We understand consumers’ concerns with regard to their privacy and we take great care to ensure that the privacy of every person that uses our site is both respected and protected. The personal data that we collect is collected and used only for the purposes of the Smart Sure business. We are committed to handling data fairly and lawfully and takes our data protection obligations seriously. Smart Sure ensures that it processes Personal Information in compliance with applicable data protection laws, including, without limitation, the General Data Protection Regulation 2016/679 ("GDPR").
We know that your privacy is important. This document outlines the types of personal information we receive and collect when you use www.smart-sure.com, as well as some of the steps we take to safeguard information. We hope this will help you make an informed decision about sharing personal information with us. www.smart-sure.com strives to maintain the highest standards of decency, fairness and integrity in all our operations. Likewise, we are dedicated to protecting our customers’, consumers’ and online visitors’ privacy on our website.
Who we are
Smart Sure is an appointed representative of City and Commercial Limited who is authorised and regulated by the Financial Conduct Authority.
What is Personal Information?
For the purposes of this Data Protection Notice "Personal Information" consists of any information that relates to you and/or information from which you can be identified, directly or indirectly. For example, information which identifies you may consist of your name, address, telephone number, photographs, location data, an online identifier (e.g. cookies identifiers and your IP address) or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. When we combine other information (i.e. information that does not, on its own, identify you) with Personal Information, we treat the combined information as Personal Information.
What Personal Information do we collect?
www.smart-sure.com collects personally identifiable information from the visitors to our website only on a voluntary basis. Personal information collected on a voluntary basis may include name, postal address, date of birth, email address, company name, telephone number and banking details.
This information is collected if you request information from us, participate in a contest or sign up to join our email list, buy a product, or request some other service or information from us. The information collected is internally reviewed, used to improve the content of our website, notify our visitors of updates, and respond to visitor inquiries.
Once information is reviewed, it is discarded or stored in our files. If we make material changes in the collection of personally identifiable information we will inform you by placing a notice on our site. Personal information received from any visitor will be used only for internal purposes and will not be sold or provided to third parties.
We may also obtain Special Category Personal Data (as defined in the GDPR) such as healthcare information (for example, medical conditions).
Children’s Online Privacy Protection Act
This website is directed to adults; it is not directed to children or young adults under the age of 16. We operate our site in compliance with the Children’s Online Privacy Protection Act, and will not knowingly collect or use personal information from anyone under 16 years of age.
In some cases, we may collect information about you that is not personally identifiable. We use this information, which does not identify individual users, to analyse trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. The information collected is used solely for internal review and not shared with other organisations for commercial purposes.
We may use the Personal Information we collect for the following purposes:
- To administer and manage your insurance policy
- To process claims or complaints
- For marketing purposes
The law allows us to use the Personal Information as set out above on the basis that the processing is necessary for the performance of a contract with you, or we are acting in our "legitimate interests", for example, for the purposes of providing goods, services, and support.
Where we collect Special Category Personal Data we will not use this except for the purposes of processing your insurance policy and associated claims.
We may contact site visitors and offer assistance regarding the services we offer. If you decide to opt-out from future contact, please communicate that to us. We may use your Personal Information to send you marketing communications by mail, telephone or email. This is necessary for the purposes of the legitimate interests pursued by us, for example, to keep our customers updated about products that they might be interested in. For situations where you are purchasing goods and services from us, this is for the performance of the contract with you. For further information on this, see the 'Your Choices' section of this Data Protection and Privacy Statement.
To whom do we disclose your information?
We will only use your Personal Information for our internal business purposes, for example, as set out above.
We do share your information with third parties, where we outsource certain functions, including but not limited to service providers and other service products that we use. We would do this, for the effective performance of your insurance cover with us, and for our legitimate interests, such as the effective financial and business management of Smart Sure .
We may also disclose Personal Information to establish, exercise or defend our legal rights including providing information to others and/or in connection with any ongoing or prospective legal proceedings. We may also disclose Personal Information to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that Personal Information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that Personal Information.
Release of Information
If sold, the information we have obtained from you as a customer may transfer to the new owner as a part of the sale in order that the service being provided to you may continue. In that event, you will receive notice through our website of that change in control and practices, and we will make reasonable efforts to ensure that the purchaser honor any opt-out requests you might make of us.
How do we keep your information secure?
We have put in place appropriate physical and technical measures to safeguard the Personal Information we collect in connection with our services. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions and they are subject to a duty of confidentiality. However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.
International transfer of data.
By using or participating in any service and/or providing us with your Personal Information, you acknowledge that we will collect, transfer, store and process your information outside of the EEA. We will take all steps reasonably necessary to ensure that your Personal Information is kept secure and treated in accordance with this Data Protection Notice and the requirements of applicable law wherever the data is located. Where we transfer your Personal Information outside the EEA to other countries, we will ensure that appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third-party service providers provide an adequate level of protection to your Personal Information. We will only transfer your Personal Information outside the EEA in accordance with applicable laws.
How long will we keep your Personal Information?
Smart Sure retains Personal Information for as long as necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Data Protection and Privacy Statement unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.
Accessing your Personal Information and your other rights.
Smart Sure will collect, store and process your Personal Information in accordance with your rights under any applicable Data Protection Laws. Under certain circumstances, you have the following rights in relation to your Personal Information:
I. Subject Access - you have the right to request details of the Personal Information which we hold about you and copies of such Personal Information.
II. Right to Withdraw Consent – where our use of your Personal Information is based upon your consent, you have the right to withdraw such consent at any time. In the event you wish to withdraw your consent to processing, please contact us using our Contact Us page.
III. Data Portability – you may, in certain circumstances, request us to port (i.e. transmit) your Personal Information directly to another organisation.
IV. Rectification – we want to ensure that the Personal Information about you that we hold is accurate and up to date. If you think that any information we have about you is incorrect or incomplete, please let us know. To the extent required by applicable laws, we will rectify or update any incorrect or inaccurate Personal Information about you.
V. Erasure ('right to be forgotten') - you have the right to have your Personal Information 'erased' in certain specified situations.
VI. Restriction of processing – you have the right in certain specified situations to require us to stop processing your Personal Information and to only store such Personal Information.
VII. Object to processing – You have the right to object to specific types of processing of your Personal Information, such as, where we are processing your Personal Information for the purposes of direct marketing.
VIII. Prevent automated decision-taking – in certain circumstances, you have the right not to be subject to decisions being taken solely on the basis of automated processing.
How You Can Correct or Remove Information
Enforcing your rights
If you wish to enforce any of your rights under applicable Data Protection Laws, then please contact us on our Contact Us page.
We will respond to your request without undue delay and no later than one month from receipt of any such request, unless a longer period is permitted by applicable Data Protection Laws.
If you are concerned that we have not complied with your legal rights under applicable Data Protection Laws, you may contact the Information Commissioner's Office (ico.org.uk) which is the data protection regulator in the UK which is where Smart Sure is located. Alternatively, if you are based outside the UK, you may contact your local data protection supervisory authority.
Your choices (e.g. marketing related communications)
Smart Sure may use your Personal Information (such as your contact details (e.g. name, address, email address, telephone number)) to send you marketing-related correspondence related to our products and services, in accordance with your email and contact preferences. When we process your Personal Information for marketing purposes, we do so on the basis that it is in our legitimate interests to do so.
We do not share Personal Information with third parties for the third parties’ marketing purposes.
We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.
To opt out of receiving marketing-related correspondence from Smart Sure, update your preferences here
Updates and Effective Date
Agreeing to Terms