Privacy Policy
Last updated: 15 April 2026
Introduction
Smooth Purse Ltd ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, and safeguard your information when you visit our website or use our services.
This policy applies to all users of our website and clients of our services. By using our website or services, you agree to the collection and use of information in accordance with this policy.
Information We Collect
Information You Provide Directly
When you contact us or use our services, we may collect:
- Your name and contact details including email address
- Information about your current situation and settling-in needs
- Details relevant to providing our guidance services
- Payment information when you purchase services
- Any other information you choose to share with us
Information Collected Automatically
When you visit our website, we may automatically collect:
- Technical information including IP address, browser type, and operating system
- Usage data including pages visited, time spent on pages, and navigation patterns
- Device information
- Cookie data as described in our Cookies Policy
How We Use Your Information
We use the information we collect for the following purposes:
- To provide our settling-in guidance services
- To respond to your enquiries and communicate with you
- To process payments for services rendered
- To improve our website and services
- To understand how visitors interact with our website
- To comply with legal obligations
- To protect our rights and prevent fraud or misuse
We will only use your personal data when the law allows us to. Most commonly, we use your information where we need to provide services you've requested or where we have a legitimate interest in doing so.
Legal Basis for Processing
Under UK data protection law, we must have a legal basis for processing your personal data. We rely on the following legal bases:
- Contract: Processing is necessary to fulfil our contractual obligations when you purchase our services
- Consent: You have given clear consent for us to process your personal data for specific purposes
- Legitimate interests: Processing is necessary for our legitimate business interests, such as improving our services, provided your rights don't override these interests
- Legal obligation: Processing is necessary to comply with the law
How We Share Your Information
We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following limited circumstances:
- Service providers: We may share data with trusted third-party service providers who assist us in operating our website or providing services, such as payment processors or email service providers. These parties are contractually obligated to keep your information confidential.
- Legal requirements: We may disclose your information if required by law or in response to valid requests by public authorities.
- Business transfers: If we're involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.
- Protection of rights: We may disclose information to protect our rights, property, or safety, or that of our users or others.
We ensure that any third parties we work with are subject to appropriate confidentiality and security obligations.
Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- Secure data storage systems
- Encryption of sensitive data
- Regular security assessments
- Access controls limiting who can view your information
- Staff training on data protection
However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security.
Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements.
When determining retention periods, we consider factors such as:
- The nature and sensitivity of the data
- The purpose for which we hold it
- Legal and regulatory requirements
- Whether we have a legitimate business need to retain it
Typically, we retain client information for up to seven years after the completion of services, though some data may be retained longer if required by law. Website usage data is generally retained for shorter periods.
Your Rights
Under UK data protection law, you have several rights regarding your personal data:
- Right of access: You can request a copy of the personal data we hold about you.
- Right to rectification: You can ask us to correct inaccurate or incomplete data.
- Right to erasure: You can request deletion of your personal data in certain circumstances.
- Right to restrict processing: You can ask us to limit how we use your data.
- Right to data portability: You can request your data in a structured, commonly used format.
- Right to object: You can object to processing based on legitimate interests.
- Right to withdraw consent: Where we rely on consent, you can withdraw it at any time.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month.
Cookies and Tracking
Our website uses cookies and similar tracking technologies. For detailed information about the cookies we use and how to manage them, please see our Cookies Policy.
Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to read the privacy policies of any website you visit.
Children's Privacy
Our services are not directed at children under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected information from a child, please contact us immediately so we can delete it.
International Data Transfers
Your information is primarily stored and processed within the United Kingdom. If we need to transfer data outside the UK, we ensure appropriate safeguards are in place to protect your information in accordance with UK data protection law.
Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our practices or for legal or regulatory reasons. We will notify you of any material changes by posting the updated policy on our website with a new "Last updated" date.
We encourage you to review this policy periodically. Your continued use of our website or services after changes are posted constitutes your acceptance of the updated policy.
Contact Us
If you have questions about this privacy policy or how we handle your personal data, please contact us:
Email: [email protected]
Address: Smooth Purse Ltd, 42 Portland Street, Manchester M1 4DG, United Kingdom
Complaints
If you're not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Website: ico.org.uk