1. Who We Are
Smartway Cleaning Ltd is the data controller responsible
for deciding how and why personal information is processed
in connection with our website and cleaning services.
Data controller:
Smartway Cleaning Ltd
Company number:
16547992
Registered address:
36 Bayfield Drive, Burwell, Cambridge,
CB25 0JE, England
Email:
alycodreanu@gmail.com
Telephone:
07745 551636
Smartway Cleaning Ltd is not currently presented on this
website as an ICO-registered organisation. This does not
affect our responsibility to comply with applicable data
protection obligations.
2. Scope of This Policy
This Privacy Policy applies when you:
- visit our website;
- complete a contact or quotation form;
- contact us by telephone, email or WhatsApp;
- request a cleaning quotation;
- make or manage a booking;
- pay for a service;
- receive cleaning services from us;
- submit feedback or a complaint;
- interact with our advertisements or marketing communications.
This policy should be read alongside our Service Terms
and any cookie or consent choices displayed on our website.
By using our services, you acknowledge that you have been
given access to this Privacy Policy. Consent is used only
where consent is the appropriate legal basis.
3. Our Data Protection Principles
Lawfulness and transparency
We use personal information fairly, lawfully and
transparently.
Purpose limitation
We use information only for specified and legitimate
purposes.
Data minimisation
We collect only information reasonably necessary
for the relevant purpose.
Accuracy
We take reasonable steps to keep relevant customer
records accurate.
Storage limitation
We do not retain information indefinitely without
a valid reason.
Security and confidentiality
We use proportionate safeguards against loss,
misuse and unauthorised access.
4. Personal Information We Collect
Depending on how you interact with us, we may collect:
4.1 Identity and contact information
- name;
- telephone number;
- email address;
- service address;
- billing address where different;
- company name and business contact details.
4.2 Booking and service information
- property type and size;
- requested cleaning service;
- selected date and time;
- access, parking and entry instructions;
- information about pets or relevant property conditions;
- service checklists and special instructions;
- quotation and appointment history.
4.3 Communication information
- emails;
- WhatsApp messages;
- telephone call notes;
- website form submissions;
- feedback, reviews and complaints.
4.4 Payment and transaction information
- amount paid;
- payment method;
- invoice and transaction references;
- payment status;
- refund or cancellation records.
We do not intentionally store complete card numbers or
card security codes. Card information should be handled
by the relevant payment service provider or financial
institution.
4.5 Photographs and service evidence
- photographs of relevant areas before cleaning;
- photographs showing completed work;
- photographs supplied in support of a quotation;
- photographs relating to a complaint or damage concern.
4.6 Website and technical information
- IP address;
- browser and device type;
- pages viewed;
- approximate location derived from technical data;
- referral source;
- cookie and consent preferences;
- website interaction and analytics information.
4.7 Sensitive information
We do not normally need health information, identification
documents or other special-category personal data to provide
standard cleaning services.
Please do not send sensitive information unless it is
genuinely necessary for a specific safety or accessibility
requirement.
5. How We Collect Your Information
We normally collect personal information directly from you when
you:
- submit an online form;
- contact us by email or WhatsApp;
- speak with us by telephone;
- request or approve a quotation;
- make a payment;
- provide access or service instructions;
- submit a complaint, review or correction request.
We may also receive information from:
- a landlord, tenant, agent or authorised representative;
- a business arranging a service for its premises;
- a person booking a service on your behalf;
- payment and banking providers;
- website analytics and advertising services;
- publicly available business sources where appropriate.
A person supplying another individual’s details should have
appropriate authority to do so and should make this policy
available to that individual.
6. How We Use Your Information
6.1 Enquiries and quotations
We use your information to respond to questions, understand
your requirements, assess availability and prepare a quotation.
6.2 Booking management
We use booking information to confirm appointments, schedule
team members, arrange access and communicate changes.
6.3 Service delivery
We use relevant property and service information to prepare
for and provide the agreed cleaning service.
6.4 Payments and accounting
We process transaction records to receive payments, issue
invoices, process refunds, maintain accounts and meet tax
and financial obligations.
6.5 Customer support
We use communications and service records to answer questions,
investigate complaints and resolve quality or damage concerns.
6.6 Safety and fraud prevention
We may use relevant information to protect customers, workers,
properties and our business against fraud, abuse, unsafe
conditions or unlawful conduct.
6.7 Website improvement
Subject to applicable cookie and consent requirements, we use
analytics information to understand website performance and
improve navigation, content and advertising effectiveness.
6.8 Legal obligations and claims
We may process and preserve records where reasonably necessary
to comply with law, respond to authorities, establish legal
rights or defend a claim.
7. Our Lawful Bases for Processing
We rely on one or more of the following lawful bases,
depending on the purpose:
| Purpose |
Typical lawful basis |
|
Preparing quotations and taking steps requested
before a booking
|
Steps before entering into a contract
|
|
Confirming, managing and providing a cleaning service
|
Performance of a contract
|
|
Processing invoices, accounts and tax records
|
Legal obligation and performance of a contract
|
|
Managing complaints, safety, fraud and legal claims
|
Legitimate interests and, where applicable,
legal obligation
|
|
Taking proportionate service photographs
|
Performance of a contract or legitimate interests
in quality assurance and dispute management
|
|
Optional analytics cookies
|
Consent where required
|
|
Optional promotional email or WhatsApp marketing
|
Consent or another legally permitted basis
|
Our legitimate interests
Where we rely on legitimate interests, those interests may
include operating and improving our business, protecting
customers and workers, maintaining service quality, preventing
fraud and handling disputes.
We consider whether those interests are necessary and balanced
against the rights and reasonable expectations of the
individual.
8. Payments
We may accept payment by card, bank transfer or cash,
depending on the agreed booking arrangements.
8.1 Card payments
Card payments may be handled by an external payment provider
or banking service. That provider may process payment details
as an independent controller or processor under its own
privacy terms.
Smartway Cleaning Ltd should not receive or retain your
complete card number, expiry date and card security code
where payment is processed through a third-party service.
8.2 Bank transfers
Bank transfer records may display the payer’s name,
account reference, amount, date and transaction information.
These records are used for payment reconciliation and
accounting.
8.3 Cash payments
Where cash is accepted, we may record the amount, date,
booking reference and confirmation that payment was received.
Never send complete card details or security codes through
email, WhatsApp or a website contact form.
9. Email, Telephone and WhatsApp
9.1 Email
Enquiries and booking communications may be received and
stored using Gmail and related Google services.
9.2 WhatsApp Business
Where you contact us using WhatsApp, your telephone number,
profile information made available by you, messages and
attachments may be processed through WhatsApp and Meta systems.
WhatsApp operates under its own terms and privacy information.
You should avoid sending unnecessary sensitive or confidential
information through WhatsApp.
9.3 Telephone calls
We may record written notes of important booking information
discussed during a call. We do not state that ordinary calls
are audio-recorded unless we tell you before a recording begins.
9.4 Service messages
Booking confirmations, arrival updates, payment reminders
and responses to customer requests are service communications,
not optional marketing messages.
10. Before-and-After Photographs
We may take proportionate photographs of areas relevant to
the service for:
- quotation assessment;
- documenting the initial condition;
- confirming work completed;
- quality assurance;
- investigating complaints or damage allegations;
- protecting customers, workers and the Company in disputes.
We aim to avoid intentionally capturing people, private
documents, family photographs, computer screens, security
details and unrelated personal belongings.
Marketing photographs
Photographs taken for service or evidence purposes are not
automatically authorised for public advertising.
Where an image identifies a customer or private property,
we will obtain appropriate permission before using it for
marketing where consent is required.
11. Cookies and Google Analytics
Cookies are small files placed on a visitor’s device.
Some cookies are necessary for website functionality,
while others support analytics or advertising.
11.1 Essential cookies
Essential cookies may be used where reasonably necessary
for security, consent preferences or core website functions.
11.2 Google Analytics
We use or may use Google Analytics to understand how visitors
find and use our website.
Depending on the configuration and your consent choices,
Google Analytics may process information such as:
- IP and approximate location information;
- browser and device information;
- pages visited;
- time and interactions on the website;
- referral and campaign information.
Analytics cookies that are not strictly necessary should
not be activated until the visitor has been given an
appropriate choice where consent is required.
11.3 Cookie choices
You can accept or reject optional cookies through the
cookie controls presented on our website. You can also
manage cookies through your browser settings.
Rejecting analytics cookies should not prevent access to
the main information and contact features of the website.
12. Marketing Communications
We may send information about Smart Way Cleaning offers
or services only where we have a lawful basis to do so.
Where marketing is based on consent, you may withdraw
that consent at any time by:
- using an unsubscribe option where provided;
- replying “STOP” to an appropriate marketing message;
- emailing alycodreanu@gmail.com;
- contacting us on 07745 551636.
Withdrawing marketing consent does not affect service
communications relating to an active quotation, booking,
payment, complaint or legal obligation.
You have the right to object to direct marketing at any time.
13. Who We Share Information With
We do not sell customer personal information.
Where reasonably necessary, information may be shared with:
-
authorised cleaners or team members who need relevant
booking information;
-
Google services used for email, storage, analytics or
website functionality;
-
WhatsApp and Meta where you communicate through WhatsApp;
-
payment processors, banks and financial institutions;
-
website hosting, domain, IT and security providers;
-
accountants, insurers and professional advisers;
-
law enforcement, courts, regulators or public authorities
where disclosure is legally required;
-
another business involved in a genuine sale,
restructuring or transfer, subject to appropriate
confidentiality protections.
Service providers should receive only the information
reasonably necessary for their role and may be subject
to contractual, professional or legal duties.
14. International Data Transfers
Some technology providers, including providers of email,
analytics, communications, hosting or payment services,
may process information outside the United Kingdom.
Where an international transfer is subject to UK data
protection restrictions, we will rely on an appropriate
mechanism where required. This may include:
- UK adequacy regulations;
- approved contractual safeguards;
- the UK International Data Transfer Agreement;
- an approved UK Addendum;
- another legally recognised transfer mechanism.
External providers may also apply their own security,
privacy and international-transfer arrangements.
15. Data Security
We use proportionate technical and organisational measures
intended to reduce the risk of accidental loss, misuse,
alteration, disclosure or unauthorised access.
Measures may include:
- password-protected accounts and devices;
- access limited to people who need the information;
- secure payment providers rather than storing full card data;
- software and device updates;
- reasonable account recovery and authentication controls;
- careful handling of access instructions and keys;
- secure deletion or disposal when records are no longer required;
- review of suspected privacy or security incidents.
No electronic system can be guaranteed completely secure.
Customers should avoid sending unnecessary sensitive
information through ordinary email, forms or messaging.
16. How Long We Keep Information
We retain personal information only for as long as reasonably
required for the purpose for which it was collected, including
legal, accounting, insurance and dispute-resolution needs.
| Record category |
Typical retention period |
|
Enquiries that do not become confirmed bookings
|
Normally up to 12 months after the last meaningful
communication
|
|
Quotations, bookings, invoices and payment records
|
Normally up to 6 years after the relevant financial
year or transaction, where required for accounting,
tax or legal purposes
|
|
Routine booking communications
|
Normally linked to the booking record and retained
only as long as reasonably necessary
|
|
Before-and-after service photographs
|
Normally up to 90 days after the service unless
required for an active complaint, claim, insurance
matter or legal obligation
|
|
Complaint, damage and insurance records
|
Normally up to 6 years after closure, depending on
the nature of the matter
|
|
Marketing preferences
|
Until consent is withdrawn, marketing ends or the
record is no longer required
|
|
Suppression record following an opt-out
|
A minimal record may be retained to ensure the
marketing preference continues to be respected
|
|
Analytics and cookie information
|
According to the analytics settings and consent
controls in use, and no longer than reasonably
necessary for analysis
|
A record may be retained longer where reasonably required
by law, taxation rules, an insurer, an ongoing dispute,
fraud prevention or a legal claim.
Information that is no longer required will be deleted,
anonymised or securely disposed of where reasonably possible.
17. Your Data Protection Rights
Depending on the circumstances, you may have the following
rights:
17.1 Right of access
You may ask whether we process your personal information
and request a copy of relevant information.
17.2 Right to rectification
You may ask us to correct inaccurate information or complete
information that is incomplete.
17.3 Right to erasure
You may request deletion in circumstances where the right
applies. The right to erasure is not absolute and some
records may need to be retained.
17.4 Right to restrict processing
You may ask us to restrict how certain information is used
while a relevant issue is considered.
17.5 Right to object
You may object to processing based on legitimate interests
in certain circumstances. You have an absolute right to
object to the use of your information for direct marketing.
17.6 Data portability
Where the right applies, you may request certain information
in a structured, commonly used and machine-readable format.
17.7 Withdrawal of consent
Where processing is based on consent, you may withdraw
consent at any time. Withdrawal does not make earlier
processing unlawful.
17.8 Automated decisions
We do not currently make decisions producing legal or
similarly significant effects about cleaning customers
solely through automated processing.
Exercising your rights
To make a request, contact:
alycodreanu@gmail.com
We may request proportionate information to verify your
identity and protect information from unauthorised disclosure.
We aim to respond without undue delay and normally within
one calendar month. In legally permitted circumstances,
additional time may be required for complex or multiple
requests, and we will explain this where applicable.
18. Children’s Information
Our website and cleaning-booking services are intended
for adults and are not directed at children.
A person making a booking must be at least 18 years old.
We do not knowingly collect children’s information for
marketing or account-registration purposes.
If you believe a child has submitted personal information
to us without appropriate involvement from a parent or
guardian, please contact us.
19. Personal Data Breaches
We will assess suspected loss, unauthorised disclosure,
account compromise or misuse of personal information.
Where legally required, we will notify the Information
Commissioner’s Office and affected individuals within the
applicable legal timeframe.
Please contact us promptly if you believe information sent
to or held by Smartway Cleaning Ltd has been disclosed,
lost or accessed improperly.
20. Privacy Complaints
Please contact us first if you have concerns about how
we have collected, used, shared, retained or protected
your personal information.
You also have the right to complain to the UK Information
Commissioner’s Office if you remain dissatisfied.
Visit the ICO complaints service
ICO telephone:
0303 123 1113
21. Changes to This Privacy Policy
We may update this policy when our services, website,
suppliers, legal obligations or information-handling
practices change.
The most recent version will be published on this page
with an updated revision date.
Material changes may also be communicated through the
website or directly to affected customers where appropriate.
22. Data Controller Contact
Legal name:
Smartway Cleaning Ltd
Company number:
16547992
Registered address:
36 Bayfield Drive, Burwell, Cambridge,
CB25 0JE, England
Email:
alycodreanu@gmail.com
Telephone:
07745 551636
Last updated: July 2026