Cookie Policy

Cookie Policy – As of 14.09.2026

Who we are

The data controller responsible in accordance with the purposes of the UK General Data Protection Regulation (UK GDPR) and other applicable data protection regulations is:

SM92 Agency LTD
Patten House, Moulders Lane
Warrington, WA1 2BA
United Kingdom

Telephone: 01244 617375
Email: Justin@sm92.com
Website: https://sm92.com/

How to contact the data protection officer

The designated data protection officer is:

DataCo International UK Limited
Suite 1, 3rd Floor
11–12 St James’s Square
London
SW1Y 4LB
United Kingdom

Telephone: +44 20 3514 6557
Email: privacy@dataguard.co.uk

Use of cookies

  1. Description and scope of data processing

When you visit our website, we use technical tools for various functions, in particular cookies, which may be stored on your device.

Cookies are text files or information stored in a database which are assigned to the browser you are using so that certain information can be passed to the entity that places the cookie.

When you visit our website for the first time, and at any time afterwards, you have the choice as to whether you generally permit the setting of non-essential cookies or which individual categories and functions you would like to permit.

You can make changes to your preferences through our cookie consent manager and, where applicable, through your browser settings.

We use both essential and non-essential cookies on our website.

Essential cookies

Essential cookies are required for the technical operation and functionality of the website.

Without these cookies, our website may not be displayed correctly or certain functionality may not be available.

The following types of information may be stored and transmitted through essential cookies:

  • Language settings
  • Cookie consent preferences
  • Frequency of page views
  • Use of website functionalities
  • Technical and security information necessary for the operation of the website

Essential cookies may also be used by our consent management provider to record whether you have accepted or rejected particular categories of cookies.

Non-essential cookies

We also use cookies which are classed as non-essential.

Non-essential cookies are used for purposes beyond the basic technical operation of the website.

Depending on the services and technologies used on the website, the following information may be processed through non-essential cookies:

  • IP address
  • Internet user location
  • Date and time of the website request
  • Browser and device information
  • Operating system
  • Pages visited
  • Interactions with website content
  • Advertising impressions and clicks
  • Customisation of advertisements
  • Tracking of browsing behaviour
  • Referral information
  • Linking website visits with advertising or social media platforms
  • Pseudonymised user identifiers

Non-essential cookies will only be placed where the required consent has been provided.

Purpose of data processing

Essential cookies

The purpose of using essential cookies is to ensure the functionality, security and technical operation of our website.

Some functions of our website cannot be offered without the use of cookies.

Essential cookies may be required for purposes including:

  • Website functionality
  • Storage of language settings
  • Security
  • Consent management
  • Prevention of misuse
  • Delivery of website content

Non-essential cookies

Non-essential cookies are used for purposes including improving the quality of our website, analysing how the website is used, improving our content and services, measuring marketing effectiveness and increasing the relevance of advertising.

We may use non-essential cookies to:

  • analyse website usage;
  • improve website performance;
  • understand visitor behaviour;
  • measure conversions;
  • analyse advertising campaigns;
  • personalise advertising;
  • deliver relevant advertising on this website and other platforms;
  • support social media functionality;
  • provide embedded content; and
  • improve the overall user experience.

Legal basis for data processing

The legal basis for the processing of personal data using non-essential cookies is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

The legal basis for the processing of personal data using essential cookies is Art. 6 (1) (f) UK GDPR, based on our legitimate interest in ensuring the technically correct, secure and functional operation of our website.

Where particular technologies are required in order to provide a service specifically requested by the user, they may also be used where permitted under applicable electronic communications legislation.

Categories of cookies and technologies used

Depending on the features currently active on our website, we may use the following categories of cookies and similar technologies.

Necessary and consent management

These technologies help operate the website and store your consent preferences.

We use:

Cookiebot
Provided by Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark.

Cookiebot is used to collect, manage and document consent regarding the use of cookies and other tracking technologies.

Cookiebot may process:

  • An anonymised version of the user’s IP address
  • Date and time of consent
  • Browser information
  • The URL on which consent was provided
  • An anonymous and encrypted key
  • Consent status

Cookiebot may store the user’s consent status in the cookie CookieConsent for up to 12 months.

The legal basis for processing is Art. 6 (1) (f) UK GDPR. Our legitimate interest lies in documenting and managing cookie consent in accordance with applicable legal requirements.

Analytics and performance technologies

We use analytics services to understand how visitors use our website and to improve our online presence.

Google Analytics 4

We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics examines how visitors use our website.

Information processed may include:

  • First visit to the website
  • Website interactions
  • Usage paths
  • External link clicks
  • Video usage
  • File downloads
  • Advertising impressions and clicks
  • Scroll behaviour
  • Searches on the website
  • Language selection
  • Page visits
  • Approximate location
  • IP address in shortened form
  • Browser and device information
  • Internet service provider
  • Referrer URL

We may use Google Analytics functionality including User ID and Google Signals, where enabled.

Google Analytics is used to evaluate use of our website and generate reports about website activity and performance.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Hotjar

We use the web analysis service Hotjar provided by Hotjar Ltd, Level 2, St Julian’s Business Centre, 3 Elia Zammit Street, St Julian’s STJ 1000, Malta.

Hotjar may process information relating to:

  • Pages visited
  • Elements clicked
  • User activity
  • Device and browser information
  • IP address
  • Operating system
  • Pseudonymised tracking identifiers

Hotjar is used to better understand how visitors use our website and to improve usability and user experience.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

WP Statistics

We may use the WP Statistics web analytics service provided by Verona Labs, Tornimäe 5, 10145 Tallinn, Estonia.

WP Statistics may process information relating to website usage, browser and device details and anonymised IP information.

The service is used to improve the usability and performance of our website.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Advertising and marketing technologies

We use marketing and advertising technologies to understand the effectiveness of our campaigns and, where applicable, to deliver advertising that is more relevant to users.

Google Ads

We use Google Ads provided by Google LLC and Google Ireland Limited.

Google Ads may process:

  • User activity
  • Pages visited
  • Elements clicked
  • Device and browser information
  • IP address
  • Operating system
  • Advertisements viewed
  • Advertisements clicked
  • Pseudonymised user identifiers

Google Ads is used to measure advertising performance and conversions.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Google Ads Remarketing

We use Google Ads Remarketing to address previous website visitors with relevant advertising.

Google may place cookies on the user’s device in order to recognise previous visits and display advertisements based on those visits.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Google Marketing Platform

We may use Google Marketing Platform to manage, measure and optimise advertising campaigns.

This service may process user activity, advertising interactions, device information, browser information, IP addresses and pseudonymous advertising identifiers.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Meta Pixel

We use the Meta Pixel provided by Meta Platforms Ireland Ltd., Merrion Road, Dublin 4, D04 X2K5, Ireland.

The Meta Pixel allows us to track actions taken by users after they have viewed or clicked on Meta advertising.

Information processed may include:

  • Website activity
  • Pages visited
  • Elements clicked
  • Device and browser information
  • IP address
  • Operating system
  • Advertising interactions
  • Pseudonymised identifiers

We use Meta Pixel to analyse and optimise advertising measures.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Facebook / Meta Retargeting

We may use Meta retargeting functionality to deliver advertising to users who have previously interacted with our website.

The service may process website activity, pages viewed, advertisements clicked, device information and IP address.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Microsoft Advertising / Bing Ads

We use Microsoft Advertising, including Bing Ads conversion tracking, provided by Microsoft Corporation.

Microsoft may process:

  • IP address
  • Device and browser information
  • User identifiers assigned by Microsoft
  • Referrer URL
  • Advertisements viewed or clicked
  • Website interactions

Microsoft Advertising is used to measure and optimise advertising campaigns and conversions.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

LinkedIn Analytics

We may use LinkedIn Analytics provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland.

LinkedIn may process:

  • Operating system information
  • Device ID
  • Internet service provider
  • IP address
  • Referrer URL
  • Browser information

LinkedIn Analytics is used to analyse website and advertising performance and understand browsing behaviour.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Twitter Analytics

We may use Twitter Analytics to analyse interaction with our content and advertising on Twitter/X.

Information processed may include:

  • IP address
  • Browser type
  • Referral and exit pages
  • Operating system
  • Date and time of access
  • Clickstream information
  • Views
  • Clicks
  • Account-related information

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Marketing and customer relationship technologies

HubSpot

We use functions provided by HubSpot Inc., 2nd Floor, 25 First Street, Cambridge, MA 02141, USA.

HubSpot provides functionality including:

  • Email marketing
  • Automated communications
  • Social media publishing
  • Reporting
  • Traffic analysis
  • Contact management
  • CRM functionality
  • Landing pages
  • Contact forms

HubSpot may process user activity, device and browser information, IP addresses, advertising interactions and pseudonymous identifiers.

HubSpot is used for the optimisation of our marketing activities.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

ActiveCampaign

We may use ActiveCampaign, a customer experience automation platform provided by ActiveCampaign, LLC.

ActiveCampaign may process subscriber activity, including email opens, clicks and interactions, together with device and browser information.

The service is used for email marketing, marketing automation, customer relationship management and communications.

The legal basis for processing is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Embedded content and third-party functionality

Our website may integrate third-party services which can place cookies or process personal data when the relevant content or functionality is used.

These services may include:

  • YouTube
  • Vimeo
  • Google Maps
  • OpenStreetMap
  • Instagram
  • LinkedIn
  • Twitter/X
  • Pinterest
  • SoundCloud
  • Tumblr
  • Facebook functionality
  • Google reCAPTCHA
  • Google Forms
  • Google Sign-In
  • Sign in with LinkedIn
  • Log in with Twitter
  • Sign in with Apple
  • AddToAny
  • AddThis
  • Gravity Forms
  • Contact Form 7
  • Unbounce
  • Taboola
  • DocuSign
  • Shutterstock
  • Google Webfonts
  • Adobe Fonts
  • Font Awesome
  • WPML
  • JsDelivr
  • other third-party content or functionality used on the website from time to time

Where the use of these services involves non-essential cookies or similar technologies, they will only be activated where the required consent has been obtained.

Further information about these providers, their purposes, legal bases and data processing activities can be found in our Privacy Policy.

Google Tag Manager

We use Google Tag Manager provided by Google LLC and Google Ireland Limited.

Google Tag Manager is used to manage and deploy tags and third-party services on our website.

Google Tag Manager may trigger other services which themselves collect information.

Information regarding the processing carried out by those services can be found in the relevant sections of this Cookie Policy and our Privacy Policy.

The legal basis for the processing of personal data associated with non-essential tags is the user’s consent in accordance with Art. 6 (1) (a) UK GDPR.

Managing and withdrawing your consent

You can manage your cookie preferences and withdraw consent at any time through the cookie consent tool available on our website.

You can use the consent manager to:

  • Accept cookies
  • Reject non-essential cookies
  • Select individual categories
  • Change previous selections
  • Withdraw consent previously provided

Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before it was withdrawn.

Browser settings

You can also manage cookies through your browser settings.

Depending on the browser you use, you may be able to:

  • Delete stored cookies
  • Prevent cookies from being stored
  • Block third-party cookies
  • Receive notifications before cookies are placed
  • Delete cookies automatically

If you disable certain cookies, some functions of our website may no longer work correctly.

Duration of storage

The duration for which cookies and information collected through cookies are retained varies depending on the individual technology and provider.

Some cookies are deleted when you close your browser, while others remain on your device for a defined period.

Where specific retention periods are known, these are described in our Privacy Policy or in the cookie information displayed through our consent management platform.

Cookiebot consent information may be stored for up to 12 months.

Google Analytics 4 data is currently configured to be deleted after 2 months, as described in our Privacy Policy.

Other third-party providers retain information in accordance with their respective retention policies and legal requirements.

International data transfers

Some service providers used on our website are located outside the United Kingdom or may process personal data outside the United Kingdom.

Where your personal data is transferred outside the UK, we take steps to ensure that it receives an equivalent level of protection.

This may include reliance on:

  • UK adequacy regulations; or
  • appropriate contractual safeguards, including recognised international data transfer mechanisms.

Further information about international transfers can be found in our Privacy Policy.

Exercising your rights

Where personal data is processed through cookies or similar technologies, you may have rights under the UK GDPR, including:

  • Right of access
  • Right to rectification
  • Right to erasure
  • Right to restriction of processing
  • Right to data portability
  • Right to object
  • Right to withdraw consent

Further information on these rights and how to exercise them is available in our Privacy Policy.

Complaints

You have the right to complain to the Information Commissioner’s Office if you are unhappy with how we have used your personal data or believe that the processing of your personal data violates applicable law.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline: 0303 123 1113

Changes to this Cookie Policy

We may update this Cookie Policy from time to time, including where:

  • cookies or technologies used on the website change;
  • new third-party services are introduced;
  • existing services are removed;
  • legal or regulatory requirements change; or
  • our website functionality changes.

The latest version of this Cookie Policy will always be made available on our website.

Further information

For more detailed information about how we process personal data, including information about individual service providers, international transfers and your rights, please refer to our Privacy Policy.

If you have any questions regarding this Cookie Policy, please contact:

SM92 Agency LTD
Email: Justin@sm92.com

or our Data Protection Officer:

DataCo International UK Limited
Email: privacy@dataguard.co.uk