Smartr365 Finance Ltd Policy for End Clients
Smartr365 Finance Ltd fully respects your right to privacy. We want you to understand the terms and conditions surrounding the capture, use and processing of any information we process on behalf of brokers about end clients.
This policy tells you how we process your personal information as a data processor on behalf of your broker / intermediary / introducer (data controller). Please take a few minutes to read it, and show it to anyone else connected to the product/service we provide.
What does this policy cover?
What is personal information?
When we talk about personal information we mean information about an individual that can identify them, like their name, address, e-mail address, telephone number and financial details. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.
What information do we hold?
We may collect and process the following personal information about you:
|Type of data||Description||Examples of how we use it|
|Contact||Who you are
Where you live
How to contact you
|Servicing your product
Analysis & profiling
Enhancing our product and service offering
Product development and pricing
Visual images & personal appearance
Lifestyle and social circumstances
Analysis & profiling
Product development and pricing
|Transactional||Bank and/or card details
How you use your product
Changes you make to your product or account
|Servicing your product
Making sure our products and services are fit for purpose
|Contractual||Your creditworthiness||Product development and pricing
Making sure the product is right for you
|Consent & preferences|| Ways you want us to market to you
|Technical||Details on the devices and technology you use
|Making sure our products and services are fit for purpose|
|Open data & public records||Electoral register
Other information about you that is openly available on the internet
|Documentary data & national identifiers||Details about you that are stored in documents like:
National Insurance number
|Prevent financial crime|
Where do we get our information from?
Information we process about you is either entered into the Smartr365 platform by a broker, intermediary or introducer or directly by you following an initial consultation with your broker / intermediary / introducer. To understand where your broker, intermediary or introducer sourced your information, you would need to speak to them directly.
How do we use your information?
We use personal information that we hold about you:
- To carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with the information, products and services that you’ve asked from us.
- To provide you with marketing information about services and products we offer which may be of interest to you. If you have opted in to receive marketing from us, based on your marketing preferences, we may deliver this information by post, telephone, e-mail, SMS or personalised online marketing via our own platform, social media platforms and/or other third party websites e.g. YouTube. Please note that if you choose not to receive online marketing, you will not see personalised messages using your personal data, however you may still see generic online advertising about our products and services. We will not sell your data to third parties for them to market to you. We may also send marketing to you using our “legitimate interests”, please see below for further information.
- To tell you about changes to our services and products.
- To comply with any applicable legal or regulatory requirements (including “know your customer” checks, or to comply with any applicable regulatory reporting or disclosure requirements).
- For carrying out market research, statistical analysis and customer profiling to help us to improve our processes, products and services and generate new business (e.g. to understand digital behaviours, identify financial attitudes and develop more engaging communications).
- To define our pricing and product / service development strategies.
- To run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit.
- For any other purpose that we’ve agreed with you from time to time.
When you apply for a product or to receive a service from us, the application form you fill out or the resulting contract may contain additional conditions relating to the way we use and process your personal information. These will apply in addition to the uses described in this document.
In some cases, we may use software or systems to make automated decisions (including profiling) based on the personal information we have, or collect from others. These may include:
- The prevention and detection of fraud and financial crime
To perform transaction monitoring, identity verification, money laundering and sanctions checks, and to identify politically exposed individuals. We are required by law to perform these activities which may be achieved using solely automated means to make decisions about you. We may use these activities to decline the services you have requested or to stop providing existing services to you.
- Servicing activities such as (i) Personalising the content and design of communications and online services and (ii) Determining when to provide tailored communications about your product (e.g. as a result of changes in your personal circumstances or lifestyle) and the appropriate channel(s) to use
These may be achieved using profiling in order to predict certain characteristics about you (e.g. your economic situation, interests, personal preferences or transactional behaviour). The activities will not have a detrimental effect on you.
Using your information in accordance with data protection laws
Providing our contracts & services to you:
We’ll process your personal information to carry out our responsibilities resulting from any agreements you’ve entered into with us and to provide you with the information, products and services you’ve asked from us, which may include online services.
Complying with applicable laws:
We may process your personal information to comply with any legal obligation we’re subject to.
- Carry out market research and product development, which can include creating customer demographics and/or profiling.
- Continue to send marketing information, via post only, to customers who purchased a product before 25th May 2018 and did not opt-out, until such time as they have reviewed their marketing preferences (which can be done at any time).
- Send marketing information, via post only, to customers who have a relevant and appropriate relationship with us.
- Develop and test the effectiveness of marketing activities.
- Develop, test and manage our brands, products and services.
- Study and also manage how our customers use products and services from us and our business partners.
- Manage risk for us and our customers.
This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.
We may provide you with marketing information about our services or products where you’ve provided your consent for us to do so.
You may opt out of marketing at any time by e-mailing or telephoning us.
Special category (sensitive) data:
We do not currently process any special category data.
Criminal Conviction Data:
We do not currently process any criminal conviction data.
Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.
How long do we keep your information for?
We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.
Who do we share your personal information with?
We’ll only disclose your information to:
- Other companies within the Group, third-party suppliers, contractors and service providers for the purposes listed under “How do we use your information” above.
- Selected third parties, so that they can contact you with details of the services that they provide, where you have expressly opted-in or consented to the disclosure of your personal data for these purposes.
- Our regulators, government (e.g. HMRC) and law enforcement or fraud prevention agencies, as well as our professional advisers etc. Additionally, we may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we’ll 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.
- In order to enforce or apply the terms of any contract with you.
- If we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
To protect you and us from financial crime, we may be required to verify the identity of new and sometimes existing customers. This may be achieved by using reference agencies to search sources of information relating to you (an identity search). This will not affect your credit rating. If you’ve been introduced to us by another company (e.g. bank, insurer, building
We may access and use from other countries the information recorded by fraud prevention agencies.
Transferring your data outside the EU
We’ll only transfer your data to a recipient outside the EEA where we’re permitted to do so by law (for instance, (A) where the transfer is based on standard data protection clauses adopted or approved by the European Commission, (B) where the transfer is to a territory that is deemed adequate by the European Commission, or (C) where the recipient is subject to an approved certification mechanism and the personal information is subject to appropriate safeguards, etc.).
Unfortunately, sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.
You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on the Information Commissioner’s website. If you wish to exercise any of these rights, please get in touch.
|1.||The right to access the personal data that we hold about you.|
|2.||The right to make us correct any inaccurate personal data we hold about you.|
|3.||The right to make us erase any personal data we hold about you. This right will only apply where for example:
· We no longer need to use the personal data to achieve the purpose we collected it for
· You withdraw your consent if we’re using your personal data based on that consent
· Where you object to the way we use your data, and there is no overriding legitimate interest.
|4.||The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:
· You dispute the accuracy of the personal data we hold
· You would like your data erased, but we require to hold it in order to stop its processing
· You have the right to require us to erase the personal data but would prefer that our processing is restricted instead
· Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
|5.||The right to object to our processing of personal data we hold about you (including for the purposes of sending marketing materials to you).|
|6.||The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.|
|7.||The right to withdraw your consent, where we’re relying on it to use your personal data (for example, to provide you with marketing information about our services or products).|
|8.||For automated decisions (including profiling), you have right to:
· Obtain an explanation of the decision and challenge it
· Request for the decision to be reviewed by a human being.
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Contacts and complaints
If you have any concerns about the way we process your personal data, or are not happy with the way we’ve handled a request by you in relation to your rights, you also have the right to make a complaint to the Information Commissioner’s Office. Their address is:
First Contact Team
Information Commissioner’s Office
Smartr365 Finance Ltd complies with the requirements of the relevant legislation in the United Kingdom, specifically:
- The General Data Protection Regulation 2016/679 (GDPR)
- The UK data protection act 2018
- PECR (Privacy & Electronic Communications (EU Directive) Regulations 2003
Smartr365’s registered office is at 1 Queen Caroline Street, Hammersmith, W6 9YN and we are a company registered in the UK under company number 10487227. We are registered on the Information Commissioner’s Office Register and act as the data controller when processing your data, and as a processor when processing your clients’ data on your behalf. Our designated Data Protection Officer can be contacted on Dataprotectionofficer@Smartr365.com.
- By visiting this page on our website: https://www.smartr365.com/contact-us/
- By email: firstname.lastname@example.org
By mail: 1 Queen Caroline Street, London, W6 9YN