Privacy Policy
Last Updated:
December 1, 2025
Privacy Policy
Welcome to Smart Growth Agency’s privacy policy.
SGA is committed to safeguarding your personal information and respecting your privacy. This policy explains how we handle your data when you visit our website or interact with our services, as well as your rights and the protections offered by law.
1. Important Information and Who We Are
Purpose of this policy
This privacy policy sets out how Smart Growth Agency (“SGA”, “we”, “us”, or “our”) collects and processes your personal information through your use of our website and services. This includes any data you provide when you:
Sign up for updates or resources
Purchase a service
Request a consultation
Enter a competition or promotion
Opt in for special offers or marketing communications
Our website is not intended for children, and we do not knowingly collect information relating to children.
Please read this privacy policy alongside any other privacy notices we may provide at specific times.
Controller
Smart Growth Agency is the controller responsible for your personal data.
We have appointed a data privacy manager who oversees all matters relating to this policy. For any questions or requests concerning your data protection rights, please contact:
Smart Growth Agency (SGA)
Email: support@smartgrowthagency.com
Postal address: Smart Growth Agency, 207 Regent St, London, W1B 3HH
Telephone: Provided on request
You may raise concerns with the Information Commissioner’s Office (ICO) at any time. However, we would appreciate the opportunity to address your concerns first.
Changes to this policy
We review this policy regularly. It is important you keep us informed if your personal information changes while working with us.
Third-party links
Our website may include links or integrations that lead to third-party websites or apps. We do not control these providers and recommend reviewing their privacy policies before using their services.
2. The Data We Collect About You
“Personal data” refers to information that can identify you.
We may collect, use, store, and transfer the following categories:
Identity Data
Names, titles, usernames.
Contact Data
Email addresses, telephone numbers, billing and service addresses.
Financial Data
Payment details such as card or account information (handled securely through our payment processors).
Transaction Data
Records of payments, purchases, subscriptions, and service history.
Technical Data
IP address, browser type, device information, time zone settings, login data, platform information, and cookies.
Profile Data
Account details, login credentials, preferences, survey responses, and service interactions.
Usage Data
Information on how you interact with our website and services.
Marketing & Communications Data
Your marketing preferences and communication settings.
We also use aggregated data (such as analytics trends). This is not considered personal data unless it can be linked back to you.
We do not collect Special Category Data or information relating to criminal convictions.
If you do not provide required data
If we need your information to perform a contract or provide a service and you do not supply it, we may be unable to deliver that service.
3. How We Collect Your Data
We collect information in the following ways:
Direct interactions
You may provide Identity, Contact, or Financial Data when you:
Request our services
Book a consultation
Sign up to newsletters or marketing
Create an account
Request resources or downloads
Communicate with us
Automated interactions
We automatically collect Technical Data through:
Cookies
Analytics tools (e.g., Google Analytics)
Behaviour tracking
Third-party sources
We may receive data from:
Analytics providers
Payment processors (e.g., Stripe)
CRM or marketing platforms
Public sources such as Companies House
4. How We Use Your Personal Data
We only use your information when legally permitted. The main reasons are:
Performance of a contract
Legitimate interests (where your rights do not override our interests)
Compliance with legal obligations
Consent (for specific marketing communications)
Examples of how we use your data
Purpose | Type of Data | Legal Basis |
|---|---|---|
Register you as a customer | Identity, Contact | Contract |
Process payments and deliver services | Identity, Contact, Financial, Transaction | Contract; Legitimate interest (debt recovery) |
Manage customer relationships | Identity, Contact, Profile | Contract; Legal obligation; Legitimate interest |
Marketing, promotions, competitions | Identity, Contact, Profile, Usage | Contract; Legitimate interest |
Improve our website and services | Technical, Usage | Legitimate interest |
Advertising relevance & performance measurement | Technical, Usage, Marketing | Legitimate interest |
Recommendations of services | Identity, Contact, Profile | Legitimate interest |
Marketing and promotions
You will receive marketing from us if you have:
Requested information
Purchased a service
Opted in to receive communications
You can opt out at any time.
Cookies
You can refuse cookies via your browser settings, but some features may not work correctly.
Change of purpose
We will only use your data for the purpose it was collected unless another compatible purpose arises.
5. Disclosures of Your Personal Data
We may share your data with:
Internal team members
Those who require access to deliver services and support.
External third parties
Including:
IT and hosting providers
CRM and marketing platforms
Professional advisers (solicitors, accountants, insurers)
Payment processors
Regulators such as HMRC
If our business is sold or restructured, your data may transfer to the new owner under the same terms.
All third parties are required to protect your data and may only use it according to our instructions.
6. International Transfers
Some of our technology providers operate outside the UK/EEA. Where this occurs, we ensure your data is protected through legally recognised safeguards such as:
Standard Contractual Clauses (SCCs)
Adequacy decisions
Additional security measures
7. Data Security
We implement industry-standard security measures to prevent your information from being lost, accessed unlawfully, or misused. Access is restricted to authorised personnel only.
We have procedures in place to handle any data breach and will notify you where legally required.
8. Data Retention
We keep your data only for as long as necessary for:
Service delivery
Legal, tax, or regulatory requirements
Business record-keeping
Typically, customer data is retained for six years after your last transaction.
We may anonymise data for analytical purposes.
9. Your Legal Rights
You have the right to:
Request access to your personal data
Request correction of inaccurate data
Request erasure in certain circumstances
Object to processing (including marketing)
Request restriction of processing
Request transfer of your data
Withdraw consent at any time
We may ask for identification to verify requests. We aim to respond within one month.
10. Glossary
Legitimate Interest:
A business reason that supports our operations and does not outweigh your rights.
Performance of Contract:
Processing required to deliver the service you have requested.
Legal Obligation:
Compliance with UK law.

