Privacy Policy

Last updated: 28/06/2021

The Smart Fund (“us”, “we”, or “our”) operates https://thesmartfund.co.uk (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.

We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

Information Collection

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes your first name, maiden name, last name, username or similar identifier, title, date of birth and gender.

Contact Data includes email address and telephone numbers.

Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].

Usage Data includes information about how you use our website, products and services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site.
• Third parties or publicly available sources. We may also receive personal data about you from various third parties and public sources such as analytics providers.

How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we send you newsletters, marketing and other promotional material to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who Your Information Might Be Shared With

As far as is reasonably necessary, we may disclose your personal data to our suppliers where it is necessary for the provision of marketing services and you have opted-in to receiving such communications from the Smart Fund.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Transfers of your information out of the UK

We may need to transfer your personal data to countries that are located outside the United Kingdom (“UK”) for the purposes of processing by parties that work for the Smart Fund or one of its suppliers. By way of example, this may happen if any of the computer services used to host our website are located in a country outside of the UK.

We may transfer your data to the USA to organisations such as Mailchimp for content delivery services; Microsoft Corporation and Salesforce for customer relationship management services; Twitter, Facebook, Google and SurveyMonkey for communication and marketing services in accordance with your preferences.

We will take all steps reasonably necessary to ensure your personal data is treated securely and in accordance with this privacy policy, these steps may include entering into processing agreements with these parties or ensuring the parties receiving your data are certified under an approved certification mechanism such as the Privacy Shield framework (details of which can found at www.privacyshield.gov).

Please contact us if you want any further information on transfers of your personal data out of the UK.

Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Unfortunately, the transmission of information over the internet is not completely secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Retention of Your Data

We will not retain your personal data for longer than is necessary in relation to the purposes for which the data was collected or otherwise processed. The criteria we use for determining the retention periods for your personal data will be any regulatory requirements, statutory retention periods or guidance provided by regulatory bodies such as the Information Commissioners Office.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can read more about these rights on the ICO’s website.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at info@thesmartfund.co.uk.

Changes To This Privacy Policy

This Privacy Policy is effective as of 28/06/2021 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.

We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

Contact Us

If you have any questions about this Privacy Policy, please contact us at info@thesmartfund.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.