Privacy Policy

At smarterfleet.com, we recognize that privacy of your personal information is important. You have certain rights in relation to your data, including the right to object to processing based on legitimate interests, and direct marketing.

At any time, you can exercise your rights by emailing us at dataprotection@mvfglobal.com. For further details about our processing and your rights, please see below.

About Our Site

smarterfleet.com (“our site”) is an online resource which provides hearing information and advice.

About Us

SmarterFleet is a brand of Marketing VF Limited (“MVF“, “we“, “us“, “our“).

MVF is a company registered in England and Wales (company number: 06951544), whose registered office address is at Imperial Works, Perren Street, London NW5 3ED, United Kingdom.

For the purposes of the General Data Protection Regulation (the “GDPR“), Marketing VF Limited is the controller in relation to your data. We are registered as a controller with the UK Information Commissioner’s Office (ICO) under registration number Z1995728. You can confirm our registration here: www.ico.org.uk

What Data We Collect, And How We Use It

1. Types of information collected

• Traffic data. We automatically track and collect the following categories of information when you visit our site: (1) IP addresses; (2) types of computers accessing the site; and (3) types of web browsers used to access the site (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the site.
• Information submitted relating to a request for quotes. On our site, there are opportunities to request quotes for certain products and services through completing online webforms.
  • If you choose to complete our webform it will ask you for your contact details including, but not limited to, (1) your name (2) email address (3) telephone number (4) post code. Our webform may also ask you for information regarding your circumstances which are relevant to your request.
  • From time to time we change our webforms and so they may ask you for other information. It will always be clear from the webform what information we’re requesting, and we only request information that is relevant to your request, and the service that we’re providing.
  • If we call you to confirm your details or requirements, we may ask you for some additional information. We may monitor and/or record these calls for the purposes of quality control and staff training. Also, occasionally, we may need to provide Suppliers (as explained below) with limited access to such recordings in order to resolve queries and disputes.
• Information provided when contacting us. If you communicate with us by e-mail or post messages, any information provided in such communication may be collected as personal information.
• Information provided when submitting reviews. If you choose to leave a review for any of the products on our site, we will ask you to provide your full name and email address.

2. How we use your data

• To contact you about your enquiry. If you contact us, we will use your information to handle your enquiry and correspond with you.
• Working with Third Party Providers. We share contact data with our Third Party Providers who assist us by performing core services (such as fulfillment, or data storage and security) related to our operation of the site. These include cloud storage providers, email service providers, and cloud telephony providers. We have appropriate contracts in place with such Third Party Providers to ensure the protection and confidentiality of data.
• To connect you with relevant Suppliers. If you submit our webform in order to request a quote, we’ll pass your request to one or more relevant product  or service suppliers (named on the webform) (“Suppliers”). We will do this in a secure way. For example, using HTTP Secure (HTTPS), which means the data is encrypted. The Suppliers then contact you directly with your quotes.
  • They may contact you by telephone, text/SMS or email. Before we pass your request to any Suppliers, our service may involve an element of automated decision-making. Our technology platform may automatically assess your requirements and pass your request to such Suppliers that would like to receive requests for quotes at the time your request is made.
  • We store IP addresses in order to stop unwanted traffic (i.e. spam) to our site. For example, if we become aware that spam is coming from a particular IP address (i.e. computer or location), we can block that IP address. From time to time, we also share IP addresses with Suppliers to enable Suppliers to verify that requests for quotes have come from a particular country.
• To call you to confirm your details or requirements. Before connecting you with relevant Suppliers, we may call you to confirm your details or requirements. We may also call you to ask about your experience using our site and service, and dealing with the Suppliers with which we connected you. Withdrawing your consent – If, at any time, you wish to withdraw your consent to be contacted by us or the Suppliers regarding your request for quotes, you can exercise this right by accessing our preference centre https://preferences.safe-click.net.
• To email you about similar products and services – But only if you haven’t opted out of such emails. If you use our quote request service, then, as an existing user, we would like to email you, or send you text/SMS messages, about similar products and services for which we think you might like quotes or information (“Other Products“). You will always be given an opportunity to opt out of such messages before we send them, and we will not send such messages if you have opted out.
• To create custom and lookalike/similar audiences. We like to work with Facebook, Google and other platforms (“Platforms“) to reach out to you with adverts for other products. We also like to use Platforms to reach out to other people who might like to use our quote request service.
  • We do this in two ways. In both cases, your data, along with other data, is used to create a custom audience and/or a lookalike/similar audience.
  • Whenever an audience is shared with a Platform, the data is first hashed and pseudonymised, meaning that any data within the audience that could identify a person is replaced with an artificial identifier.
  • So, the process is secure. Also, we don’t share more data than we need to for the purpose of creating the audience.

-Custom audience– A custom audience is a list of existing users of our service (“Existing Users“). From time to time, we share this with Platforms. As explained above, the data is first hashed and pseudonymised. The Platform uses this audience to show our Existing Users our adverts for Other Products.

-Lookalike/similar audience– A lookalike/similar audience is an audience created by the Platform. From time to time, we share with Platforms a list of Existing Users. The Platform uses this list to find and create lookalikes – i.e. other Platform users who have similar characteristics to the Existing Users – to which it shows our adverts. Again, as explained above, the data is first hashed and pseudonymised.

As we explain below, at any time, you may object to such activity by emailing us at dataprotection@mvfglobal.com.

• Receiving data from Suppliers. From time to time, Suppliers may return data to us. They may do this if they have a query regarding a request for quotes that we have sent to them in order to enable us to resolve the query. They may also return data to us, together with confirmation on whether or not a product has been purchased, in order to enable us to improve our marketing. We may also use such data to create custom and lookalike/similar audiences, as explained above.
• Receiving data from our Affiliate Partners. Our site contains Affiliate Links, which will direct you to our Affiliate Partners’ sites. From time to time, our Affiliate Partners may share data with us. In most cases, they do this anonymously (i.e. they don’t provide us with any personal data). If you visit their site from our site, and subsequently purchase their product, they will tell us. We don’t use this information for any purpose, except to record the number of visitors from our site who have purchased our Affiliate Partner’s product.
• To confirm that you are a real person and that the review is genuine. If you choose to leave a review for any of the products shown on our site, we use your information to confirm the authenticity.

Confidentiality and security of personal information

Except as otherwise provided in this Privacy Policy, we will keep your personal information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Use. Your personal information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit your personal information via secured and encrypted channels if you use a similarly equipped web browser.

Public information

We may make commenting available to you on certain pages. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your personal information.

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. At the bottom of this policy, we have included a table, setting out what cookies we use, and the purposes for which we use them.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.

Third Party Advertisements

This site also uses third party advertisements to generate revenue. Some of these advertisers may use technology such as cookies and web beacons when they advertise on our site, which will also send these advertisers (such as Google through the Google AdSense program) information including your IP address, your ISP, the browser you used to visit our site, and in some cases, whether you have Flash installed. This is generally used for geotargeting purposes (showing New York real estate ads to someone in New York, for example) or showing certain ads based on specific sites visited (such as showing cooking ads to someone who frequents cooking sites).

You can choose to disable or selectively turn off our cookies or third-party cookies in your browser settings (as explained above), or by managing preferences in programs such as Norton Internet Security, McAfee and Eset.com. However, this can affect how you are able to interact with our site as well as other websites. This could include the inability to login to services or programs, such as logging into forums or accounts.

Transferring Your Data

We may transfer your data to countries outside the European Economic Area (the “EEA”).

Some of those countries have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection.

Other countries do not have the same level of legal protection as countries in the EEA, or with an adequacy decision. If we do transfer your data in this way, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example, ensuring that the organisation receiving the data is registered with the EU-US Privacy Shield (in the case of transfers to the USA), or that we use the EU’s model contract clauses.

Storing Your Data

We have a data retention policy, which clearly sets out how long we keep data for, and for what reasons.

We will keep your data only for as long as is necessary to fulfil the purpose/s for which it was collected in the first place, i.e. as set out in this notice.

Legal Grounds

This notice sets out (above) how we use your data. Under the GDPR, controllers must have a valid lawful basis for each processing activity that they undertake. This section sets out our lawful basis for each activity.

Your Rights

Under the GDPR, you have a number of rights, which are explained below.

• Right of access – You have the right at any time to ask us for a copy of the personal information that we hold about you, and to check that we are lawfully processing it.
• Right of rectification – If personal information that we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
• Right of erasure – In certain circumstances, you have the right to request that personal information we hold about you is erased (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).
• Right to object to or restrict processing – In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests, and there are no compelling legitimate grounds for our processing which override your rights and interests.
• Right of data portability – In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
• Right to withdraw consent – In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

Exercising Your Rights

If you wish to exercise any of your rights under the GDPR, please email us at dataprotection@mvfglobal.com. Alternatively, you can write to us at the address set out above, or inform us if you speak with us on the phone.

Our lead supervisory authority for the processing set out in this notice is the UK ICO. If you are unhappy with how we have processed your data, you have the right to make a complaint to the ICO.

If you are based outside of the UK, or you have a complaint concerning our activities outside of the UK, you may prefer to lodge a complaint with a different Supervisory Authority. A list of relevant authorities can be accessed here https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Contacting Us

If you have any questions regarding this notice, or any questions relating to data protection or privacy, you can contact us at dataprotection@mvfglobal.com.

Alternatively, you can write to us at the address set out above.

Changes To This Notice

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the site.