SMO Media Limted, t/a Smart:Money:Online, collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws. When we mention “Smart:Money:Online”, “we“, “us” or “our” we are referring to SMO Media Limted. We provide you with intermediary services in relation to protection insurance products. SMO Media Limted, t/a Smart:Money:Online is incorporated in England & Wales with the number 09233532, is an appointed representative of Highview Network Limited. Highview Network Limited is a company registered in England and Wales (company number 07670037 ) whose registered office is at Basepoint Business Centre, 377-399 London Road, Camberley, GU15 3HL. Highview Network Limited is authorised and regulated by the Financial Conduct Authority. Highview Network Limited’s FCA number is 555154. We and Highview Network Limited have certain shared systems (and so shared access to your personal data). This means that in respect of certain personal data of yours, we and Highview Network Limited will be joint data controllers. The manner in which Highview Network Limited will process your personal data is set out in a separate privacy notice which we will provide you with at the start of our engagement. If you require a further copy of this privacy notice, please contact Highview Network Limited at [email protected] or Data Protection Officer, Basepoint Business Centre, 377-399 London Road, Camberley, GU15 3HL.
This privacy notice was last updated on the 27th August 2019
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
In the course of our intermediary services we may collect the following personal data when you provide it to us:
We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us. The personal data we obtain from other sources may include the following:
The below table sets out:
|Rationale/Reason for Processing||Lawful Basis for Processing||Third party recipients linked to that activity|
|to provide you with intermediary services to assist in the administration of any products you have obtained through us||Performance of a contract||Highview Network Limited|
|to apply for quotations for protection insurance products on your behalf to apply for products on your behalf||Performance of a contract||product providers External supplier(s) of software services through which we review, source and apply for decisions in principle, quotations and/or products on your behalf|
|to manage complaints||Compliance with a legal obligation||Highview Network Limited Our external solicitors|
|to manage legal claims||Legitimate interests [– we have a legitimate interest in protecting ourselves from breaches of legal obligations owed to us and to defend ourselves from litigation. This is needed to ensure that our legal rights and interests are managed appropriately]||Highview Network Limited Our external solicitors|
|to share with Highview Network Limited as the company responsible for making sure that all sales we make to you and advice we give to you are compliant with the rules and regulations that apply to financial services in the UK and with their policies and procedures||Compliance with a legal obligation||Highview Network Limited|
|to obtain feedback from you on the service you have received from us||Legitimate interests [– we have a legitimate interest in operating our business. This includes ensuring that the service we provide is of a satisfactory standard]||Highview Network Limited External supplier(s) of software services to obtain feedback from you – Feefo|
|to retain records of any services or advice provided to you in accordance with our regulatory obligations. Call recordings maybe used.||Compliance with a legal obligation||External supplier(s) of data storage and data hosting services to retain records on ourbehalf|
|to retain records of any services or advice provided to you by your adviser in order to defend potential legal claims or complaints||Legitimate interests [– we have a legitimate interest in defending ourselves from legal claims and complaints. This is needed to ensure that our legal rights and interests are managed appropriately]||External supplier(s) of data storage and data hosting services to retain records on our behalf|
|to provide you with details of products and services from us and third parties that may be of interest to you in accordance with your preferences. For more information see ‘Marketing’ below||Consent||SmartWills|
|to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting data)||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)||FLG Business Technology Limited Cloudlevel.me Lead Insight LTD|
|to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)||Advertising networks such as Facebook Google Adwords Bing Ads & Others|
|to detect, prevent and investigate fraudulent applications for products to undertake investigations into allegations of misconduct and/or criminal offences to notify the relevant authorities of any suspicious activity following an investigation undertaken by us into allegations of misconduct and/or criminal offences||Compliance with a legal obligation. [We also consider that we have a legitimate interest in protecting ourselves, other parties and the financial services industry more widely in detecting, preventing and investigating financial crime and/or misconduct]||The Financial Conduct Authority product providers Highview Network Limited National Crime Agency (NCA) Police HMRC|
|to undertake anti-money laundering, identification and verification checks, including assessment of your sanction check information (any personal data obtained for the purposes of meeting with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 will only be processed for the purposes of preventing money laundering or terrorist financing, unless the use of the data is permitted by or under another enactment other than those Regulations, or we have another lawful basis for processing it)||Compliance with a legal obligation||Highview Network Ltt External supplier(s) to conduct anti-money laundering, identification and verification checks on our behalf Lenders/product providers|
|to evidence satisfaction of any request made by you in accordance with your rights under data protection regulation||Compliance with a legal obligation||Information Commissioner’s Office|
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection. We may process:
In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance contract or (ii) for the establishment, exercise or defence of legal claims.
We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and then will do so in accordance with any marketing preferences you have provided to us. In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you. You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences please contact us:
By phone: 0800 088 2109
By email: [email protected]
By Post: Smart:Money:Online, Smart:Money:Online, Arena Business Centre, 282 Farnbrough Road, Farnborough, Hampshire, GU14 7NA
In addition, you can opt out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of every email.
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.
We will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below.
|Type of Record||Retention Period|
|Customer file containing a record of any intermediary services provided by us||For a period of six years following provision of services, or following termination of the policy.|
|Complaint file containing a record of any claim you have brought against us||For as long as we reasonably consider that you might legally bring an additional or repeat claim against us, or for as long as we reasonably consider that the information may be requested by the financial regulator or ombudsman.|
|Marketing lists||Once consent for marketing is received, we will use your data for marketing purposes until you opt out. We will then retain your data for a period of 6 months following the cessation of marketing activities.|
|Results of anti-money laundering, identification and verification checks, including assessment of your sanction check information||For as long as we are required/permitted to retain this personal data based upon our legal and regulatory obligations|
|Fraud and financial crime files||For as long as we reasonably consider that: we are required/ permitted to retain this personal data based upon our legal and regulatory obligations they may be required in the establishment, exercise or defence of legal claims|
|Records of satisfaction of any request made by you in accordance with your rights under data protection regulation||3 years from the date the request was satisfied|
We will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:
We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual. We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request. We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.
You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.
You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first. You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you. You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data. We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
You can ask that we restrict our use of your personal data in certain circumstances, for example
We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company). You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.
If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision making processes to protect your rights and freedoms.
If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data. If you would like to exercise any of the above rights, please:
We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office (www.ico.org.uk). We ask that you please attempt to resolve any issues with us before the ICO.
Please contact our Data Privacy Manager if you have any questions about this privacy notice or the information we hold about you. If you wish to contact our Data Protection Officer, please send an email to [email protected] or write to: The Data Protection Officer, Smart:Money:Online, Arena Business Centre, 282 Farnbrough Road, Farnborough, Hampshire, GU14 7NA
|we, us or our||SMO Media Ltd, t/a Smart:Money:Online is a registered company in England & Wales. Register number 09233532. Registered and Trading address is: Arena Business Centre, 282 Farnbrough Road, Farnborough, Hampshire, GU14 7NA|
|contact information||these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address|
|data controller||means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services|
|data protection regulation||applicable data privacy and protection laws|
|employment status||this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance|
|FCA||the Financial Conduct Authority, being the independent watchdog that regulates financial services|
|financial information||this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60|
|health information||this is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history|
|identity information||this is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers licence and national insurance number|
|intermediary services||these are the services we provide to you in relation to the products, which may include: advising on the products applying for a quotation on your behalf in relation to a product arranging or administering a product on your behalf|
|lifestyle information||this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits|
|product||this is a protection insurance product in respect of which we provide intermediary services to you|
|product provider||a company which provides protection insurance products (for a list of product providers which we work with, please contact us – see How to contact us above)|
|sanction check information||this is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering|
|vulnerability||a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence)|