Privacy Policy

For the Smarti website, app and platform. Last updated: 28 June 2026.

This policy explains what we do with personal information when you use our website, our app, or our platform. We have written it in plain English. Where we use a legal term, we explain it in brackets.

The short version

• Smarti is a brand of Y3K (Europe) Limited.
• For most of our website and customer information, we decide how it is used.
• For the tracking and video that the devices record, we usually act on our business customer’s instructions. If you are a driver, your employer is normally in charge of that data — please ask them first.
• You have rights over your information. You can contact us at any time at enquiries@y3k.com.

1. Who we are and how to contact us

Smarti is a brand of Y3K (Europe) Limited (“Y3K”, “we”, “us”, “our”). We are a company registered in England and Wales (company number 03924841). Our address is Airport House, 265 Purley Way, Croydon, CR0 0XZ.

We are the “controller” of the personal information described in this policy, except where we say we act as a “processor” (see Section 2). A controller is the business that decides why and how personal information is used. A processor is a business that handles personal information on someone else’s instructions.

We are registered with the Information Commissioner’s Office (the ICO — the UK’s data protection regulator).

How to contact us: email enquiries@y3k.com or call 020 8689 9999.

Personal information means any information that can identify a living person. The law calls this “personal data”.

2. What this policy covers

This policy covers personal information we handle through:

• our website at smarti.co.uk;
• our customer platform at portal.smarti.co.uk; and
• our mobile app, Protect365 (for iPhone and Android).

We act in two different roles, depending on the information.

As controller. For information about our website visitors, people who ask us for a quote or demo, our customers’ account and billing contacts, people who contact our support team, and people who receive our marketing. We decide how this information is used, and this policy explains how.

As processor. For the tracking, location, driving and video information that our devices record, we normally act on the instructions of our business customer (for example, the company that owns the vehicles). In that case, our business customer is the controller. They decide why the data is collected and how long it is kept. Schedule 2 of our Smarti Services Agreement sets out the rules we follow as their processor.

If you are a driver or another person recorded by a Smarti device, your employer or the business that runs the vehicle is usually in charge of that information. Please contact them first with any questions or requests. We will help them respond.

3. The personal information we collect

3.1 Information we collect as controller

• Account and contact information: your name, business name, job title, email address, phone number, and postal address, plus your login details for our platform and app.
• Order and payment information: your billing address, what you ordered, and payment details. Card payments are handled by our payment providers — we do not store full card numbers.
• Quote and demo requests: the details you give us when you ask for a quote, a demo, or other information.
• Website and app usage: information about the device you use, your IP address (a number that identifies your device on the internet), your approximate location, the pages you view, and how you use our website and app. We collect some of this using cookies (see Section 6).
• Support information: the messages, emails and call notes created when you contact our support team.
• Marketing preferences: whether you have agreed to receive marketing, and what you are interested in.

3.2 Information we handle as processor (the Smarti service)

When a Smarti device is fitted to a vehicle or asset, it records information and sends it to our platform. This can include:

• location and GPS position, routes and journey history;
• speed, and driving events such as harsh braking, acceleration and cornering;
• driver behaviour scores;
• video footage and still images from dashcams, including live video;
• audio, if the customer has chosen to turn audio recording on;
• “panic button”, incident and other alerts;
• vehicle details, registration numbers, and device and SIM identifiers;
• dates, times and user activity logs.

This information can identify drivers and sometimes other people (for example, passengers or people near the vehicle). As explained in Section 2, our business customer is usually the controller for this information. We handle it on their behalf to provide the service.

4. How we use your information, and our legal reasons

This section is about the information we handle as controller. The law says we must have a “lawful basis” (a valid legal reason) for using personal information. Ours are below.

• To provide our products and services and manage your account — to perform our contract with you.
• To take payment and send invoices — to perform our contract, and to meet our legal obligations.
• To deliver devices and set up the service — to perform our contract.
• To provide support and answer your questions — to perform our contract, and our legitimate interests (running our business well). Legitimate interests means a good business reason that does not override your rights.
• To run, secure and improve our website, app and platform — our legitimate interests, and your consent for non-essential cookies.
• To send you marketing — your consent, or our legitimate interests where the law lets us contact existing business customers about similar products. You can opt out at any time.
• To keep records, prevent fraud, and protect our business and customers — our legitimate interests and our legal obligations.
• To meet legal and regulatory duties, and to deal with legal claims — our legal obligations, and our legitimate interests.

Where we rely on consent, you can withdraw it at any time (see Section 12).

5. The Smarti app (Protect365)

Our app lets you view your vehicles, watch video, and receive alerts. To do this, the app may ask your permission to use certain features on your phone or tablet:

• Location: to show vehicles on a map and support live tracking.
• Notifications: to send alerts (for example, speeding, incidents or the panic button).
• Camera and photos or files: only if you choose to save or share video clips.

You can turn these permissions on or off in your device settings. Some features will not work if a permission is turned off.

The app also collects basic usage and crash information so we can keep it working properly. When you download the app, the App Store (Apple) or Google Play (Google) may collect information under their own privacy policies.

Logging in to the app shows you information from our platform. Whether we handle that information as controller or processor depends on what it is, as explained in Section 2.

6. Cookies and similar technology

A cookie is a small file stored on your device when you visit a website. We use cookies and similar tools on our website for three main purposes:

• Essential cookies: needed to make the website and online shop work (for example, to keep items in your basket and to let you log in). These are always on.
• Analytics cookies: help us understand how people use the website so we can improve it.
• Advertising cookies: help us show relevant ads and measure how well they work.

We use trusted third parties to provide some of these cookies. Analytics and advertising cookies are only used with your consent. You can change your choices at any time using the cookie settings on our website, or by changing your browser settings. Turning off some cookies may affect how the website works.

7. Marketing

We may send you information about our products, services and offers by email, phone or post. We only send marketing where the law allows — usually with your consent, or to existing business customers about similar products.

You can opt out at any time by clicking “unsubscribe” in any marketing email, or by contacting us at enquiries@y3k.com. Opting out of marketing will not stop important service messages (for example, about your account, billing, or a safety issue).

8. Who we share your information with

We share personal information with:

• Service providers who help us run our business and deliver the service. These include providers of hosting and data storage, mobile network and connectivity, payment processing, customer support, analytics, advertising, and professional advice. We only allow them to use the information to provide their service to us, and they must protect it. (When these providers help with the service data, the law calls them “sub-processors”.)
• Our business customers and their authorised users, where the information is part of the service they use.
• Other parts of the Y3K group, where needed to run the service and support you.
• The authorities, courts or regulators, where the law requires it, or to protect our rights, property or safety, or those of others.
• A buyer or new owner, if we sell or reorganise our business, subject to this policy.

We do not sell your personal information.

9. Sending information outside the UK

We store customer information in the United Kingdom, the European Union, or the United States, depending on where the customer is based.

Where we send personal information outside the UK, we make sure it is protected to the standard required by UK data protection law. We do this by transferring only to countries the UK government has approved, or by using approved contract terms (for example, the UK’s International Data Transfer Agreement, or standard contractual clauses with the UK addendum). You can ask us for more details using the contact details above.

10. How long we keep information

We keep personal information only for as long as we need it.

• Account, order and billing information: for the length of our relationship with you, and then for as long as the law requires (for example, tax and accounting records are usually kept for six years).
• Website and app usage and cookie information: for shorter periods, as set out in our cookie settings.
• Support records: for as long as needed to handle your query and any follow-up.

For the service data we handle as processor (tracking and video), our business customer decides how long it is kept. Footage is often overwritten after a set period. If you are a driver, please ask your employer about their retention settings.

11. Keeping your information secure

We use appropriate technical and organisational measures (sensible security steps) to protect personal information against loss, misuse, and unauthorised access. These include access controls, encryption where appropriate, and staff confidentiality duties. No system can be guaranteed completely secure, but we work to protect your information and to deal quickly with any problems.

12. Your rights

Under UK data protection law you have the right to:

• ask for a copy of the personal information we hold about you;
• ask us to correct information that is wrong or incomplete;
• ask us to delete your information, in certain cases;
• ask us to limit how we use your information, in certain cases;
• object to us using your information, in certain cases (including for direct marketing);
• ask us to move your information to another provider, in certain cases (“data portability”); and
• withdraw your consent at any time, where we rely on consent.

To use any of these rights, contact us at enquiries@y3k.com. We will respond within the time limits set by law (usually one month). Using these rights is free in most cases.

If your request is about the service data we handle as processor (for example, footage of a driver), please contact the business customer who controls that data. They are responsible for handling your request, and we will support them.

13. Automated decisions and driver scoring

Our platform can score driving behaviour automatically, based on things like speed, braking and cornering. This is a form of “automated processing”.

We do not use this scoring to make decisions that have a legal or similarly significant effect on individuals on our own behalf. Where a business customer uses driver scores to make decisions about their drivers, that customer is the controller and is responsible for how the scores are used, including giving drivers any rights the law requires.

14. Children

Our products and services are for businesses and are not aimed at children. We do not knowingly collect information about children through our website or app.

15. Changes to this policy

We may update this policy from time to time, for example if our services or the law change. We will post the updated policy on our website and change the “last updated” date at the top. Please check back from time to time.

16. How to complain

If you have a concern about how we use your personal information, please contact us first at enquiries@y3k.com so we can try to help.

You also have the right to complain to the ICO, the UK’s data protection regulator. You can contact the ICO at ico.org.uk, or call 0303 123 1113.

Y3K (Europe) Limited (trading as Smarti)
Airport House, 265 Purley Way, Croydon, CR0 0XZ
Email: enquiries@y3k.com   Phone: 020 8689 9999

Registered in England and Wales, company number 03924841. Registered with the Information Commissioner’s Office (ICO).