Privacy Policy

Your privacy is very important to us. We designed our Privacy Policy to make important disclosures about how you can use SmartSession to share with others and how we collect and can use your content and information. We encourage you to read this Privacy Policy, and to use it to help make informed decisions. You should read the SmartSession Terms and Conditions of Use in conjunction with this SmartSession Privacy Policy.

 
GENERAL STATEMENT

1.

Your privacy is very important to us. Our Privacy Policy has been designed to reflect our commitment to ensuring the privacy of your information. The SmartSession Privacy Policy makes important disclosures about how you can use SmartSession to share your User Profile information with all Users of the SmartSession Platform and how we in turn collect and can use your content and information. We encourage you to read the Privacy Policy and to use it to help you, the User, make informed decisions. We will only collect, store and use your personal information for defined purposes which are outlined in our Privacy Policy and our Data Protection Policy. We use your information to provide you with our service, to support and enhance our relationship with you, for example, to provide service and support, and share product, services and SmartSession news and offerings with you. Periodically, we may send you information about SmartSession products and services we feel may be of interest to you. We have no desire or intent to infringe on your privacy while using our site. See our Data Protection Policy for full information on collection and use of personal information. We understand that as a registered User of the SmartSession Platform the privacy and the security of your information is very important to you. The purpose of our Privacy Statement is to outline SmartSession's practices in this area.

 
CHANGES TO THE PRIVACY POLICY

2.

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on the SmartSession website and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us at any time through the SmartSession website or at:

Data Protection Officer
SmartSession Ltd
5-7 Cranwood Street
London
EC1V 9EE
UK.

We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Policy.

 
CONTROLLER OF PERSONAL INFORMATION

3.

Any personal information processed by SmartSession in connection with this Privacy Policy is controlled by SmartSession Ltd, which is considered the "data controller2 of your personal information under European Union and UK data protection law.

If you have arranged work on the platform with other Providers, will also separately be considered a "data controller2 under European Union and UK data protection law. You can access the privacy policies of the other Providers by contacting them directly.

Personal information means details which identify you or could be used to identify you, such as your name and contact details, or your work history. It may also include information about how you use our website and/or mobile applications.

 
PROVIDING THE SERVICE FOR WHICH YOU HAVE APPLIED

4.

The information collected by SmartSession is used to facilitate the operation of the SmartSession Platform.

 
THE LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION

5.

SmartSession will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons SmartSession collected and needs to use your information. Under EU and UK data protection laws in almost all cases the legal basis will be:

  • Because we need to use your information so that we can process your arrangement to work and otherwise perform the contract we have with you.
  • As a commercial entity providing the platform, SmartSession has a legitimate business interest to use the personal information we collect to offer an effective service and carry out our business.
  • Because it is in SmartSession's legitimate interests as an online platform to use your personal information to operate and improve our business.
  • Because SmartSession needs to use your personal information to comply with a legal obligation.
  • To protect the vital interests of you or another person.
  • Because you have consented to SmartSession using your information for a particular purpose.

If processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.

 
HOW LONG DO WE KEEP PERSONAL INFORMATION?

6.

We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you arrange work on the platform and raise invoices, we will keep the information related to your work, so we can fulfil the specific arrangements you have made and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the work. The information may also be retained so that we can continue to improve your experience with us and to ensure that you are able to retrieve data about your work history.

We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.

 
KEEPING YOU INFORMED

7.

There may be times when we feel that a service or product offered by us or a selected third party may benefit you. We may use information we obtain from your account transactions and your User Profile in this decision-making process. To make you aware of the service or product we may contact you by mail or other methods provided from your User Profile information to give you further details so that you can make an informed choice.

 
RESEARCH & STATISTICAL ANALYSIS

8.

We will use your details to assist us in understanding individual needs and business trends in order to improve the SmartSession products and services we offer.

 
THE DETAILS WE HOLD

9.

Under the UK Data Protection Act 2018, you may request a copy of any personal data about you held by SmartSession Ltd. There is no fee for this request.

The request must be in writing and must contain the following:

  • Your name and postal address.
  • Details of your request.
  • Any details which may help us locate the information which is the subject of your request, for example:
    • GMC/NMC Number

You must also provide:

  • A photocopy of your passport or driving licence, so that we can verify your identity.
  • Your signature and the date of the request.
  • If you are applying on behalf of another person then signed authority from the individual is required.

Please send your request to:

Data Protection Officer
SmartSession Ltd
5-7 Cranwood Street
London
EC1V 9EE
UK

Under data protection laws in the European Union and the UK, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to three months, but we will let you know if this is the case.

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request.

 
EMAIL/SMS

10.

If you email us, or give us your email address or mobile number, we will keep a record of it. With your explicit consent, we may use it to contact you occasionally about other SmartSession products and services which may interest you. We will not give your email address or SMS number to any unauthorised third parties. When emailing us, always use the email facility on the SmartSession website to make sure that the content of your email is secure. If you send us email in other ways, remember that it will be insecure and could be intercepted. If you do send us insecure email, please keep the amount of confidential information you include to a minimum.

 
THE INFORMATION WE COLLECT

11.

As you browse through our Website, our web server collects information about your visit, not about you personally. This information is anonymous and no attempt is or will be made to identify visitors. All information provided to us by you will be treated with the utmost confidentiality in accordance with all applicable legislative and regulatory standards. SmartSession will remove or amend the information as appropriate in accordance with applicable legislative and regulatory requirements.

 
USE OF 'COOKIES'

12.

What is a cookie? Cookies are small pieces of information, stored in simple text files, placed on your computer by a website. Cookies can be read by the website on your subsequent visits. The information stored in a cookie may relate to your browsing habits on the web page, or a unique identification number so that the website can "remember" you on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have furnished such information to the website in your User Profile.

How does SmartSession use cookies? When you visit SmartSession, we collect your browser type and IP address. This information is gathered for all SmartSession Users. In addition, we send cookies to your computer or other device that uniquely identifies your browser. We use session ID cookies to confirm that Users are logged in. These cookies terminate once the User closes the browser. By default, we use a persistent cookie that stores your login ID (but not your password) to make it easier for you to login when you come back to SmartSession. You can remove or block this cookie using the settings in your browser if you want to disable this convenience feature. We use cookies to collect information about visitors' use of the SmartSession website. The information collected by cookies enables SmartSession to understand the use of its site. This in turn helps to provide visitors with a better experience. SmartSession will not attempt to personally identify visitors from their IP addresses. We use cookies to improve the quality of our service. SmartSession also uses cookies in its advertising services to help advertisers and publishers serve and manage ads across the web. We may set one or more cookies in your browser when you visit a website, including SmartSession sites that use our advertising cookies and that view or click an ad supported by SmartSession's advertising services. Cookies will not be used to contact you for marketing purposes other than by means of advertisements offered within the SmartSession website. Cookies do not in any way compromise the security of your computer.

 
REMOVAL OF YOUR USER PROFILE

13.

If you wish to remove your User Profile information you must contact us at:

Data Protection Officer
SmartSession Ltd
5-7 Cranwood Street
London
EC1V 9EE
UK

 
CONSENT

14.

By providing SmartSession with your information and by your use of this Website you consent to all of your information being used, accessible, available processed, disclosed and retained as set out above.

 
REPRESENTATION

15.

By your use of this Website you warrant and represent to us that in respect of any personal data of any data subject which you provide to us, you have the authority of that data subject to disclose such data to us on these Terms and Conditions of Use and for all the purposes herein set out and to give the consents set out above on behalf of each such data subject, and accordingly, all references in these documents to you shall be deemed to include any such data subject.

 
WHO WE WILL SHARE YOUR INFORMATION WITH

16.

Outside of the SmartSession Platform we will treat your personal information as private and confidential (even when you are no longer a SmartSession User). Nothing about your accounts (apart from what you upload to your User Profile) will be disclosed to anyone, other than in the exceptional cases permitted by law. These include:

(a) where we are legally compelled to do so;

(b) where there is a duty to the public to disclose;

(c) where disclosure is required to protect our interests (this will not be used as a reason for disclosing information about you or your information, including your name and address, to anyone else for marketing purposes);

(d) where disclosure is made at your request or with your consent;

(e) where disclosure is necessary for the performance of our legal agreements with you.

We may also disclose your personal information to the following third parties for the purposes described here:

i) Third party service providers we are using to provide services that involve data processing, for example, to carry out marketing initiatives or run customer surveys on our behalf.

ii) Third parties, such as law firms and law courts, to enforce or apply any contract with you.

iii) Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets.

iv) We may provide usage information (but not your personal details) to other websites so that they know that you have visited our websites (see 'How we use cookies and other methods for the collection of website usage data' above).

v) We may provide usage information including your personal details to marketing agencies to deliver online advertising on websites or social networks.

vi) If necessary to comply with a legal or regulatory obligation in any jurisdiction, including where that obligation arises because of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision).

From time to time we may employ agents and sub-contractors to process your information on our behalf to ensure that your online transactions are secure. The same duty of confidentiality and security will apply to our agents and sub-contractors and all processing will only be carried out under our instruction and will be supported by written contract. In instances where your information may also be shared by contracted third parties these third parties will similarly be under the same duty of confidentiality and security in respect of your data.

 
SECURITY OF INFORMATION

17.

At SmartSession, we understand how important the security and confidentiality of your information is to you. Keeping customer information secure is a top priority for SmartSession. Even so, SmartSession Ltd cannot and does not guarantee the privacy or confidentiality of information relating to you that passes over the Internet. In accessing this Website and in availing of any of the services/information available on or via this Website, you are deemed by the Terms and Conditions of Use to accept that electronic mail messaging and Internet communication may not be free from interference by third parties and may not remain confidential. In all circumstances the use by you of this Website is at your sole risk. You are solely responsible for maintaining your User Profile information. Please be careful and responsible whenever you are online. While we strive to protect your personal information, we cannot ensure or warrant that it will be at all times secure from unauthorised use and you transmit to us at your own risk. You can be assured that we have taken the necessary steps to protect your information by using some of the latest technologies available. This enables you to transact with us online in confidence.

 
DATA ENCRYPTION

18.

To help protect your personal information, we encrypt information where necessary.

 
HYPERLINKS

19.

Some of the pages on this Website may contain hyperlinks to websites not maintained by SmartSession. You are reminded that different Terms and Conditions of Use will apply to you as a User of such websites. In addition such websites may not attain the same privacy standards that SmartSession maintains.

 
AMENDMENTS

20.

The contents of this Website, including these Terms and Conditions of Use, any information contained on this Website and our Privacy Statement are subject to change and to being updated without notice from time to time.

 
ATTEMPTED USE OF WEBSITE

21.

The SmartSession Terms and Conditions of Use shall also apply, subject to alteration as necessary, to attempted access of the Website and attempted use of information on it.

 
GENERAL

22.

In the event that any provision in the SmartSession Terms and Conditions of Use is held to be unenforceable or invalid, such provision shall be severed and the remaining provisions shall be enforceable to the fullest extent permitted by the laws of England.

23.

Clause headings in the SmartSession Terms and Conditions of Use are for reference purposes only and shall not be used to construe or determine the meaning of any or all of the SmartSession Terms and Conditions of Use.

 
SALE OF BUSINESS

24.

We reserve the right to transfer information (including your personal information) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company.

 
SECURITY

25.

Your personal information is held on secure servers hosted by our Internet Service Provider. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we will take all reasonable steps to protect your personal information, the nature of the Internet is such that we cannot and do not guarantee or warrant the security of any information you transmit to us via the Internet.

This Privacy Policy came into effect on 11 July 2018 replacing our previous Privacy Policy. This Privacy Policy applies to all information we process about you in connection with your relationship with SmartSession.

 

Correct as of 25th May 2018.