Privacy Policy
Privacy Policy
Smartbridge Ltd
(updated 15th January 2019)
The General Data Protection Regulation (“GDPR”) is Europe’s new framework for data protection laws – it replaces the previous 1995 data protection directive, which current UK law is based upon. The GDPR legislation is designed to “harmonise” data privacy laws across Europe as well as give greater protection and rights to individuals. Within the GDPR there are large changes for the public as well as businesses and bodies that handle personal information.
Each member state in the EU operates under the current 1995 data protection regulation and has its own national laws. In the UK, the current Data Protection Act 1998 sets out how your personal information can be used by companies, government and other organisations. GDPR changes how personal data can be used. Its provisions in the UK will be covered by a new Data Protection Bill, which has now been published by the government.
Smartbridge Ltd (“Smartbridge”) is committed to protecting your information by handling it responsibly and safeguarding it using appropriate technical, administrative and physical security measures. The privacy notice below explains what information we gather about you, what we use it for and who we share it with. It also sets out your rights and who you can contact for more
information or queries. This privacy statement applies to Smartbridge Ltd with Registered Office address at 25 Bedford Square, WC1B 3HH London (UK), and the entities we own or control (“we”, “us” or “our”).
In this statement:
“Data Protection Legislation” means;
(i) before 25 May 2018, the EU Data Protection Directive 95/46 and all national implementing laws (including the UK Data Protection Act 1998);
(ii) on or after 25 May 2018, the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.
“Smartbridge Network” means Smartbridge Ltd, a UK private company limited by shares, and its network of associates and agent firms, each of which is a legally separate and independent entity.
“Process” means any operation performed on information about you, including to collect, record, organise, structure, store, alter, use, transfer, destroy or otherwise make available. We are committed to protecting your privacy and handling your information openly and transparently.
This privacy statement explains how we will collect, handle, store and protect information about you when:
- providing services to you or our clients;
- you use our Website; or
- performing any other activities that form part of the operation of our business.
When we refer to “our Website” or “this Website”, we mean the specific webpages of cheso.co.uk or cheso.it
This privacy statement also contains information about when we share your personal data with other members of the Cheso Consulting Network and other third parties (for example, our service providers). In this privacy statement, your information is sometimes called “personal data”. We may also refer to “processing” your data, which includes handling, collecting, protecting and storing it.
Service specific privacy notices
If you or an entity relevant to you uses or intend to use Smartbridge for any of the services listed in this website, please read this notice for details about how we handle information about you.
What personal data we collect
We may collect, record and use your personal data in physical and electronic form, and will hold, use and otherwise process that data in line with the Data Protection Legislation and as set out in this statement.
When we provide services to you or our clients and perform due diligence checks in connection with our services (or discuss possible services we might provide), we will process personal data about you.
We may process your data because:
- you give it to us;
- other people give it to us (for example, your employer or adviser, or third-party service providers that we use to help operate our business); or
- it is publicly available.
We may process personal data from you because we observe or infer that data about you from the way you interact with us or others. The personal data we process may include your:
- name, gender, age and date of birth;
- contact information, such as address, email, and mobile phone number;
- country of residence;
- employment and education details (for example, the organisation you work for, your job title and your education details);
- financial and tax-related information (for example your income, investments and tax residency);
If you choose not to provide, or object to us processing, the information we collect, we may not be able to process your instructions or continue to provide some or all of our services to you or our client.
Personal data provided by or about third parties
When our client or another third party gives us personal data about you, we make sure they have complied with the relevant privacy laws and regulations. This may include, for example, that the client or other third party has informed you of the processing and has obtained any necessary permission for us to process that information as described in this privacy statement.
If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.
How we use your personal data
We process information about you and/or your business to enable us and other members of the Cheso Consulting Network to provide our services to you or our clients, and to meet our legal or regulatory obligations. Some of your personal data may be used for other business purposes. Below are some examples.
Use of personal data to provide services to our clients
We will use your personal data to provide you or our clients or other third parties with services, and this includes using your personal data in correspondence relating to those services. That correspondence may be with:
- you;
- other third parties or other members of the Smartbridge Network;
- our service providers; or
- competent authorities.
We may also use your personal data to conduct due diligence checks relating to the services. Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data about:
- client’s employees to help those employees manage their legal or tax affairs when working overseas;
- client’s employees and customers in the course of conducting an audit (or similar activity) for a client.
Use of personal data for other activities that form part of the operation of our business
We may also use your personal data in connection with:
- legal or regulatory requirements;
- requests and communications from competent authorities;
- client account opening and other administrative tasks;
- financial accounting, invoicing and risk analysis;
- relationship management, which may involve:
(a) sending you details of our products and services;
(b) contacting you for feedback on services;
(c) sending you event invitations; and
(d) other marketing or research purposes;
- services we receive from our professional advisors, such as lawyers, accountants and consultants;
- investigating or preventing security incidents; or
- protecting our rights and those of our clients.
Use of personal data collected via our Website
In addition to the above, we may also use your personal data collected via our Website from time to time:
- to tailor the content of our Website to give you a more personalised experience;
- to draw your attention to information about our products and services that may be of interest to you; or
- to manage and respond to any request you may submit through our Website.
The legal grounds we use for processing personal data
We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal data. We rely on one or more of the following lawful grounds:
- you have explicitly agreed to us processing your information for a specific reason;
- the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
- the processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
- the processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which might be:
(a) to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
(b) to prevent fraud;
(c) to protect our business interests;
(d) to ensure that complaints are investigated;
(e) to evaluate, develop or improve our services or products; or
(f) to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because:
- you have given us your explicit consent to process that data;
- we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us);
- the processing is necessary to carry out our obligations under employment, social security or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.
Sharing your personal data
We may disclose details about you to:
- other members of the Smartbridge Network or third parties that provide services to us and/or the Smartbridge Network;
- competent authorities (including courts and authorities regulating us and other members of the Smartbridge Network);
- your employer and/or its advisers, or your advisers;
- anyone to whom we may transfer our rights and/or obligations;
- any other person or organisation after a restructure, sale or acquisition of any member of the Smartbridge Network, as long as they use your information for the same purposes we did;
- credit reference agencies or other organisations that help us make credit decisions and reduce the incidence of fraud;
- Authorities as permitted or required by law (for example police or HMRC); and
- other third parties that reasonably require access to personal data relating to you.
Our Website may host blogs, forums and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal data that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users, so any information you potentially contribute to these Social Media Applications might not be handled in line with this privacy statement.
Transferring your personal data outside the UK
Information we hold about you may be transferred to other countries (which may include countries outside the European Economic Area (“EEA”):
- where we do business;
- which are linked to your engagement with us;
- from which you regularly receive or transmit information; or
- where our third parties conduct their activities.
These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes. When we, or our permitted third parties, transfer your personal data outside the EEA, we will impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing.
We may also transfer your personal data when:
- the transfer is to a country deemed to provide adequate protection of your personal data by the European Commission; or
- where you have consented to the transfer.
If we transfer your personal data outside the EEA in other circumstances (for example, because we have to by law), we will make sure it remains adequately protected. We may share non-personal, anonymised and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.
Protecting your personal data
We use a range of measures to ensure we keep your personal data secure, accurate and up to date. These include:
- education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
- administrative and technical controls to restrict access to personal data to a ‘need to know’ basis;
- technological security measures, including fire walls, encryption and anti- virus software; and
- physical security measures, such as security passes to access our premises.
The transmission of data over the internet (including by e-mail) is never completely secure. So, although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
How long we keep your personal data for
We seek to ensure that we only keep your personal data for the longest of:
- the period necessary for the relevant activity or services;
- any retention period that is required by law; or
- the period in which litigation or investigations might arise in respect of the services.
Your rights
You have various rights in relation to your personal data. In particular, you have a right to:
- obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
- be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from where it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
- ask us to stop or start sending you marketing messages at any time; and
- object to our processing of your personal data.
If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event within one month in line with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject. To help us ensure that your information is up to date, let us know if any of your personal details change. You may also use our contact details if you wish to make a complaint relating to your privacy.
Sending you marketing information
We and other members of the Smartbridge Network may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties) that may be of interest to you. You may, at any time, ask us and/or other members of the Smartbridge Network not to send marketing information to you by contacting us in the way described below.
Right to complain
If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us by:
- writing to Smartbridge Ltd, 25 Bedford Square, WC1B 3HH London (UK); or
- sending an email to info@smartbridge.co.uk
You can also complain to the Information Commissioner’s Office, which regulates and supervises the use of personal data in the UK, on 0303 123 1113. If you are not based in the UK, you have the right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction.
Changes to this privacy statement
We may modify or amend this privacy statement from time to time. When we make changes to this privacy statement, we will amend the revision date at the top of this page. The modified or amended privacy statement will apply from that date. We
encourage you to review this statement periodically to remain informed about how we are protecting your information.
Contacts
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@smartbridge.co.uk