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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 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.

To jump to a specific section of this Privacy Policy, please click the links 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.

  • Purposes and Legal Grounds:
  • If you are contacting us to ask questions or request more information about SMG, we use this information to provide you with appropriate client supportThe 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.
  • 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 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 the website. 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 the visitor experience.
  • 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 website. 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 website as needed, to comply with legal obligations and enforce legal rights.

  • Purposes and Legal Grounds:
  • SMG processes such Personal Data collected through the 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 the website. We may use third-party website analytics services to analyze how individuals use the website, 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 the website, 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 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.
  • 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.
  • 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.

If you have a complaint, 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.

 

Children’s Privacy

The 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.

SMG commits to resolve complaints about our collection or use of your personal information.  Individuals with inquiries or complaints 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.

 

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 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 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 website.