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Privacy Policy

Last updated: April 2026

1. Who We Are

SMITOSCO LTD is a company registered in England and Wales. Our registered address is 27 Old Gloucester Street, Holborn, London, WC1N 3AX. The data controller for this website is Kieren Toscan.

If you have any questions about how we handle your personal data, please contact us at hello@smitosco.com.

2. What Personal Data We Collect

We collect personal data only when you choose to contact us directly by email. In that case, we may collect:

We do not operate any online contact forms, user accounts, or automated data collection systems. We do not collect payment information.

3. How We Use Your Data

We use your data solely to respond to your enquiry. We do not use it for marketing purposes without your explicit consent, and we do not use it for automated decision-making or profiling. We will never share your contact details with third-party marketing platforms.

4. Legal Basis for Processing

Where you have contacted us with an enquiry, our legal basis for processing your data is legitimate interests (Article 6(1)(f) UK GDPR) — specifically, the legitimate interest of responding to a communication you initiated. Where we retain data for tax or financial compliance purposes, the legal basis is compliance with a legal obligation (Article 6(1)(c)).

5. How Long We Keep Your Data

We retain email correspondence for up to 2 years from the date of last contact. Where HMRC or other legal rules require a longer retention period (for example, up to 6 years for accounting records), we will retain data only for as long as required and then securely delete it.

6. Third Parties

We do not sell or share your personal data with third parties for commercial or marketing purposes. Your data may pass through the following infrastructure providers as part of normal website operation:

No personal data you submit to us is passed to either of these providers.

7. Your Rights Under UK GDPR

Under Articles 15–22 of the UK GDPR, you have the following rights:

To exercise any of these rights, email us at hello@smitosco.com. We will respond within 30 days.

8. Complaints

If you believe we have not handled your personal data correctly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

9. Changes to This Policy

We may update this privacy policy from time to time. The "last updated" date at the top of this page will reflect any changes. Continued use of the website constitutes acceptance of the current policy.