SmarterDS Privacy Policy

Date: 5 Dec 2025
Version: v2.0 (Final)

This privacy policy will explain how SmarterDS (“we”, “us”, or “our”) uses the personal data we collect from you when you use our systems.

SmarterDS is committed to respecting and protecting the privacy of individuals who interact with us, whether through our products and services, our websites, portals, or apps, or via other communication channels.

This policy is compliant with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, the EU General Data Protection Regulation (EU GDPR).

Important Note for End-Users:

If you are a customer of one of our clients, SmarterDS acts as a Data Processor. We process your data solely on the instructions of our Client (the Data Controller). If you have questions about your data, please contact your service provider directly.

Topics:

  1. What data do we collect?
  2. How do we collect your data?
  3. How will we use your data?
  4. Who do we share your data with?
  5. How do we store your data?
  6. What are your data protection rights?
  7. What are cookies?
  8. Do we use cookies?
  9. What technologies do we use instead?
  10. How to manage your cookies
  11. Changes to our privacy policy
  12. How to contact us
  13. How to contact the appropriate authorities

1. What data do we collect?

SmarterDS collects personal data to effectively provide our products, manage our business relationships, and bill for our services. We categorise this data as follows:

  1. Personally identifiable information. This includes information we use to identify you as a user or a business contact:
    • Full names
    • Business email addresses and telephone numbers
    • Company billing and postal addresses (including postcodes)
    • Account login credentials (including usernames, emails, full names, and account privileges and permissions)
  2. Technical and Usage Data. When you access our website, portals, or apps, our systems automatically collect and store:
    • Internet Protocol (IP) addresses
    • Browser type, version, and time zone settings
    • Logs of how you interact with our platform (e.g. login times, and various logs depending on what is being accessed)

2. How do we collect your data?

You directly provide SmarterDS with most of the data we collect. We collect data and process data when you:

  • Communicate with us: Contact us through our website, email us, or speak to our sales and support teams.
  • Enter into a contract with us.
  • Use our systems: Register an account, log in to one of our platforms or use our software products (where usage logs are automatically generated).
  • Browse our website: Use or view our website (via our web server logs and standard internet traffic data).

SmarterDS may also receive your data indirectly from the following sources:

  • Your employer or organisation: If your organisation uses our software, they may provide us with your name and email address to set up your user account within the system.
  • Publicly available Business Sources: We may collect business contact details from public sources such as Companies House, LinkedIn, or your company website for B2B marketing and sales purposes.

3. How will we use your data?

SmarterDS collects your personal data for specific reasons and only where we have a legal basis to do so. We use your data for:

  1. Service Delivery and Account Management
    • Purpose: To register you as a new customer, set up your user accounts, and provide access to our software platforms.
    • Legal Basis: Performance of a Contract.
  2. Billing and Administration
    • Purpose: To manage payments, fees, charges, and to collect and recover money owed to us.
    • Legal Basis: Performance of a Contract.
  3. Support and Relationship Management
    • Purpose: To notify you about changes to our terms or privacy policy, and to provide customer support or technical assistance when you contact us.
    • Legal Basis: Performance of a Contract / Legal Obligation.
  4. Security and Platform Improvement
    • Purpose: To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, and hosting of data).
    • Legal Basis: Legitimate Interest – for running our business, provision of administration and IT services, and network security.
  5. B2B Communications
    • Purpose: To make suggestions and recommendations to you about goods and services that may be of interest to you (B2B marketing).
    • Legal Basis: Legitimate Interest – to develop our products/services and grow our business.

4. Who do we share your data with?

We do not sell your data to third parties. However, to provide our services, we may share your data with the following categories of trusted third parties:

  • Service Providers: Companies who provide IT and system administration services (e.g. our cloud hosting providers like AWS/Azure, our email providers like Google/Microsoft/Sendgrid, our sms service providers like AWS/Twilio, and our mobile app deployment platforms such as Google Play and Apple App Store).
  • Professional Advisers: Including lawyers, banks, auditors, accountants, and insurers.
  • Regulators: HM Customs and Revenue, regulators and other authorities who require reporting of processing activities in certain circumstances.

5. How do we store your data?

1. Location and Security

SmarterDS securely stores your data on cloud-based servers, primarily within the United Kingdom, and the European Economic Area (EEA). We employ trusted industry-standard technical measures to protect your data, including:

  • Encryption: Data is encrypted in transit (using TLS/SSL) and at rest.
  • Access Control: Access to personal data is restricted to employees who have a business need to know, all of whom are subject to confidentiality obligations.

2. Data Retention

SmarterDS will keep your personal data only for as long as is necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

  • Active Accounts: We retain your account data for the duration of your contract with us.
  • Financial Records: By law, we must keep basic information about our customers (including Contract, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and legal purposes (HMRC compliance).
  • Marketing Data: We retain your contact details for marketing purposes until you unsubscribe or request that we remove you.

3. Data Disposal

Once the retention period has expired, or if you successfully request erasure, we will securely delete your data from our active databases. Any backups will be deleted in accordance with our standard backup overwrite cycle.

6. What are your data protection rights?

SmarterDS would like to make sure you are fully aware of all of your data protection rights regarding the personal data we hold about you as a Data Controller. Every user is entitled to the following:

  • The right to access: You have the right to request copies of your personal data. This service is free of charge.
  • The right to rectification: You have the right to request that SmarterDS correct any information you believe is inaccurate. You also have the right to request SmarterDS to complete information you believe is incomplete.
  • The right to erasure: You have the right to request that SmarterDS erase your personal data, under certain conditions.
  • The right to restrict processing: You have the right to request that SmarterDS restrict the processing of your personal data, under certain conditions.
  • The right to object to processing: You have the right to object to SmarterDS’s processing of your personal data, under certain conditions.
  • The right to data portability: You have the right to request that SmarterDS transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
  • The right to withdraw consent: Where we rely on your consent to process your data (e.g. for email marketing), you have the right to withdraw that consent at any time.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, contact us using the details at the bottom of this document.

7. What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. While most websites use them to track visitors, SmarterDS does not use cookies.

8. Do we use cookies?

No. SmarterDS operates a “cookie-free” environment across all our platforms.

  • Public Website: We do not use cookies on our public website. We do not track your behaviour, store information on your device, or use third-party analytics cookies (such as Google Analytics) when you visit our marketing pages.
  • SmarterDS Portals & Apps: Our software applications are also cookie-free. We do not use cookies to track you or manage your session.

9. What technologies do we use instead?

To provide a secure and functional service for our logged-in users on our product portals and apps, we use a modern industry standard technology called Local Storage instead of cookies.

  • How it works: When you log in to our portal, we store a secure digital token (JWT) in your browser’s Local Storage.
  • Why we use it: This token allows you to stay signed in securely.
  • The difference: Unlike cookies, data in Local Storage is strictly kept on your device, and is never automatically sent to third parties or used for advertising.

10. How to manage your cookies

Because SmarterDS does not use cookies, you do not need to change your browser settings to use our website.

If you have set your browser to “Block All Cookies,” our public website will still function perfectly. However, please note that blocking Local Storage (sometimes called “DOM Storage” in browser settings) may prevent you from logging into the SmarterDS Product Portals.

11. Changes to our privacy policy

SmarterDS keeps its privacy policy under regular review and will reflect any updates on this page. This privacy policy was last updated on 5 Dec 2025.

12. How to contact us

If you have any questions about this privacy policy, the data we hold on you, or if you would like to exercise one of your data protection rights (regardless of your location), please do not hesitate to contact us.

Email dpo@smarterDS.com
Address Data Protection Officer
Smarter Data Solutions Ltd
Linton House
64 High Street, Linton,
Cambridge,
CB21 4HS
United Kingdom

13. How to contact the appropriate authority

Should you wish to report a complaint or if you feel that SmarterDS has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office (ICO) at www.ico.org.uk.