Privacy Policy & Website Terms

Privacy Policy

As the operators of the website: www.smart.stream, Smartstream is committed to protecting and respecting your privacy.

This Privacy and Cookies Policy (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the General Data Protection Regulation (GDPR), from the GDPR implementation date or, until GDPR implementation date, the Data Protection Act 1998, (collectively the Data Protection Laws) the Data Controller is Smartstream Technologies.

YOUR PERSONAL INFORMATION

We collect and process some or all of the following types of information from you in the course of your use of the website or providing our services:

Information that you provide by filling in forms or using our service. This includes information provided at e.g. the time of registering to use the website in order to register for events, download content, requesting further information or make a meeting request. We may also ask you for information when you report a problem with the website.
If you contact us, we may keep a record of that correspondence.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

The provision of name, title, job title, company, country, telephone and email address is required from you to enable us to respond to any website query. We will inform you at the point of collecting information from you.

Information We Collect From Other Sources

Where we exhibit at industry events we will also obtain personal data from other sources as follows:

Information on business cards
Name and contact details from industry organisers

Google Analytics

This website uses Google Analytics, a web analytics tool from Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA; “Google”). The usage is based on Art. 6 Par. 1 S. 1 lit. of GDPR. Google Analytics uses ‘Cookies’, text files, that are saved on your computer and allow us to analyse the usage of our website. The Information that is tracked is as follows:

Type of browser and version
Operating system
Referring URL (the last visited page)
Hostname (with anonymized IP address)
Time of request

This data is usually sent to servers of Google in the USA and stored there. The tracked IP address will not be brought together with other data of Google. We additionally extended the code with “anonymizeIP” which masks IP addresses to anonymize them. Only in exceptional cases full IP addresses will be transferred to the Google servers in the USA and masked there.

I order by the operator of this website, Google will use this information to evaluate the usage of this website, produce reports over the website activities and usage. You can prevent the usage of cookies through certain browser settings, but we need to inform you that some functionality of the website will not work if cookies are turned off completely.

You can restrict the collection and processing of the above data (including the IP address) if you install a browser plugin from the following internet address: http://tools.google.com/dlpage/gaoptout?hl=en.

Alternatively, you can set an opt-out-cookie to disable Google Analytics tracking in your browser. This cookie will only block analytics in the browser you activate it in and will only work for our website. If you delete cookies in your browser, you will need to set it again. Disable Google Analytics now.

We also use Google Analytics to analyse Double-Click and AdWord campaigns we are hosting on Google. You can set your preferences for Google Ads here: http://www.google.com/settings/ads/onweb/?hl=en

USES MADE OF YOUR INFORMATION

Lawful basis for processing

We rely on your consent as provided when you register your details on our website to fulfil our contractual obligations to you as the lawful basis on which we collect and use your personal data.

Purposes of processing

We use information held about you in the following ways:

To contact you about future events
To contact you with our newsletter
To provide you with company information we feel may interest you
To notify you about changes to our service

How we do this

We will contact you by the method you have consented to receive such communication; this will be electronic means (e-mail) and/or a telephone call. If you do not want us to use your data in this way please either 1) tick the relevant box situated on the form on which we collect your data; 2) unsubscribe from our electronic communications using the method indicated in the relevant communication; or 3) inform us at any time by contacting us on the details set out below.

DISCLOSURE OF YOUR INFORMATION

We routinely disclose your personal data to third parties as follows:

We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).

We may also disclose your personal data to third parties:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website Terms and Conditions and subscribing to our service; or
To protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Website; or
In relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.

Other than as set out above and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.

STORING YOUR PERSONAL DATA

Security

We take appropriate measures to ensure that any personal data are kept secure, including security measures 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. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential.

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.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Keeping your personal data up to date

If your personal details change you may update them by e.g. accessing the relevant page of the website, or by contacting us using the contact details below.

If you have any questions about how we use data collected which relates to you, please contact us by using one of our contact methods as stated on our Website.

We will endeavour to update your personal data within seven working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.

How long we keep your personal data

We will hold personal data for the period we are required to retain this information, in this case for three years.

Where we store your personal data

All information we hold about you is stored on our secure servers within the EEA. The data that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staffs operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders. By submitting your personal data, you agree to this transfer, storing or processing.

Such countries do not have the same data protection laws as the EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the EEA, any transfer of your personal data will be subject to suitable relevant safeguards as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.

If you would like further information please contact us. We will not otherwise transfer your personal data outside of the EEA 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.

PRIVACY NOTICE (GDPR) – JOB APPLICANTS

As part of any recruitment process, the organisation collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

Data controller: Smartstream Technologies, 62-64 Cornhill, First Floor, London, EC3V 3NH, United Kingdom
Representative: David Porter, HR Director
Dated: 24 May 2018 | Version: 1.0

What information does the organisation collect?

The organisation collects a range of information about you. This includes:

your name, address and contact details, including email address and telephone number;
details of your qualifications, skills, experience and employment history;
information about your current level of remuneration, including benefit entitlements;
whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process; and
information about your entitlement to work in the country of your choice as per application.

The organisation may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

The organisation may also collect personal data about you from third parties, such as references supplied by former employers and information from criminal records checks. The organisation will seek information from third parties only once a job offer to you has been made and will inform you that it is doing so as part of background verification process.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Why does the organisation process personal data?

The organisation needs to process data to take steps at your request prior to entering into a contract with you. It may also need to process your data to enter into a contract with you.

In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check a successful applicant’s eligibility to work in the country before employment starts.

The organisation has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows the organisation to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide on whom to offer a job. The organisation may also need to process data from job applicants to respond to and defend against legal claims.

The organisation may process special categories of data, such as information about ethnic origin, sexual orientation or religion or belief, to monitor recruitment statistics. It may also collect information about whether or not applicants are disabled to make reasonable adjustments for candidates who have a disability. The organisation processes such information to carry out its obligations and exercise specific rights in relation to employment.

For some roles, the organisation is obliged to seek information about criminal convictions and offences. Where the organisation seeks this information, it does so because it is necessary for it to carry out its obligations and exercise specific rights in relation to employment.

If your application is unsuccessful, the organisation may keep your personal data on file in case there are future employment opportunities for which you may be suited. The organisation will ask for your consent before it keeps your data for this purpose and you are free to withdraw your consent at any time.

CVs that are sent speculatively may also be kept on file for future recruitment exercises.

Who has access to data?

Your information may be shared internally for the purposes of the recruitment exercise. This includes members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.

The organisation will not share your data with third parties, unless your application for employment is successful and it makes you an offer of employment. The organisation will then share your data with former employers to obtain references for you and the Disclosure and Barring Service to obtain necessary criminal records checks.

The information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers, group companies or subsidiaries may be located outside of the EU.

Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy.

By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.

How does the organisation protect data?

The organisation takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees in the proper performance of their duties.

For how long does the organisation keep data?

If your application for employment is unsuccessful, the organisation will hold your data on file for 6 months after the end of the relevant recruitment process. At the end of that period [or once you withdraw your consent], your data is deleted or destroyed.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in employee privacy notice.

Your rights

As a data subject, you have a number of rights. You can:

access and obtain a copy of your data on request;
require the organisation to change incorrect or incomplete data;
require the organisation to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and
object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing.

If you would like to exercise any of these rights, please contact datasubjectrights@smart.stream.
If you have any concern with your data being misused or leaked by SST, please contact databreach@smart.stream.

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the organisation during the recruitment process. However, if you do not provide the information, the organisation may not be able to process your application properly or at all.

YOUR RIGHTS

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

Access to your personal data and to certain other supplementary information that this Policy is already designed to address.
Require us to correct any mistakes in your information which we hold
Require the erasure of personal data concerning you in certain situations
Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
Object at any time to processing of personal data concerning you for direct marketing
Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
Object in certain other situations to our continued processing of your personal data
Otherwise restrict our processing of your personal data in certain circumstances
Claim compensation for damages caused by our breach of any data protection laws

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:

Email, call or write to us
Let us have enough information to identify your name or company
Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
Let us know the information to which your request relates

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information, email: databreach@smart.stream

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at: https://ico.org.uk/concerns/ or telephone: 0303 123 1113

CHANGES TO OUR PRIVACY POLICY

We reserve the right to modify this policy at any time. Any changes we may make to our policy in the future will be notified and made available to you using the website. Your continued use of the services and the website shall be deemed your acceptance of the varied privacy policy.

INFORMATION ABOUT OUR USE OF COOKIES AND IP ADDRESSES

We use cookies on our site: www.smart.stream for a number of purposes. They help us to provide you with a good experience when you browse our website, and also allow us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users find what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed.

You can find more information about the individual cookies we use and the purposes for which we use them below.

First-party cookies (www.smart.stream and smartsteam.ai)

This website will set some cookies that are essential for the website to operate correctly. These cookies, none of which capture personally identifiable information, are e.g. as follows:

Visitor ID – this cookie is a numeric value that identifies unique visitors and provides coherence and consistency to a site visit;
Page Number – this cookie identifies the page you are on;
Session ID – this cookie identifies your website session;
Test – this cookie checks whether or not your browser supports cookies;
Cookie Consent – remembers your agreement that our cookies policy

Third-party cookies

Our websites will set several types of third-party cookie, and we do not control the operation of any of them. The third-party cookies which may be set include:

Google Analytics – we use Google Analytics to collect data about website usage. This data does not include personally identifiable information. You can view the Google Privacy Policy here: www.google.com/policies/privacy/.
YouTube – this allows us to display embedded videos on our site. YouTube is setting these cookies to track watched videos and to be able to present appropriate content to you. You can read the YouTube Privacy Policy here: https://www.youtube.com/static?template=privacy_guidelines.
AddThis – these cookies are used when you use the sharing service on our website to share a link with LinkedIn, Facebook, Twitter, etc. You can read the AddThis Privacy Policy here: http://www.addthis.com/privacy/privacy-policy.
Google Remarketing / AdWords / DoubleClick – we use Google’s Remarketing / AdWords / DoubleClick cookies to market products and services we think may be of interest to you. You may see our adverts on Google’s Display Advertising Network of partner websites and Google’s own search results pages. We aim to carefully select the products and services we remarket to you, and do so based on the pages you have visited on our website. You can set your Google Ads preferences here: https://adssettings.google.com/authenticated . The Google Ads Privacy Policy can be found here: https://policies.google.com/technologies/ads
Facebook – we may use a Facebook pixel to obtain information regarding the activities that users engage in while visiting our web pages. For information on Facebook’s Privacy and Cookie policy, visit https://www.facebook.com/policies/cookies/
Pardot – we use Pardot as our email marketing tool and these cookies allow us to understand how you are interacting with our email communication. The Pardot Privacy Policy can be found here: https://www.pardot.com/legal/

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Cookie consent management

To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.

The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.

Some services process personal data in unsecure third countries. By consenting to the use of these services, you also consent to the processing of your data in these unsecure third countries in accordance with Art. 49 (1) lit. a GDPR. This involves risks that your data will be processed by authorities for control and monitoring purposes, perhaps without the possibility of a legal recourse.

You are under 16 years old? Unfortunately, you are not permitted to consent to this service to view this content. Please ask your parents or guardians to agree to the service with you!

By accepting all services, you allow Google Tag Manager (Functional), YouTube (Functional, data processing in unsecure third countries), Buzzsprout Podcasts (Functional), SoundCloud (Functional, Data processing in unsecure third countries), Spotify (Functional), Google Fonts (Functional, Data processing in unsecure third countries), Adobe Fonts (Functional), WordPress Emojis (Functional, Data processing in unsecure third countries), Google reCAPTCHA (Functional, Data processing in unsecure third countries), Consentric (Functional), Smartstream Recruiting Platform (Functional), LinkedIn Insight-Tag (Marketing), Pardot Email Marketing (Marketing) and Pardot Marketing Automation (Marketing) to be loaded. These services are divided into groups Essential, Functional and Marketing according to their purpose (belonging marked with superscript numbers). In addition, Elementor (Essential), WPML (Essential), Wordfence (Essential) and Cloudflare (Essential) are loaded based on a legitimate interest.

CONTACT AND OPT-OUT

All questions, comments and requests regarding this Privacy and Cookies Policy or to opt-out from communications, write to us at: info@smart.stream or Smartstream Technologies, 62-64 Cornhill, First Floor, London, EC3V 3NH, United Kingdom.

Smartstream Website Terms and Conditions

Smartstream Technologies Limited (“Smartstream”) has its registered office at 62-64 Cornhill, First Floor, London, EC3V 3NH, United Kingdom; company number: 02285524.

D-Clear Europe Ltd is a company incorporated in England and Wales. Registered office: 12 St James’s Square, London SW1Y 4RB; company number: 06412118

If you would like to contact Smartstream, please click on the ‘Contact’ section on the home page of the website (“the Website”).

By accessing this Website, you agree to be bound by the following terms and conditions and disclaimers (the “Terms”). Please read the details set out below carefully.

‘you’, ‘your’ and ‘yours’ refer to the person(s) accessing the Website
‘we’, ‘us’ and ‘our’ refer to Smartstream

Terms

These Terms are to be read by you in conjunction with any other terms, conditions and disclaimers provided or referred to in the pages of the Website. In the event of any conflict, the terms, conditions and disclaimers provided in the pages of the Website shall prevail over these Terms.

We may change the information, material and content provided on the Website at any time. Your continued access to or use of the Website will mean that you agree to any changes we may make.

Users

You use the Website at your sole risk and you are wholly responsible for such use. You must not use the Website for fraudulent purposes or in connection with any unlawful activity. You must not use the Website in any way that causes, or is likely to cause, the Website or access to it to be interrupted, damaged or impaired in any way.

We shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages, losses, costs or expenses nor for any loss of profit that results from the use of, or inability to use, this Website or any material on any site linked to this Website (including, but not limited to, any viruses or any other errors or defects or failures in computer transmissions or network communications) even if we have been advised of the possibility of such damage. In addition, no liability can be accepted by us in respect of any changes made to the content of the Website by unauthorised third parties. All express or implied warranties or representations are excluded to the fullest extent permissible by law. Smartstream does not limit in any way its liability by law for death or personal injury caused by our negligence, breach of duty, gross negligence or wilful misconduct.

Nothing on this Website shall be deemed to constitute financial or other professional advice in any way. If any advice or guidance is required on Smartstream’s products or services, please contact us as directed on this Website.

Any software is downloaded at your own risk. If you are in any doubt as to the suitability of the software to be downloaded for your computer, it is recommended that you obtain specialist advice before downloading it.

These statements do not affect your statutory rights.

Third party products, services and websites

This Website may contain links to third-party websites. These are provided for information only and we are not responsible for the content of any other websites or pages linked to or linking to this Website. No third party website may be linked to the Website without Smartstream’s prior written consent.

Smartstream excludes responsibility for the suitability or availability of third party products or services which may appear on or be linked to the Website from time to time.

Access and Accuracy

The information contained in this Website is based on up-to-date information and, while Smartstream takes care to ensure that material on this Website is correct, current and complete at the date of publication, accuracy cannot be guaranteed. Smartstream makes no warranties or representations (express or implied) as to its accuracy, currency or completeness. You should take appropriate steps to verify all information on this Website before acting upon it.

Smartstream will try to ensure that the availability of the Website will be uninterrupted and error-free. However, this cannot be guaranteed. Your access to the Website may be occasionally suspended or restricted to allow for repairs, maintenance, or the introduction of new facilities or services. We will, however, attempt to limit the frequency and duration of any such suspension or termination.

Trade marks and copyright

Copyright in this Website is owned by or licensed to Smartstream, unless otherwise noted. You may imprint, copy, download or temporarily store extracts from our Website for your personal information or when you use our products and services. Any other use is prohibited without our prior written permission. If you would like further information in this connection, please contact us using the ‘Contact Us’ link on the Website.

This Website, or any portion of it, may not be reproduced, duplicated, copied, sold or visited without our express written consent.

Data protection

Please see our Privacy Policy section.

Governing law

The Website and these Terms are governed by the law of England and Wales and the English courts shall have the non-exclusive jurisdiction to hear any dispute arising out of them.

Solution Privacy Policy

Introduction

Smartstream offers suite of integrated solutions that are used by our customers to seamlessly manage their business functions. This Privacy Policy applies to all our customers as well as guest users who access Smartstream’s on demand service.

This policy describes how Smartstream collects, uses, and discloses information, and what choices you have with respect to the information.

Services

It is Smartstream’s policy to respect your privacy regarding any information we may collect while using our on demand service.

Smartstream operates a suite of web-based applications (TLM Reconciliations Premium, TLM Corporate Actions, TLM Fees and Expense Management etc.) collectively deployed as an on demand service. All such solutions, applications, webpages are collectively called “Services”.

This Privacy Policy applies when you use our Services. For our clients and their employees, a link to this privacy policy is also available in “login” and “home page” of the application.

Data Controller and Data Processor

We process two main types of personal data.

Customer data – Personal data that forms part of data that is provided by our customers and their end-users for processing.
Other data – Personal data about our customers, visitors and other individuals that is collected and processed directly by us.

Our Customers are the controller of Customer Data. Smartstream is the processor of Customer Data and the controller of Other Data.

Information we collect

Customer data

As customers, you provide data to us for processing as part of usage of our Smartstream applications.

Customer Data may be processed by us as a result of customer’s use of the Services when our customers, or their end-users, input, or upload information into the Service. For example, customers who use our Smartstream application may upload Customer Data about themselves or their employees or their clients.

This data includes name, email address, phone number, job title etc. for your employees.

Other data

Customers provide data that is necessary to create user accounts.

For creation of user accounts, you provide your name, email address, password, and telephone number.

We also collect data when you use our applications.

Log data – Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address
Subscription data – You provide personal data to us as part of requesting customer support, or otherwise communicating with us.
Contact us data – When you raise query about our products and services, we collect and store this data to communicate with you and respond to your enquiry.

Data from others

Smartstream may receive your data from sources other than from you, such as user id creation request, escalation matrix, point of contact, workflow tool etc.

How we use your data

How we use your personal data will depend on which Services you use and how you use those Services.

Customer Data will be used by Smartstream in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. Smartstream is a processor of Customer Data and Customer is the controller.

Other Data is used by us to provide our services and to communicate with you by responding to your requests, comments, and questions.

Lawful bases for processing

We have lawful bases to process your personal data. We also use your consent as bases for lawfully processing your personal data.

We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the Data Protection Regulations.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

Where you have consented to a particular processing, you have a right to withdraw the consent at any time.

How we use customer data

We use your data to authenticate you and authorize access to our services

We only process Customer Data on behalf of our customers and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you. In each case, Smartstream collects such information only in so far as is necessary or appropriate to fulfil the purpose of the interaction with our services.

To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services and our Services offerings. These communications are considered part of the Services and you may not opt out of them.
Customer support. If you send us a request (for example via a support email or via one of our feedback mechanisms), we respond to your request or to help your issues.

For any other purpose as provided for in the Services Agreement between us and the customer, or as otherwise authorized by the customer.

In accordance with or as may be required by law.

How we use other data

We may send you service-related messages or materials. You may choose to restrict the collection or use of your personal information

We will update your details for application credentials, communicate with you for addressing your queries etc.

Users under 16 years of age

The Services do not knowingly collect personal information from users under the age of 16

If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

Data retention policy

We will retain your personal information for as long as is needed to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Customer Data – We retain your information for as long as you have an active Services account. We may also retain your personal information for extended period under applicable statutory laws.

Smartstream will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. When you decide to close your account, we delete all personal information about you.

Other Data – We retain your information for as long as necessary for the purposes that we have described in this privacy policy

Smartstream may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy

Your rights

You can request to access, update, or correct your personal information.

You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.

Your rights to control data

Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to, or restrict use of your personal information

We strive to give you ways to access, update/modify your data quickly or to delete it unless we have to keep that information for legal purposes. Some rights can be access from within the Smartstream application. For visitors, these rights can be exercised by contacting us with your specific request.

Change or correct data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
Delete data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
Object to, or limit or restrict, use of data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
Right to access and/or take your data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

Account closure

We keep some personal data even after account closure.

Once you choose to close your account, we generally delete your personal information within 60 days of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained, as necessary.

Your information shared with others

Recipients of your data

Your data will be shared with other recipients in order to provide you with services.

While we aim to limit the sharing of your data, at times, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data centre / hosting services, email services, etc.

The following categories of recipient will most likely receive your data in order for us to provide services to you:

Third party data centre services
Third party SMTP services such as Microsoft
Other modules of Smartstream applications to which you may or may not have subscribed to

To comply with laws – if we receive a request for information, we may disclose if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.

Cross-border data transfers

Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region.

Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centres in the US and APAC region. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer.

Smartstream offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between Smartstream and its Clients, suppliers, or data processors outside the EU), binding them to protect the privacy and security of the data.

Security measures to protect your data

Security measures

We implement security controls to prevent breaches and unauthorised access to your data.

We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Examples of security measures include physical access controls, HTTPS, restricted access to data, monitoring for threats and vulnerabilities etc.

We also subject our services to internationally recognised certification and attestation standards.

Protection of personal information

Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information.

Smartstream takes all measures reasonably necessary to protect against the unauthorised access, use, alteration, or destruction of potentially personally identifying and personally identifying information.

Other information

Contact information

You can contact us about this Privacy Policy or use of our services.

If you have questions or complaints regarding this policy, you may contact us through email at info@smart.stream or STL-Support@smart.stream. You may contact us at our mailing address below:

Smartstream Technologies, 62-64 Cornhill, First Floor, London, EC3V 3NH, United Kingdom.

If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.

Privacy policy change

Smartstream may change this Privacy Policy from time to time, at our sole discretion.

Smartstream encourages visitors and customers to frequently check this page for any changes to its Privacy Policy. We will notify you of material changes in advance by email or by notice when you log in to the Sites and Services or both. You confirm that your continued use of our services after any change in this Privacy Policy will constitute your acceptance of such changes and agree to be subject to the revised Privacy Policy.

Group Policy

Smartstream is committed to having at its core a culture that actively promotes sustainable development.

Sustainable development is “development that meets the needs of the present, without compromising the ability of future generations to meet their growing needs.”

Smartstream is committed to compliance with all local employment and Health and Safety legislation and has its own policies to support and enforce compliance.

Smartstream is an Equal Opportunity Employer. Smartstream does not discriminate against any employee or applicant for employment because of race, colour, creed, religion, sex, national origin, ancestry, gender, veteran status, disability, age, citizenship, sexual orientation, marital status, gender identity or expression, predisposing genetic characteristics or because of any other criteria prohibited by applicable laws.

In addition, Smartstream is committed to compliance with the United Nations Universal Declaration of Human Rights as it relates to any employment matter.

Smartstream is committed to wholly support and comply with or exceed the current international standards and EU environment legislation and codes of practice.

View our Modern Slavery and Human Trafficking Statement

UK Tax Strategy

UK Tax Strategy – December 2024

Smartstream at a glance

Smartstream is a global software and managed services provider focused on front, middle and back operations in the financial markets sector. Smartstream operates internationally with offices in many countries.

Smartstream is owned by the Investment Corporation of Dubai, the principal investment arm of the Government of Dubai, United Arab Emirates.

In accordance with the provisions contained in Schedule 19 part 1 and 2 of the UK Finance Act 2016, Smartstream publishes its tax strategy in relation to its United Kingdom tax affairs. The tax strategy will be reviewed periodically, updated as appropriate and approved by the Board.

Our approach to managing tax risk and governance

The Chief Financial Officer has overall ownership for tax risk and tax governance.

Smartstream uses its in-house finance team and professional advisors to manage its day to day tax affairs.

Smartstream ensures that its finance team is actively involved in business strategies and transactions at an early stage so that any tax risks are identified and managed and external advice obtained where necessary.

Our attitude to level of acceptable risk

As a business with offices in many countries, this brings about its own complexity with different tax legislation and tax codes which can give rise to risks in relation to compliance obligations and interpretation of the tax law.

Smartstream mitigates this risk by engaging with professional advisors to obtain appropriate professional advice.

Our attitude to tax planning

Smartstream seeks to make use of tax reliefs or opportunities that are available in line with the spirit of the tax legislation and which has substance that supports the business and reflects genuine commercial and economic activity.

Our approach towards working with HMRC

Smartstream engages with HMRC in an open, transparent, professional and respectful manner.

Smartstream addresses any enquires or information requests from HMRC as a priority and deals with them on a timely basis.