Privacy Policy

About us

We are Smarter Payments Limited, registered in England and Wales with Company number 12855928 and with the registered address of Spaces, 9 Greyfriars Road, Reading, Bekrshire, England, RG1 1NU (Smarter Payments).

We are registered with the Information Commissioner’s Office (ICO), the data protection regulator in the UK, to use personal data and our registration number is ZB008737.

We are committed to protecting and respecting your privacy.

When you visit our website, or use any of our services; or provide information to us via our website, or any of our services, you are accepting and consenting to our processing of your information in accordance with this Privacy Policy, our Cookie Policy, our Website Terms & Conditions and any other contract we may have with you.

Contact us

It is important that the personal data we hold about you is accurate and current. Please keep us informed if this information changes during your relationship with us. You can get in touch with us at sales.support@smarterpayments.co.uk.

Please contact us at sales.support@smarterpayments.co.uk if you have any questions about this Privacy Policy or how we handle privacy.

You have the right to make a complaint to the ICO (www.ico.org.uk). However we would be happy to hear about any complaints you have at sales.support@smarterpayments.co.uk

Information we hold about you

Under data protection laws, because we decide how, why, and by what means personal data is to be processed we are known as the data controller of your personal data. This Privacy Policy relates only to our activities as a data controller.

Personal data means any information about you that could be used to help identify you. In this Privacy Policy we use personal data and information interchangeably.

This includes personal and financial information about you that we collect, use, share and store. This may include your name, date of birth, address, contact information, financial information, details about your health and lifestyle, business details and device identifiers including internet protocol (IP) address. It may include information about any other services we may provide (or provided by our partners) you currently have, you’ve applied for or you’ve had in the past.

Processing of this information occurs whenever any action is taken in relation to it, regardless of whether the action is automated or not.

Information we collect

We collect, use, share and store information about you to provide you with the services you have asked us for and to share information with you about services that may be of interest to you. We use a variety of channels to do so, including via our team of self-employed [Business Development Managers].

You may provide this information direct to us, for example by the way you communicate or do business with us, such as:

• applying for our products or services;
• using our telephone services or websites;
• writing to us;
• using our websites or digital services, in which case we may gather information about how you access and use these services, such as your IP address and information about the devices or software you use;
• using and managing your accounts; and
• giving information to us at any other time, including through social media and email marketing.

This information may also come from other organisations or people, such as organisations you have a relationship with, joint account holders, credit reference agencies, employers, debt collection agencies and/or fraud prevention agencies.

We require this information to carry out all our obligations under our contractual agreements with you. If you do not provide the required, this may mean that we are unable to properly provide our products and services to you.

If you are a merchant or a corporate, we will need to confirm your identity as part of our business process and we may ask you to provide personal and corporate documents. We may collect information about you from third parties for the purpose of identification and verification only.

Please see below for examples of the types of information we collect specific to the type of individual or corporate that we contract or communicate with.

How we use your information

We use this information to:

• to provide our services to you;
• for our administration purposes and to comply with internal compliance procedures;
• improve our products and services;
• To carry out risk management and fraud prevention processes;
• to carry out checks for security purposes, to prevent fraud and money laundering, and to confirm your identity before we provide services to you;
• for training;
• to communicate with you;
• to initiate, exercise and defend any legal claim or collection procedure;
• to meet the obligations we have by law and under any regulations that apply;
• where we have a legitimate interest in using your information, for example to protect our commercial interests or to prevent fraud; and
• to keep you informed about products and services you hold with us and to send you information about products or services (including those of other companies where you have consented for us to do so) which may be of interest to you.

Information we collect from you merchants, end-users and others

1. Merchants

For the purposes of data protection, we consider a physical person (as opposed to a company) that is a sole trader or individual and who registers for/uses our services or buys products from us (such as a card reader) to be a merchant. The personal data we collect from merchants to fulfil our contractual and legal obligations to you or to pursue legitimate legal interests includes:

• Contact details (including, but not limited to, name address, phone number, email);
• Account identification information;
• Financial information (bank details, transaction history, credit history and credit score, information relevant to invoices issued by us to a merchant);
• Information required to be obtained and kept by law (for example identification information); and
• Technical and behavioural tracking data (for example IP addresses, cookies etc.).

1. Individuals within corporates

In the case of an executive, director, beneficial owner or authorised signatory of a corporate customer that communicates with us we will collect and process the following information:

• Contact details (including, but not limited to, name address, phone number, email);
• Account identification information (including Merchant ID number, password or security information);
• Information required to be obtained and kept by law (for example identification information); and
• Technical and behavioural tracking data (for example IP addresses, cookies etc.).

1. End-customers

For end-customers who use services provided by our merchants, we will collect and process the following information:

• Contact details (including, but not limited to, name address, phone number, email);
• Account identification information;
• Financial information (including, but not limited to card details and transaction history);
• Information required to be obtained and kept by law (for example identification information); and
• Technical and behavioural tracking data (for example IP addresses, cookies etc.).

1. Individuals and customer representatives

For individuals and customer representatives contacting our customer support team or us generally, via email, telephone, SMS or any other communication channel, we will collect and process the following information:

• Contact details (including, but not limited to, name address, phone number, email);
• and
• Technical and behavioural tracking data (for example IP addresses, cookies etc.).

1. Collecting information from third-parties

To ensure that the services we provide are secure and efficient we process personal data from selected third-parties. These third-party sources (and the categories of information) include:

• Credit rating agencies;
• Fraud detection agencies;
• Financial institutions such as banks and card networks
• Tax authorities
• Publicly available registries maintained by or on behalf of national authorities

Sharing your information with others

We may need to share your information with others for the purpose of fulfilling our contractual and legal obligations to you or to pursue legitimate legal interests. We may share personal data with the following named third-parties for the following purposes:

• HMRC in relation to personal data for payment of PAYE, student loan deductions, tax code notices and related matters;
• Credit reference and fraud prevention agency; Lexus Nexus
• Experian in relation to background checks as part of regulatory, enforcement and other requirements;
• LexisNexis in relation to background checks as part of regulatory, enforcement and other requirements;
• High Court and their enforcement agencies in relation to claims and enforcement action;
• suppliers and subcontractors who provide, for example, IT support, logistics, communication, customer support, marketing, acquiring and PCI compliance services and our business partners who we may share personal data with in order for them to provide you with information about similar goods and services (with your consent);
• sharing your information with a party we assign our rights to, under applicable contractual arrangements; and
• sharing information with our funding partners in circumstances concerning our financial affairs;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our various terms, policies and other agreements; or to protect the rights, property, or safety of us, our customers, or others.
• We shall share an end-customer’s personal data with a merchant when it is to enable the merchant to fulfil the end-customer’s order and mitigate the risk of fraud and other criminal activities. The personal data will also be processed when handling potential complaints and disputes. Personal data shared with a merchant will be subject to the merchant’s data protection policy and not this Privacy Policy.

Links to third-party websites

If our website features third-party links to and from third-party websites and you follow a link to any of these third-party websites, you should be aware that these websites have their own privacy policies and the operators of those websites will handle your information in accordance with such policies and not with this Privacy Policy. We have no control over such third-parties or their websites or privacy policies. These third-parties may contact you or permit third-parties to contact you for marketing purposes in accordance with their own privacy policies, unless you opt out of such communications.

We do not accept any responsibility or liability for third-party websites or their privacy policies. We strongly advise you to check such policies and the reputation of the website before you submit your information to, or carry out any transaction on, any third-party website.

How we secure your information

We have in place a level of security appropriate to the nature of the information stored and the harm that might result from a breach of security. Your information is stored on our secure servers.

Please note that the transmission of information via the internet is not completely secure and, although we will do our best to protect your information, we cannot guarantee the security of any of your information transmitted via our website or our applications. Any transmission is at your own risk. If we become aware that the security of your information has been compromised, we will notify you by email or as otherwise required by law.

How long will we will keep your information

We will keep your information for as long as is needed for the purposes set out above or as required by any laws that apply.

If you close your account, if we refuse your application for an account or product, or you decide not to go ahead with your application for an account or product, we’ll still keep your information. We may also continue to collect information from credit reference agencies to use after your account is closed. We’ll do this for as long as we’re allowed to for legitimate business purposes, to help prevent fraud and other financial crime, and for other legal and regulatory reasons.

Sharing your information outside the European Economic Area (EEA)

We do not share your information outside the European Economic Area (EEA). However if our third parties such as fraud protection agencies are required to transfer your information outside EEA we will make sure that the organisations we transfer your information to apply an equivalent level of protection.

Your rights

You can contact by email sales.support@smarterpayments.co.uk to:

• ask us to send you (or someone you nominate) a copy of the information we hold about you;
• access your personal data with us (this is known as making a data subject request;
• ask us to correct or delete any incorrect or incomplete information we hold about you (we will correct any information we believe is incorrect or incomplete);
• ask us to stop using your information;
• Ask us to transfer your personal data to another organisation;
• withdraw any permission you have previously given to allow us to use your information; and
• ask us to stop or start sending you marketing messages at any time.

We will be happy to oblige any request above unless there is a legal reason not to. We will inform you if this is the case.

How we use cookies

Our website may uses cookies to distinguish you from other website users. Cookies help to provide a more personalised experience when you browse our website and also allows us to improve our website.

Other legal information

Children

We do not knowingly collect information from individuals who are under the age of 16. If you are under the age of 16, please do not register an account with our website or provide any information about yourself on our website. If you have already done so, please contact us.

Changes to our Privacy Policy

By submitting your information to us, you consent to the use of the information as set out in this Privacy Policy.

If we change our Privacy Policy, we may post the changes on this page and may place notices elsewhere on our website (such as the home page) for a reasonable period of time.

Your continued use of our website and our services following any changes to this Privacy Policy will mean you accept those changes.