Legal
Privacy policy
What Open Smart collects, why, how long it is kept, and what you can ask me to do about it.
Who is responsible for your data
Open Smart is a business operated by Michail Fas, based in Cambridge, United Kingdom. Open Smart is the data controller for the information described on this page.
Contact for anything on this page
Email: info@opensmart.co.uk
Phone: 07706 601114
What I collect, and why
When you use the contact form
Your name and email address, plus your business name, phone number and the town you are based in if you give them, the type of enquiry, and whatever you write in the message box. I use this to reply to you and to work out how quickly I can get to you. The form is built with Fluent Forms. Submissions are stored in this website's database, emailed to me, and added to my contact records in FluentCRM, where your enquiry is tagged with the service you asked about so that I can follow up on the right thing. FluentCRM runs on this website, not on a separate marketing platform.
When you subscribe or ask to hear from me
Your name and email address. I send marketing emails only to people who have asked for them, or to existing clients about similar services, and every email carries an unsubscribe link that works straight away.
When you phone, email or message me
I keep the details you share, and a record of what was agreed, so I can do the work properly and answer questions later.
When you become a client
Contact details, the information about your systems and accounts needed to do the work, and invoices and payment records. Passwords or access details you hand over for a job are used for that job only.
When you visit this website
The web server logs your IP address, browser type and the pages requested. These logs are used for security and for diagnosing faults. Analytics, if you consent to it, tells me which pages are visited and roughly where visitors come from. This is aggregated and is not used to identify anyone. The cookie policy explains exactly what is set and how to change your choice.
The legal basis for using it
| What I do | Legal basis |
|---|---|
| Replying to an enquiry | Legitimate interests |
| Delivering work you have asked for | Performance of a contract |
| Invoicing and keeping accounting records | Legal obligation |
| Marketing emails | Your consent, or legitimate interests for existing clients |
| Analytics cookies | Your consent |
| Security logs and spam filtering | Legitimate interests |
Where I rely on legitimate interests, the interest is running a small business and being able to respond to people who contact me. You can object to that at any time and I will stop.
Who else sees it
I do not sell your data, and I do not share it with anyone for their own marketing. It is handled by a small number of suppliers who provide the services this business runs on.
| Supplier | Purpose |
|---|---|
| 20i Ltd, United Kingdom | Website and email hosting |
| Website analytics, only if you consent | |
| Accounting software provider | Invoicing and accounting records |
Google may process analytics data outside the UK. Where that happens it relies on the safeguards Google provides for international transfers. I may also have to disclose information where the law requires it, for example to HMRC.
How long I keep it
| Information | Kept for |
|---|---|
| Enquiries that do not become work | 12 months |
| Client records and correspondence | 6 years after the last piece of work |
| Invoices and accounting records | 6 years, as HMRC requires |
| Marketing email subscriptions | Until you unsubscribe |
| Website server logs | As retained by the hosting provider, typically weeks |
The six year figure on client records matches the limitation period for contract claims, so I can answer a question about work I did years ago.
Your rights
Under UK data protection law you can ask me to tell you what I hold about you and give you a copy, correct anything that is wrong, delete it where I have no legal reason to keep it, restrict what I do with it while a question is resolved, provide it in a portable format, and stop using it where I have relied on legitimate interests. You can also withdraw consent at any time, for example by unsubscribing or changing your cookie choice.
Ask by email or phone. There is no charge and I will respond within one month. I may need to confirm who you are first, which is a protection for you rather than an obstacle.
If you are unhappy
Tell me first and I will try to put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk or on 0303 123 1113.
Changes to this policy
If this policy changes in a way that matters, the date at the top will change with it.