Privacy Policy: Smarter Finance Solutions Ltd

1. Introduction

Smarter Finance Solutions Ltd ("we," "us," or "our") is committed to protecting the privacy and security of your personal data. As an ICAEW member firm, we adhere to the highest standards of professional conduct and integrity. This policy explains how we collect, use, and protect your information when you visit our website or engage our professional services.

We are a "data controller" registered with the Information Commissioner’s Office (ICO). This means we are responsible for deciding how we hold and use personal information about you.

2. The Data We Collect

We may collect, store, and use the following categories of personal information:

• Identity Data: Name, title, and job role.
• Contact Data: Email address, telephone numbers, and billing address.
• Technical Data: IP address, browser type, and location data collected via Google Analytics.
• Service Data: Financial records, tax identifiers, and payroll information provided to us for accountancy or advisory purposes.

3. How We Collect Your Data

• Direct Interaction: Information you provide via our contact forms, HubSpot lead forms, or email.
• Professional Engagement: Data shared during the onboarding process and the ongoing delivery of our services.
• Automated Technologies: As you interact with our website, Google Analytics automatically collects Technical Data about your equipment and browsing patterns.

4. Legal Basis for Processing

Under the UK GDPR, we rely on the following legal bases:

• Contractual Necessity: To perform the services agreed upon in our Letter of Engagement.
• Legal Obligation: To comply with HMRC regulations and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
• Legitimate Interests: For the effective management of our practice and the improvement of our digital services.
• Consent: Specifically for marketing communications sent via HubSpot.

5. How We Use Your Information

We use your data to:

• Provide professional accounting, bookkeeping, and tax services.
• Conduct mandatory Anti-Money Laundering (AML) checks via Iris.
• Process data efficiently using Dext and Booke AI.
• Send relevant newsletters and marketing updates via HubSpot (where you have opted in).
• Maintain client records within Xero and QuickBooks.

6. Data Sharing and Third-Party Processors

We utilise industry-leading cloud service providers to deliver our services. Your data may be processed by:

• Accounting Platforms: Xero, QuickBooks, Dext, and Booke AI.
• Productivity & Storage: Microsoft 365 and Google Workspace.
• CRM & Marketing: HubSpot.
• Compliance: Iris (for AML verification).
• Regulators: HMRC, Companies House, and the ICAEW where legally required.

7. Data Security

We have put in place appropriate security measures, including encryption and multi-factor authentication (MFA) across our Microsoft 365 and cloud accounting suites, to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way.

8. Data Retention

We will retain your personal data for a period of 7 years following the end of the tax year to which the data relates, or the termination of our professional relationship. This is to comply with HMRC requirements and ICAEW professional indemnity guidelines.

9. Your Legal Rights

You have the right to request access to your data, request corrections, or object to processing. If you receive marketing emails via HubSpot, you may click the "unsubscribe" link at any time to withdraw consent.

10. Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Lead:

You also have the right to make a complaint to the Information Commissioner’s Office (ICO) (www.ico.org.uk).