Privacy Policy

Who we are

Smart Octopus Voice Agency is a full-service voice first conversational commerce agency specialising in voice skills and digital assistants/chatbots. Our website address is: https://smartoctopusvoiceagency.com.

We are the Data Controller in relation to the processing activities described below for individuals who have been involved in our projects or who interact with our websites.  The details below describe how we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others, and how it is kept secure.  

What personal data we collect and why we collect it

When you use this website, our products or services, we collect certain personal data about you. The type of personal data we collect is information: 

• you provide to us; 
• we collect from you; 
• we observe about you (from your interaction with our email campaigns, messenger conversations and/ or website); 
• we obtain from other sources, and other third parties; and 

Personal information you give to us: 

This is information about you that you give to us by entering information via our site www.smartoctopusseo.com, our campaign landing pages, our mobile applications, social media platforms, and corresponding with us by phone, email, messenger, SMS or otherwise and is provided entirely voluntarily. 

This includes: 

• Information provided at the time of subscribing to our newsletter, including your name, email address, telephone number, job title, and current employer. 
• If you contact us online, we will collect your name and contact details keep a record of your e-mail, messenger id or relevant correspondence. 

Please be aware that if you apply for a job with us we will use your personal information in accordance with our Candidate Data Privacy Notice. 

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service Privacy Policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Contact forms

If you complete the contact form to ask us to contact you to provide a quote or book a meeting this information will be placed into our CRM system to enable our sales and marketing team to track the conversations and provide an enhanced customer experience. If you request to be removed from our CRM system then we will remove all but the essential data and mark your record to show that we should not contact you.

Cookies

If you leave a comment on our site you may opt in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

Although we do use some WordPress plugins on this website that may pass data, including personal information, to external servers to process, such as Akismet Anti-Spam. We do not share your data with anyone else.

HOW WE USE YOUR PERSONAL INFORMATION

The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.

Where you have provided CONSENT   

We may use and process your personal information where you have consented for us to do so for the following purposes: 

• contact you via email with information about the developments of our projects if you (i) sign up to our newsletter emails via our website or other medium where available;  or (ii) when you refresh your subscription preferences when responding to a request from us to do so. 

You may withdraw your consent for us to use your information in any of these ways at any time. Please see Withdrawing your consent for further details. 

Where it is in your VITAL INTEREST

Where we have supplied you with any services and software, we may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way. 

Where there is a LEGITIMATE INTEREST

We may use and process your personal information where it is necessary for us to pursue our legitimate interests, or that of a third party, for the following purposes: 

• for profile-raising activities (other than where we rely on your consent) to contact you by email with information about our products and services; 
• when you provide your contact details through our site to contact the Smart Octopus Voice Agency team, indicating that you would like to speak to a member team to request a demo of Smart Octopus Voice Agency Products or Services or when you book a demo; 
• to hold your details in our customer relationship tool in order that we may contact you about future opportunities and/or to provide a demo of the Smart Octopus Voice Agency Products or Services; 
• to pass your name and email address to our appointed suppliers and service providers for market research purposes who (if you are selected) will contact you with a request to voluntarily participate in either a survey or in-depth interview where you will be asked questions concerning your participation in any of Smart Octopus Voice Agency’s projects and your engagement with Smart Octopus Voice Agency generally; 
• for analysis to inform our profile-raising strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our website); 
• to correspond or communicate with you; 
• to verify the accuracy of data that we hold about you and create a better understanding of you as a customer; 
• for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access; 
• for prevention of fraud and other criminal activities; 
• to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for profile-raising purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request); 
• for the management of queries, complaints, or claims; and 
• for the establishment and defense of our legal rights. 

Where there is PERFORMANCE OF A CONTRACT

We may use your personal information where it is necessary for the performance of a contract, for example, to deliver our products and services under a contract to which you (or your employer) is a party or to take steps at your (or your employer’s) request before entering into such a contract.  This includes where you (or your employer) subscribes to a Smart Octopus Voice Agency Product or Service and where we provide support for the Smart Octopus Voice Agency Product or Service. 

Where there is a LEGAL REQUIREMENT

We will use your personal information to comply with our legal obligations: (i) to assist with queries raised by a public authority or criminal investigation body; (ii) to identify you when you contact us; (iii) to verify the accuracy of data we hold about you; and/or (iv) where we reasonably believe that you are or may be in breach of any applicable laws, we may disclose your personal information relevant third parties, including to law enforcement agencies. 

DATA ANONYMISATION AND USE OF AGGREGATED INFORMATION

Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes. 

For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy. 

OTHERS WHO MAY RECEIVE OR HAVE ACCESS TO YOUR PERSONAL INFORMATION

Our suppliers and service providers 

We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management), marketing agencies and administrative services. 

When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.  A list of our third party service providers is set out at Schedule 2 to this policy. 

User satisfaction surveys 

As satisfaction for people who engage with us is important to us, we may ask a third party research company to contact you for the sole purpose of gathering general information and specific information relating to us and our products and services. 

Other ways we may share your personal information 

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected. 

WHERE WE STORE YOUR PERSONAL INFORMATION  

As an organisation with an international presence the personal data which we collect may be transferred to and stored in countries outside the jurisdiction you are in, including to our group companies, suppliers and service providers.  Any international transfers of your personal information are made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission.  If you wish to enquire about these safeguards used, please contact us using the details set out at the end of this policy. 

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR 

If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary. 

We may need your personal information to establish, bring or defend legal claims.  For this purpose, we will always retain your personal information for 7 years after the date it is no longer needed by us for any of the purposes listed under How we use your personal information above. The only exceptions to this are where: 

• the law requires us to hold your personal information for a longer period, or delete it sooner; 
• you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or 
• in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place. 

SECURITY AND LINKS TO OTHER SITES

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access. 

Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website. 

COOKIES

Like many other websites, our website uses cookies including Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes to our website. ‘Cookies’ are small pieces of information sent to your computer or device and stored on its hard drive to allow our websites to recognise you when you visit. 

It is possible to switch off cookies by setting your browser preferences. For more information on how we use cookies and how to switch them off on your device, please visit our Cookies Policy. 

PROFILE RAISING ACTIVITIES

We may collect your preferences to receive information directly from us by email when you are expressing an interest in our events or attending our events and we will only do so if you have consented to received such information directly from us. 

We may contact you with targeted advertising delivered online through social media and platforms operated by other companies by using your personal information, or use your personal information to tailor our profile sharing correspondence to improve its relevance to you, unless you object. 

Once shared, the relevant third party’s privacy policy will apply to their processing of your personal information, not ours. If you would like to opt-out of receiving marketing from a third party after providing your consent, you can do so at any time by contacting the relevant third party directly.  However, we may contact you after a profile-raising activity, such as an online digital event, in order to ask for your feedback, arrange an opportunity for you to discuss use of our products and/or services and invite you to future online digital events. 

From time to time, we may ask you to refresh your subscription preferences by asking you to confirm that you consent to continue receiving profile raising information from us. 

You have the right to opt-out of our use of your personal information to provide correspondence to you in any of the ways mentioned above. Please see Withdrawing your Consent and Objecting to our use of your personal information and automated decisions made about you below for further details on how you can do this.

9. YOUR RIGHTS

You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.

• Accessing your personal information

You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy.  We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

• Correcting and updating your personal information

The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.

In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us in any of the details described at the end of this policy.

• Withdrawing your consent

Where we rely on your consent as the legal basis for processing your personal information, as set out under How we use your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy.  If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our unsubscribe tool. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.

• Objecting to our use of your personal information and automated decisions made about you

Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose(s), as out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise, we will provide you with our justification as to why we need to continue using your data.

You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.

You may also contest a decision made about you based on automated processing by writing to us at the address at the end of this policy.

• Erasing your personal information or restricting its processing

In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.

You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.  In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.

• Transferring your personal information in a structured data file (“data portability”)

Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under How we use your personal information, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used, and machine-readable form, such as a CSV file.

You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.

• Complaining to the UK data protection regulator

You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.

CHANGES TO THIS POLICY

We may review this policy from time to time and any changes will be notified to you by posting an updated version on our website and/or by contacting you by email. Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on our website, whichever is the earlier. We recommend you regularly check for changes and review this policy whenever you visit our website. If you do not agree with any aspect of the updated policy you must immediately notify us and cease using our services. 

Improved transparency – in our most recent changes (January 2021) we set out clearly how we use, process, and share your personal information when you attend a Smart Octopus Voice Agency online digital event eg webinar and how we use and process your personal information. 

CONTACT US

Please direct any queries about this policy or about the way we process your personal information to our data protection manager using our contact details below.

If you wish to write to us, please write to the address given at the start of this policy.

Our data protection manager’s email address for data protection queries is dataprotecton@smartoctopusvoiceagency.com

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments and contact forms may be checked through an automated spam detection service such as reCAPTCHA v3 which helps you detect abusive traffic on our website without user interaction.

Your contact information

We don’t set a particular time limit on storing visitor or subscriber information because we need it for future reference. If you want your information to be removed from our database, please contact us. We will remove it anytime if there are concerns about your privacy.

Additional information

How we protect your data

We believe that you have the right to control the use of your personal information, and we respect your privacy. Therefore, we strictly limit the collection and protection of your personal data. We do not sell, rent or lease your data.

What data breach procedures we have in place

We treat the risk of data breach seriously. A data breach refers to the unauthorised access and retrieval of personal data. We take steps to avoid any risks of a data breach occurring by the Breach Management Plan that consist of risk assessment, containment and recovery, and prevention of future data breaches

THIRD PARTY SERVICE PROVIDERS

Last Amended May 2021