Privacy Policy
SMARTLYY Privacy Policy
Effective 30 October 2026 · Smartlyy Ltd, company number 16587096, registered in England and
Wales
Our regulatory status
Smartlyy Ltd is a technology company. It is not a bank and is not authorised or regulated
by the Financial Conduct Authority. Smartlyy does not hold client money. Regulated
services such as payment accounts, currency conversion and cash out are provided by
licensed partners, and each partner verifies the users it serves.
CONTENTS
1. Who we are
2. What this policy covers
3. Information we collect
4. How we use your information
5. Who we share it with
6. International transfers
7. How long we keep it
8. Security
9. Your rights
10. Automated checks
11. Cookies
12. Children
13. Changes to this policy
14. Contact us
1. Who we are
Smartlyy Ltd (“Smartlyy”, “we”, “us”) is a company registered in England and Wales,
company number 16587096. Our address is 20-22 Wenlock Road, London N1 7GU,
United Kingdom. Smartlyy is the controller of the personal data described in this policy,
which means we decide how and why it is used.
You can contact us at info@smartlyy.co.uk.
2. What this policy covers
Smartlyy provides a cross border money transfer and account service, starting with
transfers from the United Kingdom, Europe, the United States and the United Arab
Emirates to Pakistan. This policy applies to our website, our mobile and web applications
and any related service (together, the “Services”). It applies to senders, recipients,
account holders, business users and visitors.
We process personal data in line with the UK General Data Protection Regulation, the
Data Protection Act 2018 and, where they apply to you, the data protection laws of the
country in which you live.
3. Information we collect
Information you give us
Identity and contact details: name, date of birth, nationality, country of residence,
address, email address, phone number, and a photograph or selfie used for identity
checks.
Identity documents: passport, national identity card or driving licence, and proof of
address.
Business details for business users: company name and registration, directors,
beneficial owners and supporting documents.
Transaction details: amounts, currencies, purpose of a transfer, source of funds, and
recipient details such as name, phone number, email address, bank account, mobile
wallet or digital wallet address.
Communications: messages to our support team, survey answers and feedback.
Information we collect automatically
Technical data: IP address, device identifiers, browser and operating system, log data
and approximate location.
Usage data: how you use the Services, including pages and features used and error
reports.
Wallet and blockchain data: your public wallet address and on chain transaction
identifiers. Where you use a non custodial wallet, we do not receive or store your
private keys or recovery phrases.
Information from others
Identity verification, sanctions, fraud prevention and screening providers.
Our licensed payment, banking and card partners.
Senders, who may give us details about a recipient so that a transfer can be made.
Public sources, such as company registers and sanctions lists.
4. How we use your information
Purpose Legal basis
Create and manage your account and provide the Services,
including processing transfers.
Performance of a contract
Verify your identity and the identity of recipients and
business owners.
Legal obligation; legitimate
interests
Screen against sanctions lists and prevent, detect and
report fraud, money laundering and terrorist financing.
Legal obligation; legitimate
interests
Keep the Services secure and resolve technical problems. Legitimate interests
Respond to your questions and complaints. Performance of a contract;
legitimate interests
Improve and develop the Services, including analysis of
usage.
Legitimate interests; consent
where required for cookies
Send you product news and offers. You can opt out at any
time.
Consent, or legitimate
interests where the law allows
Establish, exercise or defend legal claims and meet our legal
and regulatory duties.
Legal obligation; legitimate
interests
Where we rely on legitimate interests, we weigh them against your rights and freedoms.
Where we rely on consent, you can withdraw it at any time, without affecting what we did
before.
5. Who we share it with
We share personal data only where needed to provide the Services, to meet our legal
duties, or with your permission. Recipients include:
Licensed payment, banking and payout partners, including Latitude, Bridge and
Thunes, that provide accounts, currency conversion and payouts. They act under their
own licences and may use your data to meet their own legal duties.
Fiat on ramp and off ramp providers. If you choose to buy or sell digital assets
through a third party provider, that provider collects and uses your data as an
independent controller under its own privacy policy and terms. We recommend you
read them before you proceed.
Identity verification and screening providers that check documents, liveness and
sanctions status.
Wallet infrastructure providers, including Privy, that make non custodial wallets
available to you.
Service providers for cloud hosting, analytics, customer support and communications,
who act on our instructions.
Professional advisers, auditors and insurers.
Authorities and courts, such as regulators, tax authorities and law enforcement,
where the law requires or permits it.
A buyer or investor if we sell or restructure our business, under confidentiality terms.
We do not sell your personal data, and we do not share it with third parties for their own
marketing.
6. International transfers
Our service moves money across borders, so your data may be sent to or accessed from
countries outside the United Kingdom, including countries in the European Economic
Area, the United States, Canada, the United Arab Emirates and Pakistan. Some of these
countries may not have the same level of data protection as the United Kingdom.
When we transfer personal data, we use a recognised safeguard, such as a UK adequacy
decision, the UK International Data Transfer Agreement or the UK Addendum to the
European Commission’s standard contractual clauses. You can ask us for details by using
the contact information below.
7. How long we keep it
We keep personal data for as long as you have an account with us and as long as needed
for the purposes above. Anti money laundering rules require us to keep identity and
transaction records for at least five years after our relationship ends. After that, we delete
or anonymise the data unless we need it for a legal claim or the law requires us to keep it
longer.
Blockchain transactions are public and permanent. We cannot alter or delete information
recorded on a public blockchain.
8. Security
We use technical and organisational measures to protect personal data, including
encryption in transit and at rest, access controls, and monitoring. No system is completely
secure. You are responsible for keeping your login details and your wallet recovery
methods safe. If we become aware of a breach that is likely to put your rights at risk, we
will notify you and the regulator as the law requires.
9. Your rights
Under the UK GDPR you have the right to:
access the personal data we hold about you;
ask us to correct inaccurate or incomplete data;
ask us to delete your data, in some circumstances;
ask us to restrict how we use your data, in some circumstances;
receive your data in a portable format, or ask us to send it to another provider;
object to uses based on our legitimate interests, and to direct marketing at any time;
and
withdraw consent where we rely on it.
To use a right, contact us using the details below. We aim to respond within one month.
We may ask you to confirm your identity first. Some rights are limited where we must
keep records by law, for example under anti money laundering rules. If you live outside
the United Kingdom, you may have additional rights under local law, which we will respect
where they apply.
If you are unhappy with how we handle your data, please tell us first so that we can put it
right. You also have the right to complain to the UK Information Commissioner’s Office at
ico.org.uk.
10. Automated checks
We and our partners use automated tools to check identity documents, screen for
sanctions and detect fraud. These checks can lead to a refusal, delay or restriction on an
account or a transfer. If a decision affects you significantly, you can ask for a person to
review it and can tell us your point of view.
11. Cookies
Our website and applications use cookies and similar technologies. Essential cookies
keep the Services working and secure. Where we use analytics or similar cookies that are
not essential, we ask for your consent first. You can change your choices in the cookie
settings or in your browser at any time.
12. Children
The Services are for people aged 18 and over. We do not knowingly collect personal data
from anyone under 18. If you believe a child has given us personal data, contact us and
we will delete it.
13. Changes to this policy
We may update this policy from time to time. We will post the new version here with a
new effective date. If a change is material, we will tell you by email or through the
Services before it takes effect.
14. Contact us
Smartlyy Ltd
20-22 Wenlock Road, London N1 7GU, United Kingdom
Company number 16587096
Email: info@smartlyy.co.uk
Smartlyy Ltd · Privacy Policy · Effective 30 October 2026