Scope and Date of Policy
What Personal Data we collect
“Personal data” is any data that can be used to identify a natural person or individual. Examples of personal data that we may collect from you, either directly when you engage with Smartkarma or its group companies, or otherwise through your use of the Site or Mobile App, include:
- professional and personal details such as your name, gender, contact details, contact preferences and IP address;
- details of transactions or interactions you carry out through our Site and/or Mobile App;
- details of your visits to our site (including, but not limited to, traffic data, location data, weblogs and other communication data) and the resources and links that you access; and
- records in connection with service provision to Users including records of correspondence and records of use of the Site and other related services, account details, records of agreements and other transactions, notes from interactions and information used for monitoring and regulatory compliance.
How we collect Personal Data
We collect, process and retain personal information from you when you enter into a User Agreement or register for an account with us, and each time you navigate to the Site or Mobile App and interact or transact with us.
You may set up your web browser to block or disable cookies which will in turn disable the monitoring of your visit. You may also remove cookies stored from your computer or mobile device. However, if you do block or disable cookies, you may not be able to use or receive certain personalised features and functions of the Site or Mobile App.
Please also note that the Site may contain links to other websites which are not operated or maintained by Smartkarma. When visiting these third party websites, you should read their privacy and data protection policies which will solely apply to your use of those third party websites.
How we use Personal Data
Smartkarma will always process your personal data for a specific purpose, and process only the personal data that is relevant for achieving that purpose. Depending on our relationship with you and the products and services that we provide to you, we may process your personal data for the following business purposes and associated compatible purposes:
- Account opening and on-boarding;
- Understanding client needs and offering products and services;
- Providing products and services;
- Managing our relationships with Users and connected parties;
- Communicating with Users;
- Carrying out operational and administrative functions;
- Helping us to improve our products and services;
- Managing and conducting our business;
- Monitoring and assessing risk, conducting audits and enforcing our rights;
- Marketing our products and services to Users; and
- Meeting our regulatory and compliance obligations.
Disclosure and Sharing of Personal Data
To support or enhance the delivery and performance of the above business purposes, Smartkarma uses the services of selected, authorised third party processors with whom Smartkarma has data processing agreements in place to ensure that all such disclosure and use is in compliance with relevant privacy laws, including where applicable the GDPR.
Transfer of Personal Data
Retention of Personal Data
Smartkarma will retain your personal data for the period of time required for the business purposes for which it was collected or to comply with legal, regulatory and internal compliance requirements.
You may request access to or corrections in respect of your personal data held by Smartkarma. If you are a User based in Europe, the GDPR provides for more specific rights of access, modification, usage restriction and deletion of your personal information.
Please contact us for details on how you may request such access, corrections or other actions.