We are committed to safeguarding the privacy of our customers and website visitors; this policy sets out how we will treat your personal information.

1. Important Information and who we are

Purpose of this Privacy notice

This privacy notice aims to give you information on how Smartwares Group, trading as “Smartwares”, collects and processes your personal data, including any data you may provide (whether through our website or not) when you sign up to our newsletter, purchase a product or service or take part in a competition.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Contact details

Our full details are:

Full name of legal entity: Smartwares Safety & Lighting Ltd.

Email address:

Postal address:     First Floor, No.1 The Courtyard, Buntsford Drive, Bromsgrove, B60 3DJ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. What information do we collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, store and use the following kinds of personal information:

(a) Identify Data – includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;

(b) Contact Data – includes billing address, delivery address, email address and telephone numbers;

(c) Usage Data – information about your computer and about your visits to and use of our website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation);

(d) Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;

(e) Transaction Data – information relating to any transactions carried out between you and us, including information relating to any purchases you make of our goods or services;

(f) Profile Data – information that you provide to us for the purpose of registering with us;

(g) Marketing and Communications Data – information that you provide to us for subscribing to our marketing and communication services and our website services, email notifications and/or newsletters. Including recordings of calls to our Call Centre;

(h) Financial Data – includes bank account, PayPal and payment card details; and

(i) Miscellaneous Data – include any further data that you may send us that is not set out above.

Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with the terms of this privacy policy.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We only retain heath related Special Category Personal Data (such as allergies, physical limitations), when volunteered by yourself, relating to the use of our products. We do not normally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • speak with our Call Centre;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:
    • analytics providers such as Google based outside the EU;
    • advertising networks such as Facebook based both inside and outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU.
  • Third party software used to collect email details from competition entries based inside the EU.
  • Identity and Contact Data from publicly availably sources such as Royal Mail based inside the EU.


We use cookies as set out in our Cookies Policy and any personal information obtained from such cookies in accordance with this Policy.

4. Using your personal information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Type of data (as identified above)

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

(i) Miscellaneous

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(h) Financial

(e) Transaction

(g) Marketing and Communications

(i) Miscellaneous

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Asking you to leave a review or take a survey

(b) Notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(f) Profile

(g) Marketing and Communications

(i) Miscellaneous

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(f) Profile

(c) Usage

(g) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(d) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(f) Profile

(c) Usage

(g) Marketing and Communications

(d) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences

(d) Technical

(c) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you, including details of offers and promotions, and to provide you with our newsletter

(a) Identity

(b) Contact

(d) Technical

(c) Usage

(f) Profile

(i) Miscellaneous

(a) Consent to receive details

(b) Necessary for our legitimate interests (to develop our products/services and grow our business)


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have consented to receive that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Smartwares Group of companies for marketing purposes.

Your Consent

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time, or updating your preferences on our relevant website.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Financial Transactions

All our websites and Call Centre financial transactions are handled through our payment services providers, PayPal and Ingenico. You can review their privacy policies at and respectively. We will share information with PayPal and Ingenico only to the extent necessary for the purposes of processing payments you make via our websites, Call Centre, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

5. Disclosures

We may disclose your personal information to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.

We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this privacy policy.

In addition, we may disclose your personal information:

(a) to the extent that we are required to do so by law;

(b) in connection with any ongoing or prospective legal proceedings;

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and

(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this privacy policy, we will not provide your information to third parties.

6. Security of your personal information

We will ensure that appropriate technical and organizational security measures for the processing of personal data are taken. We follow generally accepted standards for the protection of personal data, both during the transfer and once we have received the personal data. We have in any case taken the following measures:

  • We have implemented physical and electronic measures designed to prevent unauthorized access, loss or misuse of personal data as much as possible.
  • We use SSL (Secure Socket Layer) technology where necessary to encrypt transmission of sensitive information or personal data to us, such as account passwords and other payment-related identifiable information.
  • Where possible, back-ups of personal data are made.
  • Sensitive information is stored encrypted wherever possible.
  • Vulnerabilities in the software are dealt with as quickly as reasonably possible.

You must take into account that our Processors are responsible for processing, managing or storing (some of) the personal data we receive. Processors are not authorized to use this data to advertise with you. These Processors are contractually, by means of a processor agreement, obliged to protect the personal data that they have received from us.

However, there is no way of transmitting over the internet or a method of electronic storage that is 100% secure. That is why we cannot guarantee absolute safety.

Links to third party sites

Our Services and / or the website may contain links to other websites, as well as advertisements from third parties. Third party websites can keep track of information about you. We have no control over such sites or their activities. Any personal data you provide on the pages of third parties will be provided directly to that third party and will be subject to the privacy policy of that third party. We are not responsible for the content, privacy and security practices and policies of websites that we link to or that advertise on our Services and / or websites. Links from our website to third parties or to other sites are only made available to you. We encourage you to review their privacy and security practices and policies before you provide personal information to them.

7. Retention of your personal information

We will retain your personal information for one or more of the following reasons:

  • For as long as you remain registered with us,
  • For as long as your warranty remain valid,
  • For as long as you maintain consent to marketing and newsletters,
  • In accordance with the licence granted for publication on our websites,
  • Until the time limit for any legal challenges to the supply of the goods has expired,
  • To comply with legal and regulatory requirements,
  • For inclusion in analysis carried out by us with respect to our business.

8. Policy amendments

We may update this privacy policy from time to time by posting a new version on our websites. You should check our websites occasionally to ensure you are happy with any changes.

9. Your rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Processing of your instructions will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept the exact email address you used to register or to place an order with us, a government issued ID such as a photocopy of your passport or driving licence, etc certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

We try to respond to all legitimate requests within 4 weeks. Occasionally it may take us longer than 4 weeks if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

We may withhold processing a rights request where it is considered excessive to the extent permitted by law. We will not normally charge a fee for processing your instructions. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You may instruct us not to process your personal information for marketing purposes, by updating your consent details on our websites or sending an email to us. In practice, you will have expressly agreed in advance to our use of your personal information for marketing purposes, and we will provide you with an opportunity to withdraw consent to the use of your personal information for marketing purposes, each time we contact you.

You have the right to lodge a complaint about the processing of your personal data to the Information Commissioner’s Office, details can be obtained at or contact their helpline on 0303 123 1113.

10. Third party websites

Our websites contain links to other websites. We are not responsible for the privacy policies or practices of third party websites.

11. Updating information

Please let us know if the personal information that we hold about you needs to be corrected or updated.

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