Privacy Policy

1. Introduction

This Privacy Policy explains how Smartledger Solutions ("we", "us", "our") may collect, use and protect personal information when you visit our website, use our services, or otherwise contact us.

We aim to be clear and transparent about our information practices. Where specific details of our processing activities are not yet finalised, this policy identifies them clearly rather than making assumptions.

2. Who We Are

• Legal company name: Smartledger Solutions Ltd
• Company number: 15187461
• Registered office address: 4 Corville Gardens, Birmingham B26 3JU, United Kingdom
• Companies House Authorised Corporate Service Provider (ACSP) number: AP002129
• Supervised for anti-money laundering purposes by the Institute of Certified Bookkeepers (ICB), Practice Number 24545
• ICO registration number: [to be confirmed]
• Contact email: team@smartledgersolutions.co.uk

3. Information We May Collect

Depending on how you interact with our website and services, we may collect the following categories of information:

• Name
• Email address
• Phone number
• Company name and related business information you provide
• Information you submit through our contact and enquiry forms, including your message and the service you are enquiring about
• Identity documents and proof-of-address documents you submit as part of an identity verification request
• A facial image/selfie and liveness capture submitted as part of an identity verification request (see Facial Images and Biometric Data below)
• Technical information such as browser type, device information and IP address
• General website usage information

We only collect the categories of information that are relevant to the specific service or interaction you use.

4. How We Collect Information

We may collect information through:

• Our contact and enquiry forms
• Service enquiries and requests you submit
• Our identity verification form, where you choose to use that service
• Direct email or other communication with us
• General use of our website
• Cookies and similar technologies — see our Cookie Policy for details

5. How We Use Information

We may use the information we collect to:

• Respond to your enquiries and requests
• Provide the services you have requested, including identity verification
• Manage our relationship with clients
• Administer and maintain our website
• Improve the functionality and content of our website
• Help protect against security incidents and fraudulent activity
• Meet applicable legal and regulatory obligations

6. Legal Bases for Processing

Where UK data protection law applies, we rely on one or more of the following lawful bases, depending on the specific processing activity:

• Consent — where you have given clear consent for us to process your information for a specific purpose
• Contract — where processing is necessary to provide a service you have requested
• Legal obligation — where we need to process information to comply with the law
• Legitimate interests — where processing is necessary for our legitimate business interests and does not override your rights and interests

The specific lawful basis that applies depends on the nature of the processing activity in question, rather than a single basis applying to everything we do.

7. Facial Images and Biometric Data

As part of our identity verification service, we collect a facial image/selfie and a short liveness capture, which is biometric data used to confirm that you are a real, present person and that you match the identity document you have submitted.

Facial images and liveness data are a special category of personal information under UK data protection law. We process this data on the basis that it is necessary for reasons of substantial public interest — specifically, the prevention and detection of fraud and identity misuse, and compliance with our anti-money laundering obligations as a business supervised by the Institute of Certified Bookkeepers (ICB).

This data is shared with our identity verification partner, Didit, solely to carry out this check, and is retained only as described in Data Retention below.

8. Automated Checks and Human Review

When you submit an identity verification request, your documents and facial image are first checked automatically by our verification partner, Didit. This automated check looks at things such as document authenticity and whether your facial image matches your identity document.

The outcome of this automated check is then reviewed by a member of our team before a final decision is made on your application. You will not be subject to a decision based solely on automated processing without human review.

9. If You Don't Provide Information

If you choose not to provide the information we ask for as part of our identity verification service — such as a valid identity document, a proof of address document, or a facial image/liveness capture — we will not be able to complete your verification request.

Where this happens, we do not retain partial submissions beyond what is described in Data Retention below, and no fee is charged unless you had already submitted a complete application for processing.

10. Sharing Information

We do not sell personal information. We may share personal information only where appropriate and necessary, including with:

• Service providers who support our business operations, such as email delivery
• Stripe, for processing payments where a paid service is used
• Didit, for carrying out identity verification checks where you choose to use our identity verification service
• Professional advisers, where necessary
• Authorities or regulators, where we are legally required to do so

We only work with providers who are appropriate for the relevant purpose. We do not name additional third parties beyond those actually used by our current services.

11. International Transfers

Some of the third-party providers referenced in this policy, including Stripe and Didit, may process information outside the UK as part of their own service delivery. Where this occurs, it is subject to those providers' own safeguards and privacy terms.

We do not otherwise transfer personal information internationally beyond what is necessary for the services described in this policy.

12. Data Retention

We retain personal information only for as long as is necessary for the purpose it was collected, or as required to meet applicable legal, accounting or regulatory requirements.

Information submitted as part of an identity verification request — including identity documents, proof of address documents, and facial/liveness data — is retained for 7 years from the date of your application, in line with our anti-money laundering record-keeping obligations as a business supervised by the Institute of Certified Bookkeepers (ICB). After this period, it is securely deleted.

13. Data Security

We take reasonable technical and organisational measures to help protect personal information against unauthorised access, loss, misuse or alteration. These include measures such as access controls and secure handling of submitted information.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We do not claim certification against any specific security standard unless this has been independently verified.

14. Your Rights

Depending on the circumstances and applicable law, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate information
• Request erasure of your information, where applicable
• Request that we restrict processing of your information, where applicable
• Object to certain processing, where applicable
• Request a copy of your information in a portable format, where applicable
• Withdraw consent at any time, where processing is based on consent

These rights are not absolute and may depend on the specific circumstances and the legal basis for processing.

15. Complaints

If you have concerns about how we handle your personal information, please contact us first at team@smartledgersolutions.co.uk so we can try to resolve the matter directly. We aim to respond within 14 days.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection matters, at ico.org.uk.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be published on this page, along with an updated "Last Updated" date.

17. Contact

If you have any questions about this Privacy Policy or how we handle personal information, please contact us:

• Smartledger Solutions Ltd
• Company number: 15187461
• Email: team@smartledgersolutions.co.uk
• Address: 4 Corville Gardens, Birmingham B26 3JU, United Kingdom

You can also reach us through our Contact Us page.