PLEASE READ THESE TERMS OF SERVICE CAREFULLY.

This is a contract between you (the Customer) and us (Smarter Financial Ltd, 85 Great Portland Street, Marylebone, London, W1W 7LT.) It describes the services we will provide to you, how we will work together, and other aspects of our business relationship.

1. General Terms

By signing up for an account with smart-bill.co.uk, (including sub-domains of smart-bill.co.uk), (Service), you are deemed to have read and agreed to the following Terms of Services.

Terminology:

"Agreement" means these Customer Terms of Service and all materials referred or linked to in here.

"Organisation", “You” and “Your” refers to you, the person accessing the Service either as a visitor or a member (registered with smart-bill.co.uk).

"The Company", “Ourselves”, “We” and "Us", refers to our Company, Smarter Financial Ltd.

“Party”, “Parties”, or “Us”, refers to both you and ourselves, or either you or ourselves.

“Client Companies” refers to companies that referred you to use our services, as part of a commercial arrangement with Ourselves.

Any use of the above terminology or other words in the singular, plural, capitalisation and/or he/she or they, are taken as interchangeable and therefore as referring to be same.

2. Service Description

The Service is an FCA approved Account Information Services Provider (AISP) that accesses your bank transaction data with your permission in a read only fashion. Using this data the service obtains information that is useful to yourself or Client Companies. This may include information to help you manage your bills and subscriptions, or information about your general spending patterns. This information can include but is not limited to identification of all your recurring payments, such as subscriptions, direct debits and standing orders.

The Service is free to you and provides you with a safe and secure way to share your transaction data with our client companies, and / or provides you with information to allow you to manage your bills and payments. When assisting you to manage your bills and subscriptions the service monitors price hikes and enables you to request cancellations of any unwanted recurring payments. This service may also present you with information relating to third party products or services (“SmartBill Offers”), general tips, recommendations and educational material.

During the process of obtaining your transaction data, we may use tools provided to us by FCA authorised 3^rd party providers such as TrueLayer Limited (www.truelayer.com, FCA firm reference 793171.)

Any 3^rd party companies we use are subject to UK and EU data protection laws and are required to treat your data in accordance with those laws, as well their own Terms of Service and Privacy Policies. In this instance, you will be asked to enter your payment account details with the 3^rd party and agree to their Terms of Service, which set out the terms on which you agree to access of your information for the purposes of transmitting it to us.

3. Account Terms

We trust you to use our Service responsibly. By using the Service, including features, content and functionality provided by us, you agree to be bound by this Agreement.

You must not:

Share your login details with other people. We cannot and will not be liable for any loss or damage from your failure to comply with this security obligation. If you become aware of any unauthorized use of your Account information for the Service, you agree to notify us immediately via smeeta.patel@smart-bill.co.uk;

Analyse, scan, or test the vulnerability of any system or network or breach or circumvent any security or authentication measures;

Forge any IP packet header or any part of the header information in any email or posting, or in any way use the Service to send altered, deceptive or false source-identifying information;

Use smart-bill.co.uk or accept this Agreement if you are under 18 years of age;

You authorise us to:

Make inquiries to validate your identity, which may require ownership confirmation of your email address. If we cannot verify the identity, then you will not be allowed to use the Services;

Encrypt your information and use it to improve the Services.

Send you electronic communications and notifications to the email address you register with.

Access your Account Information maintained by identified third parties, on your behalf.

You accept that:

We reserve the right to suspend or terminate your account for violation of any of the terms above;

We may temporarily or permanently stop providing the Service, or any features within the Service, to you and may not be able to provide you with prior notice. We will not be liable to any party for any loss, cost or damages due to the Service downtime;

We may add new and/or update pre-release features to the Service for trial purpose for your use to improve the Service;

Any alerts provided to you through the Services may be delayed or fail due to any number of reasons. We shall not be liable for any loss or damages, howsoever arising, associated with your use of the service, any report or data except for liability in respect of loss that cannot be limited under English law.

4. Data Protection

We comply with EU data protection laws and as such, any information concerning you is regarded as confidential and therefore will not be divulged to any third party, other than (1) to our affiliates, representatives, agents, service providers and professional advisors to the extent necessary in connection with the provision of the services or (2) if legally required to do so under any applicable law or regulation or by order of any legal, supervisory, regulatory, judicial or governmental authority.

We use collected information for the following general purposes: products and services provision, billing, identification and authentication, services improvement, contact, and market research.

We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by us will only be in connection with the provision of agreed Services.

5. Modifications

We may periodically revise these Terms of Services. We will update our website and at our sole discretion, will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in the Services or by placing a prominent notice on our site. By continuing to access or use the Service after revisions become effective, you agree to be bound by the revised Terms. If you do not agree to the new terms, please stop using the Services.

We reserve the right to modify or discontinue temporarily or permanently, the Service (or any part thereof) with or without notice. We shall not be liable to you or to any third party for any modification, price change, suspension or discontinuance of the Service.

We have sole discretion to change to fix, refine or add more features to the Service at anytime and may not give you prior notice. Any new features that augment or enhance the current Service, including the release of new tools and resources, shall be subject to the Terms of Service. Continued use of the Service after any such changes shall constitute your consent to such changes.

6. Disclosure

We may disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate the TERMS OF SERVICE.For more information on permitted disclosure, please see section 4 above.

7. Force Majeure

Neither party shall be liable to the other for any failure to perform any obligation under any Agreement which is due to an event beyond the control of such party including but not limited to any Act of God, terrorism, war, Political insurgence, insurrection, riot, civil unrest, act of civil or military authority, uprising, earthquake, flood or any other natural or man made eventuality outside of our control, which causes the termination of an agreement or contract entered into, nor which could have been reasonably foreseen. Any Party affected by such event shall forthwith inform the other Party of the same and shall use all reasonable endeavour to comply with the terms and conditions of any Agreement contained herein.

8. Waiver

Failure of either Party to insist upon strict performance of any provision of this Terms of Service or the failure of either Party to exercise any right or remedy to which they are entitled hereunder shall not constitute a waiver thereof and shall not cause a reduction of the obligations under this Terms of Service.

9. No Warranty

The information on the Service is provided on an "as is" basis and excludes all warranties relating to its website and its contents, including any inaccuracies or omissions in this website and/or literature. Use of the Service is at your own Risk.

The Services exclude all liability for damages arising out of or in connection with your use of this website. This includes, without limitation, direct loss, loss of business or profits (whether or not the loss of such profits was foreseeable, arose in the normal course of things or you have advised the Company of the possibility of such potential loss), damage caused to your computer, computer software, systems and programs and the data thereon or any other direct or indirect, consequential and incidental damages.

We do not warrant that

(I) the service will meet your specific requirements,

(II) the service will be uninterrupted, timely, secure, or error-free,

(III) the results that may be obtained from the use of the service will be accurate or reliable,

(IV) the quality of any products, services, information, or other material purchased or obtained by you through the service will meet your expectations, and

(V) any errors in the Service will be corrected.

8. 10. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL THE COMPANY, ITS AFFILIATES, DIRECTORS, EMPLOYEES OR SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, PUNITIVE, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES, THAT RESULT FROM THE USE OF, OR INABILITY TO USE, THIS SERVICE. UNDER NO CIRCUMSTANCES WILL WE BE RESPONSIBLE FOR ANY DAMAGE, LOSS OR INJURY RESULTING FROM HACKING, TAMPERING OR OTHER UNAUTHORIZED ACCESS OR USE OF THE SERVICE OR YOUR ACCOUNT OR THE INFORMATION CONTAINED THEREIN.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, WE ASSUME NO LIABILITY OR RESPONSIBILITY FOR ANY

I. ERRORS, MISTAKES, OR INACCURACIES OF CONTENT;

II. PERSONAL DAMAGE OF ANY NATURE WHATSOEVER RESULTING FROM YOUR ACCESS TO OR USE OF OUR SERVICE;

III. ANY UNAUTHORIZED ACCESS TO OR USE OF OUR SECURE SERVERS AND/OR ANY AND ALL PERSONAL INFORMATION STORED THEREIN;

IV. ANY INTERRUPTION OR TERMINATION OF TRANSMISSION TO OR FROM THE SERVICE;

V. ANY BUGS or VIRUSES THAT MAY BE TRANSMITTED TO OR THROUGH OUR SERVICE BY ANY THIRD PARTY;

VI. ANY ERRORS OR OMISSIONS IN ANY CONTENT OR FOR ANY LOSS OR DAMAGE INCURRED AS A RESULT OF THE USE OF ANY CONTENT POSTED, EMAILED, TRANSMITTED, OR OTHERWISE MADE AVAILABLE THROUGH THE SERVICE;

VII. USER CONTENT OR THE DEFAMATORY, OFFENSIVE, OR ILLEGAL CONDUCT OF ANY THIRD PARTY. IN NO EVENT SHALL The Company, Its DIRECTORS, EMPLOYEES, or SUPPLIERS, BE LIABLE TO YOU FOR ANY CLAIMS, PROCEEDINGS, LIABILITIES, OBLIGATIONS, DAMAGES, LOSSES OR COSTS IN AN AMOUNT EXCEEDING THE AMOUNT YOU PAID TO COMPANY HEREUNDER.

THIS LIMITATION OF LIABILITY SECTION APPLIES WHETHER THE ALLEGED LIABILITY IS BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, OR ANY OTHER BASIS, EVEN IF The company HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGE. THE FOREGOING LIMITATION OF LIABILITY SHALL APPLY TO THE FULLEST EXTENT PERMITTED BY LAW IN THE APPLICABLE JURISDICTION.

The Service is controlled and operated from its facilities in the United Kingdom. We make no representations that the Service is appropriate or available for use in other locations. Those who access or use the Service from other jurisdictions do so at their own volition and are entirely responsible for compliance with all applicable United kingdom laws.

10. Complaints

Should you have any questions or complaints in respect of this web application or the service please contact smeeta.patel@smart-bill.co.uk.

We take any complaints seriously and will aim to send you an initial response, which shall, at the very least, acknowledge our receipt of your complaint, within 3 Business Days.

We shall send you a full written response to your complaint within 15 days of our receipt of your initial complaint.

In the event that you are dissatisfied with our final response to your complaint you are able to escalate it to the Financial Ombudsman. Please see http://www.financial-ombudsman.org.uk/consumer/complaints.htm for further details.

Please read this Privacy Policy, which explains our commitment to data protection and how we will use your information. This Privacy Policy applies to our website www.smart-bill.co.uk (including sub-domains), and our Services made available through the website.

This Privacy Policy governs our data collection, processing and usage practices. By using the Website and its Services, you consent to the data practices described in this Privacy Policy.

The Service is provided by Smarter Financial Ltd, with registered office at 85 Great Portland Street, Marylebone, London, W1W 7LT.

Important Information

We may update this Privacy Policy from time to time by posting new versions online. You should check this page occasionally to review any changes. If we make any changes, we will notify you by posting the revised Privacy Policy on our Website.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at contact@smart-bill.co.uk.

Information we collect

As a visitor of the website, you are free to explore the website without providing any information about yourself. We may record certain navigation information, to help improve the Website and the Service.

When you register for the Service, we request that you provide Personal Information about yourself, such as full name, contact number and a valid email. Once you have registered you may also submit additional personal information at your discretion.

When you add your bank and/or credit card accounts and will need to use your online banking credentials. We may use some services provided to us by third-party service providers such as Truelayer or Yodlee to assist with our services. This service providers are not permitted to store, retain, or use the credential information you provide except for the sole purpose gaining “read-only” access to your bank transaction information. We cannot see or use your credentials and cannot move money or make any changes to your account.

When you link the added account through the Service, you grant us permission to process your account information, including accounts details and account transactions for the purpose of providing you the Service.

How we use your information

We will use the information which we collect about you for purposes of saving you money and making it easier to manage your finances or to provide data to companies that referred you to the service as part of a commercial arrangement with us (Client Companies). We need to process your data in order to fulfil the contract you enter when you sign up to use SmartBill, and this is the legal basis by which we undertake processing. The type of processing we undertake includes but is not limited to the following:

Maintaining general services such as password resets, account cancellations and unwanted subscription cancellations.

Sending you alerts and notifications to the email address you register with.

Analysing your data to identify all recurring payments, work out your contract status and recommend cheaper products and services to the ones which you are using to save money. To recommend cheaper products and services, we may send limited encrypted information about you to our partners. Any recommendations suggested to you may be emailed and can be viewed on your dashboard of the Service.

Requesting online surveys to help us enhance our services and products for you.

We may also use your information, which will be fully anonymised to perform statistical analyses and general market research.

Protecting your Personal Data

Personal information is any information that tells us something about you.This could be information such as your name or contact details.

We comply with EU Data Protection laws so any information regarded as Personal Information will not be divulged to any third party without your consent. We are under obligation to disclose your personal data if legally required to protect our rights and safety or investigate fraud.

The information we collect is used to improve the quality of the Service, diagnose technical problems, maintain security, and to help you efficiently access your account.

Sharing your Personal Data

We will not share or sell your personal data to other organisations, except:

To provide products or services you requested and we have your permission, or under the following circumstance:

It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Services, or as otherwise required by law.

We encrypt the transmission of all sensitive information using secure socket layer technology (SSL).

Connecting to your bank/credit card account

During the process of obtaining your transaction data, we may use tools provided to us by FCA authorised 3^rd party providers such as TrueLayer Limited (www.truelayer.com, FCA firm reference 793171.) Any 3^rd party companies we use are subject to UK and EU data protection laws and are required to treat your data in accordance with those laws.

In this instance, you will share your financial institutions login through a secure TLS channel, which is an encryption protocol used to protect data in transit between computers.Your login credentials will be fully encrypted by Truelayer so your security is never compromised. For further information on Truelayer security, please visit https://truelayer.com/security/.

Social Media access

Our Websites include Social Media Features, such as the Facebook Like button, Twitter and Linkedin. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

You have the right to your data

We use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the Service. Although we own the code, databases, and all rights to the smart-bill.co.uk, you retain all rights to your data.

We retain Personal Information that you provide us as long as you use our Services, and then we securely delete the information if you decide to leave. Hence, if you leave the service we will no longer retain your Personal Information or be able to process it in anyway.

You have control over the notifications we send you and the marketing emails you receive. You are able to turn these on or off within the notifications preferences centre on your dashboard. With regards to marketing emails you are able to opt out by following the instructions at the bottom of each marketing email we send you.

Updating your Profile

You can update your profile information and email notifications by logging into your account and changes will be effective as soon as you save them to your Profile.

Cancelling your Account

You can cancel your agreement anytime by logging into your account and select cancel. Your data will be deleted from our system as soon as the account is cancelled. Your account will be deactivated within 30 days.

Refer a Friend

When you refer a friend from our Services, we will use the friend’s email provided by you to inform them about our Services. We store this information for the sole purpose of sending a one-time email and tracking the success of our referral program.

Blogs

Our blogs are accessible to public and any information you provide may be accessed publicly. The information remains even after you have cancelled your account with us. You can request to get it removed by emailing us at contact@smart-bill.co.uk.

How do we contact you

The Service includes email alerts on your account activity, such as weekly spend analysis, upcoming payments, contract renewals, price hikes and cheaper deals on your bills and subscriptions. You can change or de-activate the alerts anytime by signing in.

We may send you email notifications to inform you of system or service related changes, such as changes to our Terms and Conditions or service downtime. We will never email you in relation to promotional matters without your consent, other than explained in our terms and conditions, and you have the option to opt out at any time.

We may need contact you by phone when processing your request for cancelling a subscription, as your subscription provider may need to verify your details.

Modifications of our Privacy Policy

We may periodically revise the Privacy Policy. We will update our website at our sole discretion and will notify you about significant changes to the use or collection of your information by sending a notice to the primary email address specified in the Services or by placing a prominent notice on our site.

"Cookies" Information

In common with many other website operators, we may use standard technology called 'cookies' on this site. Cookies are small pieces of information that are stored by your browser on your computer's hard drive and they are used to record how you navigate this website on each visit.

Our cookies are used to enable us to develop our website and to enable you to properly navigate the site. We do no use cookies to collect personal information. We may use cookies to enrich your experience of using the website by allowing us to tailor what you see to what we have learned about your preferences during your visits to the site. We may use third party services such as Google Analytics and MixPanel and they may use cookies on our behalf in order to provide their services.