GDPR DATA Privacy notice

This is the privacy notice of SmartKem Ltd (06652152).

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can request a pdf version of the policy here enquiries@smartkem.com

  1. WHO WE ARE AND IMPORTANT INFORMATION
  2. THE PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW WE COLLECT YOUR PERSONAL DATA
  4. HOW WE USE YOUR PERSONAL DATA
  5. WHO WE SHARE YOUR PERSONAL DATA WITH
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. Changes to this notice and your duty to inform us of changes
  11. QUERIES, REQUESTS OR CONCERNS

 

  1. WHO WE ARE AND IMPORTANT INFORMATION 

SmartKem is the market leader in the design, synthesis and supply of organic semiconductors for the manufacture of a new generation of lightweight, unbreakable and low power EPD, LCD, OLED and microLED displays on both glass or plastic.

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your contact and business dealings with us and when you use our website, including any data you may provide through this website when you purchase a product or service from us, or sign up for newsletters.

Our website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller(s)

SmartKem Ltd is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice). Our contact details are Hexagon Tower, Delaunays Road, Blackley, Manchester, M9 8GQ, UK, for all data matters contact our Data Protection Officer at enquiries@smartkem.com or at the above address.

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

  1. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Dataincludes: First name, Last name,
  • Contact Dataincludes: First Name, last name, Company name, Billing address, Delivery Address, Email address and contact phone numbers.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

  1. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you through:

  • You may give us your – name, contact details and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Apply for our products or services.
    • Subscribe to our service or publications.
    • Request marketing to be sent to you.

 

  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contract thismeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

  • Legitimate Interestthis means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at: enquiries@smartkem.com

 

  • Comply with a legal or regulatory obligationthis means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at enquiries@smartkem.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

 

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a)    Identity

(b)    Contact

Performance of a contract with you
To process and deliver your order including:

(a)    Manage payments, fees and charges

(b)    Collect and recover money owed to us

(a)    Identity

(b)    Contact

(c)    Financial

(d)    Transaction

(a)    Performance of a contract with you

(b)    Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a)    Notifying you about changes to our terms or privacy policy

(b)    Asking you to leave a review or take a survey

(a)    Identity

(b)    Contact

(c)    Profile

(d)    Marketing and Communications

(a)    Performance of a contract with you

(b)    Necessary to comply with a legal obligation

(c)    Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data controls:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We may use other companies to provide marketing services on our behalf, e.g. processing, mailing or delivering orders, answering customers’ questions about products or services, sending mail and emails, customer analysis. We will never sell or rent your personal information to other organisations.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following any Opt-out links on any marketing messages we may send or by contacting: enquiries@smartkem.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchased or any other transaction you have with SmartKem Ltd.

Cookies – While using our web-site

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

IP addresses – While using our web-site

We may collect information about your computer, including, where available, your domain name, IP address, operating system and browser type, for system administration and to report aggregate information to third parties for marketing, advertising or other promotional purposes. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact enquiries@smartkem.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

  1. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties such as: Internal Accounts department or Internal sales department
  • External Third Parties Service such as:
    • Providers acting as processors based In the United Kingdom who provide or maintain our IT systems or administration services.
    • Professional advisers as processors including lawyers, bankers, auditors and insurers based The United Kingdom who provide consultancy, banking, legal, Insurance and banking services to SmartKem Ltd.
  • HM Revenue & Customs, regulators and other authorities acting as processors based The United Kingdom who require reporting of processing activities in certain circumstances.
  • Specific Third parties as detailed in paragraph 4 above.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

  1. INTERNATIONAL TRANSFERS

We DO NOT transfer your personal data outside the European economic area (EEA)

 

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction data for Six (6) years after they cease to being customers for tax purposes. In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances after or during this time we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

  1. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact us enquiries@smartkem.com detailing your concerns and comments required.

 No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. Changes to this notice and your duty to inform us of changes

From 25th May 2018 there will be changes made In the Data Protection Laws. We are still working towards getting our systems ready for these changes.  You are still protected by law regarding how we use your data.

Any changes we may make to our privacy policy in the future will be posted on our web-site and, where appropriate, notified to you by e-mail.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

 

  1. Queries, requests or concerns

To exercise all relevant rights, any questions, comments, requests, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data protection officer at enquiries@smartkem.com

GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with GDPR.

Please write to us c/o Data Protection Officer, Hexagon Tower, Delaunays Road, Blackley, Manchester, M9 8GQ, UK, to requests a copy of your data held about you.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.