Privacy policy

This website privacy notice sets out how we collect and process your personal information. It is issued by Smart Pension Limited as the operator of this website. We are registered in England and Wales under company number 09026697) and our registered address is 136 George Street, London W1H 5LD. 

We are committed to maintaining the confidentiality, integrity, and availability of the data you provide to us. 

Information we hold

When you contact us through our contact form or use our website, we  may collect and process the following personal information about you:

• Basic identification and professional information, such as your name, surname, job title, location and the company or organisation you represent. 
• Contact information including your email address, telephone number, and any other details you choose to provide.  
• Website usage and technical data, such as IP address, browser and device information, and interactions with our site. 

We use cookies and similar technologies to support the operation of our website and to distinguish you from other users of the website. This helps us to provide you with the best online experience when using our website. For more information on how we use cookies please see our Cookie notice.

Our website uses anonymous tracking through local storage to monitor website performance and user interactions. These identifiers do not contain any personal information and cannot be used to identify you. This allows us to understand how the site is used and improve its performance.

How do we use your information? 

We use your information in a number of ways for different purposes. We ensure that we use your information in accordance with data protection laws and have a proper legal basis for processing your information as follows: 

• When communicating with you in response to a question submitted through our contact form, we use our legitimate business interests to manage our relationship with you. 
• When you visit our website, we may collect usage data for security monitoring and to optimise site functionality
• When promoting our services to you by email, newsletter or other communication method, we use the applicable legal basis based on our relationship with you. You may unsubscribe at any time via the link in the email or by contacting us. 

Who do we share your information with?

We may share your personal information with the following: 

• Other companies within the Smart Group. This intra-group sharing is conducted under strict controls and is limited to information necessary for service provision. 
• Third parties we use to help us develop and maintain our website. 
• Our legal, accounting and professional advisers. 
• Law enforcement or regulatory authorities where we receive a legitimate request that we are obliged to comply with by law. 

International transfers

If we are required to transfer your personal information outside the UK or the European Economic Area (EEA), whether within the Smart Group or to authorised third-party service providers or advisers, we ensure that such transfers are protected through appropriate safeguards. 

These may include the use of UK-approved Standard Contractual Clauses or other legally recognised transfer mechanisms, alongside technical and organisational controls to ensure the continued protection of your personal information.

How long do we keep your information?

We will maintain and preserve your personal information for as long as we have a legal obligation, contractual requirement, or legitimate business need to retain such information in accordance with data protection laws and our own policies. 

When establishing a retention period for specific categories of your personal information, we consider who we collected the information from, our need for the information, why we collected the information, and the sensitivity of the information. When we have no ongoing legal basis to process your information, we will either permanently delete or anonymise it. 

Security 

We have robust and comprehensive security measures and controls to protect your personal information to prevent loss or unauthorised access. These controls are supported by formal, regularly reviewed security policies and procedures.

Your rights in relation to our processing of your information

In accordance with data protection laws, you have the following rights in relation to personal information you provide to us:

• To obtain a copy of your personal data that we hold (right of access); 
• To rectify any inaccurate personal information we hold(right to rectification); 
• To request the deletion of your personal information (right to erasure); 
• To restrict our processing of your personal data, if the legal requirements are met (right to restriction of processing); 
• To withdraw your consent at any time, if our processing is based on consent, provided that such withdrawal does not affect the lawfulness of the previous processing of your data (consent withdrawal); 
• To transfer your personal information, if technically feasible, to another data controller (right to data portability); and 
• When applicable, not to be subject to a decision based solely on automated processing which produces legal effects concerning you or significantly affects you in a similar way, if the legal requirements are not met (not to be subject to automated processing). 
• To object, where applicable law provides, to the processing of your information (right to object): 
  
  • which is being processed for the purposes of our legitimate interests (where applicable and depending on the country you are based) unless such interests outweigh your individual rights; and/or 
  • for direct marketing purposes, without any special reason.

Contacting us about your information  

We have appointed a Data Protection Officer who oversees questions in relation to this notice.  If you do have any questions or wish to exercise any of your rights, please contact us using this form.

You also have the right to complain about data protection matters to the Information Commissioner’s Office, the UK's independent body set up to uphold information rights. You can find out more about the Information Commissioner's Office on its website.

Changes to the notice

We keep this notice under regular review and may change it at any time. Any changes we may make to this notice in the future will be posted on this page. Please check frequently to see any update or changes to this notice.