What does this privacy statement cover?
This privacy statement explains how we are committed to protecting your privacy and handling your information in an open and transparent manner.
This privacy statement sets out how we will collect, handle, store and protect information about you when:
you use “our Website” or
we perform any other activities that form part of the operation of this Website.
When we refer to “our Website” or “this Website” in this privacy statement we mean all the webpages of smolbol.com.
Smolbol.com is comprised of various global, country, regional and practice specific websites, each of which is provided by Mismi Foods LLC (“Mismi”) or one of its independent member firms or their related entities (collectively, the “Mismi Network”). Please note that the other country and regional websites contained within smolbol.com are provided by such other entities within the Mismi Network and are not provided by us. Such websites, as well as other websites that may be linked to this Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of these other websites before disclosing any personal information.
This privacy statement also contains information about when we share your personal information with other members of the Mismi Network and other third parties (for example, our service providers).
In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.
What information do we collect?
We may collect personal information from you when you use this Website.
The personal information that we collect or obtain in such circumstances may include: your name; e-mail address; country of residence; employment and education details; your postings on any blogs, forums, wikis and any other social media applications that we provide; your IP address; your browser type and language; your access times; complaint details; details of how you like to interact with us and other similar information.
The personal information we collect may also include so-called ‘sensitive’ or ‘special categories’ of personal information, such as details about your dietary requirements (for example, where we provide you with lunch during a meeting).
The types of personal information and special categories of personal information that we collect may vary depending on how you use our Website. In some rare circumstances, we might also gather other special categories of personal information about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.
We understand the importance of protecting children’s privacy. Our website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.
How we use information about you
Use of personal information collected via our Website
We may also use your personal information collected via our Website:
to manage and improve our Website
to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information regarding services provided by entities within the MISMI Network that may be of interest to you
to manage and respond to any request you submit through our Website.
Use of personal information for other activities that form part of the operation of our business
In addition to the purposes connected to the operation of our Website above, we may use your personal information for the purposes of, or in connection with:
applicable legal or regulatory requirements
requests and communications from competent authorities
sending you thought leadership or details of products and services provided by entities
within the Mismi Network that may be of interest to you; contacting you to receive
feedback on these services; and contacting you for other market or research purposes;
protecting our rights.
The legal grounds we use for processing personal information
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal information.
We use your personal information for the purposes outlined above because of: (a) our legitimate interests in the effective delivery of our Website; (b) our legitimate interests in the effective and lawful operation of our Website so long as such interests are not outweighed by your interests; (c) the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.
To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) the processing is necessary for the establishment, exercise or defense of legal claims or (iii) you have made the data manifestly public.
Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail.
To whom we disclose your information
In connection with one or more of the purposes outlined in the “How we use information about you” section above, we may disclose details about you to: other members of the MISMI Network; third parties that provide services to us and/or the MISMI Network; competent authorities (including courts and authorities regulating us or another member of the MISMI Network) and other third parties that reasonably require access to personal information elating to you for one or more of the purposes outlined in the “How do we use information about you?” section above.
Our Website may host various blogs, forums, wikis and other social media applications that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control
over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.
Please note that some of the recipients of your personal information referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. The adequate
safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal information to third countries.
Please contact us for further details of the transfers described above and the adequate safeguards used in respect of such transfers.
We may also need to disclose your personal information if required to do so by law, by a regulator or during legal proceedings.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.
Protection of your personal information
We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include:
education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information
administrative and technical controls to restrict access to personal information on a‘need to know’ basis
technological security measures, including fire walls, encryption and anti-virus software
physical security measures, such as staff security passes to access our premises.
Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.
How long do we keep your information?
We will hold your personal information on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; (iii) the end of the period in which litigation or investigations might arise in respect of the services.
You have various rights in relation to your personal information. In particular, you have a right to:
obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you
ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
object to our processing of your personal information.
To exercise any of your rights, or if you have any other questions about our use of your personal information, please contact us.
Right to complain
If you are unhappy with the way we have handled your personal information or any privacy query or request that you have raised with us, you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time.
To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.