1) Who we are (Data Controller)
Smart Mind is the controller of personal data processed via our website and services.
Contact for privacy matters: info@smartmindltd.co.uk | 07782543804
Postal: 72 Green Street, London, E7 8JG, United Kingdom
2) Scope
This policy explains how we collect, use, share, and protect personal data in compliance with the UK GDPR and Data Protection Act 2018.
3) Data we collect
- Identity & contact: name, DOB, nationality, addresses, phone, email, emergency contact.
- Education & application: transcripts, test scores, personal statements/CVs, references, course preferences, application IDs, CAS/offer/acceptance details.
- Compliance: passport/ID copies, visa status, immigration history (where lawful and necessary).
- Financial: fee status, payment records (we do not store full card details—handled by PCI-compliant processors).
- Usage & technical: IP address, device/browser info, pages viewed, cookies/analytics.
- Marketing preferences: subscriptions, consent records.
- Special category data (limited): e.g., disability or health information, strictly when necessary for reasonable adjustments or application requirements, processed with your explicit consent or another lawful condition.
4) How we collect data
- Directly from you (forms, email, phone, events, course enrolment).
- From third parties with your authorisation (referees, test centres, partner institutions, agents).
- Automatically via cookies/analytics on our website.
5) Lawful bases for processing
We process data under one or more of:
- Contract: to provide requested services, applications, and course delivery.
- Legal obligation: UK regulatory, tax, fraud prevention.
- Legitimate interests: running and improving our services, responding to enquiries, safeguarding, quality assurance, marketing to existing clients (you can opt out).
- Consent: email/SMS marketing to new prospects, use of special category data, and certain cookies. You can withdraw consent at any time.
6) What we do with your data
- Provide consultancy, courses, and enrolment services.
- Prepare and submit applications to institutions you select.
- Communicate with you and relevant third parties on your behalf.
- Manage payments, invoicing, and customer support.
- Run analytics and improve the website/services.
- Send updates, service notices, and (with consent or soft-opt-in) marketing.
7) Sharing your data
We may share data with:
- Universities/colleges and partner institutions (for applications/enrolment you request).
- Service providers/Processors (IT hosting, CRM, email, payment, analytics) under data processing agreements.
- Referees/test providers (e.g., IELTS/TOEFL/DUOLINGO) where you instruct us.
- Professional advisers (legal, accounting) and regulators/law enforcement where required by law.
We do not sell your personal data.
8) International transfers
Your data may be transferred outside the UK (e.g., to universities abroad or to cloud providers). Where this occurs, we use appropriate safeguards such as UK adequacy regulations, International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses, plus supplementary measures where needed.
9) Retention
We keep data only as long as necessary: typically up to 7 years after the end of services (to meet legal/accounting requirements and for service records). Application materials may be retained for shorter/longer periods if required by institutions or law. We then securely delete or anonymise.
10) Your rights
Under UK GDPR, you have rights to:
- Access your data;
- Rectify inaccurate data;
- Erase data (where applicable);
- Restrict or object to processing (including direct marketing);
- Data portability;
- Withdraw consent at any time (where consent is the basis).
To exercise rights, contact info@smartmindltd.co.uk. We respond within one month.
11) Marketing
- We may send service updates and relevant information to existing clients under legitimate interests (opt-out anytime).
- We will send promotional emails/SMS to new prospects only with consent.
- You can unsubscribe via the link in emails or by contacting us.
12) Cookies & analytics
We use essential cookies (site operation) and, with consent, non-essential cookies (analytics/advertising).
- On first visit, you’ll see a cookie banner allowing you to accept/reject categories.
- You can change preferences in your browser or our cookie settings at any time.
- Analytics help us understand site usage; data is aggregated where possible.
13) Children’s data
Our services are primarily for adults. Where we process data of individuals under 18 (e.g., sixth-form/college applicants), we seek appropriate consent/authorisation from a parent/guardian and apply enhanced safeguarding.
14) Security
We implement appropriate technical and organisational measures (access controls, encryption in transit where feasible, secure storage, role-based access, staff training). No system is 100% secure; please take care when sending sensitive information.
15) Third-party links
Our website may link to external sites with their own privacy policies. We are not responsible for their content or policies.
16) Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be posted on our website with an updated “Last updated” date.
17) Complaints
If you have concerns, please contact us first at info@smartmindltd.co.uk.
You also have the right to complain to the Information Commissioner’s Office (ICO) (www.ico.org.uk).
18) Contact us
Smart Mind
info@smartmindltd.co.uk | 07782543804
72 Green Street, London, E7 8JG, United Kingdom