1.1 This is the privacy policy referred to in the Membership Terms.

1.2 Terms defined in this privacy policy shall have the meanings given to them in the Membership Terms.

1.3 For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Smarta Water Limited of North House, Elland Road, Morley, Leeds, West Yorkshire, England, LS27 7QZ “Data” and “Personal Data” have the meanings given to them in the Act.

1.4 This privacy policy (together with our terms of and any other documents referred to in it) sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us.

1.5 Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting the website, you are accepting and consenting to the practices described in this policy. If you have any questions at all about this policy or the website or mobile Product, please email admin@smartawater.com.

1.6 Our nominated representative for the purpose of the Act is Mrs Jo Dando.


2.1 We will collect and process the following Data about you:

(a) Information you give us. This is information about you that you give us by filling in forms on the website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use the website, subscribe to our service, search for a product, place an order on the website, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, click and use links provided throughout, use and engage with the website in any way and when you report a problem with the website. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph;

(b) Information we collect about you. With regard to each of your visits to the website we will automatically collect the following information:

(i) technical information, including the Internet protocol (IP) address used to connect your computer or alternative device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and

(ii) information about your visit, including the full Uniform Resource Locators (“URL”), clickstream to, through and from the website (including date and time), products you viewed or searched for’ page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

(c) Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.


3.1 We use information held about you in the following ways:

(a) Information you give to us. We will use this information:

(i) to carry out our obligations arising under the terms of use;

(ii) to provide you with information about other goods and services that are similar to those that you have already purchased, enquired about or otherwise engaged with;

(iii) to notify you about changes to the website; and

(iv) to ensure that content from the website is presented in the most effective manner for you and for your computer or internet enabled device.

3.2 Information we collect about you. We will use this information:

(a) to administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(b) to improve the website to ensure that content is presented in the most effective manner for you and for your computer or internet enabled device;

(c) to allow you to participate in interactive features of our service, when you choose to do so;

(d) as part of our efforts to keep the website safe and secure;

(e) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

(f) to make suggestions and recommendations to you and other users of the website about goods or services that may interest you or them.

3.3 Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).


4.1 We will disclose your personal information to third parties:

(a) to give effect to clause 3.1 above;

(b) in the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets.

(c) if we are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.

(d) if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use  and other agreements; or to protect the rights, property, or safety of the website, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.


5.1 By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this privacy policy.

5.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

5.4 We use all reasonable efforts not to disclose, use or collect Personal Data from children under 13 years of age. If you believe your child has provided us with any Personal Data by registering on the website, please contact us using the contact details set out in the terms of use.


6.1 Subject Access Requests

GDPR gives you the right to access or amend information held about you. Your right of access can be exercised in accordance with the GDPR. A request for personal information is free unless the request is deemed to be manifestly unfounded or excessive. We will endeavor to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you would like to access, amend or to request copy of the information held on you please write to the Data Protection Officer, Smarta Water Limited, North House, Elland Road, Churwell, Leeds, LS27 7QZ, or by emailing us at info@smartawater.com

6.2 Right to Rectification

Data subjects have the right to request that we amend or change personal information that we hold about you, that is inaccurate or incorrect.

6.3 Right to erasure

Data subjects have the right to ask us to delete personal information from our systems without giving any reason and at any time. We will act on any request without delay.

6.4 Right to restrict processing

Data subjects have the right to rectification or erasure of personal data in the following circumstances:

  • Personal data is not accurate;
  • The processing of data is unlawful. Data subjects may request that processing is restricted;
  • Data is required to exercise legal rights or defend legal claims;
  • Data is unlawful but there may be lawful grounds for processing, which override this right.

6.5 Right to data portability

Data subjects have the right to obtain and transfer their data to different service providers.

6.6 Right to object

Data subjects have the right to object to the processing of data at any time based on their particular situation. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process data where we can demonstrate lawful grounds for doing so.

Right not to be subject to decisions based on automated processing. We do not use any automated processing that results in any automated decision based on a data subject’s personal information.

6.7 Partner networks, advertisers and affiliates

Our Site may, from time to time, contain links to and from the sites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

6.8 Requesting information we hold

Please refer to www.dataprotection.gov.uk for further information about your rights under the Act. You have the right to receive a copy of the information we hold about you by sending a request in writing (with a fee of £10) to us using the contact details set out in the terms of use.

6.9 Complaints

If you have a complaint about the use of your data, you can contact us by email to info@smartawater.com

Alternatively, you can formally report an issue of concern to the Information Commissioner’s Office (ICO), the UK body that governs Data Protection. See https://ico.org.uk


7.1 Our Site uses cookies to function and distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

7.2 For more information about Cookies and how they are used please refer to https://ico.org.uk/for-the-public/online/cookies/.


8.1 Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.


9. MOSL Summary Of Arrangements