smartFOCUS DIGITAL ("SFD")
is committed to dealing with personal data in the spirit
of the Data Protection Act 1998 ("the Act")
and protecting personal privacy in accordance with the
law.
EMR as data processor delivering client services
In providing our services EMR acts as a data processor
on behalf of our clients. The client is the data controller
for personal data generated by using our services.
Where EMR receives or otherwise processes personal
data within the meaning of the Act, EMR will only process
that data to the extent needed in order to provide an
email management or website usage service for our clients.
EMR will not use personal data obtained in the course
of providing our email management or website usage service
for any other purpose and will not release it, in whole
or in part, to anyone other than to our client in its
capacity as the data controller, unless we are obliged
to do so by law.
In delivering our services EMR may make use of cookies
or other technologies which facilitate access to information
stored in the terminal equipment of our clients and
or in the terminal equipment of users of our clients'
websites or for email tracking services in the terminal
equipment of senders or recipients of emails.
Cookies are small amounts of computer code placed on
a computer. Cookies may be used by EMR in order to track
the emails handled by EMR as part of our email service
to clients. The information received by EMR from the
cookies is used to detect when emails have been forwarded
to other users. They do not allow EMR to identify the
geographic position of the user of the relevant computer.
As part of our website usage service EMR uses cookies.
The cookies originate from EMR and are triggered by
website visitors visiting predefined pages or by the
visitor undertaking activities on our client's website.
They allow EMR clients to track actions and activities
on their websites. They do not allow EMR to identify
the geographic position of the user of the relevant
computer and we will not release website usage information,
in whole or in part, to anyone other than our client.
EMR as data controller
In certain circumstances, EMR will obtain and store
personal data and other information for its own purposes.
In those cases, EMR will act as data controller.
EMR may request and store names, addresses and other
contact details. Such information will be used by EMR
for its own administrative and marketing purposes only.
EMR will not release such information, in whole or in
part, to any third parties unless obliged to do so by
law.
EMR may make use of its own email management service
and website usage service which may make use of cookies
and other technologies as described above. Such information
will be used by EMR for its own administrative management
and marketing purposes only and we will not release
such information, in whole or in part, to any third
parties unless obliged to do so by law.
If you have any query regarding this or object to this
use please contact the Data Protection Officer in writing
at the address supplied below.
Your ability to opt out
We have provided a facility that allows anyone to refuse
the storage of or access to information created by the
use of cookies. This facility is in addition to controls
which may be available to you on your own computer equipment
via your web browser or otherwise.
If you wish to opt out please click here:
I wish to opt out
The cookies and other technologies used by EMR are
configured so as to recognise the privacy settings that
you set on your web browser assuming that you are using
Internet Explorer 6.0 and to respect them. Internet
Explorer 6.0 does this by comparing the cookie’s
machine-readable privacy policy with the user’s
privacy settings. If the settings do not match or the
cookie does not have a machine-readable privacy policy
the cookie should be blocked or restricted by your computer.
If you want more detail about the operation of EMR’s
machine-readable privacy policy in connection with a
cookie placed on your equipment you should contact EMR’s
Data Protection Officer in writing at the address supplied
below
General
Where there are links from the EMR website to other
websites, EMR emphasises that it has no control over
these sites, their content or the way in which they
collect or use personal data. EMR therefore strongly
advises users to check the privacy policy of any site
they visit.
Please note that by applying to make use of the email
management or website usage services offered by EMR,
the client is providing their consent to EMR collecting,
holding and using the information referred to above.
This consent however only extends to the uses as set
out in this Privacy Policy.
Any user wishing to enquire about the personal data
stored by EMR about themselves should contact the Data
Protection Officer in writing at the address supplied
below.
18/09/2003
Email Reaction Ltd
The Barley Mow Business Centre
10 Barley Mow Passage
London
W4 4PH
T: +44 (0)8707 425452
F: +44 (0)8707 425010
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