Last updated 12/08/2024

 

1. PURPOSE OF THIS NOTICE

This notice describes how we collect and use personal data about you, in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and any other applicable laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

 

2. ABOUT US

Smooth AI limited trading as The Digital Accountants Club is a Consultancy company providing membership services to individuals and businesses to help them understand and learn about Artificial Intelligence tools and applications.

We are registered in England and Wales as a limited company under number 15496933 and our registered office is at 1000 Lakeside North Harbour, Western Road, Portsmouth, PO6 3EN.

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.

 

3. HOW WE COLLECT YOUR PERSONAL DATA

We obtain personal data about you, for example, when:

• Subscribe to our membership community
• You OR your employer OR our clients engage us to provide our services and also during the provision of those services;
• You contact us by email, telephone, post or social media or
• From third parties and/or publicly available resources (for example, from your employer or from Companies House)

 

4. THE INFORMATION WE HOLD ABOUT YOU

The information we hold about you includes, but is not limited to, the following:

• Your personal details (such as your name and/or address);
• Contact details, such as your email address and phone numbers
• Your profile details as a member of the Digital Accountants Club community
• Comments and other interactions on our social media platforms
• Your interactions with the Digital Accountants Club Content when you watch it

 

5. Lawful Basis for Processing

In order to process your personal data, we are required to do so under a lawful basis. Your data can be processed under one or more lawful basis. Smooth AI limited trading as The Digital Accountants Club processes your personal data under the following:

Contract – Where you and Smooth AI limited trading as The Digital Accountants Club have entered into a contract for the provision of our services, we will process your personal data in order to fulfil our contractual obligations.

Legal obligation – We may be required to provide data to public authorities for purposes including, but not limited to, crime detection and prevention, online safety or other legal purposes.

Consent – Where you have provided consent to receive marketing communications, we will process your personal data to provide those communications to you.

Legitimate Interest – When we need to provide you service based messages or are seeking your feedback in order to improve our offerings and service to you.

 

6. Purposes for which we process your personal data

We may use your personal data in order to:

• Provide you the services as set out in the Terms of Service of the Smooth AI limited trading as The Digital Accountants Club community subscription
• Notify you of any changes to our services
• Provide you notification of any events to which you have consented to receive communications for
• Provide data to third parties for which we have a legal obligation to report to
• To seek your feedback and opinion in relation to the services we provide

 

7. Data retention

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.

When assessing what retention period is appropriate for your personal data, we take into consideration:

• the requirements of our business and the services provided;
• any statutory or legal obligations;
• the purposes for which we originally collected the personal data;
• the lawful grounds on which we based our processing;
• the types of personal data we have collected;
• the amount and categories of your personal data; and
• whether the purpose of the processing could reasonably be fulfilled by other means.

 

8. Change of purpose

Where we need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing. Your regulatory rights remain and any objection to the further processing that is incompatible with the original purpose.

 

9. DATA SHARING

Why might you share my personal data with third parties?

We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.

Which third-party service providers process my personal data?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.

All of our third-party service providers (Data Processors) are required to take commercially reasonable and appropriate security and data protection measures to ensure the accurate processing and safety of your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.

 

10. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

The data we directly collect from you will be processed in the UK. Where your personal data requires transfer to designated non-adequate country, we will ensure the appropriate data transfer mechanisms are in place. At this time, the UK IDTA (International Data Transfer Agreement) will be implemented as necessary.

 

11. DATA SECURITY

We implement technical and organisational measures to ensure your personal data is protected from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed inappropriately and that your rights are upheld and can be easily exercised.

As well as the controls to meet our commitment above,  we also limit access to your personal data to those employees, agents, contractors and other third parties who have reason and need to process your personal data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We only collect personal data in line with specific purposes, in line with the principles of the UK GDPR. We apply:

• Data Minimisation: collect only the data we need to provide the Smooth AI services,
• Storage Limitation: We will only retain your data for as long as it meets the purpose for which we process your data. Once it no longer meets that purpose or we are no longer required by law to retain that data, we will delete it.

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

 

12. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

 

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.

Your rights in connection with personal data

Under the Data Protection Act 2018 you have the right to:

• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data 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 basis. 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 data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

 

13. RIGHT TO WITHDRAW CONSENT

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact [email protected].

 

Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

14. CHANGES TO THIS NOTICE

We will update this Privacy Notice whenever changes to the personal data we process or any legal change requires us to do so. Please visit this Privacy Notice regular to view any updates.

This privacy notice was last updated on 24th March 2024.

 

15. CONTACT US

If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact Mrs Jeri Williams at [email protected] or telephone on 02392 982123.

 

16. CONTACTING THE ICO

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone – 0303 123 1113 (local rate) or 01625 545 745 Website – https://ico.org.uk/concerns