1. What is this?
When you deal with Financial Edge, you trust us with your information. We take privacy seriously and we are committed to protecting the data you provide to us.
This policy explains when and why we collect personal information about you, how this information is used, the conditions under which it may be disclosed to others, and how it is kept secure.
This policy may change from time to time so please re-visit this page occasionally to ensure that you’re happy with any changes.
2. Who we are
Smart MNE is a brand created and owned by Financial Edge. Financial Edge and Financial Edge Training are the trading names of IBHero.com Ltd.
IBHero.com Ltd., a limited company (registered company number 09243318), is the data controller in relation to the processing activities described below. This means that IBHero.com Ltd decides why and how your personal information is processed.
Where this policy refers to “we”, “our” or “us” below, unless it mentions otherwise, it’s referring to the particular company that is the controller of your personal information.
3. How we collect your personal information
We may collect and process the following information about you in the following ways.
1. Information that you give to us
This is information about you that you give us when you make an inquiry of, or engage us to provide services to you, or by entering information via our website, opt-in/consent forms, apps or by communicating with us by phone, post, e-mail, live chat, social media or otherwise.
The information you give us mainly includes your contact details, identification information, financial or billing information, biographical, employment, and details included in any correspondence and information about you in connection with any matter on which we deliver services to you.
2. Information we receive from other sources
We may receive information about you from third parties. These may include:
|Your employer who has engaged us to provide training services for you|
|Employers, friends, and colleagues who may provide a reference on you to us|
|Recruitment consultants who may provide information about you to us|
We may supplement the personal data collected from you with information from publicly available sources, such as information to validate your identity or address, or to perform a credit check.
The information that we receive about you from others mainly includes contact information.
3. Information we collect about you
We may automatically collect information about you which we may observe, detect or create without directly asking you to provide the information to us. In common with most other businesses, this will mainly include information gathered automatically through your use of our website or online services, such as your IP address, the pages of our website that you have visited.
4. What type of personal information do we process about you
As a firm dealing with training and related services, we may process a range of personal information about you. To make it easier to understand the information that we use about you, we have divided this information into categories in the table below and provided a short explanation of the type of information each category covers:
|Category||Personal information included in this category|
|Banking/billing||Information used to send/receive funds to/from you or that appears on your bills|
|Behavioural||Your activities, actions and behaviors on our sites|
|Cardholder||Your payment card details|
|Contact||Information that can be used to address, send, or otherwise communicate a message to you|
|Correspondence||Information contained in our correspondence or other communications with you or about you, about our products, services or business|
|Employment||Your previous, current, or future employment details|
|Geo-location||Information that contains or reveals the location of your electronic device|
|Monitoring||We may record phone calls and retain transcripts of dialogue i.e. livechat conversations, either for our records or for training purposes. If you visit one of our offices your image may be recorded on CCTV for security purposes|
5. How we use your personal information
We may use the information we collect about you in the following ways.
1. Where it is necessary for us to perform a CONTRACT with you
We may use and process your personal information where we have supplied you (or continue to supply you) with any services, where we have arranged for the supply of another firm’s services to you, or where you are in discussions with us about a service on which you are considering using.
We will use your information in connection with the contract for the provision of services when it is needed to carry out that contract or for you to enter into it.
We may also use and process your personal information in connection with our recruitment activities, if you apply for a position with us (whether directly or through a third party) or send your details to us on a speculative basis.
2. Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so via our opt-in consent process for the following purposes:
- to send direct marketing information to you which includes information about our products and services, news, event and seminar invitations and financial updates.
- to send you editorial newsletters and information created by Financial Edge and its brands.
We will seek separate and specific consent from you in circumstances where we wish to feature your identity in a published case study, press release, advertisement or testimonial or wish to include your image in a photograph or video in connection with public relations or promotional activities.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see ‘Withdrawing your consent’ for further details.
3. Where required by LAW
We may use and process your personal information in order to comply with a legal obligation as follows:
- to maintain a register of corporate gifts and hospitality to comply with anti-bribery laws;
- to maintain a record of undertakings where you are a beneficiary of an undertaking;
- to comply with our legal and regulatory obligations.
4. Where we have a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes.
- to carry out our conflict checks to ensure that we are able to provide services to you;
- for prevention of fraud and other criminal activities;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a client;
- analysis to inform our business and marketing strategy;
- to manage and deliver internal projects for business improvement;
- monitoring and management of performance standards within the business
- to assess and improve our service to clients through recordings of any calls and livechat sessions;
- network and information security in order for us to take steps to protect your personal information against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- in the management of queries, complaints, or claims.
6. Others who may receive or have access to your personal information
1. Our suppliers and service providers
Our work for you may require us to provide information to third parties who will use your information for the purposes of providing services to us or directly to you on our behalf.
When we use third-party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
2. Credit/debit card payment processors
All payment information is handled using encrypted technology and our third-party payment provider (Stripe) are compliant with the Payment Card Industry Data Security Standards (PCI-DSS). Where you make payment to us by credit or debit card we will use the payment card information only for the purpose of processing that specific transaction.
No credit or debit card details are stored by Financial Edge once your payment has been processed and the transaction is completed.
When you pay for any services over the telephone/internet, your credit/debit card payment is processed by a third-party payment processor (Stripe), who specializes in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
3. Partners and sponsors
Where explicitly indicated, for example including in the case of competitions, we may pass your details to sponsors, partners, and defined third parties for the purposes of recruitment/job offers.
4. Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts, or to protect the rights, property or safety of our visitors and customers.
However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
7. Where we store your personal information
All information you provide to us for our use is stored on our secure servers which are located within the UK and the European Economic Area.
If at any time we transfer your personal information to, or store it in, countries located outside of the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside of the EEA do not have adequate data protection laws equivalent to those in the UK.
8. How long we keep your personal information for:
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.
We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for up to 7 years after the date it is no longer needed by us (retention times vary for different types of data) for any other purposes listed under ‘How we use your personal information.’
The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further ‘Erasing your personal information or restricting its processing’)
We retain your personal information as follows:
|Data category/document||Retention period/criteria|
|User information||Retention in case of queries. We will retain your personal information in case of queries from you (for instance, if you contact us about our services but decide not to take this further); we try not to keep this information longer than necessary.Retention in the case of using our services. We will retain your personal information in the case that you use our services (either directly, or indirectly via your employer engaging our services); 5 years of inactivity|
|Recruitment data||We will retain your application data for up to 12 months following receipt of your application, or longer if you ask us to keep your details on record.|
|IP address and website history||25 Months|
9. Your rights
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no action is required, after we have received your request.
1. Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
2. Correcting and updating your personal information
The accuracy of your information is important to us.
If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, either correct it yourself by editing your profile on our web site(s), or please let us know by contacting us using any of the methods described at the end of this policy.
3. Withdrawing your consent
Where we rely on your consent as the legal basis for processing your personal information, as set out under ‘How we use your personal information’, you may withdraw your consent at any time by emailing [email protected].
If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can do so using our Unsubscribe tool at the footer of any unwanted direct marketing received. If you withdraw your consent, our use of your personal information before you withdraw your consent is still lawful.
You can modify your preferences in respect of the receipt of direct marketing information including financial updates, invitations to events, or news about our firm, products and services that may be of interest to you by visiting http://eepurl.com/c_DPP1. You may modify your subscription to MNE MKR be clicking “update your preferences” at the bottom of a newsletter.
4. Objecting to our use of your personal information made about you
Where we rely on your legitimate business interests as the legal basis for processing your personal information for any purpose (s), as set out under How we use your personal information, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our Unsubscribe tools.
You may also contest a decision made about you based on automated processing by emailing [email protected]
5. Erasing your personal information or restricting its processing
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request.
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. We may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
6. Transferring your personal information in a structured data file
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out under ‘How we use your personal information’, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file or other applicable format.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
7. Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
Security measures we put in place to protect your personal information
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
We do not collect any Special Categories of Personal Data.
Where we have given (or where you have chosen) a password which enables you to access any of our online or electronic resources, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Use of ‘cookies’
Links to other websites
Our website may contain links to other websites run by other organisations This policy does not apply to those other websites and Apps, so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites and Apps even if you access them using links that we provide, and their security cannot be guaranteed
In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
You will only receive direct marketing information from Financial Edge if you indicate to us a preference (“opt-in”) to do so. You will be invited to complete a client consent/opt-in process by email or tick box as a result of any of the following:
- Your becoming a client of Financial Edge;
- Your attendance at an event or seminar hosted, or co-hosted, by or with Financial Edge.
- You providing a business card directly to an employee of Financial Edge at (for example) a trade or networking/business event;
- You’re registering your brief contact details in order to obtain information or free downloads from a Financial Edge website;
- An email request from you to attend an event we have advertised via social media or on our website or via a third party
- Your attendance at a ‘public’ event organized or co-hosted by Financial Edge that has been promoted via social media or other advertisements
- We may contact you in response to an article or social media promotion that you have carried out
- We will never share your data with third-party partners for their own marketing uses, though we may use service providers to assist us with our own marketing. This could include sharing your information as per 6.1 to provide a service to us.
- We do not rely on your consent indefinitely. You will receive an email from us periodically, where you will be asked to re-confirm your consent and preferences for financial topics and disciplines to ensure the data we hold about your preferences, and your contact details, are current and accurate.
- You have the right to opt-out of our use of your personal information to provide marketing to any of the ways mentioned above, and/or manage your preferences. Please see ‘Withdrawing your consent and objecting to our use of your personal information and automated decisions made about you’ above for further details on how you can do this.
12. Contact us
Our Data Protection Lead is Liam Gates, who acts as head of privacy and data protection. Please direct any queries about this policy or about the way we process your personal information to our Data Protection Lead using our contact details below:
If you wish to write to us, please write to the Data Protection Lead at Financial Edge, Colin Sanders Business Innovation Centre, Mewburn Road, Banbury, Oxfordshire, OX16 9PA. Our email address for data protection queries is [email protected].
If you would prefer to speak to us by phone, please call +44 203 355 5042