Privacy Policy (UK)

Updated: 15 July, 2022

Sea of Savings, LLC (“The Smart Wallet,” “we,” “our” or “us”) provides the following Privacy Policy (“Policy”) which sets forth our practices concerning the collection, use, and disclosure of information relating to an identified or identifiable natural person (“Personal Data”), as well as information that is not Personal Data.  For purposes of this Policy, Personal Data and non-Personal Data may both be referred to collectively as “Information.” This Policy also explains why we may acquire and use your Information in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (which applies in the UK Post Brexit under the Data Protection, Privacy and Electronic Communications (Amendments, etc) (EU Exit Regulations 2019) (“GDPR”).

By accessing and using the TheSmartWallet.uk (“TSW UK”) you understand and agree to our collection, use, and disclosure of your Information that you may provide to us.  If you do not understand and agree to how we collect and handle Information, please do not use or visit TSW UK.

Sea of Savings, LLC is a limited liability company registered in the state of New York with offices at 300 Vesey Street, 9th Floor, New York, NY 10282. If you would like more information about us, please contact our Data Protection Officer, Daniel Barsky, at the address above or at [email protected].

WHAT INFORMATION MAY WE COLLECT ABOUT YOU?

  • Information collected from our web server log files, including device type(s), user agent data, referring URL(s), and IP address(es);
  • Information collected from our customer support department, including customer support inquiries; and
  • Information collected from Cookies (as defined below).

HOW DO WE COLLECT INFORMATION?

  • From the use of cookies (small text files placed on a user’s computer that track online behavior), single-pixel GIF image files (also called “web beacons”) and other technological means (collectively, “Cookies”); and
  • Emails and other contact information received when an individual contacts us.

We also collect Information from our servers that host our websites and combine that Information with Information on users that we have already collected via other means.  Here are some sources of Information and the methods we use:

  • Our hosting servers may collect Information from users through various technological means when users access and interact with TSW UK and our other websites;
  • From third parties including service providers who assist us in hosting TSW UK and our other sites and providing customer support;
  • From third parties who drive users to TSW UK and our other websites and whose goods and services are advertised on our websites; and
  • From other companies in our group of companies who share Information with us on the basis of an agreement which is in place between the group.

WHY DO WE NEED YOUR INFORMATION?

We may need your Information so that:

  • We can administer and maintain our website operations, content improvements, testing, research, analysis, and product development;
  • We can reply to any enquiries you make to us;
  • As necessary or appropriate to protect the rights, property or safety of us, parties controlled by or under common control with us (“Related Parties”), our clients, advertisers, service providers and others;
  • If we are sold, merge with a third party, are acquired or are the subject of bankruptcy proceedings, we can share it with the applicable third party(ies); if we are involved in one of these transactions, users will be notified via Policy update on TSW UK of any change in uses of your Information; and
  • To respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims or when we determine it is necessary to comply with applicable laws or regulations.

OUR LEGAL BASIS FOR PROCESSING

When we process your Information, we do so on the basis of legitimate interests, including:

  • Maintaining accurate information concerning the public’s usage of TSW UK and administering proper functioning of our websites, which entails troubleshooting and data analysis to help us keep our websites safe and secure; and
  • Other legitimate interests for purposes of protecting the rights, property, or safety of us, Related Parties, or our clients, advertisers, service providers and others.

WHO DO WE SHARE YOUR INFORMATION WITH AND HOW?

We may transfer your Information to our third-party agents or service providers who perform functions on our behalf, including:

  • Other companies which we own and control and/or are part of our affiliated group of companies which includes our affiliate Fluent, LLC which provides operational service and other support for our websites in the UK;
  • Third parties which supply us with products and services, such as hosting our databases, optimizing our website; and
  • Third parties if we believe, in good faith, that it is necessary to protect our rights, property, safety or reputation or the rights, property, safety or reputation of Related Parties.

Third-Party Data Controllers

In some cases, we may transfer Information to unaffiliated third-party controllers.  These third parties do not act as agents or service providers and are not performing functions on our behalf.  We may transfer your Information to third-party data controllers for example:

  • Third parties where we are required to do so in order to comply with our legal obligations or the requirements of a regulatory authority; and/or
  • Third parties if we buy or sell our business or assets (in which case we may need to share Information with the prospective buyer or seller of such business or assets).

If we collect any Information that is Personal Data, we will seek your affirmative, express opt-in consent before collecting it and prior to any sharing of such Information with third-party data controllers.  In those instances, we will enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level or protection for Personal Data.  We will also limit their use of your Information so that it is consistent with any consent you have provided and with the notices you have received.

WHERE IS MY INFORMATION STORED?

The Information we collect about you may be transferred to and stored outside the United Kingdom and European Economic Area (“EEA”), in particular the United States of America (“USA”). It may also be processed by staff operating outside the United Kingdom or EEA who work for us or for one of the third parties with whom we share Information.

We comply with and ensure that third parties with whom we share Information comply with, the provisions of the UK GDPR and any other relevant data protection legislation to ensure that adequate protection is provided to your Information, particularly Personal Data, whenever it is stored or processed outside the UK, if at all. You can ask us for a copy of the relevant safeguards implemented in relation to any such transfer outside of the UK.

HOW DO WE KEEP YOUR INFORMATION SECURE?

  • We maintain reasonable and appropriate security measures to protect Information from loss, misuse, unauthorized access, disclosure, alteration or destruction.
  • Information you provide to us is stored on our secure servers located in a secure facility operated by Rackspace US, Inc. and located in Ashburn, Virginia, USA.
  • We use industry standard security measures to encrypt Personal Data, if we collect any.
  • We will do our best to protect any Personal Data you provide to us via the internet, but such transmission is not completely secure. Subject to our responsibility to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, any transmission of Personal Data over the internet is at your own risk.
  • If you follow a link to any of our partners’ or advertisers’ websites, those websites may have their own privacy policies and we do not accept any responsibility or liability for those policies.

RETENTION

We may retain non-personally identifiable Cookie data indefinitely for archival purposes.

We may retain your other Information, to the extent we collect or receive it, for up to six years from when you visit TSW UK, in accordance with laws in the UK and the USA on legal limitation periods, unless a longer retention period is required or permitted by law.

If you contact us to request a service, we will keep your Information for as long as it is necessary to provide you with the services you have requested.

AUTOMATED DECISION MAKING AND PROFILING

We may use automated decision-making and profiling techniques to determine which adverts you are shown, in each such case without human intervention.

COOKIES, INTEREST-BASED ADVERTISING, AND THIRD-PARTY ANALYTICS

Although we currently don’t use Cookies, some of our third-party marketing partners may place Cookies on our Websites to track users’ online behavior while on our site and after they leave our site.  These third-party Cookies may enable the delivery of interest-based advertisements based on a user’s visit to our site and/or other websites.  In addition, our marketing partners use Information gathered in this manner to recognize you across different channels and platforms, including computers, mobile devices, and Smart TVs and may use this Information over time for advertising, analytics, attribution and reporting purposes.

We may use Google Analytics and TUNE (each are third-party services) to help analyze how users interact with the Website (e.g., clicking on images, links, and other content) and to display ads and other content to our users during a current browsing session or in the future when the user is online. These analytics are performed by using the technological means described above to monitor a user’s interactions with TSW UK and do not involve the collection of any additional Personal Data.

DESCRIPTION OF COOKIES

Name Owner Purpose
Google Analytics Google This is a web analytics service provided by Google, Inc. which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (e.g., how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.
TUNE TUNE This is a cookie-less service provided by TUNE that enables session tracking and measurement for web and mobile web traffic.

 HOW TO TURN OFF COOKIES

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this site. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

OTHER WEBSITES  

We and our Related Parties and marketing partners may advertise and promote other websites and we may permit our marketing partners to place ads and other content, including links to other websites, on TSW UK. While we try to post links only to third-party websites that share our respect for privacy, this Policy, our privacy practices do not extend to and may differ from those of third-party websites that can be accessed through links on TSW UK. You should review the applicable privacy policies of the third-party websites before registering with, providing Information to or navigating those websites.

WHAT ARE MY PRIVACY RIGHTS UNDER THE GDPR?

As a “data subject” under the UK GDPR, you have a number of rights (detailed below) which you can seek to exercise. If you wish to exercise any rights you should contact us using the ways detailed in this Privacy Policy.

If you seek to exercise your rights, we will explain to you whether or not the right applies to you; these rights do not apply in all circumstances and are subject to, for example, our legal obligations, reasons of public interest and defence of legal claims.

  1. Right to withdraw consent. To the extent you provide consent to the processing of your Personal Data, you can withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
  2. Right of access to and rectification of your Personal Data. If you would like to request access to, correction, amendment or deletion of your Personal Data, you can submit a written request to [email protected]. We may request specific information from you to confirm your identify. In some circumstances we may charge a reasonable fee for access to your information. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access.
  3. Right to erasure (or, “Right to be forgotten”). You can ask us to stop processing and delete your personal data in certain circumstances (for example where it was processed on the basis of your consent and you withdraw such consent or where it is no longer necessary for us to process it).
  4. Right to data portability. You can request to receive your Personal Data from us in a machine-readable, commonly used format of our choosing and/or have us transfer your Personal Data directly to another controller.
  5. Right to object to, or restrict processing. Where the processing of your Personal Data is based on consent, contract, or legitimate interests, you may restrict or object, at any time, to the processing of your Personal Data as permitted by applicable law. We may continue to process your Personal Data if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.
  6. Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, except as allowed under applicable data protection laws.

To the extent we collect and share any Personal Data, we will use best efforts to notify the third parties about any request for erasure, rectification or restriction you make to us, unless it proves impossible or involves disproportionate effort. Upon your request, we will share the list of recipients with you.

AMENDMENTS

We reserve the right to revise and update this Policy at any time.  If we make changes to this Policy, we will post the updated Policy on TSW UK.  If we expand the categories of Information we collect or process to include Personal Data, you will have a choice as to whether we can collect and use such Information in this different manner and we will only use your Information in this way where you opt-in to such use.  TSW UK readers and/or site visitors should periodically access this Policy to review our current policies regarding the collection and use of Information.

CONTACT AND COMPLAINTS

If you have any questions, feedback or wish to make a complaint, please contact us using the details below:

You also have the right to lodge a complaint with a supervisory authority (the ICO) by writing to the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or calling 0303 123 1113. Further information about how to do this can be found at: www.ico.org.uk.

© Sea of Savings, LLC July 15, 2022