Privacy Policy

Social Money Solutions (SMS) is committed to ensuring that your privacy is protected. This policy has been drafted with regard to SMS’s obligations under the Privacy Act 1988 (including the newly updated National Privacy Principles). This policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.

1. Collection

1.1 SMS will only collect Personal Information where the information is necessary for SMS to perform one or more of its functions or activities. In this context “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.

We may collect the following information:

name and job title
contact information including email address
demographic information such as postcode, preferences and interests
other information relevant to customer surveys and/or offers

What we do with the information we gather

1.2 SMS collects Personal Information primarily to conduct its business and or supply clients who obtain SMS products and services directly from SMS. SMS also collects and uses Personal Information for secondary purposes including:

Provision of products and services
Accounting purposes
Business planning and product development

1.3 SMS will notify individuals (including, but not limited to, our clients) of the matters listed below at the time of collecting any Personal Information:

the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
other related Uses or Disclosures that we may make of the Personal Information (Secondary Purposes);
our identity and how individuals can contact us, if this is not obvious;
that individuals can access the Personal Information that SMS holds about them;
that individuals should contact SMS if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
the organisations or types of organisations to whom we usually Disclose the Personal Information;
where applicable, any law that requires the Personal Information to be collected;

1.4 Where it is not practicable for SMS to notify individuals of all of the Collection Information before the collection of Personal Information, SMS will ensure that individuals are notified of the Collection Information as soon as possible after the collection.

1.5 SMS will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for SMS to collect such information for an activity or function.

1.6 SMS will not collect Personal Information secretly or in an underhanded way.

1.7 SMS will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.

2. Use

2.1 SMS will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.

2.2 SMS Uses Personal Information primarily for the purposes listed in 1.2 above.

2.3 If SMS is involved in Direct Marketing to individuals it will ensure that:

individuals are clearly notified of their right to Opt Out from further Direct Marketing; and
if the individual Opts Out of all Direct Marketing the Opt Out will be respected by SMS and implemented free of charge.

2.4 SMS will not use Sensitive Information for Direct Marketing.

2.5 SMS may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.

2.6 SMS will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

2.7 SMS will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.

3. Protect

3.1 Internal record keeping

We may use the information to improve our products and services.

We may occasionally email you information which we think you may find interesting using the email address which you have provided.

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone or mail.

We may use the information to customise the website according to your interests.

We may provide your information to our third-party partners for marketing or promotional purposes.

3.2 Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

3.3 Links to other websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

3.4 Third parties

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen. You may request details of personal information which we hold about you under the Data Protection Act 1998. If you believe that any information we are holding on you is incorrect or incomplete, please contact us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Should we ask you to provide certain information by which you can be identified when using our website, then you can be assured that it will only be used in accordance with this privacy statement.

Social Money Solutions may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from March 2014.