Privacy statement

smart360 is an AI-enabled 360 feedback platform that helps organisations gather, analyse and report on feedback to support individual and organisational development.

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Data Controller

Smarter 360 Ltd
Company Number: 17148420
100 High Street
Whitstable
Kent CT5 1AZ

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The personal data we collect

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Depending on how you interact with us, we may collect:

• Name

• Email address

• Organisation and job title

• Contact details

• User account information

• Feedback responses and self-assessments

• Voice or text responses submitted through the platform

• AI-generated summaries and reports

• Technical information such as IP address, browser type and device information

• Website usage information collected through cookies where applicable

 

We only collect personal data that is necessary for the purposes described in this notice.

 

How we use your information

 

We process personal data to:

• Provide and administer the smart360 platform

• Deliver 360 feedback services

• Produce reports and development insights

• Support AI-enabled feedback analysis

• Provide customer support

• Improve our products and services

• Meet legal and regulatory obligations

• Maintain the security and integrity of our systems

 

Where smart360 provides services on behalf of a client organisation, we will generally act as a data processor, with the client acting as the data controller. In certain circumstances, such as managing enquiries, demonstrations or website registrations, smart360 acts as the data controller.

 

Lawful basis for processing

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Depending on the circumstances, we process personal data under one or more of the following lawful bases:

• Performance of a contract

• Legitimate interests

• Compliance with legal obligations

• Consent, where required

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AI processing

 

smart360 uses artificial intelligence to support feedback analysis, identify themes and generate development insights.

 

Customer data is not used to train public AI models. AI processing is carried out using appropriate security and privacy controls, and only for the purposes of delivering the smart360 service.

 

Data sharing

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We may share personal data with trusted third-party service providers who help us deliver our services, including cloud hosting, authentication, email delivery and AI processing providers.

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All suppliers are subject to appropriate contractual and security requirements. We do not sell personal data.

 

International transfers

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Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place, including the use of recognised contractual mechanisms where required.

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Data retention

 

We retain personal data only for as long as necessary to provide our services, meet legal obligations and fulfil legitimate business purposes.

 

For organisations using smart360, participant data is normally retained for the duration of the agreed licence period and for a period of 12 months after the licence agreement to ensure participants are able to re-start their licence and not suffer any loss in terms of a continuity of service. Where contractually agreed, data may be retained securely for a limited period afterwards before being permanently deleted in accordance with our Data Retention Policy.

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Your rights

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Under UK GDPR, you have the right to:

• Access your personal data

• Request correction of inaccurate information

• Request deletion of your personal data where appropriate

• Restrict or object to certain processing

• Request data portability where applicable

• Withdraw consent where processing is based on consent

• Lodge a complaint with the Information Commissioner's Office (ICO)

 

To exercise any of these rights, please contact ben@thesmart360.ai.

 

Cookies

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Our website may use cookies and similar technologies to improve performance, understand website usage and enhance your experience. Where required, we will ask for your consent before placing non-essential cookies.

Security

 

We take the security of personal information seriously and maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse or disclosure. These include encryption, access controls, secure cloud infrastructure and regular security reviews.

 

Contact us

 

If you have any questions about this Privacy Notice or how your personal data is handled, please contact:

 

Ben Chambers
Co-founder
Smarter 360 Ltd
Email: ben@thesmart360.ai

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If you remain dissatisfied, you have the right to contact the Information Commissioner's Office (ICO) via www.ico.org.uk.