Smart Money Limited, referred to as ‘Smart Money’, ‘we’, or ‘our’, is committed to protecting the privacy and security of your personal information.
This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the Data Protection (Jersey) Law 2018 (DPJL).
Smart Money is a “Data Controller”. This means that we are responsible for deciding how we hold and use personal information.
Smart Money is a registered business with the Jersey Financial Services Commission (JFSC), registration number 147298, we are also registered with the Jersey Officer of the Information Commissioner (JOIC) – Registration No. 100211.
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly, and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
Smart Money is accountable to you and the Authorities to not only show compliance with the data protection laws but also to demonstrate how we are compliant.
The Data Protection Manager (“DPM”)
We have appointed a DPM to oversee compliance with this Privacy Notice.
If you have any questions about this Privacy Notice or, how we handle your personal information, please contact the DPM at [email protected]
The Kind of Information We Hold About You
Personal data 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).
To explain this to you, we will when necessary list our different services when we collect or use different information about you.
How Is Your Personal Information Collected?
We collect personal information about you when you contact us, visit our website, make an enquiry about one of our services, engage us to provide a service to arrange a loan or contact us for another specific purpose.
What Special Category Data do we collect about you?
At Smart Money we do not collect Special Category data from you during the normal course of our business. On the rare occasion when we do have to ask about your health, for example, we will always do this with your explicit consent.
How We Will Use Information About You?
We will only use your personal information when the law allows us to, this is called a legal basis (highlighted in bold) for processing your information (data).
Most commonly, we will use your personal information in the following circumstances:
- Where you have entered a contract with us to provide you with a service. This would be when you engage us for one of our services.
- Where we need to comply with a legal obligation. This would be when we must comply with lawful authority to disclose information.
- 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. An example of this is when we send you updated information about a service you have had from us in the past that we feel you may be interested in.
We may also use your personal information in the following situations, which are likely to be rare:
- Where you have given your consent to contact you for a specific purpose.
- In an emergency and it is in your vital interest that we share your information when we have it recorded.
Change of purpose
We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Specific Data Collection Points
Smart Money provides a brokerage service to arrange loans from financial institutions or private individuals to clients in Jersey. We broker services to provide clients with personal loans, business loans, and asset finance.
The personal data Smart Money collects, processes, and stores are vast and as such we have robust data governance structures in place to protect the integrity of that data you entrust us with.
The data collected for each application is but is not limited to:
Loan and Asset Finance Services
- Date of birth
- Marital status
- Billing Address
- Delivery Address
- Email Address
- Contact telephone numbers
- ID document details
- Bank Statements
- Bank account details
- Payment card details
- Statements of assets/liabilities
- Payments (to and from you)
- Other applications to us
- Accounting Records
- Insurance Policies
For more information about what information, we collect about you please contact our DPM at [email protected]
We pass your Personal Information to an organisation outside of Smart Money exclusively to process on our behalf, and as part of your application for the service you would like us to broker on your behalf. We select the most appropriate organisations for your application and circumstances to meet your needs. These organisations are called Data Processors.
We require these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice.
Another organisation we use is MailChimp. We use MailChimp for our email campaigns and other communications with clients and perspective clients. We put your email address on a database, controlled by us, but on a system operated by MailChimp. To view their privacy notice please visit their privacy notice page.
We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests.
The personal data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers.
If we do this, we ensure that your privacy rights are respected in line with this Notice and that the same protection is given to your personal information as laid down by the DPJL.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. In addition, we limit access to your personal information to those Colleagues, Agents, Contractors, and other third parties on a need to know basis.
They will only process your personal information on our strict instructions and they are subject to a duty of confidentiality.
Details of these measures may be obtained from our DPM at [email protected]
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
All data is retained securely and only used for the purposes set out in the Law. Data is retained to comply with our statutory obligations and in accordance with our retention schedule. If you would like a copy of our retention schedule, please contact our DPM at [email protected]
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of Access, Correction, Erasure, and Restriction
It is important that the personal information we hold about you is accurate and current.
Please keep us informed if your personal information changes during your relationship with us. Under certain circumstances, by law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.If you want to review, verify, correct, or request the erasure of your personal information, object to the processing, or request that we transfer a copy of your personal information to another party, please contact our DPM at [email protected] You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
How to request your information and what we may need from you
Please use the Data Subject Access request form, available on our Cookie Banner. If you have any questions about this process or any of your rights, please contact our DPM, at [email protected]
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
We will respond to your request without undue delay, but certainly within Four Weeks after and upon satisfactory verification of your identity. Depending on the complexity of the request, we may apply an extension of up to Eight Weeks on the response time, but you will be informed of this as soon as possible after a valid request is made.
Right to Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please contact our DPM at [email protected]
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to this Privacy Notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates.
We may also notify you in other ways from time to time about the processing of your personal information or requesting you confirm the accuracy of the information we hold on you.
We would like the chance to resolve any complaints you have about the way we process your information; however, you do have the right to complain to the JOIC about how we have used your personal data.
The details for each of these contacts are:
One Liberty Place, La Route de la Liberation, St Helier, Jersey, JE2 3NY
Telephone: (+44) 1534 288 977 or Email – [email protected]
Jersey Office of the Information Commissioner
2nd Floor, 5 Castle Street, St Helier, JE2 3BT
Telephone: (+44) 1534 716530 or Email – [email protected]