1. Who We Are and What We Do
We are smartKYC (“smartKYC”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 08892868 and we have our registered office at83 Victoria Street, London, SW1H 0HW, United Kingdom. We are registered with the UK supervisory authority, Information Commissioner’s Office (“ICO”) in relation to our processing of Personal Data under registration number.
What we do
We are a provider of screening and monitoring technology which helps organisations fulfil their corporate and regulatory due diligence responsibilities. We are committed to protecting the privacy and security of the Personal Data we process about you.
Controller
Unless we notify you otherwise, we are the Controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.
Processor
If smartKYC processes data about you because we have collected it or it has been provided to us by or on behalf of a smartKYC client, we are acting as a Processor, and this privacy notice does not apply. You should review the privacy notice of the smartKYC client that collected your personal data.
2. Purpose of This Privacy Notice
The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions, you can contact us using the information provided below under the ‘How to contact us’ section.
3. Who This Privacy Notice Applies To
This privacy notice applies to you if:
- You visit our website.
- You purchase goods or services from us.
- You enquire about our products and/or services.
- You sign up to receive newsletters and/or other promotional communications from us.
4. What Personal Data Is
‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.
‘Special Category Personal Data’ is more sensitive Personal Data and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purposes of uniquely identifying someone, data concerning physical or mental health or data concerning someone’s sex life or sexual orientation.
5. Personal Data We Collect
The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases and retention periods’.
6. How We Collect Personal Data
We collect most of the Personal Data directly from you in person, by telephone, text or email and/or via our website.
However, we may also collect your Personal Data from third parties such as:
- reputable companies who provide lead generation contact lists
- others to whom you have provided consent
- publicly available sources such as social media platforms
We also collect personal data indirectly from third parties, which may be subscription services, public registers or publicly accessible data sources like media outlets and social media platforms.
Where data is collected indirectly, this is for the development, testing and demonstration of our due diligence and monitoring tools. The technology we have developed allows organisations to screen individuals and companies against criteria set out in their legal and regulatory obligations to fight financial
crime, such as money laundering, terrorist financing and fraud.
Depending on the purpose, the personal data we process includes: name and contact details; bank details for payments; employer and role; records of company directorships and shareholdings; inclusion on watch/sanction lists; public domain indicators of financial history (like bankruptcy filings), criminal convictions or being a Politically-Exposed Person; along with other factors relevant to compliance regimes both in the UK and abroad.
7. Purposes and Lawful Bases
We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:
| Categories of individuals | Categories of Personal Data | Purpose of Processing | Lawful Basis |
|---|---|---|---|
| Clients & Prospective Client employees | Contact and contextual information such as name, email address, work address, telephone number, company and position. | Prospecting, marketing and sales – We take the opportunity to engage with individuals representing companies who would benefit from our services, providing them with thought-leadership and marketing materials, and demonstrations of our products. | Individuals consent to engage with us and find out more about our products and their benefits. This consent may be retracted at any time. We may also engage with individuals on the basis of our legitimate interests in running a commercial business, giving them the ability to opt out of communications at their choosing. |
| Client employees | Contact and contextual information as above, along with billing information which may include personal data. | Servicing our corporate clients, and working with partners and suppliers. The personal data of the employees of clients, partners and suppliers may be used in the context of fulfilling our service contracts and for billing purposes. | Our clients, partners and suppliers appoint employee representatives to manage their relationships and service agreements with us. This processing of personal data allows us to fulfil our contractual obligations. |
| The development, demonstration and delivery of our screening and monitoring tools | Name and contact details; personal identification numbers; familial circumstances; professional and personal associations; financial history; employment, directorship and shareholder information; criminal offence data; inclusion on watch/sanctions lists; other special category data relevant to KYC screening, such as Trade Union roles; and adverse media indicators (AKA ‘red flags’). | The personal data of employees, contractors and company directors is processed for the purposes of remuneration, taxation, operations and Human Resources management. | We have legal and contractual obligations to meet in an employment and corporate directorship context. Where these do not exist, individuals may have given consent for their data to be processed or it may be in our legitimate interests to do so. |
| The development, demonstration and delivery of our screening and monitoring tools | Name and contact details; personal identification numbers; familial circumstances; professional and personal associations; financial history; employment, directorship and shareholder information; criminal offence data; inclusion on watch/sanctions lists; other special category data relevant to KYC screening, such as Trade Union roles; and adverse media indicators (AKA ‘red flags’). | Our tools provide organisations with a less privacy-invasive means of carrying out the due diligence which is vital in fighting money laundering, fraud and terrorism, and managing corporate risk. Using Natural Language Processing, our tool’s federated search function automatically collates and disambiguates information from thirdparty content providers to surface only information relevant to KYC. | This processing is necessary for the purposes of technological development and demonstration. This scientific research furthers our legitimate interests in providing tools which in turn allow organisations to fulfil their legal and regulatory obligations, and pursue their legitimate interests in sound management. There is also substantial public interest in upholding regulatory requirements and fighting all kinds of financial crime (as per (Data Protection Act 2018Schedule 1, Part 2 , conditions 12, 14 and 15). Our tools also help organisations control compliance costs otherwise likely to be passed to consumers. |
The lawful bases for our processing of personal data
Organisations must have a lawful basis for processing personal data (and two if for special category data), as per UK GDPR Articles 6 and 9.
Below we describe what these lawful bases are in typical scenarios:
| Activities | Lawful bases which may be applicable |
|---|---|
| Business administration, including Human Resources and directorships | • Contract fulfilment/pre-contractual measures • Legal obligation • Consent • Legitimate interests • Employment, social security and social protection purposes • Occupational health purposes • Public health • The establishment, exercise or defence of legal claims |
| Marketing and sales | • Consent • Legitimate interests • Contract fulfilment/pre-contractual measures |
| Servicing clients and working with suppliers | • Consent • Legitimate interests • Contract fulfilment/pre-contractual measures • The establishment, exercise or defence of legal claims |
| Developing, testing and demonstrating our tools | • Substantial public interest in upholding regulations and fighting financial crime • The information has been manifestly made public by data subjects • Legitimate interests in R&D for technological development and demonstration |
Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.
8. Retention of Personal Data
We will retain your personal data for as long as is necessary to provide you with our services and for a reasonable period thereafter to enable us to meet our contractual and legal obligations and to deal with complaints and claims.
At the end of the retention period, your personal data will be securely deleted or anonymised for example by aggregation with other data, so that it can be used in a non-identifiable way for statistical analysis and business planning.
9. Sharing your Personal Data
We may share your Personal Data with our carefully selected third parties, including:
- Public authorities, such as HM Revenue and Customs
- Data processing suppliers, such as our accounting, payroll and CRM suppliers,
- (Prospective) client organisations such as the financial institutions we demonstrate our products to,
- Other third parties where we have a legal obligation to do so.
10. International Transfers
Your Personal Data may be processed outside of the UK. This is because the organisations we use to provide our service to you are based outside the UK.
We have taken appropriate steps to ensure that the Personal Data processed outside the UK has an essentially equivalent level of protection to that guaranteed in the UK. We do this by ensuring that:
- Your Personal Data is only processed in a country which the Secretary of State has confirmed has an adequate level of protection (an adequacy regulation), or
- We enter into an International Data Transfer Agreement (“IDTA”) with the receiving organisation and adopt supplementary measures, where necessary. (A copy of the IDTA can be found here international-data-transfer-agreement.pdf (ico.org.uk)). Or we will employ Standard Contractual Clauses and the UK International Data Transfer Addendum or equivalent safeguarding mechanisms to ensure equivalent data protection rights. (A copy of the SCCs can be found here Standard Contractual Clauses (SCCs)).
11. Marketing Communications
From time to time, we may use your information to contact you with details about our products and services which we feel may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by following the ‘unsubscribe’ link on any emails received or contacting us at info@smartkyc.com.
12. Your Rights and How to Complain
You have certain rights in relation to the processing of your Personal Data, including to:
- Right to be informed
You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this. - Right of access (commonly known as a “Subject Access Request”)
You have the right to receive a copy of the Personal Data we hold about you. - Right to rectification
You have the right to have any incomplete or inaccurate information we hold about you corrected. - Right to erasure (commonly known as the right to be forgotten)
You have the right to ask us to delete your Personal Data. - Right to object to processing
You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material. - Right to restrict processing
You have the right to restrict our use of your Personal Data. - Right to portability
You have the right to ask us to transfer your Personal Data to another party. - Automated decision-making.
You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making. - Right to withdraw consent
If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed
to, unless we are permitted by law to do so. - Right to lodge a complaint
You have the right to lodge a complaint with the relevant supervisory authority, if you are concerned about the way in which we are handling your Personal Data. The supervisory authority in the UK is the Information Commissioner’s Office who can be contacted online at:
Contact us | ICO
Or by telephone on 0303 123 1113
For supervisory authorities in other countries within the EU see the link below:
https://edpb.europa.eu/about-edpb/about-edpb/members_en
How to exercise your rights
You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.
13. How to Contact Us and Our Data Protection Officer
If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:
smartKYC
83 Victoria Street
London
SW1H 0HW
United Kingdom
data.protection@smartkyc.com
Please mark any queries for the attention of our Privacy Officer.
We have also appointed a Data protection Officer (“DPO”). Our DPO Evalian Limited who can be contacted the following ways:
By post: West Lodge, Leylands Business Park, Colden Common, Southampton, Hampshire, SO21 1TH.
By email: dpo@evalian.co.uk.
By phone: 03330 500111.
Please mark your communications FAO the ‘Data Protection Officer’.
14. Changes to this Privacy Notice
We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.
This Privacy Notice was updated on 20/10/2026.