Privacy Policy
Rules for processing personal data
Rules for processing personal data
Smart Furniture ensures that personal data are processed in a lawful, fair and transparent manner, collected only for the purposes set out and clearly defined in this Policy and are not further processed in a manner incompatible with those purposes.
Smart Furniture shall ensure appropriate security of personal data by means of organisational and technical measures, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Smart Furniture complies with the requirements of the Lithuanian and EU legal acts regulating the protection of personal data:
- 2016 m. 27 April Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR);
- Law on Legal Protection of Personal Data of the Republic of Lithuania;
- Law on Electronic Communications of the Republic of Lithuania.
- BASIC CONCEPTS
1.1. Privacy Policy – these personal data processing rules, which are placed on the website pbsmartfurniture.co.uk.
1.2. Website – the website located at pbsmartfurniture.co.uk, where a customer of Smart Furniture can leave an enquiry.
1.3. Data controller – a legal or natural person who, alone or jointly with others, determines the purposes and means of the processing of personal data. In this Privacy Policy the data controller is Smart Furniture, legal entity code: 15559599, registered office address: 7 Bell Yard, London, WC2A 2JR, UK, contact details: e-mail. p. bespoke@pbsmartfurniture.co.uk.
1.4. Data subject – a customer or website visitor whose personal data is processed by the Data Controller for the following purposes: to conclude and execute contracts (e.g. for the purchase of furniture), to administer the customer database, including the administration of customer complaints and enquiries, to assess the solvency of the customer and to carry out debt management, and for any other purposes related to internal administration.
1.5. Processor – a natural or legal person who assists the Data Controller, within the scope of the powers conferred by the Data Controller, in the fulfilment of the stated purposes.
1.6. Personal Data – data of a natural person processed by the Data Controller and from which a customer or website visitor can be identified, including but not limited to: name, surname, email address, telephone number, etc.
1.7. Processing means any operation performed on personal data, such as collection, recording, accumulation, storage, alteration (addition or rectification), supply, use, destruction or any other operation or set of operations.
1.8. Direct marketing means activities designed to offer goods or services, to offer occasional discounts and/or to seek their opinion on the goods or services offered, by mail, telephone or other direct means.
1.9. Consent – a freely given act of the Data Subject by which he or she consents to the processing of personal data.
1.10. The supervisory authority is the State Inspectorate for Personal Data Protection.
- GENERAL PROVISIONS
2.1. The Policy sets out the main provisions on the collection, aggregation and processing of personal data.
2.2. The Data Subject shall be deemed to have read and understood this Privacy Policy when he or she expresses his or her consent to the processing of his or her Personal Data.
2.3. This Privacy Policy can be accessed and printed at any time on the pbsmartfurniture.co.uk website.
- PROCEDURES FOR THE COLLECTION, STORAGE AND USE OF PERSONAL DATA
3.1. The Data Subject agrees that the Data Controller will process the following personal data relating to them for the purposes of performance of contracts, for the fulfilment and protection of the legitimate interests of Smart Furniture, for the purposes of administration of the customer database and for other purposes related to internal administration:
3.1.1. your name,
3.1.2. phone number,
3.1.3. your email address,
3.1.4. the address where the goods are delivered and/or the service is provided,
3.1.5. the payment details of the goods/services (bank account number, method of payment, etc.),
3.1.6. purchase history (goods/services purchased, price, etc.)
3.1.7. digital photographs of the subject of the contract and/or the data subject’s individual room elements and/or fitted furniture.
3.2. Smart Furniture shall store your personal data referred to in point 3.1 for no longer than required by the purposes of data processing or provided for by legal acts, if they stipulate longer storage of data. Personal data are generally kept for as long as the contractual relationship may give rise to legitimate claims or as long as necessary for the exercise and protection of the legitimate interests of Smart Furniture.
3.2.1. Personal data that are no longer needed shall be destroyed in such a way that the information contained in these documents cannot be retrieved and the contents cannot be identified: personal data stored in electronic form shall be destroyed by erasure without any possibility of retrieval; paper documents containing personal data shall be shredded and the residues securely destroyed,
3.3. The data subject is informed that data processors, such as courier companies, may be used for this purpose.
3.4. The data subject agrees that, for the purpose of administering the request, where the request is made by e-mail, the data subject may use the following by post, the Data Controller will process the following personal data relating to you:
3.4.1. name,
3.4.2. your email address,
3.4.3. phone number,
3.4.4. comment/request.
3.5. For this purpose, personal data shall be kept for as long as the matter is being examined and for up to 2 (two) calendar years from the date of submission.
3.6. The Data Subject consents to the processing by the Data Controller of the personal data relating to him/her set out below for the purpose of direct marketing:
3.6.1. your email address and name.
3.7. Personal data received for the purpose of direct marketing shall be stored for 2 (two) calendar years from the date on which the data was provided.
3.8. The Data Controller confirms that personal data is collected only directly from the Data Subject and is not collected from other sources.
3.9. The Data Controller undertakes not to disclose the Personal Data processed to third parties, except in the following cases:
3.9.1. if the Data Subject has consented to the disclosure of personal data,
3.9.2. in the case of order fulfilment or other services, to Data Processors providing delivery of goods, installation of furniture or other services ordered by the Customer,
3.9.3. to law enforcement authorities in accordance with legal requirements,
3.9.4. if it is necessary to prevent or investigate criminal offences.
3.10. The Data Controller shall ensure that the Data Subject’s data may only be transferred to third parties to the extent necessary to achieve a specific order or purpose (for example, courier companies, after-sales service companies, suppliers of goods and/or ancillary services). Data subjects shall be duly informed of the transfer and, where applicable, give their consent.
- EXERCISING THE RIGHTS OF THE DATA SUBJECT
4.1. The Data Subject authorises the Data Controller to collect, manage, process and store personal data concerning him/her to the extent and for the purposes set out in this Privacy Policy.
4.2. The Data Subject may withdraw consent to the collection, processing and storage of personal data relating to him or her at any time, and may withdraw consent to the processing of personal data processed for direct marketing purposes without any further justification, by contacting the Data Controller in writing in one of the following ways: 1) by post or by direct delivery to Žvirgždyno g. 4, Vilnius; 2) to the email address: bespoke@pbsmartfurniture.co.uk from the same email address. the postal address specified in the contract. The Data Controller shall, upon receipt of such a request from the Data Subject, immediately suspend the processing of the personal data and destroy the personal data relating to the Data Subject. The controller shall have the right not to erase personal data if he or she has a legitimate reason to retain them, in particular where it is necessary to safeguard national security and defence, public policy, the prevention, investigation, detection or prosecution of crime, the protection of important economic or financial interests of the State, or the protection of the rights and freedoms of other persons.
4.3. When contacting the Data Controller for information on the delivery of the goods/parcel, the Data Subject must provide his/her name, surname, e-mail address for identification.
4.4. The Data Subject, having duly identified himself/herself, having provided the Data Controller with a personal identity document or a notarised copy thereof, which will be used for identification purposes only and will not be stored, shall have the right to access his/her personal data by submitting a written request to the Data Controller in one of the following ways: by post or by delivering it directly to the address at 4 Žvirgždyno str 4, Vilnius.
4.5. If another person wishes to have access to the Data Subject’s personal data, he or she must provide a notarised power of attorney, and the data shall only be provided to a lawyer upon presentation of a representation agreement and the purpose of the use of the data.
4.6. The Data Controller shall, upon receipt of a Data Subject’s request for access to the personal data processed, provide a response within 30 (thirty) calendar days from the date of receipt of the request. The response shall indicate whether personal data relating to the Data Subject are processed and, if so, what personal data have been provided and to whom in the last 1 (one) calendar year. The answer is free of charge.
4.7 If, after consulting his/her personal data, the Data Subject finds that the personal data have been collected or obtained from unlawful sources, or that the personal data are being processed for purposes other than those for which the consent was given, the Data Subject shall have the right to contact the Data Controller by e-mail requesting that the processing of the Personal Data be stopped and/or that his/her Personal Data be erased. The Data Controller shall verify the Data Subject’s request and, if it finds that the request is justified, shall comply with the Data Subject’s request without delay, but at the latest within 5 days, and shall inform the Data Subject in writing of the action taken.
4.8 In cases where the Data Subject, after consulting his/her personal data, finds that it is inaccurate or incomplete, he/she shall, after duly identifying himself/herself and by applying in writing, request that the personal data relating to him/her be rectified and/or completed. The Data Controller shall, after establishing that the request is justified, rectify or supplement the personal data processed without delay, but at the latest within 5 days, and shall inform the data subject in writing of the action taken.
4.9. The Data Subject shall have the right to request that the Data Controller “forget” him/her, namely, to erase all data relating to him/her, if those data are not required for the purpose for which they were collected and processed or if the Data Subject withdraws his/her consent, or if the data are being processed in violation of the requirements of the legislation. The controller shall comply with such a request within a reasonable period of time, but no later than 5 days. d. and inform the Data Subject of the action taken.
4.10. If the data subject considers that his or her legitimate interests have been infringed as a result of the processing of his or her personal data, he or she shall have the right to contact the Supervisory Authority.
4.11 Complaints regarding improper or unlawful processing of Personal Data shall be examined by the State Data Protection Inspectorate, acting at L. Sapiegos g. 17, Vilnius (www.ada.lt, ada@ada.lt, tel. +370 271 28 04 ).
- RISK FACTORS FOR A PERSONAL DATA BREACH AND HOW TO ADDRESS THEM
5.1. The Data Controller shall implement the following organisational and technical measures for the protection of personal data in order to ensure adequate protection of Personal Data:
5.1.1. Organisational
5.1.1.1. The Data Controller’s working arrangements shall be organised in such a way as to ensure the secure handling and (where necessary) transfer of computer data and/or documents and their archives.
5.1.1.2. Only provide access to the Data Subject’s personal data to those Employees who need it to carry out their job functions and only to those who have signed confidentiality agreements and are familiar with other internal procedures within the scope of the processing of personal data.
5.1.2. Technical
5.1.2.1. Processors (service providers) appointed by the Data Controller shall act only under the authority of the Data Controller.
5.1.2.2. Personal data is protected against loss, unauthorised use and alteration.
5.1.2.3. Protecting your computer hardware from malicious software (e.g. installing anti-virus software, keeping it up to date) and firewalling your internal computer network.
5.1.2.4. The staff member who has been granted access to the information system where personal data are stored shall ensure the confidentiality and security of administrative passwords and other access data;
5.1.2.5. Change your password once a year or more often;
5.1.2.6. The password must be at least 7 (seven) characters;
5.1.2.7. Password characters are made up of numbers and letters and special characters.
- USE OF COOKIES
6.1. The pbsmartfurniture.co.uk website may use cookies for statistical purposes, to measure website traffic and the popularity of individual content. Such processing does not allow the direct or indirect identification of the website visitor.
6.2. You can delete cookies from your computer or block them in your web browser, but some of the functionality of the website may not work or may not function properly.
- FINAL PROVISIONS
7.1. This Privacy Policy is reviewed once every 2 (two) years and updated as necessary.
7.2. This Privacy Policy is effective from 2018. 1 June and is published on the Website.
7.3 This Privacy Policy will be updated in 2020. 20 May
For any questions related to the processing of personal data, please contact us at. by email to bespoke@pbsmartfurniture.co.uk or by phone +44 78 35 636596. Please note that in order to properly identify applicants, we may request additional information from you.
