Privacy policy

Effective Date: 17 April 2025

Aynam Limited t/a Smartmonies

This Privacy Policy explains how Aynam Limited, trading as Smartmonies ('we', 'us', 'our'), collects, uses, stores, and protects personal data in connection with our website (www.smartmonies.co.uk) and our online financial literacy classes.

We are the data controller for the personal data we process about you. We take our obligations under UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 very seriously.

We apply a high-privacy-by-default approach to all personal data relating to children and never use children's data for commercial purposes such as advertising.

1. Who We Are

Data Controller: Aynam Limited t/a Smartmonies

Registered address: 9 Moorhouse Road, London W2 5DH, United Kingdom

Company number: 13693137

Contact email: info@smartmonies.co.uk

Contact telephone: 07418 082304

If you have any questions about how we handle your personal data, or wish to exercise any of your rights, please contact us at the email address above.

2. What Personal Data We Collect

2.1 Information you provide to us

When you register for our Services, purchase a class, or contact us, we may collect:

Your name and the name of the child participant;
Your email address and telephone number;
Your postal address (for account and legal correspondence);
Payment confirmation details (we do not store your card numbers, payment processing is handled by our third-party payment provider);
Communications you send to us (e.g. enquiry emails, feedback).

2.2 Information collected automatically

When you use our Website, we automatically collect certain technical data, including:

IP address and approximate location;
Browser type and version;
Pages visited and time spent on our Website;
Device type.

This data is collected via cookies and similar technologies. Please see Section 8 (Cookies) for full details.

2.3 Children's data

Because our classes are for children aged 8 to 12, we collect limited personal data about child participants (primarily first name and any information relevant to their learning). This data is provided by, and processed under the authorisation of, the child's parent or legal guardian. We do not knowingly collect more data about children than is strictly necessary to deliver the Service.

We do not use children's personal data for any commercial purpose, including advertising, profiling, or marketing.

3. How We Use Your Personal Data

The table below sets out the purposes for which we use personal data, the lawful basis under UK GDPR, and the categories of data involved.

Purpose

Lawful Basis

Data Used

Delivering classes and administering your enrolment

Contract performance (Art. 6(1)(b) UK GDPR)

Name, contact details, class booking details

Processing payments

Contract performance (Art. 6(1)(b) UK GDPR)

Payment confirmation details (card processing handled by third party)

Sending service-related communications (e.g. class reminders)

Contract performance (Art. 6(1)(b) UK GDPR)

Email address, name

Sending marketing communications (newsletters, offers)

Consent (Art. 6(1)(a) UK GDPR) — you may withdraw at any time

Email address, name

Improving our Website and Services using analytics

Legitimate interests (Art. 6(1)(f) UK GDPR) — to understand how our site is used

Anonymised/aggregated usage data

Complying with legal obligations

Legal obligation (Art. 6(1)(c) UK GDPR)

As required by law

Safeguarding and child protection

Legal obligation / vital interests (Art. 6(1)(c) and (d) UK GDPR)

As necessary to protect child participants

Where we rely on legitimate interests as our lawful basis, we have balanced our interests against your rights and concluded that our use is proportionate and does not override your interests. You have the right to object to processing carried out on this basis — see Section 6.

4. Sharing Your Personal Data

We do not sell your personal data. We may share it with third parties only in the following circumstances:

Service providers: We use trusted third-party providers to help us deliver our Services, including payment processors, video conferencing platforms, email delivery services, and website hosting. These providers act as data processors and are only permitted to use your data on our instructions.
Legal requirements: We may disclose data if required to do so by law, court order, or regulatory authority, or to protect the rights, property, or safety of Smartmonies, our users, or others.
Safeguarding: We may share data with statutory authorities (e.g. local authority safeguarding teams, police) where we have a legal obligation or vital interest to do so.
Business transfers: If Aynam Limited is involved in a merger, acquisition, or asset sale, personal data may be transferred as part of that transaction. We will notify you if this occurs.

We currently use the following categories of service providers:

Payment processing (e.g. Stripe or similar);
Video conferencing (e.g. Zoom, Google Meet, or similar);
Email marketing and communications;
Website hosting and analytics (Wix).

Where any of these providers are located outside the UK or EEA, we ensure that appropriate safeguards are in place (such as Standard Contractual Clauses or an adequacy decision) before transferring personal data.

5. How Long We Keep Your Data

We keep personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by law. Our standard retention periods are:

Account and booking records: 7 years from the end of the customer relationship (for tax and legal purposes);
Financial and payment records: 7 years (as required by HMRC);
Marketing preferences and consent records: Until you withdraw consent, and for 3 years thereafter;
Safeguarding records: As required by our safeguarding policy and applicable statutory guidance;
Website analytics (cookies): As set out in our Cookie Policy — typically no longer than 2 years.

After the applicable retention period, personal data is securely deleted or anonymised.

6. Your Rights Under UK GDPR

You have the following rights in relation to your personal data. To exercise any of these rights, please contact us at info@smartmonies.co.uk.

Right of access: You can request a copy of the personal data we hold about you.
Right to rectification: You can ask us to correct any inaccurate or incomplete personal data.
Right to erasure ('right to be forgotten'): You can ask us to delete your personal data in certain circumstances (e.g. where it is no longer necessary for the purpose it was collected, or where you withdraw consent).
Right to restriction: You can ask us to restrict the way we process your data while a dispute is resolved.
Right to data portability: Where processing is based on consent or contract, you can ask us to provide your data in a portable, machine-readable format.
Right to object: You can object to processing based on legitimate interests, and you have an absolute right to object to direct marketing at any time.
Right to withdraw consent: Where we process data based on your consent, you can withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
Rights in relation to automated decision-making: You have the right not to be subject to a decision based solely on automated processing that produces significant effects on you. We do not currently carry out such processing.

We will respond to requests within one calendar month. In some cases, we may need to verify your identity before processing your request.

If you are exercising rights on behalf of your child, we may ask you to confirm your relationship to the child.

7. Complaints and the ICO

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), which is the UK's data protection supervisory authority:

Website: www.ico.org.uk
Telephone: 0303 123 1113
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us first at info@smartmonies.co.uk.

8. Cookies

Our Website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit our Website.

We use the following types of cookies:

Strictly necessary cookies: Required for the Website to function. These cannot be disabled.
Performance/analytics cookies: Help us understand how visitors use our Website (e.g. Google Analytics or Wix Analytics). These are only set with your consent.
Functionality cookies: Allow the Website to remember your preferences.
Marketing/targeting cookies: Used to deliver relevant advertising. These are only set with your consent.

When you first visit our Website, you will be asked to consent to non-essential cookies via our cookie banner. You can withdraw or change your cookie preferences at any time by clicking the 'Cookie Settings' link in our website footer.

For more information about cookies and how to control them, visit www.allaboutcookies.org.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

Encrypted transmission of data (HTTPS);
Access controls to restrict who can access personal data;
Use of reputable, security-audited third-party platforms.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, will notify affected individuals without undue delay.

10. Children's Privacy and the Age Appropriate Design Code

As a service directed at children, we take the ICO's Age Appropriate Design Code seriously. Our commitments include:

We apply high privacy settings by default for users who we know or can reasonably identify as children;
We collect only the minimum personal data about child participants that is necessary to deliver the Service;
We do not use children's personal data for profiling, targeted advertising, or any commercial purpose;
We do not use nudge techniques or design features intended to encourage children to provide more data than necessary;
Parental or guardian consent is required before a child under 18 can participate in our Services.

If you are a parent or guardian and believe we may have inadvertently collected personal data about a child without appropriate consent, please contact us immediately at info@smartmonies.co.uk and we will take prompt steps to delete the data.

11. Third-Party Links

Our Website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing any personal data.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or technology. We will notify you of material changes by email or by posting a notice on our Website. The updated policy will be effective from the date stated at the top of the document.

We encourage you to review this policy periodically.

Aynam Limited t/a Smartmonies | 9 Moorhouse Road, London W2 5DH

Email: info@smartmonies.co.uk | Tel: 07418 082304

ICO: www.ico.org.uk | 0303 123 1113