Privacy policy

Effective Date: 15th January 2025

SmartSpine (“we,” “our,” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.smartspine.co.uk (“Website”). This policy is designed to comply with the UK Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR).

1. Interpretation and Definitions

Interpretation
The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

Definitions
For the purposes of this Privacy Policy:

• Account: A unique account created for you to access our Service or parts of our Service.
• Affiliate: An entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
• Cookies: Small files that are placed on your computer, mobile device, or any other device by a website, containing the details of your browsing history and other uses.
• Country: Refers to the United Kingdom.
• Device: Any device that can access the Service such as a computer, a mobile phone, or a digital tablet.
• Personal Data: Any information that relates to an identified or identifiable individual.
• Service: Refers to the Website.
• Service Provider: Any natural or legal person who processes data on behalf of the Company.
• Usage Data: Data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (e.g., the duration of a page visit).
• You: The individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service.

2. Information We Collect

We may collect and process the following categories of personal data:

• Personal Identifiable Information: Name, email address, phone number, postal address, and other contact details you provide when filling out forms on our Website.
• Account Information: Username, password, and any other information provided during account creation.
• Usage Data: Information about your visits to and use of the Website, including IP address, browser type, operating system, referral source, pages viewed, and session duration.
• Cookies and Tracking Technologies: Details of your interactions with our Website collected through cookies, pixels, and similar technologies.

3. How We Use Your Information

We process your data for the following purposes:

• To provide, operate, and improve our Website.
• To respond to your inquiries, requests, or customer service needs.
• To manage your account and provide access to secure areas.
• To send marketing communications where consent has been provided.
• To comply with legal obligations and protect against fraud or security threats.
• To analyse usage trends and improve user experience.
• To manage Your requests or complaints.
• For business transfers in the event of a merger, sale, or asset transfer.
• To evaluate or conduct mergers, restructuring, or transfers of assets.
• To monitor and analyse Website use and improve its functionality.

4. Legal Basis for Processing

We rely on the following legal grounds under GDPR to process your data:

• Consent: When you provide explicit consent (e.g., subscribing to a newsletter).
• Contractual Necessity: To perform a contract or provide requested services.
• Legitimate Interests: For purposes such as fraud prevention and Website optimization, provided these do not override your rights.
• Legal Obligation: To comply with applicable laws and regulations.

5. Sharing Your Information

We may share your data with:

• Service Providers: Third parties who provide services such as website hosting, payment processing, analytics, and email communication.
• Compliance Partners: Law enforcement or regulatory authorities, if required by law.
• Business Transfers: In the event of a merger, sale, or transfer of assets.
• Affiliates and Business Partners: Entities under common control or in partnership with us, subject to this Privacy Policy.

6. International Data Transfers

Your personal data may be transferred to and processed in countries outside the UK and the European Economic Area (EEA). 

7. Your Rights

Under GDPR, you have the following rights:

• Access: Request access to your personal data.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of your data (“right to be forgotten”).
• Restriction: Restrict processing of your data.
• Portability: Receive your data in a structured, commonly used format.
• Objection: Object to processing based on legitimate interests or direct marketing.
• Withdraw Consent: Withdraw consent at any time for processing based on consent.

To exercise these rights, please contact us at jaykar@smartspine.co.uk.

8. Retention of Your Personal Data

We retain personal data only as long as necessary to fulfil the purposes outlined in this policy or as required by law. Usage Data is generally retained for a shorter period unless used to enhance security or functionality.

9. Security Measures

We use technical and organisational measures to protect your data from unauthorised access, alteration, disclosure, or destruction. These measures include encryption and secure servers. However, no method of transmission over the internet is entirely secure, and we cannot guarantee absolute security.

10. Cookies

Our Website uses cookies to enhance user experience. These include necessary cookies, functionality cookies, and tracking cookies.

11. Children’s Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from children under 16. If we become aware of such collection, we will delete the information promptly.

12. Links to Other Websites

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of these sites. Please review their privacy policies before providing any personal information.

13. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of any significant changes by posting an updated version on the Website. Please review this page regularly for updates.

14. Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us:

Email: jaykar@smartspine.co.uk
Postal Address: 505 Pinner Road, Harrow, Middlesex, United Kingdom, HA2 6EH.

For unresolved complaints, you may contact the UK Information Commissioner’s Office (ICO) at www.ico.org.uk.