Protection of your personal data

Privacy Policy

This Privacy Policy explains how SM Horizon Finance collects, uses, stores, discloses and protects personal data when you visit smhorizonfinance.com or submit a financing enquiry.

We are committed to handling personal data responsibly and transparently. Personal data is processed in accordance with the General Data Protection Regulation, applicable French data protection law and other relevant data protection requirements.

Limited data collection We collect only the information required to process your enquiry and operate the website.
Clearly defined purposes Your data is used to receive, assess and process your financing enquiry.
Confidential handling Access is restricted to authorised persons and necessary technical service providers.
Do not submit sensitive documents through the initial enquiry form

Please do not send copies of identity documents, bank statements, online banking details, passwords, health information or other highly confidential documents through the initial online form. If documents are required, you will be informed of an appropriate method of transmission.

1. Data controller

Trading name
SM Horizon Finance
Responsible person
Martinus Smets
Legal form
Entreprise individuelle – French sole proprietorship
Address
625 Chemin des Thenoux
45500 Saint-Brisson-sur-Loire
France

2. What personal data do we process?

Data submitted through the financing form

  • type of financing requested;
  • requested financing amount;
  • first name and surname;
  • email address and telephone number;
  • country and town or city of residence;
  • employment or professional status;
  • monthly net income where this optional information is provided;
  • description of the financing project;
  • date and evidence of privacy consent;
  • reference number assigned to the enquiry;
  • cryptographic hash of the IP address for spam and abuse prevention.

Email and telephone communications

When you contact us by email or telephone, we may process your contact details, the content of your communication, documents voluntarily supplied and the communication history required to deal with your enquiry.

Technical data

When you visit the website, technical information may be processed, including the IP address, date and time, requested page, referring page, browser type, operating system, device information, technical errors and security-related log data.

3. Purposes of processing

  • receiving and registering your enquiry;
  • identifying your financing project;
  • contacting you and responding to your enquiry;
  • conducting an initial assessment of the information provided;
  • requesting additional information where necessary;
  • preparing and administratively managing the enquiry;
  • sending a confirmation of receipt;
  • managing the internal status of the enquiry;
  • responding to data protection requests;
  • preventing spam, abuse and attempted fraud;
  • maintaining, securing and troubleshooting the website;
  • complying with legal obligations;
  • establishing, exercising or defending legal claims.

4. Legal bases

Pre-contractual measures

We process a financing enquiry submitted by you in order to respond to your request and prepare possible pre-contractual steps.

Consent

Consent is relied upon where legally required, in particular for optional cookies and voluntary additional services.

Legitimate interests

Security measures, abuse prevention, technical logs, enquiry management and the defence of legal claims may be based on our legitimate interests.

Legal obligation

Processing may be required to comply with legal, regulatory, accounting, administrative or judicial obligations.

5. Required information

Form fields marked with an asterisk are required in order to process your enquiry.

Without this information, the form may not be submitted or the enquiry may not be assessed adequately.

Information not marked as required is optional.

6. No automated credit decision

The online form does not make any decision based solely on automated processing that produces legal or similarly significant effects.

The information submitted is used only for initial contact and a preliminary review.

Submitting the form does not create a loan approval, binding offer or financing guarantee.

7. Recipients of personal data

Personal data is disclosed only to persons and organisations that require it for their work. This may include:

  • Martinus Smets as the data controller;
  • expressly authorised persons;
  • hosting and email service providers;
  • technical service providers responsible for maintenance, security, backups and administration;
  • financing partners where disclosure is necessary for the review you requested and you have been appropriately informed;
  • public authorities, courts and other legally authorised bodies.

SM Horizon Finance does not sell personal data or rent it to third parties for their own advertising purposes.

8. Hosting and email services provided by STRATO

The website and related email services are technically provided by:

STRATO GmbH
Otto-Ostrowski-Straße 7
10249 Berlin
Germany

As part of providing these services, STRATO may process server logs, IP addresses, email content, backups and other hosting data.

9. WordPress, Astra and plugins

The website uses WordPress as its content management system and the Astra theme.

Additional plugins are used for the financing form, presentation, security, language management and technical functions.

These components may process technical data or store information in the WordPress database where required for the relevant function.

10. Financing enquiry form

When you submit the multi-step financing form:

  • your enquiry is stored in the non-public WordPress area under “Financing”;
  • an individual reference number is generated;
  • a notification is sent to anfrage@smhorizonfinance.com;
  • an automatic confirmation may be sent to your email address;
  • the internal status may be managed as new, in progress, accepted or rejected.

11. Spam and abuse prevention

The form uses an invisible control field known as a honeypot, WordPress security checks and a cryptographic hash of the IP address.

These measures are used to identify or prevent automated submissions, manipulation attempts, spam and other misuse.

12. Multilingual website using Polylang

The website uses Polylang to provide French, German, English and Italian language versions.

A technically necessary cookie or similar storage method may be used to remember the language selected by the user.

13. Email delivery

For form notifications and confirmation emails, we process your email address, name, enquiry reference and the information needed to prepare and send the message.

Messages are sent through the email services configured for the smhorizonfinance.com domain.

14. Retention periods

Personal data is not retained for longer than necessary for the relevant purpose or to comply with legal obligations.

Enquiry without a contractual relationship
Generally for up to 24 months after the last meaningful communication, unless earlier deletion is requested or legal grounds require longer retention.
Enquiry followed by a contractual relationship
For the duration of the contractual relationship and afterwards for the applicable statutory retention and limitation periods.
Email communications
For as long as necessary to process and document the enquiry.
Server and security logs
For a limited period required for technical, diagnostic and security purposes in accordance with the hosting provider’s settings.
Evidence of consent
For as long as necessary to demonstrate valid consent and defend against potential claims.
Backups
Until the relevant backup is routinely overwritten or securely deleted.

15. Data security

Appropriate technical and organisational measures are used to protect personal data. These may include:

  • encrypted HTTPS connections;
  • restricted access to WordPress and email accounts;
  • secure passwords and access controls;
  • regular updates to WordPress and plugins;
  • spam and abuse prevention measures;
  • security logs and backups;
  • restriction of administrator permissions.

16. Personal data breaches

In the event of a security incident, the possible consequences will be assessed and suitable corrective measures will be taken.

Where legally required, the competent supervisory authority and affected individuals will be informed within the prescribed time limits.

17. Cookies and similar technologies

Strictly necessary cookies

The website may use strictly necessary cookies for security, language selection, session management, the form and storage of cookie preferences.

Optional cookies

Analytics, marketing, video, map and social media services may be activated only where the relevant legal requirements have been met.

Where consent is required, these services will not be loaded before consent has been given.

Cookie settings

Any consent management tool used on the website must allow users to accept, reject or select optional cookies by purpose. Consent may subsequently be changed or withdrawn.

18. External content and services

If external videos, maps, fonts, analytics services, advertising pixels or social media content are added in the future, their providers may receive technical data and online identifiers.

Such services must be reviewed before use and this Privacy Policy must be updated accordingly.

19. Transfers outside the EEA

SM Horizon Finance prefers service providers and processing locations within the European Economic Area.

If a service requires a transfer to a country outside the EEA, the transfer must be based on a lawful mechanism and suitable safeguards.

20. Marketing and newsletters

Submitting a financing enquiry does not automatically subscribe you to a newsletter.

Electronic marketing is sent only in accordance with applicable legal requirements. You may object to permitted marketing communications at any time.

21. Data relating to minors

Minors should not independently submit identity documents, bank information or other sensitive financial data through the form.

Where necessary, an enquiry must be made with the involvement or consent of a parent or legal guardian.

22. Your data protection rights

Subject to the applicable legal requirements, you may have the following rights:

01
Access Obtain information about whether and how your personal data is processed.
02
Rectification Have inaccurate or incomplete personal data corrected.
03
Erasure Request the deletion of your personal data where the legal conditions are satisfied.
04
Restriction Request the temporary restriction of processing.
05
Objection Object to processing based on legitimate interests for reasons relating to your particular situation.
06
Data portability Receive certain personal data in a structured, machine-readable format.
07
Withdrawal of consent Withdraw consent at any time for future processing.
08
Complaint Lodge a complaint with a competent data protection supervisory authority.

23. Exercising your rights

To exercise your data protection rights, please contact:

info@smhorizonfinance.com

Or write to:

SM Horizon Finance
625 Chemin des Thenoux
45500 Saint-Brisson-sur-Loire
France

In order to prevent unauthorised disclosure, appropriate proof of identity may be requested where this is necessary and proportionate.

24. Complaint to the CNIL

As SM Horizon Finance is established in France, you may in particular lodge a complaint with:

Commission nationale de l’informatique et des libertés

3 Place de Fontenoy
TSA 80715
75334 Paris Cedex 07
France

www.cnil.fr

25. Language versions

This Privacy Policy is the English-language version of the data protection information provided by SM Horizon Finance.

In the event of differences between language versions, the French original version shall generally prevail for legal interpretation, to the extent permitted by law.

26. Changes to this Privacy Policy

This Privacy Policy may be updated if legal requirements, company details, technical systems, forms, service providers or processing activities change.

In particular, the policy must be reviewed and expanded before Google Analytics, Meta Pixel, Google Maps, YouTube, externally hosted fonts, newsletters, appointment-booking services or document-upload services are introduced.

Last updated: 1 August 2026

Questions about data protection?

SM Horizon Finance

625 Chemin des Thenoux
45500 Saint-Brisson-sur-Loire
France

+33 7 57 75 21 54

info@smhorizonfinance.com

View the English Legal Notice

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