This policy describes how SmartStream collects, uses, and discloses information, and what choices you have with respect to the information.
It is SmartStream’s policy to respect your privacy regarding any information we may collect while using our on demand service.
SmartStream operates a suite of web-based applications (TLM Reconciliations Premium, TLM Corporate Actions, TLM Fees and Expense Management etc.) collectively deployed as an on demand service. All such solutions, applications, webpages are collectively called “Services”.
Data Controller and Data Processor
We process two main types of personal data.
- Customer data – Personal data that forms part of data that is provided by our customers and their end-users for processing.
- Other data – Personal data about our customers, visitors and other individuals that is collected and processed directly by us.
Our Customers are the controller of Customer Data. SmartStream is the processor of Customer Data and the controller of Other Data.
Information we collect
As customers, you provide data to us for processing as part of usage of our SmartStream applications.
Customer Data may be processed by us as a result of customer’s use of the Services when our customers, or their end-users, input, or upload information into the Service. For example, customers who use our SmartStream application may upload Customer Data about themselves or their employees or their clients.
This data includes name, email address, phone number, job title etc. for your employees.
Customers provide data that is necessary to create user accounts.
For creation of user accounts, you provide your name, email address, password, and telephone number.
We also collect data when you use our applications.
- Log data – Our servers automatically collect information when you access or use our applications and services. This data is recorded in log files. Examples of such data include IP Address
- Subscription data – You provide personal data to us as part of requesting customer support, or otherwise communicating with us.
- Contact us data – When you raise query about our products and services, we collect and store this data to communicate with you and respond to your enquiry.
Data from others
SmartStream may receive your data from sources other than from you, such as user id creation request, escalation matrix, point of contact, workflow tool etc.
How we use your data
How we use your personal data will depend on which Services you use and how you use those Services.
Customer Data will be used by SmartStream in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. SmartStream is a processor of Customer Data and Customer is the controller.
Other Data is used by us to provide our services and to communicate with you by responding to your requests, comments, and questions.
Lawful bases for processing
We have lawful bases to process your personal data. We also use your consent as bases for lawfully processing your personal data.
We process your personal data only when we have a lawful basis. Presently, we use the Performance of Contract (i.e. to deliver the services to our customers) and consent as the lawful basis for processing. For certain processing, we may also use legitimate interests as provided under the Data Protection Regulations.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
Where you have consented to a particular processing, you have a right to withdraw the consent at any time.
How we use customer data
We use your data to authenticate you and authorize access to our services
We only process Customer Data on behalf of our customers and in accordance with their instructions provided in the applicable Services agreement with us. We use the data that we have about you to provide our services and provide support to you. In each case, SmartStream collects such information only in so far as is necessary or appropriate to fulfil the purpose of the interaction with our services.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services and our Services offerings. These communications are considered part of the Services and you may not opt out of them.
- Customer support. If you send us a request (for example via a support email or via one of our feedback mechanisms), we respond to your request or to help your issues.
- For any other purpose as provided for in the Services Agreement between us and the customer, or as otherwise authorized by the customer.
- In accordance with or as may be required by law.
How we use other data
We may send you service-related messages or materials. You may choose to restrict the collection or use of your personal information
We will update your details for application credentials, communicate with you for addressing your queries etc.
Users under 16 years of age
The Services do not knowingly collect personal information from users under the age of 16
If you are under the age of 16, you are not permitted to use the Sites and Services or to disclose Personal Information. If we learn we have collected or received Personal Information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.
Data retention policy
Customer Data – We retain your information for as long as you have an active Services account. We may also retain your personal information for extended period under applicable statutory laws.
SmartStream will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. When you decide to close your account, we delete all personal information about you.
You can request to access, update, or correct your personal information.
You may have additional rights pursuant to your local law applicable to the processing. For example, if the processing of your personal information is subject to the EU General Data Protection Regulation (“GDPR”), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation. Under GDPR you may also have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.
Your rights to control data
Whenever you use our services, we aim to provide you easy means to access, modify, delete, object to, or restrict use of your personal information
We strive to give you ways to access, update/modify your data quickly or to delete it unless we have to keep that information for legal purposes. Some rights can be access from within the SmartStream application. For visitors, these rights can be exercised by contacting us with your specific request.
- Change or correct data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it is inaccurate.
- Delete data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
- Object to, or limit or restrict, use of data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
- Right to access and/or take your data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
We keep some personal data even after account closure.
Once you choose to close your account, we generally delete your personal information within 60 days of closure of your account. Some information that is necessary for statutory obligations such as records of payment processing, invoicing data will be retained, as necessary.
Your information shared with others
Recipients of your data
Your data will be shared with other recipients in order to provide you with services.
While we aim to limit the sharing of your data, at times, it is necessary to share your data with certain service providers. Examples of when and for what purpose your data is shared include data centre / hosting services, email services, etc.
The following categories of recipient will most likely receive your data in order for us to provide services to you:
- Third party data centre services
- Third party SMTP services such as Microsoft
- Other modules of SmartStream applications to which you may or may not have subscribed to
To comply with laws – if we receive a request for information, we may disclose if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process.
Cross-border data transfers
Your data will be stored and processed in multiple countries including outside of the European Union (EU) Region.
Since we are an international company, your data will be processed outside of the EU region. Your data will be processed within Third Party Data Centres in the US and APAC region. Some countries where we process data may not have as protective laws as your own country and there are risks associated with such transfer.
SmartStream offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. These clauses are contractual commitments between parties transferring personal data (for example, between SmartStream and its Clients, suppliers, or data processors outside the EU), binding them to protect the privacy and security of the data.
Security measures to protect your data
We implement security controls to prevent breaches and unauthorised access to your data.
We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
Examples of security measures include physical access controls, HTTPS, restricted access to data, monitoring for threats and vulnerabilities etc.
We also subject our services to internationally recognised certification and attestation standards.
Protection of personal information
Our Sites and Services uses commercial efforts to maintain safeguards for protection of your Personal Information.
SmartStream takes all measures reasonably necessary to protect against the unauthorised access, use, alteration, or destruction of potentially personally identifying and personally identifying information.
If you have questions or complaints regarding this policy, you may contact us through email at firstname.lastname@example.org or STL-Support@smartstream-stp.com. You may contact us at our mailing address below:
SmartStream Technologies, St Helen’s, 1 Undershaft, London EC3A 8EE.
If you are a resident of the European Economic Area and we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you have additional rights. If you are not satisfied with the resolution, you can also lodge a complaint with the Supervisory Authority in the country of your residence.