1.        Introduction and General Terms

SmartWater Technology Limited is committed to safeguarding your personal information.  Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the Data Protection Act 1998 (the “Act”).

For the purpose of the Act, the Data Controller is SmartWater Technology Limited

This Data Usage Policy (together with our Terms of Use and any other documents referred to in it) sets out how we obtain, use and protect any personal information you provide to Us, whether online, via phone, text, email, in letters or other correspondence.  When you access and use the website you agree to be legally bound by our Terms of Use as well as our Data Usage Policy outlined below.

2.       Who we are

We are SmartWater Technology Limited (“SmartWater”/”We”/”Us”).  We operate the website  SmartWater is a company registered in England and Wales under company number 02875523 and with our registered office at 27 Queen Anne’s Gate, London, SW1H 9BU.  To contact Us, please see our Contact Us page

We are an ISO 27001 registered company. This means that we manage and secure your data through strict guidelines which are independently assessed annually through the ISO27001 Information Security Management certification. This accreditation provides confidence to customers and the law enforcement community that data will never be misused or altered in any way.

Our products conform to the British Standards Institution PAS 820:2012 Grade A external classification.

3.        What information do we collect?

We collect information for the purposes described under section 4 below. This may include your name, address, telephone number, email address, credit or other payment card details.

By providing Us with your contact details, you consent to being contacted for the purposes set out below.  Other than as set out below, We will only use your information for the purposes that you would reasonably anticipate or that We state when we collect it.

You can, of course, withdraw this consent by clicking on and entering the email address used to make your purchase.

This will automatically send an email to the email address entered, containing a link to your ‘Marketing Subscriptions’ page. Once clicked, you will be able to manage your subscriptions.

4.        How will we use the information we collect about you?

We will use the  information you provide to us for a number of purposes including the following:

  • administration and/or order processing purposes;
  • to fulfil sales contracts you have entered into with Us;
  • prevention of fraud, theft or loss;
  • customer services;
  • for marketing purposes (where you have not opted out from receiving further information, including when signing up to our newsletter), to provide you with information about other goods and services We offer; that are similar to those that you have already purchased or enquired about;
  • to provide you, [or permit selected third parties to provide you] with information about goods or services We feel may interest you. If you have previously made a purchase with Us, We will  contact you with information about our own goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. We may permit selected third parties to provide you with information about goods or services [e.g. insurance savings and offers], where you have not opted out from receiving this information.
  • to analyse and improve the activities and content offered by our website to provide you with the most user-friendly navigation experience.  We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purpose;
  • any other purposes made clear in the data entry forms themselves, in any relevant terms and conditions and on any pages or emails that link to such forms.

We will retain the personal information you provide within the United Kingdom and will not transfer it to any other country except with your express prior consent; however the internet is global and it is possible that the information you provide to Us will be temporarily transferred via a route outside the European Economic Area as it passes between you and this website or a third party provider.

We may retain your credit card and/or payment details on our database for the purpose of renewals but we will not pass these details on to third parties for marketing purposes.

We are committed to treating your personal data with due care and in accordance with the data protection principles.

5.        Will SmartWater share my personal information with anyone else?

In order to process orders for goods or services we may pass your personal information and payment details to third party providers. We may also, where lawfully requested to do so, pass your personal information to regulatory authorities and law enforcement agencies.  Where SmartWater acts as an agent for a third party, We will pass your details to the third party who may then need to contact you to complete the transaction and their terms and conditions will apply to that transaction.

Such third party providers will only have access to the personal information needed to provide the relevant goods or services.  They may not use your personal information for any other purposes and are required to process your personal information in accordance with the Data Protection Act 1998.  We will not otherwise provide any of the personal information you give it to any third party for any purpose unconnected with a transaction you initiate, except with your prior express consent.

6.       Offensive or inappropriate content placed on the SmartWater website

If you post or send offensive, inappropriate or objectionable content to or anywhere on the SmartWater website or otherwise engage in any disruptive behaviour on any of our services, we may use your personal information to stop such behaviour.

Where SmartWater reasonably believes that you are or may be in breach of any of the laws of England and Wales (or the law of Scotland if you live there) for example, because content you have posted may be defamatory, We may use your personal information to inform relevant third parties such as your employer, internet provider or law enforcement agencies about the content and your behaviour.

7.       How long will SmartWater keep my personal information?

We will hold your personal information on our systems for as long as is necessary for the relevant activity.  If you request Us not to send you marketing information We will keep a record of your contact details and appropriate information to enable Us to comply with your request not to be contacted by Us.

8.       Can I update, correct or delete my personal information?

The accuracy of your information is important to Us.  If any of the information We hold about you is inaccurate or out of date please contact Us using our Contact Us page

Under the Data Protection Act 1998 you have the right to request a copy of the personal information We hold about you and to have any inaccuracies corrected.  We may charge you a reasonable administration fee for providing you with a copy of the information We hold about you and We would require you to prove your identity with two pieces of approved identification.

Please address requests and questions about this or any other question about this Data Usage Policy to the Data Protection Officer using our Contact Us page

9.       Cookies Policy – How we collect data about your use of our website

Cookies are small data files that are sent to your browser and pixel tags are used to reach such cookies or to establish that a page has been viewed.  Most internet browsers automatically accept cookies but you can delete existing cookies from your browser and by editing your internet browser options, choose not to receive cookies in the future.

We use cookies to ensure that you have the best experience on our website.  These may include a mix of cookies falling within the ICC classifications Strictly Necessary, Functionality and Performance and/or Behavioural Targeting.  Cookies may either be session cookies, which last for only a single browser session (for example to remember search results), or persistent cookies.  Persistent cookies remain on your device and allow us to authenticate you and remember your preferences and otherwise enhance your experience on our website.

Our session and persistent cookies may be a mixture of first party cookies (which are sent from our website) and third party cookies (which are not).

If you continue browsing, We will assume that you are happy to receive all our cookies.  You can change your settings at any time but if you do opt to reject cookies, some elements of our website may not function correctly as cookies enable the site to recall data specific to you.

You can find more information about the individual cookies We use and the purposes for which We use them in the table below:

COOKIE name COOKIE Description
CART (1) The association with your shopping cart.
CATEGORY_INFO (2) Stores the category info on the page, that allows to display pages more quickly.
COMPARE (1) The items that you have in the Compare Products list.
CURRENCY (1) Your preferred currency
CUSTOMER (1) An encrypted version of your customer id with the store.
CUSTOMER_AUTH (1) An indicator if you are currently logged into the store.
CUSTOMER_INFO (1) An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS (1) Stores the Customer Segment ID
EXTERNAL_NO_CACHE (2) A flag, which indicates whether caching is disabled or not.
FRONTEND (1) You session ID on the server.
GUEST-VIEW (1) Allows guests to edit their orders.
LAST_CATEGORY (1) The last category you visited.
LAST_PRODUCT (1) The most recent product you have viewed.
NEWMESSAGE (1) Indicates whether a new message has been received.
NO_CACHE (1) Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART (1) A link to information about your cart and viewing history if you have asked the site.
POLL (1) The ID of any polls you have recently voted in.
POLLN (1) Information on what polls you have voted on.
RECENTLYCOMPARED (1) The items that you have recently compared.
STF (1) Information on products you have emailed to friends.
STORE (1) The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE(1) Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS(1) The products that you have recently viewed.
WISHLIST(1) An encrypted list of products added to your Wishlist.
WISHLIST_CNT(1) The number of items in your Wishlist.
LOCATION(1) Used to determine which site is most applicable


10.   Security

SmartWater is committed to the security of your personal information and We have security procedures in place to protect the loss, misuse or alteration of information under our control.

11.   Changes to our Data Usage Policy

This Data Usage Policy may be updated from time to time. It is your sole responsibility to check it frequently and each time you submit personal information to Us. This Data Usage Policy was last updated on 29 September 2014.


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