Privacy Policy
Last updated: 22 July 2025
At Smooth Portfolio, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website and services.
This policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Table of Contents
1. Information We Collect
1.1 Information You Provide to Us
- Contact Information: Name, email address, phone number, postal address
- Account Information: Username, password, account preferences
- Order Information: Billing and shipping addresses, payment information, purchase history
- Communication Data: Messages, inquiries, feedback, and customer service interactions
- Marketing Preferences: Newsletter subscriptions and communication preferences
1.2 Information We Collect Automatically
- Technical Data: IP address, browser type, device information, operating system
- Usage Data: Pages visited, time spent on pages, click-through rates, search queries
- Cookies and Tracking Data: As described in our Cookie Policy
1.3 Information from Third Parties
- Payment Processors: Transaction details and payment verification
- Delivery Partners: Shipping and delivery status updates
- Social Media: If you interact with us on social platforms
2. How We Use Your Information
We use your personal information for the following purposes:
2.1 Service Provision
- Processing and fulfilling your orders
- Managing your account and providing customer support
- Communicating about your orders, deliveries, and account
- Processing payments and preventing fraud
2.2 Business Operations
- Improving our website and services
- Conducting market research and analytics
- Managing inventory and supply chain
- Compliance with legal obligations
2.3 Marketing and Communications
- Sending newsletters and promotional materials (with your consent)
- Personalizing your shopping experience
- Recommending products based on your interests
- Conducting customer satisfaction surveys
3. Legal Basis for Processing
Under UK GDPR, we process your personal data based on the following legal grounds:
- Contract Performance: To fulfill our contractual obligations for product sales and services
- Legitimate Interests: To improve our services, prevent fraud, and conduct business operations
- Consent: For marketing communications and non-essential cookies (where required)
- Legal Obligation: To comply with UK tax, accounting, and regulatory requirements
5. Data Retention
We retain your personal information for as long as necessary to:
- Provide you with our services
- Comply with legal, accounting, and regulatory requirements
- Resolve disputes and enforce agreements
Typical Retention Periods:
- Account Information: Until account deletion or 7 years after last activity
- Order Records: 7 years for tax and accounting purposes
- Marketing Data: Until you unsubscribe or withdraw consent
- Website Analytics: 26 months (Google Analytics default)
6. Your Rights
Under UK GDPR, you have the following rights regarding your personal data:
Right of Access
Request a copy of the personal data we hold about you
Right to Rectification
Request correction of inaccurate or incomplete data
Right to Erasure
Request deletion of your personal data in certain circumstances
Right to Restrict Processing
Request limitation of how we process your data
Right to Data Portability
Request transfer of your data in a machine-readable format
Right to Object
Object to processing based on legitimate interests or for marketing
To exercise any of these rights, please contact us using the details in Section 10. We will respond within one month of receiving your request.
8. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
- Encryption: SSL/TLS encryption for data transmission
- Access Controls: Restricted access to personal data on a need-to-know basis
- Regular Security Reviews: Ongoing assessment of security measures
- Staff Training: Regular data protection training for all employees
- Incident Response: Procedures for handling potential data breaches
While we strive to protect your personal information, no method of transmission over the internet is 100% secure. We encourage you to use strong passwords and keep your account information confidential.
9. International Transfers
Your personal data is primarily processed within the UK. When we transfer data outside the UK, we ensure appropriate safeguards are in place:
- Adequacy Decisions: Transfers to countries with adequate data protection
- Standard Contractual Clauses: EU/UK approved contract terms
- Certification Schemes: Recognized data protection certifications
10. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:
Data Protection Officer
Email: [email protected]
Phone: +44 131 229 1456
Post:
Smooth Portfolio
Data Protection Department
9 Robertson Ave
Edinburgh EH11 1QA
United Kingdom
Complaints
If you believe we have not handled your personal data properly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
ICO Website: www.ico.org.uk
ICO Helpline: 0303 123 1113
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.