Privacy Policy

Introduction

Welcome to LewisSmith.co and Dropship Unlocked, operated by SRL ECOM LTD (“SRL ECOM,” “we,” “our,” or “us”), a company dedicated to safeguarding your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your personal information in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018, and other applicable privacy laws.

We are registered with the Information Commissioner’s Office (ICO) under registration number 00013134529.

This Privacy Policy, together with our Cookie Policy, Terms of Use, and any other referenced documents, outlines the basis on which we process your personal data in relation to the services provided through our websites, including https://lewissmith.co/, https://dropshipunlocked.com/, and https://htabook.com/ (collectively referred to as the “Platform”).

Definitions

• Data Controller, Data Processor, Data Subject, and Supervisory Authority shall have the same meanings as in the Data Protection Laws.

• Data Protection Laws includes Regulation (EU) 2016/679 (the GDPR), and applicable subordinate legislation and regulations implementing those including the Data Protection Act 2018 (the DPA), USA state-specific regulations including, but not limited to – the California Consumer Privacy Act of 2018 (the CCPA), California Privacy Acts Right of 2023 (the CPRA), the Virginia Consumer Data Protection Act of 2023 (the VCDPA), Connecticut’s Data Privacy Act (CTDPA), and the Utah Consumer Privacy Act (UCPA) and/or any applicable local implementation as amended from time to time.

• Personal Data means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable Data Protection Laws.  User: Any individual or legal entity that has access and is using our Websites or Services.

Minimum User Age

Our services are intended for individuals aged 18 or older. If you are under 18, you may use our website only with the involvement of a parent or guardian and should not provide us with any personal data without explicit parental consent. If we discover that we have collected data from an individual under the age of 18 without appropriate consent, we will take immediate steps to delete such data.

Controller/Processor Position

We act as the Data Controller for data collected directly through our Websites for service provision.

User Information & Data Submission

You provide personal data when you:

• Complete forms on our Platform, correspond with us via email, phone, or otherwise.

• Register for services or create an account on the Platform.

• Report an issue with our services.

• Respond to surveys or submit feedback.

You must have explicit permission to share the personal data of any third party. By providing such information, you confirm that you have obtained their consent for its use in accordance with this Privacy Policy.

Information We Collect about you

• When we collect Personal Data for the purposes of creating a User account with us or engaging with the services in our Platform, we act as a Data Controller of the Personal Data and will determine how this data will be used to best provide Services to the User. We comply with all applicable requirements of the Data Protection Laws.

We collect the following types of information:

• Identity and Contact Data: Names, addresses, email addresses, phone numbers, and user preferences in relation to respective consents when interacting with our Services.

• Financial and Transaction Data: Details of products and services you have purchased from us. On a rare occasion, when you have provided us with this data, we may be able to process your bank account information.

• Technical Data: IP addresses, browser types, Country location,  operating system and browser type, for system administration and analytical purposes.

• Educational Level

• Usage Data: Information about how you use our website, products, and services.

• Any other Personal Data, including conversational data, voluntarily provided by the User through the use of the Platform including, but not limited to any mentoring or live support session provided.

How we use your information and justification of use

• Consent. Where you have consented to the use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstances outlined below by notifying us).

• Contract Performance. Where your information is necessary to enter into or perform a contract with you.

• Legal Obligation. When processing is required by law.

•Legitimate Interest. Where processing is necessary to achieve our legitimate interest and reasons for using it outweigh any prejudice to your data protection rights, and

• Legal claims. Where information is necessary to defend, prosecute or make a claim against you or a third party.

Information shared with other sources

When using our Platform, we may collect certain information about you in order to enable your use of the Platform from the following resources:

• Service Providers. For example, we may use analytics Service Providers to analyse how you interact and engage with the Platform, or third parties may help us provide you with customer support. Our product is built and served from recognised cloud service providers as detailed on our sub-processors page.

• Social networks connected to the Services. If you provide your social network account credentials to us or otherwise sign in to the Platform through a third party site or service, you understand some content and/or information in those accounts may be transmitted into your account with us.

In respect of the use of the Platform, SRL uses information held about you (and information about others that you have provided us with) in the following ways:

Types of Information Collected
Use Justification
Lawful Basis
First name, surname, email, phone number
To provide you with access to our Platform and any other information which you request from us and to notify you of changes to our Platform.

To send automated product communications to support the operation and your use of the Platform.

To send automated product re-engagement communications for marketing purposes.

To send automated product re-engagement communications for marketing purposes.
Contract performance



Contract performance



Legitimate interest



Legitimate interest
Education Level
To provide respective relevant Services, when using our Platform.
Legitimate interest
Financial and Transactional Data
To ensure that a payment is administered for the delivery of our Services; usage for auditing purposes, when needed.
Contract performance
Information we collect about you, including Technical data (as detailed above)
To administer and improve the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes in a pseudonymised manner. To conduct and facilitate user experience research, including to gauge feedback on new products and features in early stages of development, to determine whether those new products and features would be of sufficient value to users. To ensure the content on our Platform is presented in the most effective manner for you and your computer or mobile device.
Legitimate interest (to improve the Platform and report internally on usage and gain insight on user basis at a statistical level)
Conversation history and other information submitted when interacting with Users (as applicable).
To allow seamless interaction within the Platform and ensure respective support is provided to the Users.
Legitimate interest

Where we store your personal information

Your personal data is securely maintained, processed, and stored by us and our authorized Service Providers in the United Kingdom, European Economic Area (EEA), United States, and the Philippines. Additionally, data may be retained in other locations where necessary to ensure the functionality and performance of our Platform or to comply with legal requirements.

We ensure that all personal data is handled in compliance with this Privacy Policy, industry best practices, and applicable legal standards, regardless of the jurisdiction in which it is processed. For data transfers outside the UK or EEA, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs), to provide adequate protection for your personal information in line with GDPR and other relevant data protection laws.

A complete list of our Service Providers is available here, and it is updated periodically. By using our Platform, you agree to the use of these Service Providers as outlined. If any significant changes are made to our Service Providers, you will be notified, and you will have the option to either continue using the Platform under the updated terms or discontinue your use if you do not agree with the changes.

Disclosure of your information

We may also disclose your personal information to third parties in the following circumstances:

Purpose of disclosure and third party(s) to which disclosure might be made
Use Justification
We may disclose your Personal Data to our Service Providers to assist us in performing any contract we enter into with them or you, including providing the Website and the services it enables, analytics providers, and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Contract performance

Legitimate interest (to allow our Service Providers to provide the necessary services)
If SRL or substantially all of its assets are acquired by a third party, personal information will be one of the transferred assets.
Contract performance

Legitimate interest (to allow our Service Providers to provide the necessary services)
If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or to protect the rights, property, or safety of Dropship Unlocked, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
Legal obligation.
We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Legal obligation.

How long we retain your Personal Data

We will hold the above information for as long as is necessary in order to provide you with the ability to use our Platform, deal with any specific issues that may arise, or otherwise as is required by law or any relevant regulatory body. 

You may delete your account at any time, following which your Personal Data will be immediately and securely deleted.

Some Personal Data may need to be retained for longer to ensure we can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing. If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.

We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.

Your Rights

Under the GDPR (EU and UK) and DPA, you have various rights in relation to your personal data. 

In the first instance you shall contact us as your Data Controller at [email protected] for any questions or queries. The Data Controller is primarily responsible for ensuring you can exercise these rights effectively.

You have the following rights in relation to your Personal Data.

Rights
Details
Right to access
You have the right to access Personal Data held by the Controller(s), including a description of your data. Personal Data processed can be found in the profile section of your SRL account, while further information is available on request.
Right to rectification/correction
You have the right to rectify any details to ensure that your personal information is accurate. In order to assist with this, you should notify the Data Controller of any changes to the personal information that you have provided by sending a request to rectify your Personal Data where you believe the Personal Data collected is inaccurate or incomplete.
Right to erasure/ ‘Right to be forgotten’
Asking the Data Controller(s) to delete all of your Personal Data will result in the deletion of your Personal Data held by that Data Controller without undue delay (unless there is a legitimate and legal reason why the Data Controller is unable to delete certain Personal Data, in which case you will be informed of this in writing).
Right to restriction of processing
You have the right to ask the Data Controller to stop processing your Personal Data at any time in certain circumstances. Such a request will result in the Data Controller restricting its processing of such data.
Right to data portability
You have the right to request that the Data Controller provides you with a copy of all of your Personal Data and to transmit your Personal Data to another Data Controller in a structured, commonly used and machine-readable format, where it is technically feasible to do so where such processing is based on consent or pursuant to contractual performance.
Right to complain
You have the right to lodge a complaint to a Supervisory Authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage you to engage with us in the event you have any concerns or complaints.

We will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests.  Where we are required to provide a copy of Personal Data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative cost. 

Requests to stop processing your Personal Data or deleting your personal data will likely mean that you are no longer interested to use our Services or at least aspects of the Platform, which require the processing of types of Personal Data you have asked us to delete, which may result in you no longer being able to use the Platform. 

Where you exercise any of your rights above, the Data Controller may notify third parties to whom such personal Data has been disclosed for such request. However, such third parties may have the right to retain and continue to process such Personal Data on its own right.

State of California, USA - Resident Rights

If you are a resident of the State of California, USA, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at  [email protected].

For the purposes of this section solely, Business would mean SRL ECOM LTD.

Rights
Details
Right to access
You have the right to access Personal Data held by the Business, including a description of your data. Essential Personal Data held by the Business can be found in the profile section of your Dropship Unlocked account, while further information is available on request. The categories of sources from which Personal Data was collected. The business or commercial purpose for collecting your Personal Data. The categories of third parties with whom we have shared your Personal Data. The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.
Right to correct inaccurate information
You have the right to rectify any details to ensure that your personal information is accurate. In order to assist with this, you should notify the Business of any changes to the personal information that you have provided by sending a request to rectify your Personal Data where you believe the Personal Data collected is inaccurate or incomplete.
Right of deletion
Asking the Business to delete all of your Personal Data will result in the deletion of Personal Data held by that Business without undue delay (unless your Personal Data is required to provide you with the Platform or complete a transaction or other action you have requested). If your deletion request is subject to one of these exceptions, your deletion request may be denied, in which case you will be informed of this in writing.
Right to know what data is being sold or shared and to whom
We do not sell personal information to any third parties.
Right to Opt-out of Sale and data sharing
You have the right to request that the Business does not sell or share your Personal Data to third parties.
Right to Opt-out of automated decision making
We do not utilise automated decision making
Right to limit disclosure and use of sensitive information
You have the right, at any time, to direct the Business that collects sensitive personal information about you to limit its use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services.
Right of no retaliation
We will not discriminate against you for exercising your rights. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA and CPRA.

Subject Access Request Process/Valid Request

To exercise the rights described above, you must send us a Subject Access Request/Valid Request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

“Authorised Agents”: you may submit a request to know or a request to delete your Personal Information through an Authorised Agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of residency with us. If you have submitted a request via Authorised Agents and have followed the prescriptions above, we shall count these requests as Valid Requests.


We will work to respond to your Valid Request within a 30-day period of receipt for all Valid requests under the GDPR and DPA and 45 days of receipt under CPPA/CPRA. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.


You may submit a Valid Request by sending an email to [email protected] Or by post to: SRL ECOM LTD, 124 City Road, London, EC1V2NX.

Third party websites

Our Website may, from time to time, contain links to third party websites. If you follow a link to any of those third party websites, please note that they have their own Privacy Policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

Cookies and Tracking Technologies

We are our third-party partners, such as our analytics partners, use cookies and other tracking technologies to provide functionality and to recognise you across different Services and devices. For more information, please refer to our comprehensive Cookie Policy, which outlines how we use cookies and similar technologies to enhance user experience and analyse site usage.

Changes and Contact Information

This Privacy Policy may be updated to reflect changes in our practices or regulatory changes. Users are encouraged to review it periodically. When we make significant changes, we will make such changes clear on this page, or by some other means of contact such as email or notification via the Platform. Your continued use of the Platform and the Website shall be deemed as your acceptance of the varied privacy policy.

If you have any further questions or would like to exercise any of the rights set out above, please contact us at: [email protected] or postal address: SRL ECOM LTD, 124 City Road, London, EC1V2NX. 

We always welcome your comments or suggestions, including thoughts on how we can improve or clarify this privacy policy.

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