Privacy Policy

1. Introduction

Smart Group (“we,” “us,” “our”) is committed to protecting and respecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, process, and share personal data when providing:

• Debt help and financial assistance services
• PCP (Personal Contract Purchase) mis-sold car finance claims services
• Related financial product support services

2. The Data We Collect

We may collect and process the following categories of personal data:

A. Identity Data

• Full name
• Date of birth
• National Insurance number
• Photographic ID

B. Contact Data

• Address
• Email address
• Telephone number

C. Financial Data

• Bank account details
• Credit agreements
• PCP finance agreements
• Loan balances
• Income and expenditure information
• Credit history information

D. Technical Data

• IP address
• Device information
• Website usage data

E. Special Category Data (Where Necessary)

In some cases, we may process health or vulnerability information where relevant to debt advice or financial hardship assessments.

F. Data From Affiliate Suppliers

We may collect personal data from trusted sub affiliate data suppliers who we work with.

3. How We Use Your Personal Data

We use your data to:

• Assess eligibility for debt solutions
• Review PCP agreements for mis-selling
• Submit claims to lenders or financial institutions
• Communicate with lenders, brokers, or solicitors on your behalf
• Provide regulated financial services
• Comply with legal and regulatory obligations
• Prevent fraud and financial crime

4. Legal Basis for Processing

Under UK GDPR, we rely on the following lawful bases:

• Contract — Where processing is necessary to provide services you have requested.
• Legal obligation — To comply with regulatory requirements including those set by the Financial Conduct Authority.
• Legitimate interests — To improve our services and prevent fraud.
• Consent — Where we use your data for marketing or additional services.

You may withdraw consent at any time by contacting us.

5. Use of Data for Additional Services Within Smart Group

Smart Group operates as a group of related service providers. With your informed and explicit consent, we may use your personal data to:

• Offer additional financial products or claims services
• Refer you internally to affiliated companies within Smart Group
• Conduct eligibility checks for related financial solutions
• Provide tailored offers relevant to your financial circumstances

We will not share your data outside Smart Group for unrelated third-party marketing without your explicit consent.

6. Sharing Your Information

We may share your personal data with:

• Lenders and finance providers
• Claims management companies
• Solicitors and legal representatives
• Credit reference agencies
• Regulatory authorities such as the Financial Conduct Authority
• The Information Commissioner's Office where required

All third parties are required to respect the security of your personal data and process it in accordance with the law.

7. Data Retention

We retain your personal data only for as long as necessary to:

• Fulfil the purposes we collected it for
• Comply with legal and regulatory requirements
• Defend potential legal claims

Financial and client records are typically retained for up to 6 years after the end of the client relationship, in line with UK regulatory obligations.

8. Data Security

We implement appropriate technical and organisational measures to protect your data, including:

• Secure servers
• Encryption
• Restricted staff access
• Confidentiality agreements

9. Your Rights Under UK GDPR

You have the right to:

• Request access to your personal data
• Request correction of inaccurate data
• Request erasure (“right to be forgotten”)
• Restrict or object to processing
• Request transfer of your data
• Lodge a complaint with the Information Commissioner's Office

10. International Transfers

We do not transfer your personal data outside the UK unless adequate safeguards are in place in accordance with UK GDPR.

11. Marketing Communications

We may contact you about related services if:

• You have provided consent; or
• It is otherwise permitted under UK electronic marketing laws.

Where applicable, we may contact you by telephone, email, or SMS.

You may opt out of marketing communications at any time by contacting us or using the unsubscribe link in our emails.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be published on our website with a revised effective date where applicable.

13. Contact Us