Privacy Policy

Your privacy matters to us. This comprehensive policy explains how Smartly collects, uses, protects, and manages your personal information when you use our investment strategy platform.

Last Updated: January 15, 2025

1. Information We Collect

At Smartly, we collect various types of information to provide you with exceptional investment strategy services and personalized experiences. Understanding what information we gather helps you make informed decisions about sharing your data with us.

Personal Information

When you create an account or use our services, we collect personal details that help us verify your identity and provide tailored investment strategies:

Full name, email address, and phone number
Residential address and postal code
Date of birth and identification documents
Employment information and income details
Investment experience and risk tolerance preferences
Banking information for transactions and withdrawals

Technical Information

We automatically collect technical data to improve our platform's performance and security:

IP address, browser type, and operating system
Device identifiers and hardware specifications
Website usage patterns and click behavior
Session duration and page interaction data
Cookies and local storage information

Financial Information

To provide investment strategy services, we collect and process financial data including:

Investment portfolio details and transaction history
Risk assessment responses and investment goals
Credit history and financial statements when required
Tax identification numbers for reporting purposes
Trading preferences and strategy selections

2. How We Use Your Information

Your information enables us to deliver personalized investment strategies and maintain the highest standards of service. We use your data responsibly and only for legitimate business purposes that benefit your investment journey.

Purpose	Information Used	Legal Basis
Account Management	Personal details, contact information	Contract performance
Investment Strategy Development	Financial data, risk preferences	Legitimate interest
Regulatory Compliance	Identity verification, transaction records	Legal obligation
Customer Support	Account details, communication history	Contract performance
Platform Improvement	Usage patterns, technical data	Legitimate interest

We never use your personal information for unauthorized purposes or share it with third parties without your explicit consent, except as required by law or outlined in this privacy policy.

3. Information Sharing and Disclosure

Transparency is crucial when it comes to sharing your information. We only disclose your data in specific circumstances that are necessary for providing our services or complying with legal requirements.

Service Providers

We work with trusted third-party service providers who help us deliver our investment strategy platform:

Payment processors for secure transaction handling
Cloud storage providers for data hosting and backup
Identity verification services for account security
Customer support platforms for service delivery
Analytics providers for platform improvement

Legal Requirements

We may disclose your information when legally required or to protect our legitimate interests:

Compliance with court orders, subpoenas, or legal processes
Regulatory reporting to South African financial authorities
Prevention of fraud, money laundering, or illegal activities
Protection of our rights, property, or safety
Business transfers or mergers (with proper notification)

4. Data Security and Protection

Protecting your information is our top priority. We implement comprehensive security measures to safeguard your data against unauthorized access, theft, or misuse. Our security framework includes both technical and organizational measures.

Technical Safeguards

256-bit SSL encryption for all data transmission
Advanced firewall protection and intrusion detection
Regular security audits and vulnerability assessments
Multi-factor authentication for account access
Encrypted data storage with restricted access controls
Automated backup systems with secure off-site storage

Organizational Measures

Strict employee background checks and confidentiality agreements
Role-based access controls limiting data exposure
Regular security training for all staff members
Incident response procedures for potential breaches
Third-party security certifications and compliance monitoring

While we implement industry-leading security measures, no system is completely immune to threats. We continuously monitor and update our security practices to address emerging risks and maintain the highest protection standards.

5. Your Privacy Rights

You have significant control over your personal information. We respect your privacy rights and provide multiple ways to manage your data according to your preferences and applicable privacy laws.

Access and Control Rights

Right to Access: Request copies of all personal information we hold about you
Right to Rectification: Correct inaccurate or incomplete personal data
Right to Erasure: Request deletion of your personal information (subject to legal requirements)
Right to Data Portability: Receive your data in a structured, machine-readable format
Right to Restrict Processing: Limit how we use your information in specific circumstances
Right to Object: Opt out of certain data processing activities

How to Exercise Your Rights

To exercise any of these rights, contact our privacy team at info@sythorina.sbs or submit a written request to our physical address. We will respond to your request within 30 days and may require identity verification to protect your information.

6. Data Retention and Deletion

We retain your information only as long as necessary to fulfill the purposes outlined in this policy, comply with legal obligations, and maintain accurate business records. Our retention practices balance your privacy rights with regulatory requirements.

Retention Periods

Account Information: Retained for 7 years after account closure for regulatory compliance
Transaction Records: Maintained for 5 years as required by South African financial regulations
Marketing Communications: Deleted within 2 years of last engagement or upon opt-out
Technical Logs: Automatically deleted after 12 months unless required for security purposes
Customer Support Records: Retained for 3 years to improve service quality

Secure Deletion Process

When retention periods expire, we use secure deletion methods that make data recovery impossible. This includes overwriting digital storage media and physical destruction of hardware when necessary.

7. International Data Transfers

While Smartly operates primarily in South Africa, we may transfer your information internationally to trusted service providers who help us deliver our investment strategy platform. We ensure all international transfers meet strict privacy protection standards.

Transfer Safeguards

Adequacy decisions recognizing equivalent privacy protection
Standard contractual clauses with international service providers
Binding corporate rules for multinational partners
Certification schemes ensuring privacy compliance
Regular monitoring of international privacy law changes

We never transfer your information to countries or organizations that do not provide adequate privacy protection. All international partners must meet our strict data protection requirements.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to enhance your browsing experience, analyze platform usage, and provide personalized content. You have control over these technologies and can adjust your preferences at any time.

Types of Cookies We Use

Essential Cookies: Required for basic website functionality and security
Performance Cookies: Help us understand how visitors interact with our platform
Functional Cookies: Enable personalized features and remember your preferences
Analytics Cookies: Provide insights into platform usage and improvement opportunities

Managing Cookie Preferences

You can control cookies through your browser settings or our cookie preference center. Disabling certain cookies may affect website functionality and your user experience.

9. Children's Privacy

Smartly's investment strategy platform is designed for adults and we do not knowingly collect personal information from individuals under 18 years of age. If we discover that we have inadvertently collected information from a minor, we will promptly delete it and terminate any associated accounts.

Parents or guardians who believe their child has provided personal information to Smartly should contact us immediately at info@sythorina.sbs so we can remove the information and prevent further collection.

10. Privacy Policy Updates

We regularly review and update this privacy policy to reflect changes in our practices, services, or applicable laws. Material changes will be communicated through email notifications and prominent website notices before they take effect.

Notification Process

Email notification to all registered users at least 30 days before changes take effect
Prominent banner notification on our website during the transition period
Updated version date clearly displayed at the top of this policy
Summary of key changes provided in plain language
Opportunity to review changes and adjust your privacy preferences

Contact Our Privacy Team

If you have questions about this privacy policy, want to exercise your privacy rights, or need assistance with data-related concerns, please contact us:

Email: info@sythorina.sbs
Phone: +27 73 758 3960
Address: 14 Beatrix St, Zeekoewater 311-Js, Emalahleni, 1044, South Africa

We typically respond to privacy inquiries within 5 business days and are committed to resolving your concerns promptly and professionally.