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SMG Website and App Privacy Policy

 

Effective Date: May, 2018

 

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:

  • Categories of Personal Data Processed, including Personal Data Processed through Cookies
  • Third-Party Recipients of Personal Data
  • Cross-Border Transfers of Personal Data
  • Children’s Privacy
  • Retention of Personal Data
  • Information Security
  • Your Rights
  • Your California Privacy Rights
  • How to Contact Us
  • Data Controller and Data Protection Officer
  • Privacy Policy Translations and Updates

 

Categories of Personal Data Processed, including Personal Data Processed through Cookies

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.

  • Purposes and Legal Grounds:
  • If you are contacting us to ask questions about your current program, request help logging in to your account, request a demo of SMG’s offerings, or request more information about SMG, we use this information to provide you with appropriate client support. If you are contacting us because you are interested in a career at SMG, we use this information to provide you with relevant information about potential career opportunities at SMG. We also use this information to monitor the quality and types of client support that we provide. The legal ground for processing this information for these purposes is SMG’s legitimate interest in providing quality support to users’ requests for assistance and information. The legal ground for logging in to your SMG account, if appropriate, to help troubleshoot and assist you in accessing your account, is consent, which you may withdraw.
  • SMG may also process the Personal Data of its website and app users for the purpose of sending you emails regarding SMG events, webinars, reports, newsletters, other publications, marketing materials, and surveys. If you reside in the European Union (EU) or in any country that requires us to obtain your consent before using your Personal Data for purposes of direct marketing, we will process this information based on your opt-in consent, which you may withdraw at any time by contacting 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.

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.

  • Purposes and Legal Grounds:
  • SMG processes your username and password for the purpose of enabling you to log in to your smg360 account. The legal ground for processing your username and password for this purpose is based on SMG’s legitimate interest in protecting the security of your smg360 account.
  • SMG also processes your username and password to associate it with your smg360 account when you contact us for support purposes. The legal ground for this processing is our legitimate interest in providing quality client support.

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.  

  • Purposes and Legal Grounds:
  • SMG processes this information for the purpose of permitting you to download the information you have requested. SMG may also follow up with you via email to ensure you received the information you requested, to find out if you have any questions, and to find out if you would like to receive any additional information about SMG’s Sites and Apps. The legal ground for this purpose is SMG’s legitimate interest in providing you with the information you requested and providing you with quality support.
  • SMG may also process the Personal Data of its website and app users for the purpose of sending you emails regarding SMG events, webinars, reports, newsletters, other publications, marketing materials, and surveys. If you reside in the EU or in any country that requires us to obtain your consent before using your Personal Data for purposes of direct marketing, we will process this information based on your opt-in consent, which you may withdraw at any time by contacting 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.

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.  

  • Purposes and Legal Grounds:
  • SMG processes your email address and password for the purpose of sending you the job recommendation information you requested. The legal ground for processing your email and password for this purpose is SMG’s legitimate interest in providing you with the information you requested and protecting the security of your account.

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.  

  • Purposes and Legal Grounds:
  • SMG processes your email address for the purpose of permitting you to submit your job application for a potential position at SMG. The legal ground for processing your email for this purpose is SMG’s legitimate interest in permitting you to submit your job application.

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. 

  • Purposes and Legal Grounds:
  • SMG processes your contact data, demographic data, and responses on surveys for the purpose of conducting market research on behalf of SMG and our clients, to better understand consumer preferences about goods and services. We use this information to derive consumer insights, such as where, when, and how often consumers visit retail locations and their experiences during the visits. The legal ground for this processing is our clients’ legitimate interests in obtaining feedback from their customers to help them improve their products and services for the benefit of their customers and their businesses, and SMG’s legitimate interest in enhancing our products, services, and market research.

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. 

  • Purposes and Legal Grounds:
  • When you contact us for assistance with a survey, we use your Personal Data to provide you with the assistance or information requested, and to monitor the support we provide. When you provide your Personal Data to SMG in an online form, we use your Personal Data to respond to your specific request, such as helping you log in, or providing you with resources about SMG Sites and Apps. The legal ground for processing this information for these purposes is SMG’s legitimate interest in providing quality support to user requests for assistance and information
  • When you provide comments to SMG, the information you provide contributes to the services we provide to our clients and to our overall market research. If you choose to provide us with permission, your comments may be posted on TrumpetRatings.com and/or on our clients’ websites. When such information is posted in a public forum, such as TrumpetRatings.com or other websites accessible to the general public, such information becomes public information. What you have written may be seen and/or collected by third parties and be used by others in ways we are unable to control or predict. The legal ground for this purpose is our clients’ legitimate interests in obtaining feedback from their customers to help them improve their products and services for the benefit of their customers and their businesses, and SMG’s legitimate interest in enhancing our products, services, and market research.

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.

  • Purposes and Legal Grounds:
  • SMG may use this information for any purposes described in this Privacy Policy and for any additional purposes of which you were advised at the time the information was collected. If you do not want your Social Media information to be shared with SMG by a Social Media provider, you should not use your Social Media accounts to access SMG Sites and Apps. The legal basis for processing this information for these purposes is your consent, which you provide in your privacy settings to the social networking service. You may withdraw your consent by changing your privacy settings to no longer allow us access to your Social Media data.

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).

  • Purposes and Legal Grounds:
  • The purpose of this processing is to enhance the market research we conduct and services we provide for our clients. The legal ground for this purpose is our clients’ legitimate interests in improving and enhancing their products and services, and SMG’s legitimate interest in enhancing our products, services, and market research.

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.

  • Purposes and Legal Grounds:
  • We use this usage data to facilitate communication between your device and our systems, store your preferences, authenticate users and detect and prevent fraud, enable certain functions of the website, administer and improve our website and applications, and analyze usage of and improve and enhance SMG Sites and Apps
  • If you are in the EU or another country that requires obtaining your consent before processing your usage data, we process your usage data based on the consent you provide when you click the box noting that you “agree” to the processing of your Personal Data Obtained through Cookies and Other Data Collection Tools. You may withdraw your consent by contacting 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.
  • Your Control of Cookies: Web browsers allow some control of most Cookies through browser settings. Some web browsers (including mobile web browsers) provide settings that allow you to reject Cookies or that alert you when a Cookie is placed on your computer, tablet, or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept SMG’s Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the SMG Site or App. You will have an opportunity to manage your Cookie preferences on our websites and/or applications; except that certain Cookies are required to enable the core functionality of such websites and applications and you cannot choose to disable those Cookies. 

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. 

  • Purposes and Legal Grounds:
  • SMG processes such Personal Data collected through the smg.com website to enforce its rights, protect SMG’s property or protect the rights, property, or safety of others, or, as needed, to support SMG’s external auditing, compliance, and corporate governance functions. The legal ground for processing Personal Data for this purpose is SMG’s legitimate interest in enforcing its rights, protecting its property or protecting the rights, property or safety of others, or as needed to support its external auditing, compliance, and corporate governance functions.

 

Third-Party Recipients of Personal Data

  • Third-Party Service Providers Analyzing Usage of SMG Sites and Apps: We use Personal Data collected from cookies and other data collection tools for usage analytics, fraud detection, and performance improvement for SMG's Sites and Apps. We may use third-party website analytics services to analyze how individuals use SMG's Sites and Apps, including to record mouse clicks, mouse movements, scrolling activity, and text that you type into free-form boxes. We use information collected from these third-party services to help us better understand how our users find and use SMG's Sites and Apps, enhance our services, and improve your user experience.
  • Third Parties Assisting with Electronic Communications: Your Personal Data will be used, as needed, to manage our relationship and communicate with you by mail, telephone, email, mobile alerts, and SMS text messaging. We may share your Personal Data with service providers that assist us in communicating with you.
  • Third-Party Administrators of Promotions: We may use and share your Personal Data with third parties in order to provide rewards and fulfill benefits you have requested and earned by taking surveys. If you elect to participate in a sweepstakes or other promotion, we send your information to third-party administrators of those promotions, so they can answer your questions or contact you about a prize you won or other issues related to the promotion.
  • Third-Party Service Providers Assisting with Electronic Direct Marketing: Where permissible by law, we may share your Personal Data with service providers assisting us with electronic marketing communications. SMG does not share the Personal Data of survey participants with direct marketing service providers, but, where permissible, we may share the Personal Data of other users of SMG Sites and Apps with such service providers. If you are a survey participant, you should review the Privacy Policy of the client for which we are collecting your Personal Data to determine such client’s direct marketing practices. 
  • Third-Party Service Providers Assisting with Print Mail Direct Marketing: Where permissible, we also may share your Personal Data with direct mail service firms that assist us in printing, addressing, and distributing printed materials and other physical marketing materials. Such firms may access name, title, company, and company address information for the purpose of printing shipping and mailing labels. SMG uses this data to reach clients and prospects with non-digital marketing and product-related communications.
  • Other Service Providers: We may share your information, including your Personal Data, with other service providers we use to perform the functions for which we engage them, such as hosting, data storage, and security. We may also share your Personal Data as needed to operate other related SMG Sites and Apps, such as ratings and reviews websites that we operate.
  • Clients: If you access SMG’s services to take a survey regarding your consumer experience with one of our clients, we share the Personal Data we collect from you about and relating to your survey responses with that client. We also may use this Personal Data to derive market research insights and provide consumer behavior analytics and business intelligence to our clients. For information concerning how the client for which we are collecting your Personal Data uses, protects, and otherwise processes Personal Data, read such client’s privacy policy. We and our clients also may combine different types of information, including Personal Data collected from or about you by us, our client, or third-party sources. SMG may use the combined information for any of the purposes described in this Privacy Policy, and our clients may use the combined information for any purposes described in their privacy policies.
  • Third Parties Viewing Your Posts or Receiving Your Communications: We may use and share your Personal Data in order to perform services you request or actions you initiate, such as when you post information on message boards, forums, or on our Social Media pages. In addition, when you give us permission, we may disclose your Personal Data in order to identify you to anyone to whom you send communications through the SMG Sites and Apps. 
  • Law Enforcement and Other Public Authorities: SMG may also share the information we collect from you, as needed, to enforce its rights, protect its property or protect the rights, property or safety of others, or, as needed, to support SMG’s external auditing, compliance, and corporate governance functions. SMG will disclose Personal Data as it deems necessary to respond to a subpoena, binding order of a data protection authority or judge, legal process, governmental request, or any other legal or regulatory obligation. In each case, the disclosure may be to a person or entity outside of your country of residence. SMG may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. SMG may also share Personal Data as required to pursue available legal remedies or limit damages it may sustain. 
  • Third Parties in Connection with Business Reorganization: We may transfer information about you, including Personal Data, in connection with any actual or impending reorganization, merger, sale, joint venture, assignment, transfer, acquisition, or other change in ownership or control by or of SMG or any affiliated company (in each case whether in whole or in part), including without limitation, in connection with any bankruptcy or similar proceeding. Any such entity to which we transfer Personal Data will be required to provide you with notice of any purposes of processing not compatible with the purposes set forth in this Privacy Policy, as well as any privacy practices that are materially different than the practices set forth in the Privacy Policy. Where required by law, such entity also will be required to obtain your consent. 

 

Cross-Border Transfers of Personal Data

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 arbitration process.

 

Children’s Privacy

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.


Retention of Personal Data

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.

 

Information Security

 

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.

 


Your Rights

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.


Your California Privacy Rights

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. 

 

How to Contact Us

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.

Attn: Data Protection Officer

38-40 The Maltings

St Albans

Hertfordshire AL1 3HL

UNITED KINGDOM

 

Service Management Group G.K.

Attn: Data Protection Officer

2-7-16 No. 3 Komoriya Building 9F

Hamamatsu-cho, Minato-ku

Tokyo 1050013, Japan

 

Data Controller and Data Protection Officer

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.

 

Privacy Policy Translations and Updates

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.