Disclaimer/Privacy Policy

Disclaimer / Privacy Policy — Smartrose Estates Ltd

Last updated: 13^th August 2026

Introduction

We are committed to protecting your privacy. This Privacy Notice sets out our privacy practices and explains how we collect, use, store, share and otherwise process (“handle”) personal data, and who we share it with.

We only handle the personal data required to deliver the services you request from us. Except as set out in this Notice, we do not share your details with any other organisation for marketing purposes.

You may browse our website without telling us who you are. We only collect information that is needed to provide site functionality, respond to enquiries, or deliver our services.

This Notice is reviewed regularly and may be updated from time to time. Material changes will be notified to you (for example by email, where we hold your details) and the current version will always be available on this page, dated above.

Who we are

We are Smartrose Estates Ltd, registered in England and Wales, company number 06019433, registered office 49 Mowbray Road, Edgware, Middlesex, England, HA8 8JL.

We are the data controller for the personal data described in this Notice.

• T. 020 8809 7005
• E. info@smartrose.co.uk
• W. www.smartrose.co.uk

The information we collect

• Contacting us — telephone, postal, email and other electronic communications you send us, so we can act on your instructions accurately.
• Website statistics — pages visited, navigation paths, and search terms used to find us, to improve the site and understand visitor needs. See our Cookies Policy for details of the specific cookies and analytics tools used, and how to manage your preferences.
• Online/contact forms — information you submit through our forms. We take appropriate technical and organisational measures to protect this data, but no transmission over the internet can be guaranteed completely secure.
• Tenant, landlord and client data — information needed to manage tenancies, property transactions and client accounts (e.g. identity, contact, financial and referencing information), collected directly from you or from third parties such as referencing agencies, with your knowledge.

Our lawful basis for processing

We only process personal data where we have a lawful basis under UK GDPR, which will typically be one of:

• Contract — to take steps at your request before entering a contract, or to perform a tenancy, management or client agreement.
• Legal obligation — for example, right-to-rent checks, anti-money laundering checks, or regulatory reporting.
• Legitimate interests — for general business administration, service improvement, and fraud prevention, where these interests are not overridden by your rights. Where applicable, we rely on the categories of “recognised legitimate interests” set out in the Data (Use and Access) Act 2025, which do not require a full balancing assessment.
• Consent — for direct marketing communications and non-essential cookies, which you can withdraw at any time.

Why we collect and use your data

• To provide information about, and deliver, our services;
• To manage tenancies and client relationships, and communicate on service matters;
• To keep you informed of relevant new features or services (where you have consented, or it is otherwise permitted);
• To comply with our legal and regulatory obligations, including anti-money laundering and right-to-rent requirements;
• To maintain the security and functionality of our website.

Who we share your data with

• We do not sell, rent or share your name, email address or other personal data with third parties for their own marketing purposes.
• We may disclose data to third parties who provide services to us — for example accountants, contractors, referencing agencies, and other professional advisers — under contracts that require them to protect your data appropriately.
• We may disclose relevant data to your landlord or tenant, as applicable to the tenancy.
• We may disclose data to the police or other law enforcement bodies for the prevention or detection of crime.
• We may disclose data where required by law or regulatory obligation.
• We may share aggregated, anonymised statistics that cannot identify you with partners or advertisers.

International transfers

Where personal data is transferred outside the UK, we ensure this is done in line with UK GDPR requirements — for example, using UK adequacy regulations or the “data protection test” introduced by the Data (Use and Access) Act 2025, or approved safeguards such as the International Data Transfer Agreement.

How long we keep your data

We retain personal data only for as long as necessary for the purposes it was collected, including to meet legal, accounting or regulatory requirements.

Your rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate or incomplete data;
• Erasure of your data in certain circumstances;
• Restrict or object to our processing of your data;
• Data portability, where processing is based on consent or contract and carried out by automated means;
• Withdraw consent at any time, where processing is based on consent;
• Not be subject to solely automated decision-making that produces legal or similarly significant effects, subject to limited exceptions.

To exercise any of these rights, contact us using the details above. We will normally respond within one month, and may extend this by a further two months for complex requests, in which case we will explain why.

How to complain

Complain to us directly: If you are unhappy with how we have handled your personal data, you can complain to us using the contact details above. We will acknowledge your complaint within 30 days and provide a full response without undue delay, in line with the new statutory complaints right introduced by the Data (Use and Access) Act 2025.

Complain to the regulator: You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at any time:

• Website: ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

How we store and protect your data

• Your data is stored securely in line with industry best practice, reviewed at least annually.
• Data is held on servers either in the UK/EEA, or in jurisdictions with an adequate level of protection, or subject to appropriate safeguards as set out above.

Related policies

For further detail, please see our:

• Client Money Handling Policy
• Cookies Policy
• Terms of Business (available on request)

Smartrose Estates Ltd 93 Northwold Road, London E5 8RN