SMARTY CIRCLE

Privacy Policy

1. Introduction

This Privacy Policy explains how Smarty Software Ltd, trading as Smarty Circle (“we,” “us,” or “our”), collects, uses, shares and protects personal data when you access or use the Smarty Circle community platform, including the associated website, mobile applications, member profiles, groups, forums, direct messaging, courses and events (together, the “Service”).

This policy applies to every member, visitor and administrator who interacts with a community built on Smarty Circle. It should be read alongside our Terms of Service.

2. Who We Are

The Service is operated by Smarty Software Ltd, a company registered in England and Wales under company number 08532478, with a registered office at 3 More London Pl, London SE1 2RE. For data protection purposes, Smarty Software Ltd acts as the data controller for the personal data described in this policy.

3. Information We Collect

3.1 Information you provide directly

• Account and profile details: name, username, email address, password (stored in hashed form), profile photo, bio, location, and any professional or organisational details you choose to add.
• Content you create: posts, comments, replies, direct messages, group posts, media uploads, course submissions, and event RSVPs.
• Billing details for paid memberships: billing name, address and payment method, collected and processed on our behalf by our payment processor. We do not store full card numbers on our own servers.
• Anything you send us directly, such as support requests or feedback.

3.2 Information collected automatically

• Community activity: groups joined, connections, likes, mentions, notifications and badges.
• Technical and usage data: IP address, device and browser type, log data, pages viewed, session duration and referring pages.
• Cookies and similar technologies, described in Section 8 below.

4. How We Collect Information

• Directly from you, when you register, complete your profile, post content or contact us.
• Automatically, through your use of the Service (cookies, analytics and server logs).
• From third parties, such as a single sign-on provider you choose to use, or our payment processor confirming that a transaction has completed.

5. Our Legal Basis for Processing

Where UK GDPR or EU GDPR applies, we rely on the following legal bases:

• Contract: to create your account and provide the community features you sign up for.
• Consent: for optional marketing communications and non-essential cookies, which you may withdraw at any time.
• Legitimate interests: to keep the platform safe and functioning, prevent abuse, and improve the Service, balanced against your rights and interests.
• Legal obligation: to meet accounting, tax or law enforcement requirements.

6. How We Use Your Information

• Provide, operate and personalise the Service.
• Process membership payments and manage subscriptions.
• Enable community interaction: posts, messaging, groups, notifications and directories.
• Moderate content and enforce our Terms of Service and community guidelines.
• Send service, security and (with your consent) marketing communications.
• Analyse usage to improve features, performance and reliability.
• Detect, investigate and prevent fraud, abuse and security incidents.
• Comply with our legal obligations.

7. Visibility Within the Community

Profile information, posts and comments made in public areas or public groups may be visible to other members and, depending on configuration, to visitors of the site. You can adjust visibility for some profile fields in your account settings; certain information needed for the Service to function, such as your display name within a group, cannot be hidden from that group.

Direct messages are visible only to the sender and recipient(s). Administrators and moderators may access message content where necessary to investigate a reported violation of our Terms of Service, or where required by law.

8. Cookies and Similar Technologies

We use cookies and similar technologies for the following purposes:

• Essential: required for login, security and core site functionality. These cannot be switched off.
• Functional: remember your preferences, such as display settings.
• Analytics: help us understand how the Service is used so we can improve it.
• Marketing (optional, where enabled): used only with your consent, for example to measure the effectiveness of a campaign that brought you to the Service.

You can manage your cookie preferences at any time through the consent banner or your browser settings.

9. How We Share Your Information

• Service providers who process data on our behalf, including hosting, platform infrastructure, payment processing, email delivery, analytics and customer support tools, each bound by a data processing agreement.
• Other members, limited to content you choose to share publicly or within a group.
• Legal and safety purposes, where necessary to comply with the law, enforce our Terms of Service, or protect the rights and safety of our users or the public.
• A buyer or successor in the event of a merger, acquisition or sale of assets, subject to continued protection of your data under an equivalent policy.

We do not sell personal data to third parties for their own marketing purposes.

10. International Data Transfers

Where personal data is transferred outside the UK or EEA, for example to a service provider located in another country, we rely on an applicable adequacy decision, the UK International Data Transfer Addendum, or Standard Contractual Clauses to ensure your data continues to receive an equivalent level of protection.

11. Data Retention

We keep personal data for as long as your account is active, and for a reasonable period afterward where needed to meet legal, accounting or reporting obligations, resolve disputes, and enforce our agreements. As a general guide: account and profile data is retained for the life of the account plus 12 months; billing records are retained for the period required by applicable tax law (typically six to seven years in the UK); posts and messages are retained according to configured settings. You may request earlier deletion as described in Section 13.

12. Data Security

We use encryption in transit, hashed password storage, access controls limited to a need-to-know basis, and regular security reviews to protect personal data. No system can be guaranteed completely secure, and we encourage members to use a strong, unique password and enable two-factor authentication where it is available.

13. Your Rights

Subject to applicable law, you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data.
• Request erasure of your data, subject to certain legal exceptions.
• Restrict or object to certain processing.
• Receive your data in a portable format.
• Withdraw consent at any time, where processing is based on consent.
• Lodge a complaint with the Information Commissioner’s Office (ICO), or the supervisory authority in your country of residence.

To exercise any of these rights, contact us using the details in Section 17. We aim to respond within one month.

14. Children’s Privacy

The Service requires members to be at least 18 years old and is not directed at, or intended for use by, anyone under that age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take steps to remove it.

15. Third-Party Links

Posts, groups and profiles within the community may contain links to third-party websites or services that we do not control. This policy does not apply to those third parties, and we encourage you to review their own privacy policies.

16. Changes to This Policy

We may update this policy from time to time. Material changes will be notified through the Service or by email, and the “last updated” date at the top of this document will be revised.

17. Contact Us