Privacy Policy
SMARTSELECT TECHNOLOGY UK LTD ("we," "us," or "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you use our website and services ("Service") for purchasing NFTs with Fiat Currency.
Our principal place of business is 61 Bridge Street, Kington, Herefordshire, United Kingdom HR5 3DJ.
We act as the data controller for the personal data we process, meaning we determine the purposes and means of processing your data.
1. Information We Collect
We may collect and process the following types of personal data about you:
- Identity Data: Name, date of birth, gender.
- Contact Data: Email address, postal address, telephone numbers.
- Financial Data: Limited payment information (e.g., last four digits of your card, transaction IDs from payment processors). We do not store full payment card details.
- Transaction Data: Details about your NFT purchases, the value of transactions, and payment history.
- Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data: Information about how you use our website and services, including your Browse patterns, pages viewed, and links clicked.
- Communication Data: Your preferences in receiving marketing from us and our third parties, and your communication preferences.
- KYC/AML Data: If required by law, we may collect data necessary for Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, such as copies of identification documents.
2. How We Collect Your Information
We collect data from and about you through various methods:
- Direct Interactions: You provide us with your Identity, Contact, and Financial Data when you create an account, purchase NFTs, subscribe to our newsletter, or contact us.
- Automated Technologies or Interactions: As you interact with our website, we automatically collect Technical and Usage Data using cookies and similar technologies. Please refer to our separate Cookie Policy for more details.
- Third Parties: We may receive personal data about you from various third parties, such as payment service providers (e.g., Stripe, PayPal), analytics providers (e.g., Google Analytics), and identity verification services for KYC/AML purposes.
3. How We Use Your Information (Purposes and Legal Basis for Processing)
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
| Purpose of Processing Your Data | Legal Basis for Processing |
|---|---|
| To register you as a new user and manage your account. | Performance of a contract with you. |
| To process and fulfill your NFT purchases. | Performance of a contract with you. |
| To manage payments, fees, and charges. | Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us). |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. | 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). Consent (where required for marketing cookies). |
| To enable you to participate in surveys or provide feedback. | Performance of a contract with you. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and to grow our business). |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). | 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 reorganization or group restructuring exercise). Necessary for compliance with a legal obligation. |
| To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences. | 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 comply with legal and regulatory obligations (e.g., anti-money laundering (AML), Know Your Customer (KYC) regulations). | Necessary for compliance with a legal obligation. |
4. Sharing Your Personal Data
We may share your personal data with the following categories of recipients:
- Service Providers: Third-party companies that provide services on our behalf, such as payment processors, hosting providers, analytics providers, customer support services, and identity verification services. These providers are contractually bound to protect your data and only use it for specified purposes.
- Professional Advisors: Lawyers, bankers, auditors, and insurers who provide legal, banking, audit, or insurance services.
- Regulators and Law Enforcement: We may disclose your data if required by law or in response to valid requests by public authorities (e.g., a court or government agency), particularly for AML/KYC compliance.
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the acquiring entity.
5. International Transfers
We may transfer your personal data outside the UK or European Economic Area (EEA) to countries that may not have the same level of data protection laws. When we do so, we ensure appropriate safeguards are in place, such as using Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner's Office (ICO), or relying on a country's adequacy decision.
6. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. Your Legal Rights (GDPR Rights)
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data (commonly known as a "data subject access request").
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing of your personal data.
- Request the transfer of your personal data to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of these rights, please contact us using the details provided below.
9. Complaints
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The latest version will always be posted on our website. We encourage you to review this policy periodically for any changes.
11. Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us at:
This Privacy Policy was last updated: 2025-04-03