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Your privacy is important to us, and we want to make sure you understand exactly how we use your data when you entrust your information with us.
Service Management Group (“SMG,” “we” or “us”) developed this SMG Privacy Policy (“Privacy Policy”) to provide you with information on how we process your Personal Data when you visit the smg.com website and other websites and applications, including mobile applications, on which this Privacy Policy is posted, linked, or referenced (“SMG Sites and Apps”).
Other SMG websites and apps that do not include a link to this Privacy Policy and include a link to a different privacy policy are governed by that privacy policy.
“Personal Data” is information relating to an identified or identifiable natural person.
Each section of this Privacy Policy is listed below:
Personal Data that is processed when you submit a “Contact Us” form through the website: When you contact us online, we may collect Personal Data, including your name, company name, job title, business email address, department, and reason for contact, which may tell us that you need help logging in, you would like a demo of SMG’s offerings, you would like to learn more about SMG, you are interested in a career at SMG, or you have a question about your current program.
We may also create event logs that are useful in diagnosing performance-related issues and capturing information relating to the client support or service issue. To improve client service, subject to applicable laws, we may also record and review conversations with client support specialists, and analyze any feedback provided through voluntary client surveys. With your consent, we may log in to your account, if appropriate, to help troubleshoot and resolve your issue.
Personal Data that is processed when you access your smg360® account: When you log in to your smg360 account, we collect your username and password.
Personal Data that is processed when when you download information from the smg.com website: You may sign up to download information, including reports, ebooks, best practice guides, presentations, or case studies from the smg.com website by entering your email address, phone number, name, company, job title, industry, and resource language.
Personal Data that is processed when you sign up to receive job recommendations: You may sign up to receive job recommendations through the smg.com website by entering your email address and password or by using your social media login credentials (e.g., Facebook, Google+, LinkedIn, or Microsoft). After logging in on our website or using your social media login credentials, you will be directed to a third-party recruiting site that will process your personal information for the purpose of sending you job recommendation information. The handling of any Personal Data you provide to that third party will be governed by the third-party recruiting site’s privacy policy, which you should review.
Personal Data that is processed when you apply for a job through the smg.com website: You may apply for a job online through the smg.com website by entering your email address. You will be directed to a third-party recruiting site that will process your personal information for the purpose of permitting you to submit a job application. The handling of any Personal Data you provide to that third party will be governed by the third-party recruiting site’s privacy policy, which you should review.
Personal Data that is processed when you complete a survey: When you complete a survey, we collect: (1) your contact data (such as email address, telephone number, and employer); (2) demographic data (such as gender, date of birth, and zip code); and (3) your responses on surveys to the extent the information identifies you or is linked to you as an individually identifiable person; and (4) information relating to your use of SMG Sites and Apps (“Usage Data”), which is addressed in more detail in the section below concerning automatic processing of Personal Data.
Personal Data that is processed when you contact SMG in connection with your survey responses: When you submit your Personal Data in connection with your use of SMG Sites and Apps, such as contacting us for survey assistance or providing comments about your experiences with one of our clients, we collect and analyze the information you submit.
Personal Data that is processed when you access surveys through Social Media credentials: SMG may offer you the opportunity to use social networking services (collectively, “Social Media”) to access SMG surveys. When you choose to access SMG surveys through Social Media login credentials, SMG may, depending on your privacy settings, have access to information that you have provided to the Social Media platform, such as your name, email address, profile photo, posts, comments, and other information associated with your Social Media account.
Personal Data that is processed when clients send us information about your interactions with them: For some of our products and services, our clients may send us information about your interactions with their brands, products, and services, which may include information relating to any loyalty programs in which you are enrolled and information about your transactions with our clients. We may combine this information with other information we have concerning you (e.g., your survey responses).
Personal Data that is automatically processed: We automatically collect the following usage data when you interact online with SMG Sites and Apps through the use of Cookies and other data collection tools: (1) IP address; (2) domain server; (3) type of device(s) used to access the website; (4) statistics and information associated with the interaction between your browser and device, such as device model, carrier/network, battery life information, and basic usage statistics about your device; (5) real-time GPS or other geolocation data when you allow us to receive information through the location (or similar) settings on your device; and (6) referring webpage or other source through which you accessed the SMG Site or App.
Cookies are small computer files sent or accessed from your web browser on your computer’s, mobile device’s, or tablet’s hard drive that contain information about your computer, such as user ID, user settings, browsing history, and activities conducted while using SMG Sites and Apps. A Cookie typically contains the domain name (internet location) from which the Cookie originated, the “lifetime” of the Cookie (i.e., when it expires), and a randomly generated unique number or identifier.
Personal Data that is processed when complying with legal obligations and enforcing legal rights: SMG will process Personal Data collected through the smg.com website as needed, to comply with legal obligations and enforce legal rights.
SMG controls and operates our Sites and Apps from the United States. If you are located outside of the United States, SMG will transfer, store, and process your Personal Data in the United States. The data protection and privacy laws of the United States may not be as comprehensive as the laws in your country. For example, Personal Data transferred to the United States may be subject to lawful access requests by federal and state authorities in the United States.
Any transfers of Personal Data from the European Economic Area (“EEA”) to the United States are made pursuant to the EU-U.S. Privacy Shield. Service Management Group, LLC participates in and complies with the EU-U.S. Privacy Shield principles regarding the collection, use, sharing, and retention of Personal Data from the EEA, as described in our EU-U.S. Privacy Shield certification. SMG is committed to subject to the EU-U.S. Privacy Shield principles all Personal Data received from the EU in reliance on the Privacy Shield. View the Privacy Shield list here. Learn more about the Privacy Shield here.
Service Management Group, LLC is subject to the oversight of the U.S. Federal Trade Commission, and will remain responsible for any processing of Personal Data transferred pursuant to the EU-U.S. Privacy Shield that is inconsistent with the Privacy Shield Principles by any third parties to which Service Management Group, LLC has transferred Personal Data unless Service Management Group, LLC proves it is not in any way responsible for the event giving rise to the damage. Any and all such transfers of Personal Data outside the EEA shall be in accordance with this Privacy Policy and all applicable laws.
If you live in the EU and you have a complaint about our Privacy Shield compliance, contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108. If your complaint cannot be resolved through SMG’s internal processes, you can refer a complaint, free of charge, to our chosen independent dispute resolution body, American Arbitration Association, and in certain circumstances, invoke the Privacy Shield binding arbitration process.
The smg.com website is not directed to individuals under the age of 16, and we request that individuals under 16 not provide Personal Data to SMG. If we learn that we have collected Personal Data from a child under 16, we will take steps to delete the information as soon as possible.
We will retain your Personal Data in our records for no longer than is necessary for the purposes for which it was originally collected. When such information is no longer needed for the purposes for which it was originally collected, we will securely delete all of your electronic Personal Data, and securely dispose of any hard copy Personal Data, except for what is needed to comply with our legal obligations. See section below under “Your Rights” for additional information pertaining to the right of erasure, as well as other data subject rights.
SMG has an information security program that implements technical, physical, and organizational measures designed to assist in maintaining the security and confidentiality of Personal Data; safeguarding against anticipated threats to the confidentiality, integrity, and availability of Personal Data; and protecting your Personal Data against loss, misuse, unauthorized alteration or destruction, and unauthorized access or disclosure.
However, whenever Personal Data is processed, there is a risk that such data could be lost, misused, modified, hacked, breached, and/or otherwise accessed by an unauthorized third party. No system or online transmission of data is completely secure. In addition to the technical, physical, and organizational measures that SMG has in place to protect your Personal Data, you should use appropriate security measures to protect your Personal Data. If you believe that your account or any information you provided to us is no longer secure, notify our Data Protection Officer immediately by email at privacyofficer@smg.com or by calling 800-764-0439 and asking to speak with SMG’s Data Protection Officer.
If you reside in the EU, you have the right under the General Data Protection Regulation to request access to and rectification or erasure of your Personal Data, data portability, restriction of processing of your Personal Data, the right to object to processing of your Personal Data, the right to withdraw your consent, and the right to lodge a complaint with a supervisory authority.
If you reside in the EU, you may opt out of usage of your Personal Data for purposes materially different than those for which your Personal Data was originally collected or subsequently authorized. You also may opt out of disclosures of your Personal Data, if any, to third-party controllers. But if you do not want your Personal Data disclosed to the client for which a survey is being conducted, you may not be eligible to participate in the survey. If we collect any sensitive Personal Data (e.g., health data) from you, we will obtain your opt-in consent before disclosing such data to a third party or using your Personal Data for a purpose other than that for which it was originally collected or subsequently authorized.
If you live in the EU, and if you wish to exercise any of these rights, contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
If you reside outside of the EU, you may have similar rights under your local laws. If you do not live in the EU but you think you have any of these data subject rights under your local laws, please contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
To the extent that the personal data SMG Sites and Apps collects is considered to be HR data (e.g. recruitment information), the independent recourse mechanism is the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
In compliance with the Privacy Shield Principles, SMG commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact our Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
SMG has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
Do Not Track. SMG does not track its customers over time and across third-party websites and online services (e.g., mobile apps), and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites and apps may track your browsing activities when they provide you content, which enables them to tailor what they present to you. Third parties may collect Personal Data relating to your online activities over time and across different websites and apps when you use our services.
If you have questions about privacy, need assistance with accessing or updating your Personal Data, or have complaints relating to the processing of your Personal Data, contact our Data Protection Officer by email at privacyofficer@smg.com or by calling 800-764-0439 and asking to speak with SMG’s Data Protection Officer.
You can also write to us at:
Service Management Group, LLC
Attn: Data Protection Officer
1737 McGee Street
Kansas City, MO 64108
Service Management Group, Ltd.
38-40 The Maltings
St Albans
Hertfordshire AL1 3HL
UNITED KINGDOM
Service Management Group G.K.
2-7-16 No. 3 Komoriya Building 9F
Hamamatsu-cho, Minato-ku
Tokyo 1050013, Japan
SMG is the controller of the Personal Data that is collected through the smg.com website. You can contact SMG’s Data Protection Officer by email at privacyofficer@smg.com or by writing to Data Protection Officer, Service Management Group, LLC, 1737 McGee Street, Kansas City, MO 64108.
This English-language Privacy Policy is SMG’s official statement of its privacy practices relating to the smg.com website and related services. In case of any inconsistency between this English-language Privacy Policy and any translation into another language, this English-language document prevails.
We will update this Privacy Policy from time to time when we make changes impacting the Privacy Policy, such as adding new services and applications, improving our services, and addressing changes in technologies and laws. The Effective Date of this Privacy Policy, which is set forth on the first page of the Privacy Policy, reflects the date the Privacy Policy was last updated. SMG will provide notice to you if these changes are material, and where required by applicable law, we will obtain your consent. This notice will be provided by posting notice of the changes on the smg.com website.
