Smart Crowd Limited are committed to providing the highest level of privacy and security regarding collection and use of their customers’ personal information. This policy describes how we may collect, use and disclose your personal information including when contacting us.
Personal information comprises all the details Smart Crowd holds or collects directly or indirectly (including via cookies or other similar tools) about you, your transactions, financial information, interactions or dealings with Smart Crowd, including information received from third parties and information collected through use of our websites and mobile solutions.
There are a number of laws which set out important standards regarding information that identifies a living individual. This is known as “personal data.” All organisations processing personal data must do so fairly and lawfully.
At Smart Crowd Limited we treat all of our obligations seriously and take all steps necessary to comply when we store and process your personal data.
It is essential to us to collect, store and process only the minimum required amount of personal data so that we can offer and perform our services. Typical information we might ask for includes your name, your address, other contact details and Anti Money Laundering / Know Your Customer (AML/KYC) related information. In addition our servers automatically receive and record information on all visitors to our websites. Please see section 5 (below) about cookies for more information.
We will record your personal data (aside from the automatic information detailed above) once we you have full registered.
We collect your personal data in a number of different ways, including the following:
- if you provide it when communicating with us (For example when registering for our services);
- if you invest in any of our products or services;
- if you enter a competition or promotion;
- if you make payments or modify your account details; and
- when you visit our websites (for example by cookies, technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and other browser-generated information such information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.).
- Assessing customer suitability for products and services.
- Anti Money Laundering (AML), Know Your Customers (KYC) assessments, and setting investor risk profile.
- Conducting market research and surveys with the aim of improving our products and services.
- For the prevention, detection, investigation and prosecution of crime (including without limitation, money laundering, terrorism, fraud and other financial crime) in any jurisdiction, identity verification, government sanctions screening and due diligence checks.
- To comply with local or foreign law, regulations, voluntary codes, directives, judgements or court orders, agreements between any member of the FAB group and any authority, regulator or enforcement agency policies, reporting requirements under financial transaction legislation and demands or requests of any authority, regulator, enforcement agency or exchange body.
- To seek professional advice, including in connection with any legal proceedings (including any prospective legal proceedings) for obtaining legal advice or establishing, exercising or defending legal rights.
3. How do we use your personal data?
We retain and use your personal data for the following main purposes:
- We reserve the right to access and disclose your personal data if we are required to do so by law, or if it is necessary for the proper operation of our systems, the protection of Smart Crowd Limited or its users and customers, or for the enforcement of our Terms and Conditions;
- Processing applications made by you, running your accounts, providing our services, contacting you and
- servicing our relationship with you; administration and accounting, billing and auditing and other legal purposes;
- Security, payment verification, preventing and detecting money laundering, fraud and other crime, recovering debt; and
- Generating statistics on our users, such as the popularity of certain of our services, about the “traffic” on our websites. When we do this, data is anonymized and you are not personally identifiable.
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
- to notify you about changes to our service; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Except where you have opted out we may also use your personal data to keep you informed about relevant products and services. We may use your personal data including your contact details, your application details and details of the services we provide you with and how you use them, to decide what products and services may be of interest to you. We may contact you by telephone, post, email and other electronic messages such as short text, video and picture messaging with information, news, events and seminars on our investment, banking and financial services.
4. Safeguarding your personal data
The security of your personal information is important to us and Smart Crowd Limited has invested significant resources to protect the safekeeping and confidentiality of your personal information. When using external service providers, we require that they adhere to the same standards as Smart Crowd Limited. Personal information may be transferred or stored at a location outside of your country of residence. Regardless of where personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal information is kept secure.
The Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorized third parties. Information passing over the Internet may be transmitted internationally (even when the sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than your country of residence. We do not accept responsibility or liability for the confidentiality, security or integrity of your personal information in connection with its transmission over the Internet.
However, we take all reasonable care in the collection, storage, processing and disclosure of your personal data and have implemented internal security procedures so as to minimise the risk that unauthorised parties will be able to access the information. It is because of these security procedures that we may ask for proof of identity before we disclose any personal information about you.
To help protect your personal data and minimise the risk of it being intercepted by unauthorised third parties our secure servers use industry standard Secure Socket Layer (SSL) and Transport Layer Security (TLS) technology when you submit information to us through our website. This security is documented by the usage of the secure “https” protocol and the padlock on the URL bar.
You can also help to protect your personal data, by following the guidelines below:
- choose a password that you will be able to remember but that would be hard for someone to guess. Ideally it should include special characters (such as “?” or “#” for example) and numbers. We recommend that you change it regularly and if you need to write it down, always keep it in a safe place;
- make sure that no-one can see the details you are entering when you log-in;
- remember to close your browser each time you log-off and end your session and, if possible, clear any history of the websites you have visited and that your browser may have
- saved or “cached”; and never disclose your account details
- to anyone;
- ensure that the software you use has installed the latest security upgrades and that your software protection is up-to-date.
To get the best from our services, please keep your personal data (including your email address) accurate and up to date. You can do this by logging into our secure website. We will store your personal data (aside from the automatic information detailed above) once we have received your registration.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
5. Retention of your data
Information relating to your financial transactions with us will be kept for the period required by relevant UK tax and revenue legislation.
Your personal profile and membership data for will be retained whilst you continue to be an active free or paid member, and for up to 7 years following cessation of membership activity.
In all other cases, we will erase or anonymise your data once it is no longer necessary for the purpose we obtained it for.
6. Disclosure of personal information
We allow third party service providers to process personal information where this is needed in connection with a service they provide Smart Crowd Ltd. These arrangements may involve your personal information being located in various countries around the world including the United Arab Emirates where Smart Crowd Limited has its head office.
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; and
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- We may disclose your personal information to third parties:
- 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 we or substantially all of our 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; and
- 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 any agreements between you; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
7. Withdrawal of consent including marketing opt-out
You may withdraw consent for data processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
You may also instruct us not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt-out of the use of your personal information for marketing purposes.
You contact details us at [email protected] should you wish to exercise these important rights.
To the extent permitted by law, Smart Crowd Limited may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.
9. Right of Access
Subject to applicable law, regulations and/or real-estate industry guidelines, you may have the right to request a copy of the personal information processed in relation to you. Smart Crowd Limited may be allowed, by law, to charge a fee for providing you with a copy of your personal information.
To request a copy of your personal information, please contact us on [email protected]
10. Third party websites
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
10. Social media
Smart Crowd Limited operates channels, pages and accounts on some social media sites to inform, assist and engage with customers. We monitor and record comments and posts made on these channels about Smart Crowd Limited so that we can improve our services.
Smart Crowd Limited is not responsible for any information posted on those sites other than information we have posted ourselves. We do not endorse the social media sites themselves or any information posted on them by third parties.
12. International data transfers
Information which you provide may be transferred to countries, including the United States, which do not have data protection laws equivalent to those in force in the European Economic Area.
In addition, personal information that you submit for publication on the website will be published on the internet and may be available, via the internet, around the world. Smart Crowd Limited cannot prevent the use or misuse of such information by others.
You expressly agree to such transfers of personal information.