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Privacy center

Privacy notice

SmartRemit is designed for compliant money movement. This notice explains what customer data is collected, why it is used, how security and compliance checks rely on it, what consent means, and how deletion, anonymisation, and retention decisions are handled truthfully.

Collect only what the service genuinely needs

SmartRemit should collect data required for onboarding, account security, transfer fulfilment, customer support, fraud prevention, and legal compliance, instead of hiding broad collection behind vague catch-all wording.

Separate mandatory service use from optional consent-based use

Core regulated-service processing is not the same as optional research, analytics expansion, or AI/model-improvement work. The notice should say exactly which uses are required to operate SmartRemit and which would need a separate disclosure and consent step first.

Keep access limited and observable

Customer data access should stay restricted by role, operational need, and audit visibility so SmartRemit can explain who accessed what and why.

Be honest about deletion, anonymisation, and retention

A deletion request should open a real review path, but the notice must also explain that some records may need temporary retention, minimisation, or anonymisation before the case can close.

What data SmartRemit collects and why

Profile and contact data

Collected

Name, email address, phone number, country, profile edits, and policy acknowledgements.

Why SmartRemit uses it

Used to open the account shell, contact the customer, protect access, and keep a record of which SmartRemit notices were accepted.

Operational / legal basis

Required for account administration, contract performance, and operational/legal record keeping.

Retention posture

Held for the active account lifecycle and then reviewed for deletion or anonymisation when no legal hold still applies.

Identity and verification data

Collected

KYC profile fields, verification evidence metadata, review outcomes, sanctions/AML screening posture, and reviewer notes.

Why SmartRemit uses it

Used to satisfy customer due-diligence, transfer eligibility, fraud review, and compliance obligations for a regulated remittance product.

Operational / legal basis

Required for legal and regulatory compliance plus fraud-control duties.

Retention posture

Kept according to verification, compliance, and audit retention needs even if the customer later asks for deletion.

Authentication and device-security data

Collected

Passwords, MFA enrollment state, sessions, remembered devices, login attempts, IP/device/location signals, and security events.

Why SmartRemit uses it

Used to secure sign-in, detect unusual activity, step up verification when risk rises, and support incident investigations.

Operational / legal basis

Required for service security, fraud prevention, and account protection.

Retention posture

Minimised after review windows expire, but some audit traces may remain as security evidence.

Transfer, payment, and ledger records

Collected

Quotes, transfers, bill payments, beneficiaries, funding accounts, transaction history, and operational references.

Why SmartRemit uses it

Used to deliver money movement, reconcile balances, resolve disputes, investigate exceptions, and satisfy AML/audit obligations.

Operational / legal basis

Required to operate the regulated financial service and satisfy financial-recordkeeping rules.

Retention posture

Often retained for the required regulatory or dispute window before any further minimisation or anonymisation can be considered.

Support, complaint, and review records

Collected

Support tickets, case notes, privacy-erasure requests, policy decisions, and closeout evidence.

Why SmartRemit uses it

Used to investigate issues, manage deletion reviews truthfully, and show what SmartRemit decided and why.

Operational / legal basis

Required for customer support, operational accountability, and compliance explainability.

Retention posture

Minimum closeout evidence may remain even after profile fields are removed or anonymised.

How the platform uses data

Service delivery

SmartRemit uses account, identity, device, session, payment, and support data to open accounts, secure sign-in, process transfers, review verification, investigate issues, and keep customers informed.

Risk, fraud, and compliance

Some personal data must be checked to satisfy AML, sanctions, fraud, dispute, audit, and record-retention obligations. Those uses are part of operating a regulated remittance product and should not be hidden inside vague copy.

Optional research or product improvement

Account creation alone must not imply consent for optional research, product analytics beyond core service delivery, or AI/model-improvement use. If SmartRemit introduces those uses, the notice, legal basis, consent control, and withdrawal path must be disclosed explicitly first.

Deletion and retention

Customers should be able to request account deletion, but SmartRemit still has to explain when data can be fully removed, when it must be anonymised, and when financial or compliance obligations require temporary retention or manual review.

What consent means

Consent is not hidden inside account creation

Account creation does not automatically authorise optional research, broad product experimentation, or AI/model-improvement use. SmartRemit may still process the data needed to run the service lawfully, but optional uses should remain separately disclosed and actively chosen.

Optional uses need a real control

If SmartRemit later adds optional research or improvement programs, the customer should see the purpose, the data involved, the legal basis, and a clear on/off control before those uses begin.

Withdrawal should be understandable

Where consent is the legal basis, customers should be told how to withdraw it and what changes operationally after withdrawal.

Mandatory regulated processing stays separate

AML, sanctions, fraud checks, security controls, and financial-record retention may still continue where the law or the core service requires them, even if a customer declines optional uses or requests deletion.

Deletion, anonymisation, and retention truth table

Profile, preferences, and contact details

While the request is under review

Keep available to the customer and reviewers while the deletion case is assessed.

After approved review

Delete or anonymise once legal-hold checks clear and the approved review says those fields can be removed.

Why

These are usually the first customer-facing fields that can be minimised after offboarding, but the exact action still depends on the approved review outcome.

Passwords, sessions, MFA, and remembered devices

While the request is under review

Do not revoke automatically at the moment of request; SmartRemit should schedule auth cleanup deliberately once the review reaches the approved offboarding stage.

After approved review

Disable future sign-in, revoke tokens, and remove remembered-device trust as part of the approved authentication cleanup step.

Why

Authentication cleanup is operationally separate from legal retention of financial or audit evidence.

Transfers, bill payments, and ledger evidence

While the request is under review

Treat as retained evidence during review.

After approved review

Retain, restrict, or anonymise only within the legal/compliance matrix; do not promise immediate automatic purge.

Why

Regulated remittance activity may need retention for AML, reconciliation, disputes, chargebacks, or audits.

Support tickets, policy decisions, and audit trail

While the request is under review

Keep available to reviewers and case owners.

After approved review

Retain the minimum closeout evidence showing what was deleted, anonymised, retained, and why.

Why

SmartRemit still needs explainability and proof of the action taken on the deletion request.

Security posture and customer commitments

Role-limited access

Customer data should be visible only to the teams and tools that genuinely need it for support, compliance, fraud review, or product operations.

Security monitoring

Authentication, device, and transaction signals should be used to spot suspicious activity, trigger stronger checks, and keep an audit trail of important security actions.

Deletion requests without false promises

The product should provide a real deletion-request path, clear status, and truthful explanations of what SmartRemit can revoke immediately, what needs review, and what must remain retained.

Customer-readable rights surfaces

Privacy pages should show export, correction, restriction, portability, deletion posture, and intentional fallback states instead of blank failures or hidden routes.