Smile Financial Services appreciates your visit to this website and your interest in the products and services featured on our website. Your privacy is extremely important to us and we want you to feel comfortable using our website. We take great care to protect any of your personal data collected, processed, or used during your visits to the Smile FS website.
Smile FS and all associated persons and entities (“Smile FS” or “Smile Financial Services” or “Smile” or “we”) are fully committed to safeguarding any and all personal information that we obtain from individuals and companies who use the Smile FS website. Accordingly, we have developed this policy to describe how and what type of data will be collected from users of this website and the purposes for which we may collect, share or disclose the data. It also covers the precautions which are taken to keep your data secure.
This policy applies to any information obtained by Smile FS through your use of this website. It is not applicable to any other internet websites controlled by third parties that this website may link to (“Third Party Sites”). Please review the privacy policies of third party sites as we are not responsible for them and has no influence over the content or privacy policies of third party sites.
The terms of this policy are subject to additional terms of disclaimers or other contractual terms that you have entered into with Smile FS, and any applicable laws and regulations.
The information we collect
When you visit the Smile FS website, our web server automatically records details about your visit, for example your IP address, the website from which you visit us, the type of browser software used, the Smile web pages that you actually visit, and the date, time and duration of your visit.
In addition, we collect personal data that you provide through this website, for example when you enter personal details on a form or sign up for an email newsletter.
Smile FS will use your personal data for the purposes of technical administration and research and development of the Smile FS website, for client and user administration and marketing, to inform you about our products and services, and for such purposes as otherwise specified. We respect and follow all applicable laws and regulations in our use of personal data.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
How we may collect and store information
We may use tracking technology such as cookies or tags to gather information as outlined above, to understand how visitors use this website. Tracking technology helps us manage and improve the usability of this website, for example by detecting whether there has been any contact between your computer and us in the past and to identify the most popular sections of the Smile FS website.
Disclosure of information collected
We may disclose information collected from this website to our affiliates, agents, and third party providers inside or outside your country of residence to perform services for Smile Financial Services and for the purposes stated above. Our affiliates, agents, and third party providers who have access to data obtained through the Smile FS website are obliged to respect privacy and comply with all relevant laws and regulations.
We may also disclose information to government agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request, and under any guidelines issued by regulatory or other authorities, or similar processes as either required or permitted by applicable law.
Smile FS and its affiliates, partners, and associated companies are subject to various data protection regulations in various jurisdictions around the world. We consider the European Union General Data Protection Regulation (GDPR) to be the current benchmark for international best practise and as such adhere to it across all jurisdictions in which we operate.
If you use the services of Smile FS we will hold only the date necessary to fulfil the function to which you have appointed us. A copy of this is available on request. The vast majority of the data we have access to is not held by us directly but held with financial institutions, also subject to the GDPR, which you have authorised to provide data to us in order for us to fulfil any role you have appointed us to.
If you have subscribed to our email newsletters, updates, or other communications in any format, we will store the data you provided in electronic format. You may unsubscribe from any newsletters, updates, or other communications simply by making a request in line with the processes laid out in the GDPR.
Due to the confidential nature of the services we provide to our clients we take data protection very seriously and do not provide, sell, or otherwise disseminate any private information to any third parties, other than where consent has been expressly given (such as the submission of an application form to an external financial institution, itself subject to data protection regulations).
Smile Financial Services has implemented reasonable technical and organisational security measures to protect your personal data collected by us via this website against unauthorised access, misuse, loss or destruction.
How we treat electronic communications
All electronic messages sent to and from Smile FS are automatically retained in a distinct journaling system which preserves the evidential weight of the emails. They are protected by reasonable technical and organisational measures and may only be accessed in justified cases in line with applicable laws and regulations, such as a court order, suspicion of criminal conduct, violation of regulatory obligations, or material breach of an employment contract, to specific persons in defined functions, such as Legal, Compliance, or Risk. Every step of the process, as well as the search criteria used, are logged in an audit trail. All emails are disposed of after the applicable retention period has expired.
General internet precautions
The internet is generally not considered to be a secure environment, and information sent via the internet (such as to or from the Smile FS website or via electronic message) may be accessed by unauthorised third parties, potentially leading to disclosures, changes in content, or technical failures. Even if both sender and receiver are located in the same country, information sent via the internet may be transmitted across international borders and be forwarded to a country with a lower data protection level than exists in your country of residence.
Please note that we accept no responsibility or liability for the security of your information whilst it is in transit over the internet to the Smile FS website. In order to protect your privacy, we would like to remind you that you may choose other means of communication with Smile FS, where you deem it appropriate.
Accessing your personal data
You may, where permitted by applicable law or regulation, check whether we hold any of your personal data, ask us to provide you with a copy of your personal data, or require us to correct any of your personal data that is inaccurate. Should you have a request regarding the processing of your personal data, please contact us in writing.
Thank you for using the Smile FS website.