Privacy Policy

Privacy Policy

Last revised 22nd August 2023 (the "Site") is owned and operated by Smart Gift Voucher Ltd. Smart Gift Voucher Ltd acts as the data processor and can be contacted at:


The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:

  • The personal data we will collect;
  • Use of collected data;
  • Who has access to the data collected;
  • The rights of Site users; and
  • The Site's cookie policy.

This Privacy Policy applies in addition to the terms and conditions of our Site.


For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

The appointed Data Protection Officer is Theodore Whittington who can be contacted by email at


By using our Site users agree that they consent to:

The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal basis to collect and process the personal data of users in the EU:

Users have provided their consent to the processing of their data for one or more specific purposes.

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically

When you visit and use our Site, we may automatically collect and store the following information:

  • IP address;
  • Location;
  • Hardware and software details;
  • Clicked links; and
  • Content viewed.
  • Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

  • First and last name;
  • Age;
  • Date of birth;
  • Email address;
  • Phone number;
  • Address; and
  • Payment information.

This data may be collected using the following methods:

  • Recording form requests for reply
  • User provided contact and delivery information for the fulfilment of orders
  • Customer provided import data for the redemption of vouchers

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used statistics and informing our security practices.

The data we collect when the user performs certain functions is used provide core services.

Who We Share Personal Data With

The Data Controller

Smart Gift functions primarily to enable our customers to in turn serve their customers. Our customers assume the role of data controller.


We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Other Disclosures

  • We will not share your data with other third parties, except in the following cases:
  • If the law requires it;
  • If it is required for any legal proceeding;
  • To prove or protect our legal rights; and
  • To buyers or potential buyers of this company in the event that we seek to sell the company.
  • If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data

User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data

In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All user accounts are equipped with multi-factor authentication and all stored data is encrypted in transit and at rest.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

Your Rights as a User

Under the GDPR, you have the following rights:

  • Right to be informed;
  • Right of access;
  • Right to rectification;
  • Right to erasure;
  • Right to restrict processing;
  • Right to data portability; and
  • Right to object.

Our partners’ customers (data controller) have various obligations under the GDPR and Data Protection Act of 2018 with respect to their use of customers' personal data. As the data processor, we commit to the support of those obligations as directed by GDPR and Data Protection Act of 2018 as follows.

Right to Access / Subject Access

Right to Access requests provided to Smart Gift by the data controller or partner will be responded to within 28 days of the request being received. Requests received directly from data subjects to Smart Gift will be passed to the data controller, before being passed back to us if further information is required. We outline the ways that we store customer data and the purpose for which we store it in our privacy policy available at

Right to Rectification

We provide tools for the data controller to rectify data that may be incorrect or incomplete. Should they not be able to amend certain information that fits this criteria, they can contact us for assistance. The first port of call for the data subject should be the data controller, we will refer direct requests back to the data controller if we receive them unless it is shown that the data controller has been unable to fulfill a Right to Rectification request.

Right to Erasure

As the data processor, we do not dictate whether certain information is necessary or unnecessary, we instead leave this assessment up to the data controller. We also do not allow for complete erasure of data, opting instead for anonymisation as some records will have significant value that does not fall under the scope of personally identifiable information. Our data controller can anonymise data using the tools available or by contacting us directly.

Right to Object

The right to object to processing of data completely applies in several cases, but most notably for direct marketing. As the processor of data, we collect information required for our partners’ customers (data controllers) to fulfill the orders of their customers (e.g. hotels) but are not responsible for any direct marketing. We do offer a facility for data subjects to opt-in to marketing from the data controller, however this is for use outside of Smart Gift the platform, and we do not perform any marketing within Smart Gift.

Right to Data Portability

You may have the right to obtain certain information from us in machine readable form, e.g exports. We provide tools for this purpose within the application, however if you feel that you have a right to information not available by this means, please contact us


There are some cases in which we may not provide the data requested. If the request is excessive, has no basis or would reveal private information about another party then we may refuse the request or provide a partial response. We will also deny the request if we are legally prevented from sharing the requested information.


We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here: Theodore Whittington

Cookie Policy

A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

use the following types of cookies on our Site:

  • Functional cookies: Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
  • Analytical cookies: Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc;
  • Targeting cookies: Targeting cookies collect data on how you use the Site and your preferences. This allows us to personalise the information you see on our Site for you; and
  • Third-Party Cookies: Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes: Monitor user preferences to tailor advertisements around their interests.


This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.


If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority.

Contact Information

If you have any questions, concerns or complaints, you can contact our privacy officer, Theodore Whittington, at: