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Privacy Policy

Last updated: 26 February 2026

Smart Legals ("we," "us," "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website or use our services.

This policy is compliant with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Controller: Smart Legals, 15 Parsons Court, Welbury Way, Aycliffe Business Park, County Durham DL5 6ZE

Contact: info@smartlegals.co.uk

Information We Collect

We may collect and process the following personal data about you:

Information you provide to us

  • •Identity Data: First name, last name, title, date of birth, and copies of identification documents.
  • •Contact Data: Email address, telephone number, and postal address.
  • •Financial Data: Bank account details, investment amounts, investor type classification, and source of funds information.
  • •Profile Data: Your username and password, investment preferences, and feedback or survey responses.

Information collected automatically

  • •Technical Data: IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
  • •Usage Data: Information about how you use our website, including pages visited, time spent on pages, page interaction information, and navigation paths.
  • •Cookie Data: Data collected through cookies and similar tracking technologies. Please see our Cookie Policy for more details.

How We Use Your Information

We use your personal data for the following purposes:

  • •To register you as a new investor and manage your account.
  • •To process and facilitate your investments in our bond products.
  • •To conduct anti-money laundering (AML) and know your customer (KYC) checks as required by law.
  • •To communicate with you about your investments, including interest payments and maturity notifications.
  • •To send you marketing communications where you have opted in to receive them.
  • •To improve our website, products, and services.
  • •To comply with legal and regulatory obligations.

Legal Basis for Processing

We process your personal data on the following legal bases under the UK GDPR:

Contract Performance (Article 6(1)(b))

Processing necessary for the performance of our contract with you, including managing your account and processing your investments.

Legal Obligation (Article 6(1)(c))

Processing necessary for compliance with legal obligations, such as AML/KYC requirements and tax reporting.

Legitimate Interests (Article 6(1)(f))

Processing necessary for our legitimate interests, such as improving our services, fraud prevention, and network security.

Consent (Article 6(1)(a))

Where we rely on your consent, such as for marketing communications. You may withdraw consent at any time.

Data Sharing

We may share your personal data with the following categories of recipients:

  • •Security Trustee: Our regulated security trustee who holds security on behalf of bondholders.
  • •Professional Advisors: Solicitors, accountants, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • •Regulatory Bodies: HMRC, the Financial Conduct Authority, and other regulatory authorities where required by law.
  • •Service Providers: Third-party service providers who assist us in operating our platform, including IT providers, payment processors, and identity verification services.

We do not sell your personal data to third parties. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

Data Retention

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.

In general:

  • •Investment records are retained for a minimum of 6 years after the end of the bond term, in accordance with financial regulatory requirements.
  • •AML/KYC records are retained for 5 years after the end of the business relationship.
  • •Marketing consent records are retained until consent is withdrawn.
  • •Website analytics data is anonymised after 26 months.

Your Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

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Right of Access

You have the right to request a copy of the personal data we hold about you.

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Right to Rectification

You have the right to request correction of any inaccurate personal data we hold about you.

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Right to Erasure

You have the right to request deletion of your personal data where there is no compelling reason for its continued processing.

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Right to Portability

You have the right to request transfer of your personal data to another organisation in a structured, commonly used format.

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Right to Restrict Processing

You have the right to request restriction of processing of your personal data in certain circumstances.

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Right to Object

You have the right to object to the processing of your personal data where we rely on legitimate interests.

To exercise any of these rights, please contact us at info@smartlegals.co.uk. We will respond to your request within one month.

Cookies

Our website uses cookies to distinguish you from other users and to provide you with a better browsing experience. For detailed information about the cookies we use and the purposes for which we use them, please see our Cookie Policy.

Security Measures

We have implemented appropriate technical and organisational security measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

  • •SSL/TLS encryption for all data transmitted between your browser and our servers.
  • •Encrypted storage of sensitive personal and financial data.
  • •Regular security assessments and penetration testing of our systems.
  • •Access controls limiting access to personal data to authorised personnel on a need-to-know basis.
  • •Regular staff training on data protection and information security.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have a complaint about how we handle your personal data, please contact us:

Email: info@smartlegals.co.uk

Phone: 0132 580 8936

Address: 15 Parsons Court, Welbury Way, Aycliffe Business Park, County Durham DL5 6ZE

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.