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Published January 2018

INTRODUCTION

Smartbox Assistive Technology Limited (we and us) are committed to protecting and respecting your privacy.

This policy (together with our website Terms of Use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998, we are the Data Controller (as defined in that Act).

This Privacy Policy applies whenever you are using the Online Grids website at https://grids.thinksmartbox.com (the Site) directly or through the Grid Player software or The Grid 2 software or Grid 3 software or Grid for iPad (the Software).

INFORMATION WE MAY COLLECT FROM YOU

We may collect and process the following data about you:

Information that you provide by filling in forms on the Site, including, but not limited to, information provided at the time of becoming a registered user of the Site;

Information from surveys that we may send to you use for research purposes, if you choose to respond to them;

Communications you send to us (including via info@thinksmartbox.com), for example, when reporting a problem;

Details of your visits to the Site, including traffic data, location data and the resources that you access;

Details of your device, including device manufacturer, device model, operating system name, operating system version and device peripherals; and

Details of Software performance, including start times, responsiveness times, power and battery life, hours of screen off time, time device is plugged in to AC vs. battery, and crash data; and

Details of your Software use, including grid sets accessed, language of grid sets and time spent using grid sets.

IP ADDRESSES

We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

COOKIES

Cookies contain information that is transferred to your computer's hard drive. The Site uses simple cookies for system administration purposes to help us deliver a better and more personalised service. For example, if you register with us, we will store your user login and password by using a cookie file stored on your browser or the hard drive of your computer. For further details of what cookies are used by the Site, please contact us using the details below.

If you register with us or if you continue to use the Site, you agree to our use of cookies.

You may block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all parts of the Site or the Software. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon as you visit the Site.

For more information about cookies and how to stop cookies being installed or how to delete existing cookies from your hard drive visit the following website: www.allaboutcookies.org.

HOW WE PROCESS AND STORE YOUR INFORMATION

All information you provide to us is stored on our secure servers. Where you have chosen a password which enables you to access the Site, you are responsible for keeping this password confidential. You must not share the password with anyone.

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 the data that you transmit to the Site or the Software. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

USES MADE OF YOUR INFORMATION

We use information held about you in the following ways:

To provide you with information, products or services that you request from us or which we feel may interest you, subject to any preferences you have communicated to us, by post, email, SMS, telephone or other means of electronic communication;

To ensure that content from the Site or the Software is presented in the most effective manner for you and for your computer;

To notify you about changes to the Site or the Software or our other services; and

To create new services, features or content. When we do this, individuals will not be identified or identifiable unless we have obtained their permission.

If you do not want us to use your data for direct marketing purposes, please let us know by contacting Smartbox Assistive Technology Ltd.

DISCLOSURE OF YOUR INFORMATION

We may, for system administration purposes, disclose your personal information to any company which is, from time to time, a member of our group of companies, including, but not limited to, Smartbox Assistive Technology Limited.

We may disclose your personal information to third parties, but only:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

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 or other agreements; or to protect our rights, property, or safety or those of our customers or other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

OTHER WEBSITES

The Site may, from time to time, contain hyperlinks to and from internet sites operated by other organisations. If you follow a hyperlink to any of these sites, please note that they will have their own privacy policies and that we do not accept any responsibility or liability for these sites. Please check these policies before you submit any personal data to such sites.

ACCESS TO YOUR INFORMATION

The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act by contacting us using the details below. Any access request may be subject to a fee not exceeding £10 to meet our costs in providing you with details of the information we hold about you.

OTHER IMPORTANT INFORMATION

Smartbox Assistive Technology Limited is a company registered in England and Wales. Our company number is 05541084.

Any formal legal notices should be sent to us at the address at the end of this Privacy Policy by email and confirmed by post.

Failure by us to enforce a right does not result in waiver of such right. You may not assign or transfer your rights under this Privacy Policy.

If any part of this Privacy Policy is found to be unenforceable as a matter of law, all other parts of this Privacy Policy shall be unaffected and shall remain in force.

You and we agree that English law applies to this Privacy Policy and that any dispute between us regarding the Site or arising out of or in connection with this Privacy Policy will only be dealt with by the English courts, unless you are resident in another part of the United Kingdom, in which case the applicable law of that part of the United Kingdom will apply and any dispute will be brought before the courts there.

We may modify this Privacy Policy at any time, but if we do so, we will notify you by publishing the changes on the Site. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of these changes, you continue to use our services, you will be considered as having expressly consented to the changes in our privacy policy.

Non-English translations of this privacy policy are provided for convenience. In the event of any ambiguity or conflict between translations, the English version is authoritative.

HOW TO CONTACT US

If you have any questions, comments or requests regarding this privacy policy, please feel free to contact us in any of the following ways:

By email at info@thinksmartbox.com

By telephone on +44 (0)1684 578868.

By writing to us at: Smartbox Assistive Technology Ltd, Ysobel House, Enigma Commercial Centre, Sandys Road, Malvern, WR14 1JJ