Privacy Policy

INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.smartsage.com.

By providing us with your data, you confirm that you are over 13 years of age.

Lucan Consulting Ltd, trading as SmartSage (Company Registration Number [Insert Company Registration Number]), is the data controller and is responsible for your personal data (referred to as “we,” “us,” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: Lucan Consulting Ltd, trading as SmartSage

Email address: hello@smartsage.com

Registered address: [Insert Registered Address]

Please inform us if any of your personal information changes by emailing us at hello@smartsage.com to ensure the accuracy and up-to-date status of our records.

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE, AND ON WHAT GROUND WE PROCESS IT

Personal data refers to any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

• Communication Data: Includes any communication sent to us through our website contact form, email, text, social media, or other means. We process this data to communicate with you, maintain records, and manage or defend legal claims. Our lawful ground for this processing is our legitimate interests, specifically to respond to communications, keep records, and address legal claims.

• Customer Data: Includes information related to purchases of goods and/or services, such as name, title, billing and delivery addresses, email, phone, purchase details, and card details. We process this data to supply purchased goods/services and maintain transaction records. Our lawful ground is the performance of a contract with you or taking steps at your request to enter into a contract.

• User Data: Includes data on how you use our website and services, and any content posted for publication on our site. This is processed to operate and secure our website, provide relevant content, and manage backups. Our lawful ground is our legitimate interest in properly managing our website and business.

• Technical Data: Includes usage data such as IP address, login details, browser type, visit duration, page views, navigation paths, usage frequency, time zone settings, and device details. We process this data to analyse and improve your experience on our site, manage security, and understand our marketing effectiveness. Our lawful ground is legitimate interest in efficiently administering our site and business, growing our business, and developing a marketing strategy.

• Marketing Data: Includes your preferences regarding marketing from us and third parties. We process this data to engage you in promotions and deliver relevant content and advertisements. Our lawful ground is our legitimate interest in growing our business and refining our marketing approach.

We may use Customer, User, Technical, and Marketing Data to provide relevant content and advertisements on our website (including on platforms like Facebook) and measure advertising effectiveness. Our lawful ground for this is legitimate interest in expanding our business.

Sensitive Data

We do not collect Sensitive Data (e.g., data about race, ethnicity, religious beliefs, sexual orientation, or health information). If we are required to collect personal data by law or under contract terms, you may not be able to receive our services if this data is not provided.

We may use your personal data for purposes that are reasonably compatible with the purpose of collection. In such cases, we will inform you and explain the legal grounds for processing.

HOW WE COLLECT YOUR PERSONAL DATA

Data may be collected directly from you via forms or email or automatically through cookies and similar technologies. We may also receive data from third parties, such as analytics providers (e.g., Google), advertising networks (e.g., Facebook), and publicly available sources (e.g., Companies House).

MARKETING COMMUNICATIONS

Our lawful ground for processing your personal data for marketing communications is either your consent or our legitimate interests. You may receive marketing communications if you have previously made a purchase, requested information, or agreed to receive marketing communications and have not opted out.

You may unsubscribe from marketing communications at any time by following the opt-out instructions in our emails or emailing us at hello@smartsage.com.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with:

• Service providers for IT and system administration.

• Professional advisors, such as lawyers and auditors.

• Government bodies as required.

• Third parties in the event of a business transfer.

All third-party data processors are required to respect your personal data’s security and process it according to our instructions.

INTERNATIONAL TRANSFERS

Where data transfers outside the EEA are required, we will implement adequate safeguards to ensure a similar level of data protection, including reliance on European Commission-approved data protection measures.

DATA SECURITY

We have implemented security measures to prevent unauthorized access, use, or disclosure of your personal data. Access is limited to employees and partners with a business need who are obligated to confidentiality.

DATA RETENTION

Personal data will be retained only as long as necessary for the purpose it was collected, including for legal, accounting, or reporting requirements. In some instances, data may be anonymised for statistical purposes and used indefinitely.

YOUR LEGAL RIGHTS

Under data protection laws, you have rights concerning your personal data, including access, correction, erasure, restriction, transfer, and objection to processing. If you wish to exercise these rights, please contact us at hello@smartsage.com.

We aim to respond to legitimate requests within one month. For complex requests, this period may be extended, and we will notify you.

For complaints, you may contact the Information Commissioner’s Office (ICO) but are encouraged to reach out to us first.

THIRD-PARTY LINKS

Our website may contain links to third-party sites. Clicking on these may allow third parties to collect data about you. We do not control these websites and recommend reading their privacy notices.

COOKIES

Cookies are used to enhance your experience on our website. You may set your browser to refuse cookies; however, some website functions may be impaired. For details on our cookie usage, refer to our Cookie Policy.