Privacy Policy

Privacy Policy

Purpose

At E-Smart Money we take all necessary measures to protect your privacy and are committed to safeguarding your information.

This Privacy Policy explains in detail the use we make of any information you provide to us as well as the information we may obtain during our business relationship.

1. Information We collect

You will provide us with information about yourself when filling in forms on our “Website” or “App” (i.e. during profile creation or whilst initiating a “Transfer” or when reporting a problem to us).

Information you provide us may include:  

• Name, Date of Birth and Home Address
• Mobile Number, Email Address
• Occupation, Purpose of Payment/Transfer
• Financial Information including Source of Funds
• Geographical location
• Proofs of Identification and Address

2. How E-Smart Money uses the Information gathered

E-Smart Money uses the information given by you, mainly, to provide you with the services you require and to also provide you with details about our products and services.

But “we” (or agents and sub-contractors acting on our behalf, or third–party data processors) may also use the information to:

• Enforce E-Smart Money’s rights under our Terms & Conditions if necessary
• Maintain the safety and security of our “Website”, and “App”
• Communicate with you and to improve our products & services
• Help us perform our services, and to assess the risks of carrying out the service
• Data analysis, research, statistical, and survey purposes
• Administer the “Website” and “App, and to Help with internal operations
• Measure & understand the effectiveness of our advertising efforts
• Promotional purposes

3. How E-Smart Money stores your Personal Data

Any information you provide to us is stored on our secure servers. We are committed to ensure that your information is kept secure. To prevent unauthorized access or disclosure, E-Smart Money has put in place the appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Unfortunately, the transmission of information over the internet is not completely secure. We cannot guarantee the security of your data transmitted to our “Website” or “App”; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our “Website” or “App”, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Transfers/payment transactions are all encrypted [using SSL technology].

We will only retain your information for as long as it is necessary for providing our service to you, usually no more than 5 years after the end of the business relationship.

4. Your Rights under GDPR

General Data Protection Regulation - The Data Protection Act 2018

• Right to access - you have the right to request access to your personal data and to ask how your data is being used after it has been gathered. E-Smart Money will provide a copy of the personal data, in electronic format if requested -free of charge.
• Right to be forgotten - if no longer customers, or if you withdraw your consent from us to use your personal data, then you have the right to have your data deleted. We will not use your data in further processing.
• Right to data portability - you have a right to transfer your data from one service provider to another.
• Right to be informed - You must get informed before we collect any data from you. You have to opt-in for your data to be gathered, and consent must be freely given rather than implied.
• Right to have the information corrected - you can have your data updated if it is out of date or incomplete or incorrect. We will update the information as informed.
• Right to restrict processing - you can request your data is not used for processing. Your record can remain in place, but not be used.
• Right to object - to stop the processing of your data for direct marketing. Any processing must stop as soon as the request is received. This is made clear to you at the very start of any communication.
• Right to be notified – If there has been a data breach that compromises your personal data, we will inform you within 72 hours of becoming aware of the breach.

You can exercise your right at any time by contacting us at info@e-smartmoney.co.uk

5. Safeguarding and Security

As a result of the increasing cybersecurity threat to organizations. We promote the encryption of data, constant assurance of confidentiality, integrity, availability, and resilience of processing systems and services to comply with GDPR. To do so, E-Smart Money takes both technical and organizational measures to acquire the level of security appropriate to deal with the risks involved.

6. Prompt notification

In the case of an accident or breach, the GDPR stipulates mandatory security breach notification. To reduce identified risks and to prevent data breaches, under GDPR, administrative and technical safeguards for personal data are also required. The owner of the data is required to be notified without undue delay if the breach poses a high risk to their rights and freedoms.

The GDPR states that notification of a personal data breach to a supervisory authority must occur not later than 72 hours after becoming aware of it. In addition, the company has an incidence response plan and trained its employee on how to respond.

Not all personal data breaches need to be notified to a supervisory authority. The notification obligations under the GDPR are only triggered when there is a breach of personal data which is likely to result in a risk to the rights and freedoms of individuals. The GDPR recitals explain that such a risk exists when the breach may lead to physical, material or non-material damage for data subjects such as: discrimination; identity theft or fraud; financial loss; or damage to reputation.

7. Cross-border data transfer

As a money remittance company, our operations involve the transfer of personal data of employees and clients across jurisdictions to manage our global workforce and facilitate operations, as our processing is outsourced too. We export personal data from the territory of the EU and UK to other companies within our group located in third countries.

The GDPR imposes restrictions on the transfer of personal data outside the European Union, to third-party countries or international organisations, to ensure that the level of protection of individuals afforded by the GDPR is not undermined. (As with much of the GDPR, this strengthens and codifies the UK’s existing Data Protection legislation). The GDPR limits an organisation’s ability to transfer personal data outside the EU where this is based only on that body’s assessment of the adequacy of the protection afforded to the personal data. Ideally, transfers may be made where the European authorities have decided that a third country, a territory in that third country or an international organisation ensures adequate safeguards for the protection of data.

For countries where the European Commission has made no ruling that there are adequate safeguards, personal data may still be transferred to those countries under certain specific circumstances. These include where the transfer is not being made by a public authority in the exercise of its public powers, involves data related to only a limited number of individuals, or is necessary for compelling legitimate interests of the organisation.

      Summary

      Complying with GDPR, E-Smart Money:

• Ensure consent is freely given and data subjects must “opt-in” rather than “opt-out” of data collection schemes. We will utilize personal data strictly for the purpose of collection and retain only, as long as needed.
• Use strong encryption, to ensure the security of personal data at rest and in transit.
• Developed a data security breach response scheme and comprehensive incidence response plan. We train our employees on how to identify a breach in real-time and spot a potential threat. The notification and report should be prompt.
• Review and regularly update our privacy policy, and other documentation and communications. This will ensure any new type of risk is managed accordingly, as well as any information provided in our privacy policy will always be easy to understand.
• Conduct privacy and data security audit. Carefully evaluating the existing subjects’ data and processing activities and detect potential inconsistency with the GDPR.
• Regularly run compliance test before implementing a new technology.
• Ensure Cross-border data transfer policy complies with the GDPR by our binding corporate rules.

 Persons under the age of 18

We ask that persons under the age of 18 (which we treat as children and minors) refrain from using our Service or submitting any personal information to us. Persons under the age of 18 years are not eligible to use our Service and if we discover that someone under the age of 18 has registered a Profile with us, we will close it.

If you have any questions about our Privacy Policy or your information please contact us by calling on 0044(0)2087460197 or via email at info@e-smartmoney.co.uk.