Privacy notice
This notice explains what personal data we collect through thesmithkingston.com, how we use it, who we share it with, and the rights you have under UK data protection law.
We take these responsibilities seriously and only collect what we need to answer your enquiry.
1. Who we are
The Smith Pension Scheme is the data controller for personal data collected through this website. The Scheme owns the property at 145 London Road and is administered by its trustees.
Pension Scheme Tax Reference (PSTR): 20012004RA
ICO registration number: ZC0900052
Data protection contact: enquiries@thesmithkingston.com
2. What personal data we collect
When you submit an enquiry form on this site, we collect:
- Your name
- Your email address
- Your phone number
- What you're interested in (offices, serviced offices, or co-working)
- Any details you choose to add in the message field
- Whether you have opted in to receive marketing updates (only if you tick that box)
We also collect standard technical data through our web host (Cloudflare) — IP address, browser type, referrer URL, timestamps — for security and diagnostic purposes only. This is not used to identify you or to build a profile.
We do not use analytics cookies, advertising pixels, or any behavioural tracking on this site.
3. Why we use your data
- Responding to your enquiry. We use your contact details to reply, arrange a viewing, and follow up as needed.
- Passing your enquiry to the right contact. Serviced offices and co-working enquiries go to our commercial manager, Kam Khun (employed by The Boutique Workplace Company Ltd). Offices enquiries go to our appointed letting agent, Andy Armiger of Cattaneo Commercial. These parties act as processors on our behalf and use your data only to respond to you.
- Optional marketing updates — only if you have ticked the marketing opt-in box on the form.
We will never sell your data. We will never share your data with any third party unrelated to your enquiry or the operation of this site.
4. Our lawful basis under UK GDPR
For responding to your enquiry
Article 6(1)(f) — legitimate interests. We have a legitimate interest in responding to enquiries about our property. This is a routine, expected use of the contact details you have chosen to provide and has minimal impact on your privacy.
For marketing updates (only if you have opted in)
Article 6(1)(a) — consent. You can withdraw consent at any time by clicking the unsubscribe link in any marketing email, or by contacting us.
5. Who we share your data with (processors)
We use the following third-party services to operate the website and handle enquiries. Each is bound by written data processing terms.
- Cloudflare, Inc. (United States) — website hosting, content delivery (CDN) and infrastructure security. Cloudflare participates in the EU-US Data Privacy Framework. Their privacy notice: cloudflare.com/privacypolicy.
- Make (Make.com, operated by Celonis) — receives website form submissions and routes them by email to the correct on-site contact. Form data is processed in Make's US region; transfers are covered by Make's Data Processing Agreement and EU Standard Contractual Clauses. Their privacy notice: make.com/en/privacy-and-gdpr.
- Google Workspace — delivers enquiry notifications to Kam and Andy.
- Google Ireland Limited / Google LLC (Ireland / United States) — website analytics (Google Analytics 4) and tag management (Google Tag Manager). Google participates in the EU-US Data Privacy Framework. Their privacy notice: policies.google.com/privacy.
- Microsoft Corporation (United States) — website behaviour analytics (Microsoft Clarity). Microsoft participates in the EU-US Data Privacy Framework. Their privacy statement: privacy.microsoft.com.
- The Boutique Workplace Company Ltd (United Kingdom) — receives and responds to serviced offices and co-working enquiries on our behalf.
- Cattaneo Commercial (United Kingdom) — receives and responds to offices enquiries on our behalf.
International transfers
Where personal data is transferred outside the UK (for example to US-based Cloudflare, Google, Microsoft or Make), we rely on the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, and/or the UK-US Data Bridge where applicable. Both arrangements are recognised by the ICO as providing an adequate level of protection.
6. How long we keep your data
- Enquiry data — kept for 24 months from your last contact with us, then deleted. If your enquiry leads to a viewing or lease, retention is extended for the lifetime of any resulting relationship plus 6 years for accounting and tax purposes.
- Marketing consent — retained until you unsubscribe or ask us to delete your data.
- Cloudflare server logs — rotated per Cloudflare's standard retention (typically 30 days or less).
- Website analytics — Google Analytics and Microsoft Clarity data is pseudonymised and retained in line with each provider's standard retention settings, after which it is deleted or kept only in aggregate.
7. Your rights under UK GDPR
You have the right to:
- Access — request a copy of the personal data we hold about you.
- Rectification — ask us to correct inaccurate data.
- Erasure — ask us to delete your data (subject to legal retention obligations).
- Restriction — ask us to pause use of your data while a query is resolved.
- Objection — object to us processing your data based on legitimate interests.
- Portability — receive your data in a machine-readable format.
- Withdraw consent for marketing at any time.
To exercise any of these rights, contact us at enquiries@thesmithkingston.com or by post at the address above. We will respond within one month.
You also have the right to complain to the Information Commissioner's Office (ICO) at any time: 0303 123 1113 or ico.org.uk.
8. Automated decision-making
We do not carry out any automated decision-making or profiling that produces legal or similarly significant effects.
9. Changes to this notice
We may update this notice from time to time. Material changes will be highlighted at the top of this page, and the "last updated" date above will change accordingly.