Last Updated: 24 May 2018
This privacy statement sets out how Smart Alpha (the data controller) uses and protects any information that you provide to us when you use the smartalpha.global website or otherwise provide Smart Alpha with your personal information.
Smart Alpha is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using the website, you can be assured that it will only be used in accordance with this privacy statement.
Smart Alpha 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 24 May 2018.
By providing us with your personal information, you agree and consent to its transfer, processing, use and disclosure as outlined in this privacy statement.
What we collect:
We collect personally identifiable information (PII) that you provide to us, which is information that identifies you as an individual. We only do this when you have agreed to our request for that information. This PII may include your:
· Name in full.
· Contact information including email address and phone number.
· Demographic information such as postcode, street name, residency number.
What we do with the information we gather:
We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:
· To allow Smart Alpha to accurately deliver our service.
· Internal record keeping, such as new user or repeat customer.
· To improve our products and services.
· To send you emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
· To respond to your requests or queries and improve the content of our communication.
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.
Sharing PII with 3rd Parties:
At Smart Alpha we do not pass personal information on to any 3rd party providers
How we protect your PII:
Smart Alpha will take appropriate legal, organizational, and technical measures to protect your personal information consistent with applicable privacy and data security laws. When Smart Alpha uses a third-party service provider including a Service Partner, that provider will be carefully selected and required to use appropriate measures to protect the confidentiality and security of personal information. We use a variety of security technologies and procedures to help protect your PII from unauthorised access, use or disclosure. Unfortunately, the transmission of information via the Internet or a mobile phone network connection is not completely secure. Although we will do our best to protect your PII, we cannot guarantee the security of the PII you transmit to our websites: any transmission is at your own risk. While we cannot guarantee that loss, misuse or alteration to data will not occur, once we have received your information, we will employ appropriate technical security measures to prevent such unfortunate occurrences.
How we use cookies:
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
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.
Links to other websites:
Our website may contain links to other websites of interest. 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.
When we may disclose your PII to others:
Smart Alpha reserves the right to disclose personal information about you, including your e-mail address, for reporting to government authorities, to parties in relevant legal proceedings as authorized by the presiding court or tribunal and otherwise to the extent required or explicitly authorized by applicable law. In certain special cases where permitted by local law, we may disclose your PII:
· When we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to you or otherwise injuring or interfering with Smart Alpha’s rights, property or operations, other users of this website or mobile application or anyone else who could be harmed by such activities.
· When we believe the law requires it, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.
· In connection with a substantial corporate transaction, such as the sale of a product line or division, a merger, consolidation, asset sale or in the unlikely event of bankruptcy.
PII collected may be transferred to, stored and processed in your country of residence or any other country in which Smart Alpha (including its affiliates), subcontractors or agents maintain facilities, including the United States and countries outside the European Economic Area (EEA). This means that your information may be processed in countries with lower data protection standards than your country of residence. By using our website, you consent to any transfer, processing or storing of information outside of your country of residence and outside the EEA. We will ensure that if information is transferred outside your country of residence, it will still be treated in accordance with this Privacy Statement.
Use of IP Addresses
An IP address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet service provider or through your organisation's local area network (LAN) or wide area network (WAN). Web servers automatically identify your computer by the IP address assigned to it during your session online.
Smart Alpha, or third party companies acting on our behalf, may collect IP addresses for the purposes of systems administration and to audit the use of our websites. We also may use IP addresses to identify users of our websites when we feel it is necessary to enforce compliance with the websites’ terms of use or to protect our service, websites or other users.
Controlling your Personal Information:
You may choose to restrict the collection or use of your personal information in the following ways:
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the below email address. We will promptly correct any information found to be incorrect.
Contact information:
Data Controller: Dave McEwan
Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
Post: Smart Alpha, C/O Delta Global Limited, Suite 925A, Block 8/9, Gibraltar