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.

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