S&S IT Consultants Ltd.
Privacy Policy – July 2026

 

System and Smiles  is committed to protecting your privacy and handling your personal data in an open and transparent manner.  This Privacy Policy explains how System and Smiles collects, uses, stores, and protects your personal information when you visit our website, request information about our IT support services, contact us, or otherwise interact with us through our website and related communications (collectively, the “Services”). This includes information collected when you submit inquiries, request consultations or quotes, subscribe to updates, or engage with us online. It also provides information about your rights and how you can manage your personal information.

Owner and Data Controller

In relation to the information collected through our website and our human resources and recruitment operations, we act as the Controller of your personal information. With respect to the information processed in connection with the IT support services we provide to our customers, we act as the Processor of our customers’ personal information and process such information only on their behalf, in accordance with their instructions and our contractual obligations. 

We Collect Data About You in the Following Instances:

 

We may collect personal data about you in the following instances:

 

• Use our Services or otherwise  contact or request information from us

• Applying to our team

• We may collect browsing data automatically when you visit our Site.

Personal data we collect:

 

• Contact & Identity Data: including your name, email address, telephone number, business address, your role within your organization.

• Billing and payment information: Name, Business Email, Phone, Billing Address

• Technical Data includes internet protocol (IP) address or other identifier for each computer, mobile device, technology or other device you use to access the Service.

• Usage Data: Log Data such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our site that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

• Employment Data such as contact information, employment history, professional qualifications, and any other information provided through the CV.

• Marketing this may include your preferences in receiving marketing communications from us.

• IT Support Service: Name, Email, Ticket content, Usernames, Screen view, User ID, IP Address

• CRM and Service Device Mgmt (RMM) Service: Name, email, password, Hostnames, Usernames, IP Address, Device status. 

• Endpoint Security: File names, Activity logs, User IDs, Security events.

How and why we use your data:

 

We use and collect data for various purposes:

• Provide you with our Services – Performance of a contract 

• Responding to questions for support and requests – Steps taken at your request prior to entering a contract; legitimate interests (responding to business enquiries) 

• Solicit feedback from customers – Legitimate interests (improving our services and customer experience). 

• Understand how to optimize our website to provide a better user experience –  Legitimate interests (improving our website and services); consent, where required by law for non-essential cookies or similar technologies. 

• To contact you for marketing purposes when we have your permission – Consent (where required by law); legitimate interests (B2B direct marketing to existing or prospective business contacts) 

• To enforce our agreements, exercise or defend legal claims, and prevent fraud or misuse – Legitimate interests (protecting our rights, customers, and business); legal obligation, where applicable. 

• To process job applications and recruitment enquiries – Steps taken at your request prior to entering a contract; legitimate interests (managing recruitment and evaluating candidates). 

Data sharing and disclosures:

 

We may share all categories of personal information listed above with the following categories of third parties and/or service providers:

 

• Third-parties and/or service providers: We may share personal information with third parties and/or service providers that provide services for us. For example, we may share personal information with vendors to help us host and manage the site; provide targeted advertising and other marketing; improve the content and functionality of the site; perform data analysis and statistical analysis; troubleshoot problems with the site; provide payment processing services and online storefronts; provide public relations; provide learning management systems; provide email services; provide data processing; and support or provide the security of the site.

• Government officials / law enforcement: we will cooperate with law enforcement and other governmental agencies, and may disclose personal information: (i) if we believe in good faith we are legally required to disclose that personal information, (ii) if we are advised to disclose personal information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, anthill or any other party.

• Professional advisors: We may share personal information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to anthill.

• Other: We may share personal information with third parties and/or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Retention periods:

 

We have established retention periods based on the purpose for which personal data is processed and applicable legal and regulatory requirements. For example, we remove personal data when it has fulfilled its intended purpose and is no longer needed. We regularly review the personal data we collect (such as information relating to our business contacts) to ensure it remains accurate, current, and is not retained for longer than necessary. 

 

If you wish to have more detailed information about our retention times, please contact us at privacy@systemsandsmiles.com.

 

International Transfer

 

In some cases, System and Smiles may transmit, or store personal data collected with affiliates, vendors, or sites in other countries. We will only transfer personal data as allowed by applicable law to further the purposes set out in this document. Where personal data is transferred to another country, we take administrative and technical measures to ensure adequate safeguards and protections are applied as provided for by applicable law. In cases where personal data is transmitted to other countries, we will ensure that safeguards equivalent to those required by applicable data protection laws are in place

Data security:

 

System and Smiles has an appropriate information security policy tied to procedures that protect personal data from breach, misuse and loss. We ensure we have technical and operational measures in place that define a standard for how we protect our client data.

 

We have implemented strict security protocols and hold the following certifications to ensure the highest level of protection:

 

• ISO 27001 – international standard for information security management.

 

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology

 

Your rights:

 

Under the law, you are granted six fundamental rights when data about you is being processed. We will ensure to reach out without undue delay (no more than 30 days) when you submit a request related to exercising your data subject rights. Although uncommon, when applicable for official or legal reasons we may be unable to address the specific request you make related to your rights. 

 

Also, if a request is manifestly unfounded or excessive, in particular because of their repetitive character, we may either:

 

• charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or

 

• refuse to act on the request.

 

In this scenario will we inform you of the reasons we believe your request is manifestly unfounded or excessive character of the request.

 

As a data subject, you may: 

 

• request access to the personal information we process about you; 

 

• request that we correct inaccurate or incomplete personal information about you;

 

• request deletion of personal information about you; 

 

• request restrictions, temporarily or permanently, on our processing of some or all personal information about you; 

 

• request transfer of personal information to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; 

 

• and opt-out or object to our use of personal information about you where our use is based on your consent or our legitimate interests. 

 

If we have reasonable doubts concerning your identity, we may request the provision of additional information necessary to confirm it.

If you wish to exercise your rights, or if you have any other question relating to your rights or this privacy statement, please contact us at privacy@systemsandsmiles.com. You also have the right to lodge a complaint with a supervisory authority. You can complain to the Information Commissioner’s  Officer or exercise any of your other rights pursuant to data protection law.

 

Information about how to do this is available on the ICO website at ico.org.uk/global/contact-us/. You can find a list of Supervisory Authorities at edpb.europa.eu/about-edpb/about-edpb/members_en 

Updates on our Privacy Policy:

 

From time to time it may be necessary to adapt the content of this Privacy Policy. We, therefore, reserve the right to change these at any time without prior notice. The current version published on our website shall apply.

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