Smile understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this Website, https://www.wearesmileapp.com/ and will only collect and use personal data in ways that are described here, and in a way that is consistent with my obligations and your rights under the law.

Privacy Policy

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Smile. If you do not accept and agree with this Privacy Policy, you must stop using this site immediately.

 

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Cookie” means a small text file placed on your computer or device by Smile when you visit certain parts of the site and/or when you use certain features. Details of the Cookies used by my Site are set out in Part 14, below; and

“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003

 

2. Information About Smile

Founded by Emma Amoscato 2021

Email address: notifications@blog.ascendbywix.com

3. What Does This Policy Cover?
 

This Privacy Policy applies only to your use of the Smile Website and Application. The Site/App may contain links to other Websites. Please note that we have no control over how your data is collected, stored, or used by other Websites and we advise you to check the privacy policies of any such Websites before providing any data to them.

4. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

 

5. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. The right to be informed about my collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact me to find out more or to ask any questions using the details in Part 15.

  2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.

  3. The right to have your personal data rectified if any of your personal data held by me is inaccurate or incomplete. Please contact me using the details in Part 15 to find out more.

  4. The right to be forgotten, i.e. the right to ask me to delete or otherwise dispose of any of your personal data that we have. Please contact me using the details in Part 15 to find out more.

  5. The right to restrict (i.e. prevent) the processing of your personal data.

  6. The right to object to me using your personal data for a particular purpose or purposes.

  7. The right to data portability. This means that, if you have provided personal data to me directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask me for a copy of that personal data to re-use with another service or business in many cases.

  8. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
     

For more information about my use of your personal data or exercising your rights as outlined above, please contact me using the details provided in Part 15.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about my use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

 

6. What Data Do We Collect?

Depending upon your use of the Smile Site/App, we may collect some or all of the following personal and non-personal data (please also see Part 14 on my use of Cookies and similar technologies)
 

  • Name;

  • Email address;

  • Telephone number;

  • IP address;

  • Web browser type and version;

  • Operating system;

  • A list of URLs starting with a referring site, your activity on my Site/App, and the site you exit to.
     

​7. How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for my performance of a contract with you, because you have consented to my use of your personal data, or because it is in my legitimate business interests to use it. Your personal data may be used for one of the following purposes:
 

  • Personalising and tailoring your experience on my Site/App;

  • Communicating with you. This may include responding to emails or calls from you.

  • Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by
     

I will always work to fully protect your rights and comply with my obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

Third Parties (including; Smile App Experts, Mind, NHS) whose content appears on my Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

 

8. How Long Will You Keep My Personal Data?

I will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

  • The life of the Smile Website and application

 

9. How and Where Do You Store or Transfer My Personal Data?

I will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.

10. Do You Share My Personal Data?

I will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

UNLESS
 

You are the winner of a giveaway; in which case you will be asked to confirm your contact details and address to receive the prize(s). We will make it clear if it will be Smile sending you the prize(s) or if we need to pass your details onto the company to arrange delivery of your prize. This will not be done without your approval.

You have submitted feedback for a Smile survey and asked for a response, agreed to us contacting you, or have been chosen at random to receive a voucher as thanks for completing the survey.

11. How Can I Control My Personal Data?
 

  • In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via my Site, you may be given options to restrict my use of your personal data. In particular, we aim to give you strong controls on my use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from me which you may do by unsubscribing using the links provided in my emails and, at the point of providing your details and by managing your Account).

  • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
     

12. Can I Withhold Information?

You may access any area of my site without providing personal information unless you choose to leave a comment.

You may restrict my use of Cookies. For more information, see Part 14.

 

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask me for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell me everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover my administrative costs in responding.

I will respond to your subject access request within a month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of my progress.

14. How Do You Use Cookies?

The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customise Website content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics and Hot Jar as described herein.
 

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers.

 

However, if users deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.

15. How Do I Contact Smile?

To contact me about anything to do with your personal data and data protection, including to make a subject access request, please contact us notifications@blog.ascendbywix.com for questions related to this Privacy Policy.

16. Changes to this Privacy Policy

I may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on my Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of my Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

17. Affiliate Program Participation

The Website may engage in affiliate marketing, which is done by embedding tracking links into the Website. If you click on a link for an affiliate partnership, a cookie will be placed on your browser to track any sales for purposes of commissions.

Where this occurs, you the purchaser incur no extra cost, but Smile receive a small monetary payment for introducing you to the product/person/brand/business.

18. Newsletters

On the Website, you may subscribe to our newsletter, which may be used for advertising purposes. All newsletters sent may contain tracking pixels. The pixel is embedded in emails and allows an analysis of the success of online marketing campaigns. Because of these tracking pixels, we may see if and when you open an email and which links within the email you click. Also, this allows the Website to adapt the content of future newsletters to the interests of the user. This behaviour will not be passed on to third parties. MailChimp/Wix – this service is used for delivery of email updates and newsletters. We store your name and email address for purposes of delivering such communications.  Please refer to the MailChimp privacy policy for further information/Please refer to the Wix privacy policy for further information.

 

19. Children’s Information

The Website does not knowingly collect any personally identifiable information from children under the age of 16. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately via email and we will use our best efforts to promptly remove such information from our records.

20. Members Area/Smile File

Finally, the members area of Smile and your personal Smile File is private to you. We at Smile cannot access your Smile File’s personal notes.

We/other members can see your Members Area name, nickname, bio and any images you download for avatars/profile pictures or cover pictures. All other information is private to you.

 

SMILE Privacy Policy up to date as of January 2022

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