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For the purpose of the Data Protection Act 1998 (the Act), the Data Protection Act 2018, once in force, and the General Data Protection Regulation (GDPR), the data controller is Smart Money People Limited, Office 107, 154-160 Fleet Street, London, EC4A 2DQ. We are registered with the Information Commissioner's Office (Registration Number: ZA190919).
Our nominated representative for the purpose of the Act is Michael Fotis.
1. Collecting information on our websites
1. Master Data
When you write your first review on our website, or create a profile without having written a review, a personal account is created on Smart Money People, and the following personal data is collected about you:
- Your username (this is public)
- Your password (which we store in an encrypted format)
- Your email address
The above information is required to enable a personal account to be created. It is not possible to leave a review on Smart Money People without this information.
You can choose to add further personal data to your profile. The additional data you can add is your name, photo, gender, channel preference, affluence, and age range, e.g. 18-24. This additional information will be part of your public profile and will also be part of the Master Data.
Smart Money People is an open review platform which means that we display your review and connect this to the profile you create, so that other people can see who wrote the review. Therefore, depending on the information that you have chosen to add to your profile and the username you choose, you may or may not be anonymous.
1.2 Information in reviews and ratings
When you write a review about a company and post it on our Website, we collect the information you put in your review. This includes a number of items including:
- Which company you review
- Which product your review
- The headline and content of your review
- Your Customer Service rating with the company (1-5 stars)
- Your Value for Money rating with the company (1-5 stars)
- Whether you felt Fairly Treated
- The date of your review
If you notify us about a review that you believe violates our User Guidelines, we will collect the information that you provide to use in your notification. This can include which review you’ve notified us about, the reason for your notification, the date of your notification, etc.
1.4 Information from other services, including social networks like Facebook
You can connect your Smart Money People profile with your profile on social networks, e.g. Facebook (“Social Network”). When you use this option we automatically collect selected information about you from your Social Networks. The information we collect depends on what information you have made available on those Social Networks and your privacy settings for sharing such information on the Social Networks. Depending on your settings and selection, we will collect the following information:
- Name and/or username
- Email address
- Profile photo
When you make a request to connect your Smart Money People profile with a Social Network profile, you will be informed about which information we will collect from the Social Network in question. You will receive this information before your request is carried out.
Should you wish to disconnect your Social Network profile from your Smart Money People profile, you can do so by deleting your Smart Money People account.
1.6 Your IP address, browser settings and location
When you visit the Website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Website. We also use the IP address to approximate your location (at city level) and so that we know which sets of our Terms & Conditions apply to your use of our Website.
1.7 For what purposes do we use your personal information?
We will use the information you provide to us to:
- Provide our services to you, including displaying your reviews, and providing you with access to your profile and our Website
- Identify you as a registered user when you log in to the Website and re-visit the Website
- Verify the legitimacy of your reviews
- Improve the Website and our services
- Invite you to leave more reviews
- Respond to your questions and provide related customer service
- Pass on a message from the company you reviewed via the Website
- Contact you if your review is flagged by other users or companies and, if necessary, ask you to provide documentation to verify your review or customer experience
- Send you our newsletters
- Inform you when other users find your review helpful
- Engage in various internal business purposes, i.e data analysis and identifying usage trends
- Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies
- Enforce our Terms & Conditions
- Protect our rights, privacy, safety or property and/or that of our affiliates, you or others
1.8 On what legal basis do we process your personal data?
We need to process your personal information in order to:
- Perform our contract with you
- Comply with our legal obligations and operate an online review platform in compliance with, for example, the Unfair Commercial Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The Consumer Protection from Unfair Trading Regulations 2008, The Competition and Markets Authority’s guidance on online reviews and endorsements
- Pursue legitimate business interests of our own related to operating the Website and providing our services to you
- For the establishment, exercise or defence of legal claims, where necessary
Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.
In those limited circumstances where you have expressly given your consent to us to process your personal data for example, when subscribing to our newsletters, you are free to revoke your consent at any time. You have the right to object to how we process your personal information, or ask us to restrict the processing.
1.9 Emails from Smart Money People
If you have opted-in to receive emails from Smart Money People you may receive transactional emails – for example, should a company respond to your review, you’ll be notified of this. You may also receive campaign emails. You can unsubscribe from our emails at any time.
2. Disclosure Of Personal Information
2.1 Disclosure of personal information on the Website
We are an open review website which means that your review on our Website is shared so that other consumers can read about your experience with a specific company and product. When you write a review, we will disclose your review, your username and other information you have chosen to connect with your profile. Remember that if you have selected to use your name as your username, this could reveal your identity in full or in part. You may choose to use a pseudonym.
We recommend that you exercise care in deciding which information to make available for disclosing on the Website, and be aware that depending on the level of information provided.
Master Data & other information
When you write a review on our Website and create an Account, your username, review, photo, and the number of reviews you have written will be visible on the Website. As such the companies you review can also view this information.
If you connect to a Social Network, information such as your profile photo and your name will be collected from your Social Network profile and used to identify you on the Website. Subject to your privacy settings and the level of information available from the Social Network, users of the Website can use this information to identify which reviews you have written.
If you have chosen to preserve anonymity by using a pseudonym for your Smart Money People username, be aware that information from Social Network(s) can reveal your identity in part or in full and make it possible to identify which reviews you have written.
2.2 Disclosure on services to which you connect your account
2.3 Disclosure to other services, websites and companies
We permit selected services to show reviews created on the Website. This increases the potential audience for your reviews. The categories of third party services and companies who can show your review(s) together with your public user profile are:
- Search engines, including Google
- Companies reviewed on Smart Money People
- Consumer portals and business portals, including price comparison websites
- Twitter or Facebook “If your review has been shared on the Social Network”
Once you submit your review, it is published on the Website. This means that the following information is disclosed:
- Your review(s), (see 1.2, above)
- Your username and the additional data you choose to add to your profile, such as your photo
If you write a review on Smart Money People in response to an invitation sent by a company via our review invitation services, the company who sent you the invite will be able to link your review with the invitation.
One of our main goals is to make Smart Money People a trusted home for your reviews. Therefore at times, we may ask you to verify your review. To enable this we may contact you to ask for documentation that shows you’ve had a Customer Experience with the company you’ve reviewed. We will not share the documentation you send to us with the reviewed company.
2.4 Other disclosures
In addition to the above, we disclose your personal information to the following parties and in the following circumstances:
- To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public bodies, regulatory bodies and government authorities
- To third parties in connection with enforcement of our Terms & Conditions
- To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Website
3. Data Controller
3.1 Information for which we are the data controller
Smart Money People shall be the data controller of the Master Data that you choose to submit in connection with the creationion of a profile or registration for emails, i.e. your name, your password and your email address, as well as registration of your IP address.
3.2 Information for which you are the data controller
You shall be data controller of the content you choose to disclose on the Website and for the data disclosed on your profile on Social Networks, which is the consequence of the connection of your profile on the Website with your profile on the Social Network.
4. Links to Other Websites
The Website contains links to other websites. Note that by clicking such links you will be transferred to other websites for which Smart Money People is not the data controller. We thus recommend that you always read the personal data policy of these websites, as their procedure for collecting and processing personal data may be different from ours.
5. Data Processors & Transfer Of Personal Information Outside The EU
We use MailChimp email software to communicate to design and distribute emails to you if you have opted in to receive these communications. Some of this data processing is performed outside of the European Union, such as in the US. You consent to us using data processors in non-EU countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.
6. Data retention
We keep the Master Data and other personal data you provide, including your reviews, for as long as you have an Account or as needed to provide you with our services. If you choose to delete your Account please note that all your reviews will also be deleted. We will delete this information upon your request and we will only save a log with the following information: your name, email address and the date of the deletion of your Account. We will keep the log for 1 year. All other information will be deleted.
If you only use our Website for searching for reviewed companies, but have created an Account, your Account will remain open until you decide to close your Account.
7. Security Measures
Smart Money People has a responsibility to ensure that the recorded data, including the personal information, is handled carefully and protected properly following the currently applicable safety standards. However, the internet is not a 100% secure environment, Smart Money People cannot ensure or warrant the security of information you transmit to Smart Money People. Emails sent via the Website are not encrypted, and Smart Money People therefore advises you not to communicate any confidential information through these means.
8.1 What types of Cookies do we use?
Cookies are small information units which the Website places on your computer's hard disk, on your tablet or on your smartphone. Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. The cookie does not identify you as an individual user but identifies your computer.
There are two types of cookies - session cookies and persistent cookies. Session cookies are temporary bits of information which are deleted when you exit your web browser. Persistent cookies are more permanent bits of information that are stored and remain on your computer until they are deleted. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website. We use session cookies and persistent cookies.
Measuring Website traffic such as the number of visits to the Website, which domains the visitors come from, which pages they visit on the Website and in which overall geographical areas the visitors are located.
Authentication and improving the functionality of our Website
Optimizing your experience with the Website, which includes remembering your username and password when you return to the Website, and remembering information about your browser and preferences (e.g. which language you prefer).
Connecting you to Social Networks
We give you the option of connecting with Social Networks, such as Facebook.
Ensuring the quality of reviews and to prevent misuse or irregularities in connection with writing reviews and using the Website.
8.3 Third party Cookies
Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third party Cookies may be set:
- Facebook cookies: should you choose to log in to our Website with Facebook
- Google Analytics: for statistical purposes. You can decline cookies from Google Analytics by clicking on this link: http://tools.google.com/dlpage/gaoptout
- Google AdSense cookies, set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google
8.4 Deletion of cookies
If you want to delete the cookies already on your equipment, you can, if you use a PC or a more recent browser, press CTRL + SHIFT + DELETE simultaneously. If the shortcuts do not work on your browser, please visit the support page for the browser in question.
Please note that our Website will not work in its full extend if you delete the cookies.
9. Correction & Deletion Of Your Personal Data
If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you can correct most of the information yourself via your Account. You may also ask Smart Money People to assist with this.
You may at any time correct or delete any content and personal information on the Website for which you are the data controller. If your personal information changes, or if you no longer wish to appear on the Website, you can update or delete the information by logging in to your Account.
If your Account is deleted, all the data associated with your Account will be deleted, including your Master Data and reviews on the Website.
10. Other Rights
In addition to the rights set out above concerning your personal data, you also have the following rights:
- You have the right to object to the processing of your personal data and have the processing of your personal data restricted, including for the purposes of direct marketing
- You have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at firstname.lastname@example.org
We reserve the right to make updates to this Policy. The date shown at the start of this Policy indicates when it was last revised. Smart Money People may at any time make changes to this policy. Should any material changes be made, we will provide notice through our Website, or by other means, to enable you to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our Website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy.
12. How To Access The Personal Data We Hold About You
If you have an Account on Smart Money People, you can log in to your Account and see what information we have about you, including your reviews. You can sign-in here: https://smartmoneypeople.com/sign-in
Address: Smart Money People Limited, Office 107, 154-160 Fleet Street, London, EC4A 2DQ