Smartr365 Privacy Policy for End Users
Smartr365 Finance Limited is committed to safeguarding your privacy and ensuring the security of your personal information. This Privacy Policy outlines our practices as a Data Processor, regarding the collection, use, and sharing of personal data for end customers on behalf of our clients (brokers/intermediaries/introducers). We have a separate Privacy Policy for professional business clients, which can be found here.
WHAT DOES THIS POLICY COVER?
This Privacy Policy relates to end clients whose broker/intermediary/introducer uses the Company platform to capture, store, and process personal information. It also outlines how we comply with data protection obligations when processing personal data on behalf of our clients as a Data Processor. Please take a few minutes to read it and show it to anyone else connected to the product/service we provide.
WHAT IS PERSONAL INFORMATION?
When we refer to personal information, we mean information about an individual that can identify them, such as their name, address, email address, telephone number, and other contact or financial details. Any reference to “information” or “data” in this Privacy Policy is a reference to personal information about a living individual.
We may collect and process certain personal information and data about you to provide our products and services effectively. The information we collect may include but is not limited to:
| Type of data | Description | Examples of how we use it |
|---|---|---|
| Contact Details | Address and Location | |
| Proof of Address | Servicing your product | |
| Marketing | ||
| Analysis & profiling | ||
| Enhancing our product and service offering | ||
| Product development and pricing | ||
| Identity and Biometric Data | Names and Previous Names | |
| Date of Birth | ||
| Visual Images & Personal Appearance | ||
| Usernames or Unique ID | ||
| Facial Recognition Data | ||
| Proof of ID (Passport / Driver's License) | ||
| National Insurance Number | Marketing | |
| Social and Demographic Data | Title | |
| Age | ||
| Gender | ||
| Nationality | ||
| Marital Status | Marketing |
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. In some cases, we may also process information obtained from publicly available sources (such as company registries or government databases) or from licensed third-party data providers, where lawful and appropriate.
HOW DO WE USE YOUR INFORMATION?
We use personal information that we hold about you:
- To provide you with marketing information about services and products we offer that may be of interest to you.
- To inform you about changes to our services and products.
- To comply with any applicable legal or regulatory requirements.
- For conducting market research, statistical analysis, and customer profiling to help us improve our processes, products, and services.
- To define our pricing and product/service development strategies.
- To operate our business efficiently and appropriately.
USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAWS
Compliance with applicable laws:
We may process your personal information to comply with any legal obligation we are subject to.
Legitimate interests:
To use your personal data for any other purpose described in this Privacy Policy, we will rely on a condition known as "legitimate interests".
Consent:
We may process your personal information for different purposes where you have provided your consent to do so.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We will retain your personal information in accordance with our internal retention policies. The length of time we retain it will be determined by the minimum retention periods required by law or regulation.
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We will only disclose your information to:
- Other third-party suppliers, contractors and service providers.
- Selected third parties, where you have expressly opted-in or consented to the disclosure of your personal data for specific purposes.
- Our regulators, government, and law enforcement agencies as required.
DATA SECURITY
We take data security seriously and employ reasonable measures to protect personal information from unauthorized access, disclosure, alteration, or destruction.
LINKS TO OTHER SITES
Our Service may contain links to other sites that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
TRANSFERRING YOUR DATA OUTSIDE THE EU
The data that we collect from you may be transferred to third-party suppliers outside the United Kingdom or European Economic Area (“EEA”). We will take all reasonably necessary steps to make sure that your data is treated securely.
YOUR RIGHTS
You have rights under data protection law that relate to how your personal data is collected and processed. More information on these rights is available on the Information Commissioner’s Office (ICO) website.
- The right to be informed about how your personal data is being collected and processed.
- The right to access the personal data that we hold about you.
- The right to make us correct any inaccurate personal data we hold about you.
- The right to make us erase any personal data we hold about you.
- The right to restrict our processing of the personal data we hold about you.
- The right to receive personal data you have provided to us in a structured, commonly used and machine-readable format.
- The right to object to our processing of your personal data we hold about you.
- The right to withdraw your consent.
- The right to lodge a complaint with a supervisory authority if you believe your rights have been violated.
CONTACTS AND COMPLAINTS
Smartr365 Finance Limited complies with applicable data protection laws in the United Kingdom. For any data protection inquiries, please contact us at dataprotection@smartr365.com.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons.