DATA Privacy Notice

This is privacy notice of SMPV Limited (the Business).

We respect your privacy and are determined to protect your personal data. This policy (together with any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This includes information collected as part of our business activities when you interact with us via email, in person or via telephone, through this website and/or any service and offer. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person.

Data protection legislation – Means the data protection legislation enforce in the UK from time to time and includes the Data Protection 2018 (as amended) and the UK General Data Protection Regulation (UK GDPR).

Categories of data - Personal data and special categories of personal data

Personal data - The UK GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of UK GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The UK GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of UK GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.

Processing - Means any operation or set of operations which is performed on 

personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - Means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who we are and important information

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data we collect from you through our services and offers, attending/registering to our events, contacting us or interacting with us on social media, completing our surveys or questionnaires, visits or using of our website.

Our website (and any webpage we use) is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data controller

SMPV Limited is the controller and responsible for your personal data (collectively referred to as "Business" , "we", "us" or "our" in this privacy notice). Our contact details are: Registered Address: 241 Mitcham Road, Tooting, London, England, SW17 9JQ.; email: contact@smpvlimited.com. For all data matters contact us at dpo@smpvlimited.com.

Third-party links outside of our control

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

3. The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

●  Identity Data: includes first name / last name / username.

●  Contact Data: includes business address / billing address / email address / telephone numbers.

●  Bank details: include bank name and address / account number

●  Usage Data: include information about the use of our website, products and services

●  We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with offers and services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. How we collect your personal data

We use different methods to collect data from and about you including through:

Directly by contacting us about our services or subscribing to our events or newsletters.  

Indirectly via third parties such as technical data from analytics provided such as Google, contact made via our social media pages such as Scorecard or LinkedIn.  

This includes personal data you provide when you:

●  Apply for our products or services

●  Perform a contract

●  Complete our scorecards through our landing pages or complete our surveys, questionnaires 

●  Register to our events

●  Subscribe to our service or publications

●  Request marketing to be sent to you

5. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Legitimate Interest: this means the interest of our business in conducting and managing our business 

to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us via email to contact@smpvlimited.com.

Comply with a legal or regulatory obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at dpo@smpvlimited.com.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at dpo@smpvlimited.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1. Existing/prospective clients and suppliers:

-  Name, contact details for the performance of a contract or to take steps to enter into a contract and for the preparation and storage of invoices 

-  Bank details for payments of invoices.

2. Prospective clients and other contacts:

- Name and contact details for the legitimate interest of promoting and growing our business (marketing purposes), improving our services, and business conduct.

Marketing activities:

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Any marketing activity performed is carefully reviewed to support full compliance with the UK data protection regulations and PECR. All our marketing activities are based on legitimate interest. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you by contact@smpvlimited.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of performing a contract or taking steps to enter into a contract and for the preparation and storage of invoices.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our data protection office at dpo@smpvlimited.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we share your personal data with

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

●  External Third Parties acting as processors for hosting our data for the provision of our services or using their systems and platforms to perform our activities such as registering to webinars, booking calls or creating scorecards. 

●  Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, accountants and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. 

●  HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based on the requirement to report processing activities in certain circumstances.

●  Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. 

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We are based in the UK and in general data collected will be stored in the UK or within the European Economic Area (EEA). However some our external third parties and professional advisors process data outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever your personal data are transferred out of the UK, we ensure a similar degree of protection is afforded to it by implementing safeguards. We also ensure every third party has appropriate security in place. 

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by email at dpo@smpvlimited.com.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

9. Your legal rights

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

●  The right to request a copy of the personal data which we hold about you;

●  The right to request that we correct any personal data if it is found to be inaccurate or out of date;

●  The right to request your personal data is erased where it is no longer necessary to retain such data;

●  The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;

●  The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);

●  The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

●  The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer at dpo@smpvlimited.com.

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.  Changes to this notice and your duty to inform us of changes

This notice was last updated on 18 June 2026 and historic versions can be obtained by contacting us.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

11.  Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data protection office at dpo@smpvlimited.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.