Smart Soho Ltd.<\/p>\n<\/div>
We\u00a0are very delighted that you have shown interest in our enterprise. Data\u00a0protection is of a particularly high priority for the management of Smart Soho\u00a0Ltd. The use of the\u00a0Internet pages of Smart Soho Ltd is possible without any\u00a0indication of personal data; however, if a data subject wants to use special\u00a0enterprise services via our website, processing\u00a0of personal data could become\u00a0necessary. If the processing of personal data is necessary and there is no\u00a0statutory basis for such processing, we generally obtain consent from the\u00a0data\u00a0subject.<\/p>\n
The\u00a0processing of personal data, such as the name, address, e-mail address, or\u00a0telephone number of a data subject shall always be in line with the General\u00a0Data Protection\u00a0Regulation (GDPR), and in accordance with the country-specific\u00a0data protection regulations applicable to Smart Soho Ltd. By means of this data\u00a0protection declaration, our\u00a0enterprise would like to inform the general public\u00a0of the nature, scope, and purpose of the personal data we collect, use and\u00a0process. Furthermore, data subjects are informed, by\u00a0means of this data\u00a0protection declaration, of the rights to which they are entitled.<\/p>\n
As\u00a0the controller, Smart Soho Ltd has implemented numerous technical and\u00a0organizational measures to ensure the most complete protection of personal data\u00a0processed through this\u00a0website. However, Internet-based data transmissions may\u00a0in principle have security gaps, so absolute protection may not be guaranteed.\u00a0For this reason, every data subject is free to\u00a0transfer personal data to us via\u00a0alternative means, e.g. by telephone.<\/p>\n<\/div><\/div><\/div><\/div><\/div>
DEFINITIONS<\/p>\n<\/li>\n<\/ol>\n
The\u00a0data protection declaration of Smart Soho Ltd is based on the terms used by the\u00a0European legislator for the adoption of the General Data Protection Regulation\u00a0(GDPR). Our\u00a0data protection declaration should be legible and understandable\u00a0for the general public, as well as our customers and business partners. To\u00a0ensure this, we would like to first explain\u00a0the terminology used.<\/p>\n
In\u00a0this data protection declaration, we use, inter alia, the following terms:<\/p>\n
Personal\u00a0data means any information relating to an identified or identifiable natural\u00a0person (\u201cdata subject\u201d). An identifiable natural person is one who can be\u00a0identified, directly or\u00a0indirectly, in particular by reference to an identifier\u00a0such as a name, an identification number, location data, an online identifier\u00a0or to one or more factors specific to the physical,\u00a0physiological, genetic,\u00a0mental, economic, cultural or social identity of that natural person.<\/p>\n
Data\u00a0subject is any identified or identifiable natural person, whose personal data\u00a0is processed by the controller responsible for the processing.<\/p>\n
Processing\u00a0is any operation or set of operations which is performed on personal data or on\u00a0sets of personal data, whether or not by automated means, such as collection,\u00a0recording,\u00a0organisation, structuring, storage, adaptation or alteration,\u00a0retrieval, consultation, use, disclosure by transmission, dissemination or\u00a0otherwise making available, alignment or\u00a0combination, restriction, erasure or\u00a0destruction.<\/p>\n
Restriction\u00a0of processing is the marking of stored personal data with the aim of limiting\u00a0their processing in the future.<\/p>\n
Profiling\u00a0means any form of automated processing of personal data consisting of the use\u00a0of personal data to evaluate certain personal aspects relating to a natural\u00a0person, in\u00a0particular to analyse or predict aspects concerning that natural\u00a0person\u2019s performance at work, economic situation, health, personal preferences,\u00a0interests, reliability, behaviour,\u00a0location or movements.<\/p>\n
Pseudonymisation\u00a0is the processing of personal data in such a manner that the personal data can\u00a0no longer be attributed to a specific data subject without the use of\u00a0additional\u00a0information, provided that such additional information is kept\u00a0separately and is subject to technical and organisational measures to ensure\u00a0that the personal data are not attributed to\u00a0an identified or identifiable\u00a0natural person.<\/p>\n
Controller\u00a0or controller responsible for the processing is the natural or legal person,\u00a0public authority, agency or other body which, alone or jointly with others,\u00a0determines the\u00a0purposes and means of the processing of personal data; where the\u00a0purposes and means of such processing are determined by Union or Member State\u00a0law, the controller or the\u00a0specific criteria for its nomination may be provided\u00a0for by Union or Member State law.<\/p>\n
h) Processor<\/p>\n
Processor\u00a0is a natural or legal person, public authority, agency or other body which\u00a0processes personal data on behalf of the controller.<\/p>\n
Recipient\u00a0is a natural or legal person, public authority, agency or another body, to\u00a0which the personal data are disclosed, whether a third party or not. However,\u00a0public authorities\u00a0which may receive personal data in the framework of a\u00a0particular inquiry in accordance with Union or Member State law shall not be\u00a0regarded as recipients; the processing of those\u00a0data by those public\u00a0authorities shall be in compliance with the applicable data protection rules\u00a0according to the purposes of the processing.<\/p>\n
Third\u00a0party is a natural or legal person, public authority, agency or body other than\u00a0the data subject, controller, processor and persons who, under the direct\u00a0authority of the\u00a0controller or processor, are authorised to process personal\u00a0data.<\/p>\n
Consent\u00a0of the data subject is any freely given, specific, informed and unambiguous\u00a0indication of the data subject\u2019s wishes by which he or she, by a statement or\u00a0by a clear\u00a0affirmative action, signifies agreement to the processing of\u00a0personal data relating to him or her.<\/p>\n
Controller for the\u00a0purposes of the General Data Protection Regulation (GDPR), other data\u00a0protection laws applicable in Member states of the European Union and other\u00a0provisions\u00a0related to data protection is:<\/p>\n
Smart Soho Ltd<\/strong><\/p>\n 55 Greek Street<\/strong> Phone:\u00a0020 3026 2711<\/strong> The Internet pages of\u00a0Smart Soho Ltd use cookies. Cookies are text files that are stored in a\u00a0computer system via an Internet browser.<\/p>\n Many\u00a0Internet sites and servers use cookies. Many cookies contain a so-called cookie\u00a0ID. A cookie ID is a unique identifier of the cookie. It consists of a\u00a0character string through\u00a0which Internet pages and servers can be assigned to\u00a0the specific Internet browser in which the cookie was stored. This allows\u00a0visited Internet sites and servers to differentiate the\u00a0individual browser of\u00a0the dats subject from other Internet browsers that contain other cookies. A\u00a0specific Internet browser can be recognized and identified using the unique\u00a0cookie\u00a0ID.<\/p>\n Through\u00a0the use of cookies, Smart Soho Ltd can provide the users of this website with\u00a0more user-friendly services that would not be possible without the cookie\u00a0setting.<\/p>\n By\u00a0means of a cookie, the information and offers on our website can be optimized\u00a0with the user in mind. Cookies allow us, as previously mentioned, to recognize\u00a0our website\u00a0users. The purpose of this recognition is to make it easier for\u00a0users to utilize our website. The website user that uses cookies, e.g. does not\u00a0have to enter access data each time the\u00a0website is accessed, because this is\u00a0taken over by the website, and the cookie is thus stored on the user\u2019s computer\u00a0system. Another example is the cookie of a shopping cart in an\u00a0online shop. The\u00a0online store remembers the articles that a customer has placed in the virtual\u00a0shopping cart via a cookie.<\/p>\n The\u00a0data subject may, at any time, prevent the setting of cookies through our\u00a0website by means of a corresponding setting of the Internet browser used, and\u00a0may thus permanently\u00a0deny the setting of cookies. Furthermore, already set\u00a0cookies may be deleted at any time via an Internet browser or other software\u00a0programs. This is possible in all popular Internet\u00a0browsers. If the data\u00a0subject deactivates the setting of cookies in the Internet browser used, not\u00a0all functions of our website may be entirely usable.<\/p>\n The website of Smart Soho Ltd collects a series of general data and information\u00a0when a data subject or automated system calls up the website. This general data\u00a0and information\u00a0are stored in the server log files. Collected may be (1) the\u00a0browser types and versions used, (2) the operating system used by the accessing\u00a0system, (3) the website from which an\u00a0accessing system reaches our website\u00a0(so-called referrers), (4) the sub-websites, (5) the date and time of access to\u00a0the Internet site, (6) an Internet protocol address (IP address), (7)\u00a0the\u00a0Internet service provider of the accessing system, and (8) any other similar\u00a0data and information that may be used in the event of attacks on our\u00a0information technology\u00a0systems.<\/p>\n When\u00a0using these general data and information, Smart Soho Ltd does not draw any\u00a0conclusions about the data subject. Rather, this information is needed to (1)\u00a0deliver the content\u00a0of our website correctly, (2) optimize the content of our\u00a0website as well as its advertisement, (3) ensure the long-term viability of our\u00a0information technology systems and website\u00a0technology, and (4) provide law\u00a0enforcement authorities with the information necessary for criminal prosecution\u00a0in case of a cyber-attack. Therefore, Smart Soho Ltd analyzes\u00a0anonymously\u00a0collected data and information statistically, with the aim of increasing the\u00a0data protection and data security of our enterprise, and to ensure an optimal\u00a0level of\u00a0protection for the personal data we process. The anonymous data of the\u00a0server log files are stored separately from all personal data provided by a\u00a0data subject.<\/p>\n The data subject has the possibility to register on the website of the\u00a0controller with the indication of personal data. Which personal data are\u00a0transmitted to the controller is\u00a0determined by the respective input mask used\u00a0for the registration. The personal data entered by the data subject are\u00a0collected and stored exclusively for internal use by the\u00a0controller, and for\u00a0his own purposes. The controller may request transfer to one or more processors\u00a0(e.g. a parcel service) that also uses personal data for an internal purpose\u00a0which\u00a0is attributable to the controller.<\/p>\n By registering\u00a0on the website of the controller, the IP address\u2014assigned by the Internet\u00a0service provider (ISP) and used by the data subject\u2014date, and time of the\u00a0registration are\u00a0also stored. The storage of this data takes place against the\u00a0background that this is the only way to prevent the misuse of our services,\u00a0and, if necessary, to make it possible to\u00a0investigate committed offenses.\u00a0Insofar, the storage of this data is necessary to secure the controller. This\u00a0data is not passed on to third parties unless there is a statutory obligation\u00a0to pass on the data, or if the transfer serves the aim of criminal prosecution.<\/p>\n The\u00a0registration of the data subject, with the voluntary indication of personal\u00a0data, is intended to enable the controller to offer the data subject contents\u00a0or services that may only be\u00a0offered to registered users due to the nature of\u00a0the matter in question. Registered persons are free to change the personal data\u00a0specified during the registration at any time, or to have\u00a0them completely\u00a0deleted from the data stock of the controller.<\/p>\n The\u00a0data controller shall, at any time, provide information upon request to each\u00a0data subject as to what personal data are stored about the data subject. In\u00a0addition, the data\u00a0controller shall correct or erase personal data at the\u00a0request or indication of the data subject, insofar as there are no statutory\u00a0storage obligations. A Data Protection Officer\u00a0particularly designated in this\u00a0data protection declaration, as well as the entirety of the controller\u2019s\u00a0employees are available to the data subject in this respect as contact persons.<\/p>\n The newsletter of Smart Soho Ltd contains so-called tracking pixels. A tracking\u00a0pixel is a miniature graphic embedded in such e-mails, which are sent in HTML\u00a0format to enable\u00a0log file recording and analysis. This allows a statistical\u00a0analysis of the success or failure of online marketing campaigns. Based on the\u00a0embedded tracking pixel, Smart Soho Ltd\u00a0may see if and when an e-mail was\u00a0opened by a data subject, and which links in the e-mail were called up by data\u00a0subjects.<\/p>\n Such\u00a0personal data collected in the tracking pixels contained in the newsletters are\u00a0stored and analyzed by the controller in order to optimize the shipping of the\u00a0newsletter, as well\u00a0as to adapt the content of future newsletters even better\u00a0to the interests of the data subject. These personal data will not be passed on\u00a0to third parties. Data subjects are at any time\u00a0entitled to revoke the\u00a0respective separate declaration of consent issued by means of the double-opt-in\u00a0procedure. After a revocation, these personal data will be deleted by the\u00a0controller. Smart Soho Ltd automatically regards a withdrawal from the receipt\u00a0of the newsletter as a revocation.<\/p>\n The website of Smart Soho Ltd contains information that enables a quick\u00a0electronic contact to our enterprise, as well as direct communication with us,\u00a0which also includes a\u00a0general address of the so-called electronic mail (e-mail\u00a0address). If a data subject contacts the controller by e-mail or via a contact\u00a0form, the personal data transmitted by the data\u00a0subject are automatically\u00a0stored. Such personal data transmitted on a voluntary basis by a data subject\u00a0to the data controller are stored for the purpose of processing or contacting\u00a0the data subject. There is no transfer of this personal data to third parties.<\/p>\n The data controller shall process and store the personal data of the data\u00a0subject only for the period necessary to achieve the purpose of storage, or as\u00a0far as this is granted by the\u00a0European legislator or other legislators in laws\u00a0or regulations to which the controller is subject to.<\/p>\n If\u00a0the storage purpose is not applicable, or if a storage period prescribed by the\u00a0European legislator or another competent legislator expires, the personal data\u00a0are routinely blocked\u00a0or erased in accordance with legal requirements.<\/p>\n 1a) Right of confirmation<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator to obtain\u00a0from the controller the confirmation as to whether or not personal data\u00a0concerning him or her are\u00a0being processed. If a data subject wishes to avail\u00a0himself of this right of confirmation, he or she may, at any time, contact our\u00a0Data Protection Officer or another employee of the\u00a0controller.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator to obtain\u00a0from the controller free information about his or her personal data stored at any\u00a0time and a copy\u00a0of this information. Furthermore, the European directives and\u00a0regulations grant the data subject access to the following information:<\/p>\n the\u00a0purposes of the processing;<\/p>\n the\u00a0categories of personal data concerned;<\/p>\n the\u00a0recipients or categories of recipients to whom the personal data have been or\u00a0will be disclosed, in particular recipients in third countries or international\u00a0organisations;<\/p>\n where\u00a0possible, the envisaged period for which the personal data will be stored, or,\u00a0if not possible, the criteria used to determine that period;<\/p>\n the\u00a0existence of the right to request from the controller rectification or erasure\u00a0of personal data, or restriction of processing of personal data concerning the\u00a0data subject, or to object\u00a0to such processing;<\/p>\n the\u00a0existence of the right to lodge a complaint with a supervisory authority;<\/p>\n where\u00a0the personal data are not collected from the data subject, any available\u00a0information as to their source;<\/p>\n the\u00a0existence of automated decision-making, including profiling, referred to in\u00a0Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful\u00a0information about the\u00a0logic involved, as well as the significance and envisaged\u00a0consequences of such processing for the data subject.<\/p>\n Furthermore,\u00a0the data subject shall have a right to obtain information as to whether\u00a0personal data are transferred to a third country or to an international\u00a0organisation. Where this is\u00a0the case, the data subject shall have the right to\u00a0be informed of the appropriate safeguards relating to the transfer.<\/p>\n If\u00a0a data subject wishes to avail himself of this right of access, he or she may\u00a0at any time contact our Data Protection Officer or another employee of the\u00a0controller.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator to obtain\u00a0from the controller without undue delay the rectification of inaccurate\u00a0personal data concerning\u00a0him or her. Taking into account the purposes of the\u00a0processing, the data subject shall have the right to have incomplete personal data\u00a0completed, including by means of providing a\u00a0supplementary statement.<\/p>\n If\u00a0a data subject wishes to exercise this right to rectification, he or she may,\u00a0at any time, contact our Data Protection Officer or another employee of the\u00a0controller.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator to obtain\u00a0from the controller the erasure of personal data concerning him or her without\u00a0undue delay, and\u00a0the controller shall have the obligation to erase personal\u00a0data without undue delay where one of the following grounds applies, as long as\u00a0the processing is not necessary:<\/p>\n The\u00a0personal data are no longer necessary in relation to the purposes for which\u00a0they were collected or otherwise processed.<\/p>\n The\u00a0data subject withdraws consent to which the processing is based according to\u00a0point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the\u00a0GDPR, and where there\u00a0is no other legal ground for the processing.<\/p>\n The\u00a0data subject objects to the processing pursuant to Article 21(1) of the GDPR\u00a0and there are no overriding legitimate grounds for the processing, or the data\u00a0subject objects to the\u00a0processing pursuant to Article 21(2) of the GDPR.<\/p>\n The\u00a0personal data have been unlawfully processed.<\/p>\n The\u00a0personal data must be erased for compliance with a legal obligation in Union or\u00a0Member State law to which the controller is subject.<\/p>\n The\u00a0personal data have been collected in relation to the offer of information\u00a0society services referred to in Article 8(1) of the GDPR.<\/p>\n If\u00a0one of the aforementioned reasons applies, and a data subject wishes to request\u00a0the erasure of personal data stored by Smart Soho Ltd, he or she may at any\u00a0time contact our Data\u00a0Protection Officer or another employee of the controller.\u00a0The Data Protection Officer of Smart Soho Ltd or another employee shall\u00a0promptly ensure that the erasure request is\u00a0complied with immediately.<\/p>\n Where\u00a0the controller has made personal data public and is obliged pursuant to Article\u00a017(1) to erase the personal data, the controller, taking account of available\u00a0technology and the\u00a0cost of implementation, shall take reasonable steps,\u00a0including technical measures, to inform other controllers processing the\u00a0personal data that the data subject has requested erasure\u00a0by such controllers\u00a0of any links to, or copy or replication of, those personal data, as far as\u00a0processing is not required. The Data Protection Officer of Smart Soho Ltd or\u00a0another\u00a0employee will arrange the necessary measures in individual cases.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator to obtain\u00a0from the controller restriction of processing where one of the following\u00a0applies:<\/p>\n The\u00a0accuracy of the personal data is contested by the data subject, for a period\u00a0enabling the controller to verify the accuracy of the personal data.<\/p>\n The\u00a0processing is unlawful and the data subject opposes the erasure of the personal\u00a0data and requests instead the restriction of their use instead.<\/p>\n The\u00a0controller no longer needs the personal data for the purposes of the\u00a0processing, but they are required by the data subject for the establishment,\u00a0exercise or defence of legal\u00a0claims.<\/p>\n The\u00a0data subject has objected to processing pursuant to Article 21(1) of the GDPR\u00a0pending the verification whether the legitimate grounds of the controller\u00a0override those of the\u00a0data subject.<\/p>\n If\u00a0one of the aforementioned conditions is met, and a data subject wishes to\u00a0request the restriction of the processing of personal data stored by Smart Soho\u00a0Ltd, he or she may at any\u00a0time contact our Data Protection Officer or another\u00a0employee of the controller. The Data Protection Officer of Smart Soho Ltd or\u00a0another employee will arrange the restriction of\u00a0the processing.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator, to\u00a0receive the personal data concerning him or her, which was provided to a\u00a0controller, in a structured,\u00a0commonly used and machine-readable format. He or\u00a0she shall have the right to transmit those data to another controller without\u00a0hindrance from the controller to which the personal\u00a0data have been provided, as\u00a0long as the processing is based on consent pursuant to point (a) of Article\u00a06(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract\u00a0pursuant to point (b) of Article 6(1) of the GDPR, and the processing is\u00a0carried out by automated means, as long as the processing is not necessary for\u00a0the performance of a task\u00a0carried out in the public interest or in the exercise\u00a0of official authority vested in the controller.<\/p>\n Furthermore,\u00a0in exercising his or her right to data portability pursuant to Article 20(1) of\u00a0the GDPR, the data subject shall have the right to have personal data\u00a0transmitted directly\u00a0from one controller to another, where technically feasible\u00a0and when doing so does not adversely affect the rights and freedoms of others.<\/p>\n In\u00a0order to assert the right to data portability, the data subject may at any time\u00a0contact the Data Protection Officer designated by Smart Soho Ltd or another\u00a0employee.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator to object,\u00a0on grounds relating to his or her particular situation, at any time, to\u00a0processing of personal data\u00a0concerning him or her, which is based on point (e)\u00a0or (f) of Article 6(1) of the GDPR. This also applies to profiling based on\u00a0these provisions.<\/p>\n Smart\u00a0Soho Ltd shall no longer process the personal data in the event of the\u00a0objection, unless we can demonstrate compelling legitimate grounds for the\u00a0processing which override\u00a0the interests, rights and freedoms of the data\u00a0subject, or for the establishment, exercise or defence of legal claims.<\/p>\n If Smart\u00a0Soho Ltd processes personal data for direct marketing purposes, the data\u00a0subject shall have the right to object at any time to processing of personal\u00a0data concerning him or\u00a0her for such marketing. This applies to profiling to the\u00a0extent that it is related to such direct marketing. If the data subject objects\u00a0to Smart Soho Ltd to the processing for direct\u00a0marketing purposes, Smart Soho\u00a0Ltd will no longer process the personal data for these purposes.<\/p>\n In\u00a0addition, the data subject has the right, on grounds relating to his or her\u00a0particular situation, to object to processing of personal data concerning him or\u00a0her by Smart Soho Ltd for\u00a0scientific or historical research purposes, or for\u00a0statistical purposes pursuant to Article 89(1) of the GDPR, unless the\u00a0processing is necessary for the performance of a task carried\u00a0out for reasons\u00a0of public interest.<\/p>\n In\u00a0order to exercise the right to object, the data subject may directly contact\u00a0the Data Protection Officer of Smart Soho Ltd or another employee. In addition,\u00a0the data subject is free\u00a0in the context of the use of information society\u00a0services, and notwithstanding Directive 2002\/58\/EC, to use his or her right to\u00a0object by automated means using technical\u00a0specifications.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator not to be\u00a0subject to a decision based solely on automated processing, including\u00a0profiling, which produces\u00a0legal effects concerning him or her, or similarly\u00a0significantly affects him or her, as long as the decision (1) is not is\u00a0necessary for entering into, or the performance of, a contract\u00a0between the data\u00a0subject and a data controller, or (2) is not authorised by Union or Member\u00a0State law to which the controller is subject and which also lays down suitable\u00a0measures\u00a0to safeguard the data subject\u2019s rights and freedoms and legitimate\u00a0interests, or (3) is not based on the data subject\u2019s explicit consent. If the\u00a0decision (1) is necessary for entering\u00a0into, or the performance of, a contract\u00a0between the data subject and a data controller, or (2) it is based on the data\u00a0subject\u2019s explicit consent, Smart Soho Ltd shall implement\u00a0suitable measures to\u00a0safeguard the data subject\u2019s rights and freedoms and legitimate interests, at\u00a0least the right to obtain human intervention on the part of the controller, to\u00a0express\u00a0his or her point of view and contest the decision. If the data subject\u00a0wishes to exercise the rights concerning automated individual decision-making,\u00a0he or she may at any time\u00a0directly contact our Data Protection Officer of Smart\u00a0Soho Ltd or another employee of the controller.<\/p>\n Each\u00a0data subject shall have the right granted by the European legislator to\u00a0withdraw his or her consent to processing of his or her personal data at any\u00a0time.<\/p>\n f\u00a0the data subject wishes to exercise the right to withdraw the consent, he or\u00a0she may at any time directly contact our Data Protection Officer of Smart Soho\u00a0Ltd or another\u00a0employee of the controller.<\/p>\n Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for\u00a0which we obtain consent for a specific processing purpose. If the processing of\u00a0personal data is\u00a0necessary for the performance of a contract to which the data\u00a0subject is party, as is the case, for example, when processing operations are\u00a0necessary for the supply of goods or to\u00a0provide any other service, the\u00a0processing is based on Article 6(1) lit. b GDPR. The same applies to such\u00a0processing operations which are necessary for carrying out pre-contractual\u00a0measures, for example in the case of inquiries concerning our products or\u00a0services. Is our company subject to a legal obligation by which processing of\u00a0personal data is required,\u00a0such as for the fulfillment of tax obligations, the\u00a0processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of\u00a0personal data may be necessary to protect the vital\u00a0interests of the data\u00a0subject or of another natural person. This would be the case, for example, if a\u00a0visitor were injured in our company and his name, age, health insurance data or\u00a0other vital information would have to be passed on to a doctor, hospital or\u00a0other third party. Then the processing would be based on Art. 6(1) lit. d GDPR.\u00a0Finally, processing\u00a0operations could be based on Article 6(1) lit. f GDPR. This\u00a0legal basis is used for processing operations which are not covered by any of\u00a0the abovementioned legal grounds, if\u00a0processing is necessary for the purposes\u00a0of the legitimate interests pursued by our company or by a third party, except\u00a0where such interests are overridden by the interests or\u00a0fundamental rights and\u00a0freedoms of the data subject which require protection of personal data. Such\u00a0processing operations are particularly permissible because they have been\u00a0specifically mentioned by the European legislator. He considered that a legitimate\u00a0interest could be assumed if the data subject is a client of the controller\u00a0(Recital 47 Sentence 2\u00a0GDPR).<\/p>\n Where the processing of personal data is based on Article 6(1) lit. f GDPR our\u00a0legitimate interest is to carry out our business in favor of the well-being of\u00a0all our employees and the\u00a0shareholders.<\/p>\n The criteria used to determine the period of storage of personal data is the\u00a0respective statutory retention period. After expiration of that period, the\u00a0corresponding data is routinely\u00a0deleted, as long as it is no longer necessary\u00a0for the fulfillment of the contract or the initiation of a contract.<\/p>\n We clarify that the provision of personal data is partly required by law (e.g.\u00a0tax regulations) or can also result from contractual provisions (e.g.\u00a0information on the contractual\u00a0partner). Sometimes it may be necessary to\u00a0conclude a contract that the data subject provides us with personal data, which\u00a0must subsequently be processed by us. The data subject\u00a0is, for example, obliged\u00a0to provide us with personal data when our company signs a contract with him or\u00a0her. The non-provision of the personal data would have the consequence\u00a0that the\u00a0contract with the data subject could not be concluded. Before personal data is\u00a0provided by the data subject, the data subject must contact our Data Protection\u00a0Officer. Our\u00a0Data Protection Officer clarifies to the data subject whether the\u00a0provision of the personal data is required by law or contract or is necessary\u00a0for the conclusion of the contract,\u00a0whether there is an obligation to provide\u00a0the personal data and the consequences of non-provision of the personal data.<\/p>\n As a responsible\u00a0company, we do not use automatic decision-making or profiling.<\/p>\n<\/div><\/div><\/div><\/div><\/div> Back to the smart stuff<\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>
\n Soho<\/strong>
\n London<\/strong>
\n W1D 3DT<\/strong><\/p>\n
\n Email: agency@smartsoho.co.uk<\/strong>
\n Website: www.smartsoho.co.uk<\/strong><\/p>\n\n
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