel ID and the Facebook Cookie.
• Button Click Data – Includes any buttons clicked by site visitors, the labels of those buttons and any pages visited as a result of the button clicks.

As well as the standard information collected above, the Facebook pixel allows us to send additional Optional Values. These could include:

• Order value (upon completion of your order)

The information we collect via the Facebook Pixel is used to

• measure the effectiveness of our online advertising;
• serve you with more relevant ads when using Facebook’s services (Facebook, Instagram, Messenger, Oculus etc.) or in other third-party apps that use the Facebook Audience Network;
• help us optimise and improve the way our website works, and ensure our users are able to easily find all the information and services we offer.

SharpSpring Remarketing Data

EasyGates Ltd uses SharpSpring remarketing to analyse how visitors use our site, how effective our ads are, and to deliver relevant ads to our customers.

When analytics are enabled, various details about your computer, browser and visit behaviour are passed on to SharpSpring. This information may include, but is not limited to:

• Your IP Address
• Preferences and settings: time zone, language, and character size.
• Technical information: type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution.
• Traffic Data: What pages you visit, how long for and when; referrer URL

Your IP address is collected by the SharpSpring service purely for the purpose of determining the approximate geographic location of visits. SharpSpring does not share your IP address with us, and only provides us with an anonymous, approximated geographic location.

SharpSpring Remarketing Data is retained where SharpSpring "have justifiable business need to do so, and/or for as long as it is needed to fulfill the purposes outlined in [their] Privacy Notice, unless a longer retention period is required by law, such as for tax, legal, or accounting purposes."

Please see SharpSpring’s Privacy Policy for more information.

Raw Access Logs

EasyGates Ltd uses various technologies to log traffic across our websites. The majority of this data is anonymous and is not linked to any IP addresses or other personally identifiable information.

However, in addition to this anonymous data, EasyGates Ltd keeps raw access logs. These raw access logs store the following information about visitors each time a page is accessed:

• IP Address
• User Agent String
• What resource was accessed
• What time it was accessed

These raw logs do not contain any other information. The data transferred between your computer and our servers is not logged, only the page accessed.

EasyGates Ltd keeps these raw logs in order to:

• Ensure network and information security.
• Ensure we can resist malicious actions that compromise the security of our systems and data, such as brute force entry, DDOS and DOS attacks.

Any data that contains personally identifiable information will be kept for no longer than one month.

However, if we believe an IP Address or range of IP addresses to be behind malicious actions that threaten the security and upkeep of our systems, they will be kept on file as long as we believe they may cause us harm, in order to prevent repeat behaviour.

Backed up Data

The following personally identifiable data is backed up to a remote server (separate from our webserver) once per week:

• Registration Information
• Cart Contents
• Order Details
• Raw Access Logs

A "snapshot" of the data we store is taken once per week. These snapshots are stored on the remote server for seven days, when they are replaced by the subsequent week’s backup.

Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.

Contract: processing this data is necessary to fulfil our contractual obligations to you