Privacy Policy

Updated March 2021

Who are we?

This Privacy Policy (Policy) describes how Smart Pension Co (‘Smart USA’, ‘we’, ‘us’ or ‘our’) and our affiliates use any personal information collected about you during any written, electronic, oral communications, or through online interactions related to our websites and services.  This Policy is not, however, a contract and does not create any legal rights or obligations.

Please note that certain details of this policy may depend on how you interact with us and your role in interacting with us.


What is the significance of this Policy?

Use of our services is subject to this Policy. Please read this Policy carefully before you use our services. By using our services, you accept our privacy practices described in this Policy. If you cannot accept the practices outlined in this Policy, you must not use or access our services.

This Policy applies to all persons employed by an employer utilizing our services, participants, beneficiaries, and alternate payees (including, but not limited to, active, deferred vested, former participants, and retired participants) participating in plans or programs using or accessing our services, employers using or accessing our services, and any other persons using or accessing our services. It also applies to visitors to our websites and other individuals who contact us or interact with us through our website at smartreitre.com.

What is personal information?

When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with you, or could reasonably be linked, directly or indirectly to you. For example, it could include your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, fingerprints, and inferences from other personal information that could create a profile about your preferences and characteristics. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

What types of personal information do we collect?

We collect information related to the services we provide.  This includes:

  • Contact information.  For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
  • Information you post.  We may collect personal information you post in a public space on our website.
  • Employment information.  We collect personal information directly from you as well as from your employer about your work history, salary, and other information related to your employment and related benefits.
  • Financial information.  We collect information about the benefits to which you may be entitled, account balances, and other financial information.
  • Information you submit.  We may collect personal information when you send us a message through our website or otherwise contact us.
  • Demographic information.  We may collect your birthdate, age, gender and zip code.   We may also collect personal information related to your hobbies and interests.
  • Device information.  We may collect the type of device you use to access our services.  For example, we may collect your device identifier, IP address or mobile operating system.
  • Location information.  We may collect precise location information from your device.  This may include information about your exact location when you use our services or may include information that allows us to approximate your location.  We may also collect this information in the background whenever mobile applications are not in use.
  • Log and analytics data.  If you use our website, we may collect information about the browser you are using.  We may look at what site you came from, or what site you visit when you leave us.  If you use our app, we may look at how often you use the app and where you downloaded it.

How do we collect personal information?

We collect personal information in a variety of ways:

Directly. From you. For example, when you:

  • Register your account.
  • Submit a request to our participant assistance team.
  • Request a form.
  • Interact with our website.

Automatically.

  • Install and use our mobile apps.
  • Visit and navigate our website on any device.

From third parties.

  • Your employer.
  • Our business partners, including online advertising networks and analytics vendors.
  • Social media sites. The information we receive from social media sites is dependent upon the social media sites policies and your settings on that site.
  • Family members and beneficiaries who provide your personal information to us.
  • Companies that provide personal information to supplement what we already know about you, including data aggregators. For example, we may engage a missing participant locator firm to help supplement your address.

By combining personal information. For example, we may:

  • Combine personal information that we collect offline with personal information we collect through our website.
  • Combine personal information we collect about you from different devices yo use to access our services.
  • Combine personal information we get from third parties with personal information we already have about you.

What do we use personal information for?

We use personal information primarily to provide the employee retirement benefits you expect to receive as a result of your employment. As examples, we collect and use personal information:

  • To calculate and facilitate the payment of benefits. This includes providing you with details of your benefits and options under a plan and dealing with any questions that you have about these.
  • To carry out our obligations arising from any agreement that we have with, or concerning, you and to provide you with the information, benefits and services that you request from us.
  • To notify you about services provided to participants or beneficiaries of a plan and any changes to those services or to enable you to access those services.
  • For statistical, financial modelling, funding, accounting and reference purposes.
  • For internal record keeping.
  • For risk management purposes, including the insurance or management of risks or of a plan’s benefits.
  • To comply with our legal obligations, any relevant industry or professional rules and regulations or any applicable voluntary codes.
  • To comply with demands or requests made by any relevant regulators, government departments and law enforcement or tax authorities or in connection with any disputes or litigation.
  • In connection with any sale, merger, acquisition, disposal, reorganization or similar change of our business.
  • To ensure that our website is as fast and efficient as possible, and compatible with your software and settings.
  • To enable our sub-contractors to provide aspects of our services to you.
  • To analyze and improve the services we provide.
  • To allow you to use different resources and materials on our website.
  • To allow you to access certain details about your benefits via a home or mobile assistant including, but not limited to, an Alexa skill or Google Home (please also see our Terms and Conditions).
  • To personalize the way information on our website is presented to you.
  • To allow you to share content and materials on our website via social media or other communication means.
  • To give you information on products and services which you have asked for or which we think may be of interest to you.
  • To track the use of referral links you have shared.
  • As otherwise permitted by law.

Can you opt out of marketing communications?

Participants

We may send you marketing communications about goods and services related to your employee benefits. You can stop receiving marketing messages from us at any time.

You can do this by:

  • By clicking on the 'unsubscribe' link in any email.
  • By contacting us at contact privacy@smartretire.com.
  • Once you do this, we will update your profile to seek to ensure that you do not receive further marketing messages.
  • Stopping marketing messages will not stop service communications (such as pension updates).

Employers

We will rely on our existing commercial relationship with our employer customers, to provide limited communications in respect of similar products or services.

Our customers are provided with the opportunity to opt out (unsubscribe) on each communication.

How long do we keep your information for?

We will hold your personal information on our systems for as long as is necessary for us to provide services to you or your beneficiaries pursuant to our legal agreement with you, your employer, or another person utilizing our services and to satisfy other legal requirements.

Whom do we share the information with?

Where appropriate for the purposes of administering a plan and providing other products and services on the Smart USA platform, we may share your information with:

  • A plan's professional advisers. These organizations use the information when advising the trustee and carrying out their professional obligations.
  • A plan's insurers and annuity providers (and other insurers or brokers for the purpose of obtaining quotations relating to a plan or its benefits), investment managers, banks and other service providers.
  • Any financial adviser or other organization appointed by the trustee or Smart USA to advise you about your options under a plan or any adviser appointed by you where you have asked us to provide them with details of your benefits under a plan.
  • Any other person who is authorized to act on your behalf.
  • Companies within the Smart USA family and their professional advisers.
  • Regulators, government departments, law enforcement authorities, tax authorities and insurance companies.
  • Any relevant ombudsman, dispute resolution body or the courts.
  • Persons in connection with any sale, merger, acquisition, disposal, reorganization or similar change in the Smart USA business.
  • Third parties who provide products and services available through the Smart USA platform.
  • Third party suppliers who provide tracing services in order to enable better accuracy of our member records.

The entities listed above may also share personal data with their own business suppliers, for example in relation to the operation of IT systems or where they outsource part of their services.

Smart may also share personal data with third party service providers to process your information on our behalf. These third parties will generally be required to strictly comply with the instructions of Smart.

Please note that some of a plan’s former service providers may continue to hold information about you for their own record keeping purposes once they have ceased to be involved with the your plan.


Where do we store your personal information?

Personal information may be stored in or outside the United States. If you live outside of the United States, you understand and agree that we may transfer your information into the United States. Our services are intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protection as those in your own country.

Is your information secure?

The internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal information you provide to us. We have, however, taken certain steps designed to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction.

Does my state provide additional rights?

The following explains the rights provided by certain states.

If you are a California resident, your information will only be used for the categories of information described above and all use will be related either to your employment at Smart or in connection with the provision of employment benefits.

If you are a Nevada resident, you may opt out of future sales of certain covered information collected through our website by contacting us at [ ] with the subject line “Nevada opt—out”.

The applicability of these and other state laws may vary depending on our relationship with you and/or a plan.


How will we modify this Policy?

We may modify this Policy at any time, without prior notice, and changes may apply to any personal information we already hold about you, as well as any new personal information collected after the Policy is modified. If we make changes, we will notify you by revising the date at the top of this Policy. If you continue to access or use our services after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.


How can you contact us?

Privacy

If you have any queries about this Policy, or wish to exercise any of the rights above, please contact privacy@smartretire.com or complete this form.

If you have any other questions about the Scheme, please contact claire.altman@smartpension.co.uk.

Security

If you have any security related issues about our website, please contact security@smartretire.com.