Privacy & Cookies Notice

This Privacy & Cookies Notice was updated on 16th May 2018.

This notice explains how personal information about you is collected and used when you contact us, or use our products and services through our website, (the "Website") or otherwise. SmartFocus UK Limited (and its affiliates and group companies) (referred to in this policy as “we” or “us”) are joint data controllers (as we operate as a group for operation and administrative purposes), as appropriate to the relationship between you and us.  We are responsible for how your personal information is collected and used.

We are committed to protecting and respecting your privacy and this notice explains how we look after your personal information and about your privacy rights.  We have a data protection officer who is responsible for data protection at SmartFocus and please see the contact us section for contact details for our data protection officer if you have any queries concerning this notice, how we use your personal information and or how to exercise your rights.

Please read this notice together with our Terms of Use before you use or access our products and services, to understand how we may use your personal information, and your rights in respect of it.

This Notice provides you with information about:

1. Information We Collect From You

We may collect and process personal information about you:

 (a) When you interact with us directly by:

  • Visiting our Website;
  • Contacting us via our Website to find out more information (by email, phone or direct mail) about any of our products or services highlighted on our Website, or previously to enable access to content hosted on our Website such as webinars, videos, eBooks or whitepapers;
  • Taking part in customer surveys and questionnaires hosted on our Website or via third party survey tools; and
  • Contacting us either in writing, or by calling our customers services number, or via our live chat functionality on our Website.

(b) From third parties:

  • When you interact with a third party to access their products or services which may be sponsored by us and they tell you that your information may be shared with us; and
  • We may also check and update the details that we hold on you with the professional details which are publicly available on your professional social media profile (for example, LinkedIn) or your business website.

Personal information that you provide voluntarily to us may include: name, email address, phone number (including mobile number), job title, company name, country, state, your communications and marketing preferences, information about products and services you’ve bought, enquired about or shown an interest in and details provided to us as part of an application for employment.   

Personal information that we automatically collect about you may include: Personal information about your business contact details and job title, if confirmed via your publicy available professional social media profile or business website. Information about your interaction with our Website collected using cookies stored on your device, your IP address, which is a number (which indicates the country you are in) that allows your device to communicate with websites and apps, your location or your online browsing activities.

Third Party Sites

This Notice only applies to our Website. The Website may contain links to other sites which are outside our control and not covered by this Notice. Please be aware that we are not responsible for the privacy practices of these other sites. We encourage our visitors to be aware of this when they leave our Website, and to read the privacy policy of such websites linked to when visiting them.

2. How and Why We Use Your Information

We use your personal information to:

  • Provide you with the product or service requested by you and to fulfil our contractual obligations to you.
  • Allow you to participate in interactive features of our services, when you choose to do so. 
  • If you are a customer, to manage your account with us and provide you with customer services and service messages relating to our products and services.
  • Personalize our electronic communications to you and our content based on your language or location.
  • Provide you with information about our products and services or thought leadership content that we believe will be of interest to you, via email, phone or direct mail if you sign up with us or choose to do so.  At any time you may withdraw your consent by clicking the unsubscribe link on any of our emails, or change your communication preferences by emailing us at
  • Analyse, manage and improve our Website and products and services.
  • Tell you about important changes to the Website via email.
  • Carry out customer and marketing research.
  • To ensure business policies are adhered to.
  • If you apply to work with us, to process that application.
  • To comply with any legal, regulatory ort corporate governance obligations and good practice or in connection with legal proceedings or investigations.

Sharing Your Personal Information

We may share your personal information within the SmartFocus Group so we can provide you with the relevant products and services, where we are required or permitted to do so by law or to any successors in title of our business.

We may be required by law or a court of competent jurisdiction to share your personal information with third parties, including to meet national security or law enforcement requirements.

We may share your personal information with third parties including our business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, for the above reasons or with your agreement.

Sharing your information internationally

The personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

Where we share your personal information in countries outside of the EEA, we will take appropriate measures to protect your privacy and your personal information, by obtaining assurances from the recipients (to the extent permitted by law) that they will safeguard your personal information in a manner that is consistent with this Notice. In addition, if we learn that a third party is using or disclosing your personal information in a manner that is contrary to this Notice, we will take reasonable steps to prevent or stop such use or disclosure.

SmartFocus US, Inc. Complies with the EU-U.S. Privacy Shield Framework  and the Swiss – U.S.  Privacy Shield Framework

Where we share your personal information with SmartFocus, US Inc, we do so on the basis that SmartFocus US, Inc. complies with the EU – U.S. Privacy Shield Framework and the Swiss – U.S.  Privacy Shield Framework. These frameworks are established by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union member countries and Switzerland. SmartFocus US, Inc. has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, and to view SmartFocus US, Inc.’s certification, please visit

Additionally, we are subject to the investigatory and enforcement powers of the Federal Trade Commission.

SmartFocus may be liable for onward transfers of personal data to third parties in violation of this Notice and the Privacy Shield.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection and use of your personal information.

You may also request limitations on how SmartFocus uses or discloses personal data about you. Under the Privacy Shield Framework and this Notice, you have the right to request limitations on how SmartFocus uses or discloses personal data about you. With our Privacy Shield certification, SmartFocus has committed to respect these rights. To exercise these rights, please contact us as indicated below. We will respond to such requests within a reasonable timeframe.

In the event your complaint is not resolved by us or our U.S.-based third party dispute resolution provider you may have the option under Privacy Shield to binding arbitration. For more information please visit

3. Information Security

We take appropriate technical and organisational measures to safeguard your personal information.  Even though we take these measures, we cannot guarantee its security if you transfer information over the Internet to us.

4. Cookies

What is a Cookie?

Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user's device.

How We Use Cookies on the Website

A list of all the cookies used on the Website by category is set out below.

The Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site and your browsing experience. By using the Website, you agree that we can place these types of cookies on your device.

Session Cookies
These cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. If you have chosen to identify yourself to us, we use session cookies containing encrypted information to allow us to uniquely identify you.

  • ASP.NET_SessionId
    Enables us to store a unique identifier for your session

Persistent Cookies
These cookies remain on your computer after you close your browser or turn off your computer. They are activated each time that the user visits the website that created that particular cookie. When you purchase our services or provide us with personal information, a unique identifier is assigned to you. This unique identifier is associated with a persistent cookie that we place on your Web browser. We are especially careful about the security and confidentiality of the information stored in persistent cookies. For example, we do not store account numbers or passwords in persistent cookies.

  • __ar_v4
    Enables other websites to know that you have visited our website (using DoubleClick)
  • _ga
    Enables us to track non-personal visitor information such as number of visits, visit length and referrer (using Google Analytics)
  • AdRoll
    Enables us to present you with retargeting advertising on other websites (using AdRoll)
  • GeolocatedCountry
    Enables us to predict your location and display content in the appropriate language
  • Google AdWords Conversion
    Enables us to track leads and other conversions from our advertising (using Google AdWords)
  • Smartfocus#lang
    Enables us to store your preferred content language
    Enables us to track who has visited our website (using Lead Forensics

5. Marketing and Customer Research

We may contact you with information about our products or services or other marketing research, if you agree for us to do so.  If you are a customer, we will assume that you expect us to keep you up to date with our latest products and services unless you tell us you prefer us not to.  If you decide not to receive any further marketing information from us, please follow the unsubscribe instructions included in our emails or you can contact us at to update your communication preferences.

6. Your Rights

Our business means that we perform marketing services for our clients, who will be the data controller for these communications.  If you wish to exercise your rights in respect of these activities, please contact the sender of the marketing communication, as identified in the email that you receive.

Where you have a relationship direct with us – ie. if you are one of our clients, contacts, suppliers, job applicant, employees or contractors (or ex-employees or previous contractors), then we will be acting as data controller in respect of the information we hold on you.  So, under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please complete the Data Subject Request form available here.

​7. Changes to Our Privacy Notice

We may need to update and to change this Notice at any time and, where appropriate and possible, these changes will be notified to you by e-mail. Please check back frequently to see any updates or changes to our Notice.

8. How to Contact Us

For questions, comments, requests or complaints regarding this privacy Notice or about how we collect store or use your personal information please contact us at

If you wish to find out more about your rights or if you are not satisfied with our response and wish to make a complaint, please contact the Information Commissioners Office at

© SmartFocus 2018