PRIVACY POLICY
Last updated: August 2026
WHO WE ARE
Smiths Developments is a trading name of Smiths Capital Ltd, a company registered in England and Wales.
Company number: 16821808
Registered office: Frampton on Severn, Gloucester
ICO registration number: ZC221037
Redress scheme: Property Redress, membership number PRS060200
HMRC anti-money laundering supervision: [PENDING — add number when issued]
Smiths Capital Ltd is the data controller for the personal information described in this notice.
Contact us about any data protection matter:
Email: info@smithsdevelopments.com
Phone: 07481 008406
Post: 22 The Oval, Frampton on Severn, Gloucester, GL2 7HQ
1. IF YOU RECEIVED A LETTER FROM US
What we hold
Your name, your correspondence address, and the address of a property connected to you.
Where we got it
From public registers and open government data:
- The probate register, published by HM Courts and Tribunals Service
- HM Land Registry title and ownership data
- The Energy Performance of Buildings Register
These are public registers, published under statute and made available for reuse.
Why we use it
To write to you to ask whether you would consider selling a property. We buy and source residential property in Gloucester.
Our lawful basis
Legitimate interests, under Article 6(1)(f) UK GDPR. Our legitimate interest is identifying property owners who may wish to sell. We have carried out a documented balancing assessment and concluded this does not override your rights. You can request a copy of that assessment.
How long we keep it
12 months from the last time we contacted you. If you tell us you are not interested, we delete your details but keep the minimum record necessary to make sure we do not write to you again.
How to stop receiving mail
Contact us by any method above. We will stop within 5 working days and will not contact you again. You do not need to give a reason.
2. IF YOU CONTACT US ABOUT SELLING A PROPERTY
What we hold
Your name, contact details, property address, details of the property and its condition, and information about your circumstances and timescales that you choose to share.
Why
To assess whether we can make you an offer, and to communicate with you about it.
Lawful basis
Legitimate interests, and where a transaction proceeds, steps taken at your request prior to entering a contract.
If a transaction proceeds
We are legally required to verify your identity and, in some cases, your authority to sell, under the Money Laundering Regulations 2017. Our lawful basis for this is legal obligation.
How long
6 years for general enquiry records. Where a transaction proceeds, identity and transaction records are kept for 5 years from the end of our business relationship, as the Money Laundering Regulations require.
3. IF YOU ARE AN INVESTOR
What we hold
Your name and contact details, your investment criteria, and — where you proceed with a purchase — identity documents, proof of address, and evidence of your source of funds.
Why
To match you with suitable opportunities, and to meet our legal obligations.
Lawful basis
Legitimate interests and contract for the commercial relationship. Legal obligation for identity and source of funds checks under the Money Laundering Regulations 2017.
Important
We are legally required to carry out these checks and cannot proceed without them. In certain circumstances we are legally required to report suspicions to the National Crime Agency, and we are prohibited by law from telling you if we do so.
How long
5 years from the end of our business relationship.
4. IF YOU USE OUR WEBSITE
We use cookies and analytics as described in our cookie settings. Any enquiry form submission is held on the basis of legitimate interests so that we can respond to you.
5. WHO WE SHARE INFORMATION WITH
- Our letter printing and postal fulfilment provider, acting as our processor under a written contract
- Solicitors and conveyancers, where a transaction proceeds
- Our professional advisers (accountant, insurer, legal advisers)
- HMRC, the National Crime Agency, the ICO, or other authorities where we are legally required to do so
- Our redress scheme, if you make a complaint
We do not sell your information. We do not share it for anyone else's marketing.
6. WHERE YOUR INFORMATION IS HELD
Within the UK or the European Economic Area. Where any provider stores data elsewhere, appropriate safeguards are in place under UK GDPR.
7. YOUR RIGHTS
You have the right to:
- Be told what we hold about you and get a copy
- Have inaccurate information corrected
- Have your information deleted
- Restrict how we use it
- Object to our use of it
- Receive it in a portable format, in certain circumstances
- Withdraw consent, where we rely on consent
THE RIGHT TO OBJECT TO MARKETING IS ABSOLUTE. If you tell us to stop sending you marketing, we stop. No reason required, no exceptions.
To exercise any right, contact us using the details above. We respond within one calendar month, free of charge.
Note: some rights are limited where we hold information to comply with the Money Laundering Regulations. We cannot delete records we are legally required to keep.
8. COMPLAINTS
If you are unhappy with how we have handled your information, please contact us first so we can put it right.
You also have the right to complain to the Information Commissioner's Office at any time:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
ico.org.uk/make-a-complaint
9. CHANGES
We may update this notice. The current version is always at smithsdevelopments.com/privacy.