Last Updated: 13th December 2013
We may update this policy from time to time. Please check this page regularly for notification of any significant changes in the way we treat your personal information. We will try to provide Consumers with reasonable advance notice of any proposed changes.
Where the words "SmartTrade App", "we", "us" or "our" are used in this document, they are all references to SmartTrade App Limited.
Your privacy is very important to us. We have put in place measures to ensure that any personal information or data that we obtain from you is processed in accordance with the accepted principles of good information handling.
We deal with individuals who pay using SmartTrade App in a way which is not related to their trade, business or profession ("Consumers"). We also deal with those who are using SmartTrade App in relation to their business, such as suppliers wanting to enable Consumers to pay SmartTrade App by direct debit ("Business Customers"). Our responsibilities to you depend on whether you are a Consumer or a Business Customer. Some Business Customers are parties to agreements with us which may change some of their rights.
This policy gives you information about how we treat personal information received from our website visitors and customers.
What is personal information?
Personal information is defined as information that may be used to identify a living individual, such as their title, name, address, email address and phone number.
Information collection and use
We collect visitor information in the following ways:
If you apply to use SmartTrade App as a Consumer or Business Customer we will use your details to facilitate your application and future transactions
Where you are using the system to make payments, we may share your information with the party you wish to receive funds, and any partner organization which is facilitating the transaction.
Where you are using the system to receive payments, we may share your information with each person wishing to make payments to you, and any partner organizations which are facilitating transactions.
Where you are a partner organization using the system to make it easier for other parties to use, we may share information about you to those making and receiving payments through the system.
If you call us or send us an enquiry or details via email or another method, we will use your details to respond to any request/comment you have. We may also keep these details for the purpose of evaluating and assessing applications, performing contracts and technical administration.
When you visit our website, we may automatically collect certain system-related information about your visit, and we also use "cookies" to provide you with access to certain private areas of the website. See the "Cookies" section below for further information.
Telephone calls may be recorded for security and regulatory purposes and may be monitored under our quality control procedures.
Where you are applying to use the SmartTrade App system, we may also contact credit or identity reference agencies with information you provide to enable us to confirm your identity.
If you send us your CV we may want to keep your details on file in case an opportunity comes up in the future. If you’d rather we didn’t do this, please let us know as soon as possible by emailing firstname.lastname@example.org and we will delete your record as soon as we are able.
The only time we will use your details for any other purpose than those listed above is to provide you with details from time to time about our services. However we will only do this if either (i) you have given us permission to do so, or (ii) you are one of our customers and we are telling you about similar products and services to the ones you have previously purchased or asked us about. In each case you can contact us to opt out of any further marketing communications.
We may pass your personal information to our subcontractors to enable them to provide services for us but for no other purpose. We respect your privacy and will not rent, sell or share personal information about you with other people or non-affiliated companies without your express permission.
Information collection and use
You have the right to request a copy of the personal information we hold about you, its origin and any recipients of it as well as the purpose of any data processing carried out. Please note that, in accordance with the Data Protection Act 1998, a £10 admin fee is applicable. For further information, please contact us by emailing email@example.com with the subject "Data subject access request".
In accordance with the Data Protection Act 1998, you have the right to correct, restrict our use of or ask us to delete your personal information. Use the details on the "Contact Us" to ask any questions or request the correction, restriction or deletion of your personal information.
The first is to collect system-related information, such as the type of internet browser and operating system you use, the website from which you have come to our website, the duration of individual page views, paths taken by visitors through the website, and other general information and your IP address (the unique address which identifies your computer on the internet) which is automatically recognised by our web server. This information is collected for system administration and to report aggregate information to our subcontractors and partners to enable them to provide services to us. It is statistical data about our users' browsing actions and does not, of itself, contain any personally identifiable information. It is often not possible to identify a specific individual from this information, although for example we may be able to identify it relates to a specific individual in conjunction with other information in our control.
The second is that Cookies are also used when registered users access the private sections of our website. Cookies are used to facilitate the log in process. In this case, we may be able to identify that your login details have been used
Most web browsers offer users controls, to give you the option to delete or disable cookies. You can usually find out how to do so by referring to the ‘Help’ option on the menu bar of your browser, or by visiting the browser developer's website. This will usually tell you how to prevent your browser from accepting new cookies; notify you when you receive new cookies; and disable cookies altogether. Please note that disabling cookies will stop you accessing private areas of the website.
This website uses Google Analytics, a web analytics service provided by Google Inc. ( "Google"). Google Analytics uses. "Cookies", text files that are stored on your computer, to help analyze how users use the website. The information generated by the cookie about your use of this website (including your IP address) is transmitted to a Google server in the USA and stored there.
Google conversion tracking and Google Re-marketing
Google conversion tracking is an analysis service of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043; "Google") to measure the success of our running on Google advertising (AdWords). It set a cookie on your computer when you access our website via a Google ad on Google. These cookies are not used to personally identify you. Using Google conversion tracking and Google, we can see that someone has clicked on our Google ads and has been forwarded to our site. We can not see what other websites you have visited. The information collected by Google conversion tracking are used to compile statistics on success and use of our AdWords campaigns. We do not obtain information that can identify a user personally.
We use our website as well the re-marketing technologies from Google.
Disclosure of your information
We may share your personal information with any 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.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site. This may include the use of Google Analytics; more data on how Google uses data obtained through Google Analytics can be found at this link to the Google website: https://www.google.com/policies/privacy/partners/.
- We may disclose your personal information to third parties:
- If we conclude that is is required by law or in good faith believe that access, preservation or disclosure of the data is reasonably necessary to protect the rights, property, or safety of the SmartTrade App Ltd or any member of its group, its users or the public
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If SmartTrade App Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
In all such circumstances we will use reasonable efforts to ensure that the minimum possible personal information is shared and the parties with which the data is shared are subject to an agreement that obliges them to process your personal information on our instruction and with appropriate confidentiality and security measures.