We respect your privacy.
Welcome to the Smuts & Taylor Ltd (“Smuts & Taylor”) privacy notice.
We are currently registered as a ‘data controller’ with the UK Information Commissioner and are committed to ensuring that your privacy is protected in accordance with our legal obligations under the Data Protection Act 1998 (as amended) and other applicable law.
Purpose of this privacy notice
This privacy notice aims to give you information on how Smuts & Taylor collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a service or contact us regarding careers at Smuts & Taylor.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing 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.
What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers. It does not include data where the identity has been removed (anonymous data).
Smuts & Taylor Ltd is the controller and responsible for your personal data (collectively referred to as Smuts & Taylor, “we”, “us” or “our” in this privacy notice).
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us using the following contact details:
By Post: Smuts & Taylor Ltd, Bank House, 81 St Judes Road, Englefield Green, Surrey,
TW20 0DF, United Kingdom; or
By Email: email@example.com
Links to other websites
Our website may contain links to other external websites (‘Third-Party Sites’).
We do not have any control over such Third-Party Sites to which we link and we cannot be held responsible for their privacy statements or the privacy of any personal information which you provide after you have used any link on our website to visit these Third-Party Sites. You should exercise caution and look for any applicable privacy statement or policy appearing on such Third-Party Sites.
What Personal Data we collect
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, company name and job title.
Contact Data includes postal address, email address and telephone numbers.
Property Preference Data includes type of home, area, number of bedrooms, price and any further comments.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, information provided by Google Analytics and other technology on the devices you use to access this website. This is also includes information when you report a problem with our website.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also need to collect and maintain information from external sources such as credit reference and identify verification agencies. We will tell you when we receive information from them and how we will use it.
We 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 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 goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How your personal data is collected
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- request one of our services;
- request marketing to be sent to you;
- give us some feedback.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from analytics providers such as Google based outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
- Identity and Contact Data from third parties who are acting on your behalf, such as your lawyers or financial advisors. These third parties may be based inside or outside the EU.
What we do with your Personal Data
We will only use your personal data when the law allows us to. Generally, we will collect, use and hold your information for the purposes of:
- Assessing the suitability of new potential clients for Smuts & Taylor Ltd services
- Conducting business, developing relationships with Smuts & Taylor Ltd and affiliates
- Process payments including: Accounting, Billing, Complaints and related dispute resolution activities
- Protect against and prevent fraud, unauthorised transactions, money laundering, tax evasion, claims, other liabilities and manage risk exposure and agent /franchise quality, integrity, compliance and security of business processes
- Provide, administer and communicate with you about Smuts & Taylor Ltd services
- Compile business directories, including business contact information
- Operate, monitor, evaluate and improve our services, websites, mobile applications, other digital assets and business
- Managing communications, assess effectiveness and optimisation of advertising
- Functionality of our websites, mobile applications and other digital assets
- Evaluate your interest in employment and contact you regarding possible employment opportunities
- Comply with industry standards and Smuts & Taylor Ltd policies.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party). and your interests and fundamental rights do not override those interests.
Generally, we do not rely on consent as a legal basis for processing your personal data other than where we ask you to provide a testimonial and in relation to sending direct marketing communications to individuals acting in a personal capacity via email or other electronic communications. You have the right to withdraw consent to marketing at any time by contacting us.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Monthly newsletter and other direct marketing information – when you register to receive Smuts & Taylor’s newsletter, or other of our regular communications, we need to collect personal information. We’ll process this information by adding your contact details to a list that we hold on our CRM system Zoho. You can unsubscribe at any time by clicking the unsubscribe link at the bottom of our emails.
Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
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 us.
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.
Disclosure of your personal data
We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice or as indicated via the consent process at the time the data is collected. We may have to share your personal data with, but not limited to:
- Landlords and landlord associates and sub processors
- Vetted affiliates and partners / Financial Institutions / Insurance Companies for business facilitation to provide required services, such as mortgages, insurance cover etc.
- Formally contracted service providers to perform services on our behalf:
- Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services (Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)
- Helpdesk, Call Centres etc. We contractually require these service providers to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements
- Councils, health and care providers
- Other Law firms
- Credit agencies, Land Registry Office, Her Majesty’s Revenue and Customs (HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies
- Additionally, we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.
- Perspective employers requesting references via your written consent
On websites, features can be accessed where we partner with other entities that are not affiliated with Smuts & Taylor Ltd. These include social networking, geo-location tools etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties’ privacy policies if you use the relevant features.
Smuts & Taylor Ltd reserve the right to transfer your information to 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.
International transfers and storage
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve storage or a transfer of data outside the EEA. For example, our IT service suppliers may store data in the Cloud and not on servers located in the EEA.
It may also be processed by persons or entities operating inside or outside the EEA who work for us or for one of our suppliers. Such persons or entities maybe engaged in, among other things, the fulfilment of your instructions, the processing of your payment details and the provision of support services.
Whenever we transfer personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. These can be found at https://ec.europa.eu/commission/index_en
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process 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 or actual personal data breach and will notify individuals and any applicable regulator of a breach where we are legally required to do so
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect personal data, we cannot guarantee the security of any data transmitted to Our Website or to or from us via the internet. Any transmission is at the individual’s own risk. Once we have received an individual’s information, we will use procedures and security features to try to prevent unauthorised access.
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data: this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is commonly known as a “data subject access request”.
- Request correction of your personal data: this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data: this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You can also ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Object to processing of your personal data: where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data: this enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
- Request transfer of your personal data: we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. (Note: this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.)
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 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.
Any changes we may make to this Policy in the future will be posted on this page. Please review this page regularly so that you are aware of any changes.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to Smuts & Taylor Ltd, Bank House, 81 St Judes Road, Englefield Green, Surrey, TW20 0DF, United Kingdom or by email to firstname.lastname@example.org