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Privacy Policy

Welcome to SMKDEV! This Privacy Policy applies to www.smkdev.co.uk operated by me, Shane Kirby, 7 Bell Yard, London, WC2A 2JR, UK and the third parties I`m using to provide the website “we”, “us”, “our”.

If you have any questions about my Privacy Policy or wish to exercise your rights under applicable laws, please contact me using contact@smkdev.co.uk, or my contact form or write to me at the above address. 

Background
This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective I would like to explain to you the following three concepts. 

What is Personal Data?
Personal Data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute Personal Data. 

What is Processing?
"Processing" means and covers virtually any handling of data.

What law applies?
I act as the data controller in accordance with the UK`s Data Protection Act (“DPA”) and the EU`s General Data Protection Regulation (“GDPR”).
General Principles
  •  Purpose and legal basis of processing
In accordance with the DPA and GDPR we need to have both a purpose and a legal basis to process Personal Data. The purposes are:

  • providing the website and my apps and their functions and contents,
  • responding to contact requests and communicating with our customers,
  • providing my services, customer and user support, and
  • security measures.

Of course, we can only do that if we have at least one of the following legal bases or in other words lawful reasons to do so. Unless specifically described below, we typically link the above purposes to one of the following:

  • consent,
  • to fulfil my services and carry out contractual obligations,
  • to fulfil our legal obligations, and
  • to protect our legitimate interests. 

  •  Security
We take appropriate technical and organisational measures, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. We also have procedures in place to ensure the exercise of data subjects' rights, deletion of data and response to data compromise. Furthermore, we already take the protection of Personal Data into account during the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Nevertheless, internet-based data transmissions can always have security gaps, so absolute protection cannot be guaranteed. In this sense, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. 

Upon becoming aware of a data breach, I will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

  • Retention
I retain your Personal Data as necessary in connection with the purposes described in this Privacy Policy, and in accordance with the UK’s Statutory Retention Periods and other applicable laws for up to 6 years.

  • Minors
I do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

  •  Automated decision-making
Automated decision-making including profiling does not take place.

  •   Do Not Sell
I do not sell your Personal Data.

  •  Special Category Data
Unless specifically required and consent is obtained, for a particular service, we do not process special category data.

  •  International Transfer
In the course of my website operation, we process data. We usually do not transfer Personal Data to countries outside the UK or the EEA. However, if we do, I will make sure that processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses for a high level of data protection.

  •  Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings at home or abroad or to fulfil our legitimate interests.

Data collection and processing
  • Data we collect directly
I may ask you for Personal Data when you:
  • use my website,
  • request services, support, or information,
  • participate online or otherwise in marketing activities,
  • subscribe to my marketing and promotional emails or other materials,
  • interact with me on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
  • contact me.

Categories of Personal Data we collect may include your name, email address, phone number, IP addresses, the context of your message which may also include certain Personal Data, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs. We may also collect demographic data such as your interests and preferences. 

In order to provide you with a more consistent and personalised user experience in your interactions with me, data collected through one source may also be linked to other data collected by us through other sources. This may include data that helps us to identify you when you access my website through several different devices.

I also collect, process, and use the information you provide for the purpose of initiating and executing a contract when you ask me to. This may include Personal and non- Personal Data, in particular your name, billing address and e-mail address phone number, as well as information on the type of payment method you have chosen. I store the information you provide for the period of processing and handling the contractual services. Afterwards, your data will be deleted. Data that I am required to store due to legal, statutory, or contractual retention obligations will be blocked instead of being deleted to prevent it being used for other purposes. The processing of the data serves the fulfilment of the contract with you. 

  • Data we collect automatically 
We may automatically collect information about user behaviour and usage regarding your visits to my websites, such as the pages you view, the links you click, and other actions you take in connection with my website. 

We may also collect certain information about the browser you use to access my website, such as your IP address, device identifier, location data, browser type and language, and your access times, the URL ("Uniform Resource Locator") of the website from which you arrived at my website, and the URL to which you are directed after leaving my website if you clicked on a link on my website.

  • Data from third party sources
We may obtain data about you from third-party sources, such as our marketing partners, social networks, and other third parties. We may use this data to better analyse your user behaviour to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.

  • Cookies
We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

  • Hosting
To provide my website, we use the services of Weebly operated by Squareup International Ltd. Doing so, Weebly processes the data to be processed in connection with the operation of this website on my behalf. The legal basis is our legitimate interest.

Our use of Personal Data
I may use your Personal Data for the following purposes:

  • providing you with my services and apps and support, and conducting transactions you request,
  • enabling you to use my website,
  • providing support to respond to your online inquiries,
  • customise, analyse, and optimise my website and services (including content to gauge usage trends and determine the effectiveness of our marketing campaigns),
  • better understanding our readers and website users, 
  • personalising content and implementing your preferences,
  • prevention of fraud and other prohibited or unlawful activities,
  • protecting the security and integrity of my websites, businesses, and services; and
  • other functions and purposes disclosed to you at the time of collection or as required or permitted by law.

Cooperation with processors
We use content or service offers of third-party providers on the basis of my legitimate interests in order to integrate their content and services on my website. This usually requires that the third-party provider becomes aware of your IP address so that the content and services can be displayed on your device. 

Below you can find a list of the relevant content and services we use along with the relevant third-party provider. We would like to ask you to review their privacy policies, which contain further information on the processing of Personal Data and so-called opt-out measures, if any. 

  • Analytics and Tracking: Google Analytics by Google LLC 
  • Spam protection: reCAPTCHA by Google LLC

Marketing
Insofar as you have also given me your consent to process your Personal Data for marketing and advertising purposes, I`m entitled to contact you for these purposes via the communication channels you have given your consent to.

Your Rights and Privileges 
  • Privacy rights 
Under the DPA and GDPR, you can exercise the following rights:
  • Right to information
  • Right to rectification
  • Right to object to processing
  • Right to deletion
  • Right to data portability
  • Right of objection
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing

If you have any questions, please contact us.

  • Updating your information
If you believe that the information I hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting me.

  • Withdrawing your consent 
You can withdraw consents you have given at any time by contacting me. 

  • Access Request 
In the event you want to make a Data Subject Access Request, please contact us. I will respond to requests regarding access and correction as soon as reasonably possible. Should I`m not be able to respond to your request within thirty (30) days, I will tell you why and when I will be able to respond to your request. If I`m unable to provide you with any Personal Data or to make a correction requested by you, I will tell you why.

  • Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in the UK is: The Information Commissioner's Office (ICO) is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK www.ico.org.uk 

Changes 
I may update this Privacy Policy from time to time. If I make changes to this Privacy Policy or we materially change our use of your Personal Data, I will revise the Privacy Policy accordingly. 

Questions?
If you have any questions about the processing of your Personal Data, please contact me using contact@smkdev.co.uk, or my contact form or write to me at the above address.

This Privacy Policy was last updated on Friday, 17 February 2023.
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