Privacy and Policy
PRIVACY POLICY
Introduction
1.1 We are committed to safeguarding the privacy of our
users. This policy is designed to ensure that we safely handle your personal
data in accordance with relevant regulations and legislation such as Data
Protection Act 1998 and the EU General Data Protection Regulations 2018 (the
“Data Protection Regulations”).
1.2 This policy applies in those cases where we act as
a data controller for the personal data of our website visitors and service
users. This means those cases where we can decide the purposes and method of
processing your personal data.
1.3 By using our website, you are agreeing to the terms
of this policy.
1.4 These privacy rules explain what data we may
collect from you, what we will do with that data and explains how you can limit
the publication of your information and how you can choose whether you would
like to receive direct marketing communications.
1.5 In this policy, “we”, “us” and “our” refer to
iSmarten Ltd, the owner and operator of the iSmarten.co platform. Further
details about us can be found below, in section 9 of this Privacy Policy.
1.6 We reserve the right to update and make changes to
this Privacy Policy from time to time. You should check back regularly to
ensure that you are up to date with any changes to this policy. Any changes
posted will influence the date of such posting.
How We Use Your Personal Data
2.1 In Section 2 we set out:
(a) the general categories of personal data that we may
process.
(b) the purposes for which we may process personal
data; and
(c) the legal basis of the processing in each case.
2.2 We may obtain personal data from you:
(a) when you register with us on our website.
(b) when you complete the iSmarten.com Profile Builder.
(c) by talking to our representatives, advisors, or
experts.
(d) which you give to us over the phone or by email or
by text message.
2.3 We may process data about your use of our website
and services (“usage data “). The usage data may include your IP address,
geographical location, browser type and version, operating system, referral
source, length of visit, page views and website navigation paths, as well as
information about the timing, frequency and pattern of your website or service
use. The source of the usage data is our analytics tracking system. This usage
data may be processed for the purposes of analysing the use of the website and
services. The legal basis for this processing is either your specific consent
or where we are not legally required to ask for consent, we may process this
data for our legitimate interests, namely monitoring and improving our website
and services.
2.4 We may process your account data (“account data “).
The account data may or may not include your name, surname, date of birth,
marital status, family details, home address, email address, mobile phone
number, your qualifications, your passport details, financial data such as bank
account, payment details, card details, and your website user ID and password.
We may also receive from your photographs, and copies or photocopies of
educational documents. The account data may be processed for the purposes of
providing our services to you, operating our website, ensuring the security of
our website and services, maintaining back-ups of our databases, and
communicating with you. Specific services, which may be the subject of your
account data, include but are not limited to, using such data for the following
purposes:
(a) to provide, personalise and improve the products
and services that we offer to you.
(b) to notify you of news and events.
(c) to assist us to measure and analysing the use of
the website to improve the services we can offer to you.
(d) to ensure the safety, integrity, and security of
our website; and
(e) to communicate with you.
The legal basis for this processing is either your
specific consent or where we are not legally required to ask for consent, we
may process this data for our legitimate interests, namely providing services
requested and monitoring and improving our website and services.
2.5 We may process information relating to
transactions, including purchases of goods and services that you enter with us
and/or through our website (“transaction data “). The transaction data may
include your contact details, your card details, and the transaction details.
The transaction data may be processed for the purpose of supplying goods or
services and keeping proper records of those transactions. The legal basis for
this processing is the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract and our legitimate
interests, namely our interest in the proper administration of our website and
business.
2.6 We may process any of your personal data identified
in this policy where necessary for administrative purposes including in the
exercise or defence of legal claims. The legal basis for this processing is our
legitimate interests, namely for administrative record-keeping, processing
transactions and maintaining business records or for the protection and
assertion of our legal rights.
2.7 If you supply any other person’s personal data to
us, you must do so only if you have the authority of such person to do so and
you must comply with any obligations imposed upon you under the Data Protection
Regulations.
The following table shows a sample of the typical
personal information we may collect from you (although this table is not exhaustive
and is subject to change):
Data Type, Details of Data Collected, Personal Identity
data, Name, Passport (Front & last page), Driving Licence, Nationality,
Date of Birth, Gender, Country of Citizenship & Country & City of
Residence, Contact data, Email Address, Mobile Number, Home Address, and Social
Media.
The following table shows how we may use information
about you:
Purpose/Activity
Type of data
Lawful basis for processing including the basis of
legitimate interest
To register you as a new member
(a) Identity
(b) Contact
To process and deliver your request, including:
(a) Manage payments, fees, and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover
debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy
policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our
records updated and to study how customers use our products/services)
To administer and protect our business and this website
(including troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running
our business, provision of administration and IT services, network security, to
prevent fraud and in the context of a business reorganisation or group restructuring
exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements
to you and measure or understand the effectiveness of the advertising we serve
to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how
customers use our products/services, to develop them, to grow our business and
to inform our marketing strategy)
To use data analytics to improve our website,
products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types
of customers for our products and services, to keep our website updated and
relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about
goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our
products/services and grow our business)
Providing Your Personal Data to Others
3.1 We may disclose your personal data to any member of
our group of companies (this means our subsidiaries, our holding company and
its subsidiaries) insofar as reasonably necessary for the purposes, and on the
legal basis, set out in this policy.
3.2 We may disclose your personal data to our insurers
and/or professional advisers insofar as reasonably necessary for the purposes
of obtaining or maintaining insurance coverage, managing risks, obtaining
professional advice, or exercising or defending legal claims.
3.3 We may pass your personal information to credit
reference agencies or other agencies that provide services to verify your identity
or for any other checks or searches required by legislation or our regulators
relating to money laundering. These agencies may keep a record of any search
that they do.
3.4 If you carry out financial transactions through our
website, these services will be handled by our payment services providers. We
share transaction data with our payment services providers to the extent
necessary for the purposes of processing your payments, refunding such
payments, and dealing with complaints and queries relating to such payments and
refunds.
3.5 We may outsource or contract the provision of IT
services to third parties. If we do, those third parties may hold and process
your personal data. In these circumstances, we will require that the IT
supplier only process your personal data for us, as directed by us, and in
accordance with the Data Protection Regulations.
3.6 If we sell all or part of our business, we may pass
your personal data to the purchaser. In these circumstances, we will require
the purchaser to contact you after completion of the sale to inform you of the
identity of the purchaser.
3.7 In addition to the specific disclosures of personal
data set out in this Section 3, we may disclose your personal data where such
disclosure is necessary for compliance with a legal obligation to which we are
subject, or in order to protect your legal interests or the legal interests of
another person.
International Transfers of Your Personal Data
4.1 In Section 4, we provide information about the circumstances
in which your personal data may be transferred to countries outside the
European Economic Area (EEA).
4.2 Except where such transfer is made with your
consent or is required in order to fulfil the terms of any services requested
from us, we will not transfer any of your personal data to any country outside
the EEA unless such transfer is to an organisation that provides adequate
safeguards in compliance with the Data Protection Regulations.
4.3 You acknowledge that personal data that you submit
for publication through our website or services may be available, via the
Internet, around the world. We cannot prevent the use (or misuse) of such
personal data by others.
Retaining and Deleting Personal Data
5.1 Section 5 sets out our data retention policies and
procedure, which are designed to help ensure that we comply with our legal
obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose shall
not be kept for longer than is necessary for that purpose. This means that
unless there is a good reason to do so we will not keep your personal data more
than 6 years after our business relationship has ended.
5.3 Notwithstanding the other provisions of this
Section 5, we may retain your personal data where such retention is necessary
for compliance with a legal obligation to which we are subject, or in order to
protect your legal interests or the legal interests of another person.
Amendments
6.1 We may update this policy from time to time by
publishing a new version on our website.
6.2 You should check this page occasionally to ensure
you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by
email or through the private messaging system on our website.
Your Rights
7.1 In Section 7, we have summarised the rights that
you have under data protection law. Some of the rights are complex, and not all
the details have been included in our summaries. Accordingly, you should read
the relevant laws and guidance from the regulatory authorities for a full
explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access.
(b) the right to rectification.
(c) the right to erasure.
(d) the right to restrict processing.
(e) the right to object to processing.
(f) the right to data portability.
(g) the right to complain to a supervisory authority;
and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether we
process your personal data and, where we do, access to the personal data,
together with certain additional information. That additional information
includes details of the purposes of the processing, the categories of personal
data concerned and the recipients of the personal data. Providing the rights
and freedoms of others are not affected, we will supply you with a copy of your
personal data, as described below (clause 7.13).
7.4 You have the right to have any inaccurate personal
data about you rectified and, considering the purposes of the processing, to
have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the
erasure of your personal data without undue delay. Those circumstances include:
the personal data is no longer necessary in relation to the purposes for which
it was collected or otherwise processed; you withdraw consent to consent-based
processing; you object to the processing under certain rules of applicable data
protection law; the processing is for direct marketing purposes, and the
personal data have been unlawfully processed. However, there are exclusions of
the right to erasure. The general exclusions include where processing is
necessary: for exercising the right of freedom of expression and information; For
compliance with a legal obligation; or for the establishment, exercise, or
defence of legal claims.
7.6 In some circumstances you have the right to
restrict the processing of your personal data. Those circumstances are: you
contest the accuracy of the personal data; processing is unlawful but you
oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or
defence of legal claims; and you have objected to processing, pending the
verification of that objection. Where processing has been restricted on this
basis, we may continue to store your personal data. However, we will only
otherwise process it; with your consent; for the establishment, exercise, or
defence of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of
your personal data on grounds relating to your particular situation, but only
to the extent that the legal basis for the processing is that the processing is
necessary for; the performance of a task carried out in the public interest or
in the exercise of any official authority vested in us; or the purposes of the
legitimate interests pursued by us or by a third party. If you make such an
objection, we will cease to process the personal information unless we can
demonstrate compelling legitimate grounds for the processing which overrides
your interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of
your personal data for direct marketing purposes (including profiling for
direct marketing purposes). If you make such an objection, we will cease to
process your personal data for this purpose.
7.9 You have the right to object to our processing of
your personal data for scientific or historical research purposes or
statistical purposes on grounds relating to your situations unless the
processing is necessary for the performance of a task carried out for reasons
of public interest.
7.10 To the extent that the legal basis for our
processing of your personal data is;
(a) consent; or
(b) that the processing is necessary for the
performance of a contract to which you are a party or to take steps at your
request prior to entering a contract,
and such processing is carried out by automated means,
you have the right to receive your personal data from us in a structured,
commonly used, and machine-readable format. However, this right does not apply
where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your
personal information infringes data protection laws, you have a legal right to
lodge a complaint with a supervisory authority responsible for data protection.
You may do so in the EU member state of your habitual residence, your place of
work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our
processing of your personal information is consent, you have the right to
withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
7.13 You may request that we provide you with any
personal information we hold about you. Provision of this information will be
subject to the supply of appropriate evidence of your identity (for this
purpose, we will usually accept a photocopy of your passport certified by a
solicitor or bank plus an original copy of a utility bill showing your current
address).
Cookies
8.1 Our website uses cookies. For further details,
please see our Cookies Policy.
Our Details
9.1 This website is owned and operated by iSmarten Ltd.
9.2 Our registered home office address is 46 Hill
Street, Belfast, United Kingdom, BT1 2LB and our company registration number
are NI676383 with Data Protection Act and Trademark registered.
9.3 You can contact us:
(a) by post, to the postal address given above; or
(b) by email, at info@ismarten.com
This Privacy Policy is simplified and straightforward
for easy understanding. If there are any questions regarding the privacy policy
or want to read the full details, you may contact us via email at contact@ismarten.com
COMPANY POLICY
iSmarten Ltd
iSmarten is a free and paid membership social
marketplace networking platform where iMembers will surely enjoy our exciting
online services, receive better products, and lifetime cash rewards and other
incentives. iSmarten is a company registered in Company House UK, Trademark
Office UK and Data Protection UK that offers exciting services, better
products, and lifetime rewards to any race and nationality.
iSmarten Policy
iSmarten company set in place a policy to ensure fair
treatment for members and the company in imposing the services, products,
rewards, and programs. When you register to become a member of iSmarten you
agree with the company policy, and you are bound to its terms and conditions.
The policies are Refund, Crypto, Rewards. Recruit, Slander, Report, Closure and
Lawsuit.
Refund Policy
If you are not happy or you change your mind, the
company will guarantee you a 100% full refund of your money anytime, no
questions asked. You just need to find a new member to be able to assume your
account and, obviously, you should return the iSmarten crypto and all the cash
rewards you have received. Be mindful that your account will be changed to the
new owner, and you will be banned from joining the company for 25 months.
Crypto Policy
The company will set up a managed crypto wallet for you
to receive your free iSmarten crypto. The company will help you sell your
crypto on your behalf when the iSmarten crypto price is right for excellent
profit, but you have to comply with the 5 direct referrals (invites). If you
don't agree, you can request a transfer of your crypto to any 3rd party crypto wallet
and the company is not responsible if you face problems in the near future.
Rewards Policy
To receive your rewards from the cash rewards or
commissions, except the iMember rewards program, you must comply with the 5
personal direct invites. By doing so, you will also qualify for lifetime cash
rewards and other rewards. The company makes every effort to ensure that the
cash rewards program can be a potential substantial income. But of course, you
must do your part to get the best result for financial stability.
Recruit Policy
Strictly no recruiting among iSmarten members to other
company. The company will not permit any dubious activities by sharing other
company programs with iSmarten members. iSmarten company designed the exciting
lifetime cash rewards for the members' long term good advantage. So, there's no
reason to be disloyal to the company's noble intentions for the members.
Slander Policy
iSmarten company will not tolerate any slanderous
statements and comments against the company to destroy the company name and
reputation, and its programs. You will be warned, and you will face the
consequences, and you will be punished if you do such wrong doings. Termination
of your account/s will be recommended as early as possible, and you will be
banned.
Report Policy
Members who recruit our members to other companies will
be penalized. As well as those members who spread slander comments against the
company. OFFENCES: 1st - will be warned. 2nd - 25% cash rewards deduction. 3rd
- 50% cash rewards deduction. 4th - Account termination. The cash deductions
will be offered to the member who made the report with solid evidence.
Closure Policy
iSmarten company is serious in implementing the Terms
of Use, Privacy Policy, and Company Policy. Once a member goes against the
company policy severely, their account will be terminated and they can't access
the company services and no refund will be received, and they will be banned
for 25 months. They are welcome to join the company again after the ban.
Lawsuit Policy
iSmarten company is providing fair treatment to all
members to ensure that members have the legal rights. If a member believes that
they have the legal claims for compensation, then the member can sue the
company. The company will welcome a lawsuit against the member where the
iSmarten main company is registered and situated in the United Kingdom.