SE COMMERCIAL SERVICES
Privacy Policy
How we collect, use and protect personal information.
1. Who we are and how to contact us
SE Commercial Services is a partnership operated by Steven Reid and Emma Maginn. We provide commercial, industrial and specialist cleaning services.
SE Commercial Services is the controller responsible for the personal information covered by this notice.
Postal address: Merchant City Tower, 4 Bell Street, Glasgow, G1 4LG
Email: info@secommercialservices.co.uk
Telephone: 0141 463 6689
Emma Maginn manages privacy requests and complaints. Please use these details and mark your message “Privacy”.
This notice explains how we use personal information when you visit our website, contact us, request a quotation or deal with us as a customer or a contact at another business. This notice also explains initial job enquiries and applications received through Indeed or email. Detailed employee information, employment checks and any sensitive recruitment processing require separate privacy information where applicable.
Last updated: 28 October 2026.
2. Information we collect
Depending on your interaction with us, we collect:
- Contact details: your name, work email address, telephone number, company or organisation, job role if supplied, and correspondence.
- Enquiry and quotation details: your premises address or postcode, the service requested, preferred dates, site requirements and information you choose to include in a message.
- Customer and service records: proposals, contracts, relevant site contacts, access arrangements, service communications, feedback, complaints and records needed to manage the work.
- Billing information: billing names and addresses, invoices, transaction references and payment/accounting records relevant to our services.
- Recruitment information: your CV, contact details, work history, qualifications and application correspondence when you apply through Indeed or email. We do not routinely download unsuccessful applicants’ CVs from Indeed into a separate CV database. Applications remain on Indeed, while emailed CVs and recruitment messages are held in Microsoft 365.
- Marketing preferences: whether and how you agreed to receive marketing, the wording you were shown, the date and source of your choice, and any withdrawal or objection.
- Website and security information: IP address, browser and device information, requested pages, dates and times, cookie preferences and information used to detect spam, abuse or security incidents. The information collected depends on the website services used and your settings.
Our contact form marks the information needed to handle the enquiry. Company, telephone and premises-postcode fields are optional. Without sufficient contact information or details of your enquiry, we may be unable to respond or provide a useful quotation.
Please avoid sending health information, patient or student records, criminal-record information, passwords or other unnecessary sensitive information through the general enquiry form. If your project requires sensitive information, contact us first so that suitable arrangements can be agreed.
3. Where information comes from
We usually collect information directly from you through our website, email, telephone conversations, meetings, site visits and our dealings with you.
We may receive your business contact details from a colleague, your employer or a contractor involved in the service, for example when you are nominated as the premises contact. We use those details for the relevant business purpose and provide privacy information as required.
For recruitment, we receive applications directly by email and through Indeed. Indeed also uses information under its own privacy notice: https://uk.indeed.com/legal/privacy.
Technical information is collected when your device connects to our website and the services used to deliver, measure and protect it.
4. Why we use information and our lawful bases
We use the appropriate lawful basis for each purpose; we do not rely on a single blanket consent to everything.
| Purpose | Lawful basis |
|---|---|
| Responding to a request for a quotation or taking steps at your request towards a contract with you personally | Contract: necessary pre-contractual steps |
| Providing and administering a contract with you personally | Contract: performance of that contract |
| Handling general enquiries, communicating with contacts at customer organisations, arranging site surveys, preparing business quotations and managing services for organisations | Legitimate interests in responding to business requests, operating our cleaning business and delivering services effectively |
| Managing billing, service records and ordinary business administration | Contract where necessary for a contract with you personally; otherwise legitimate interests in administering our business |
| Keeping records that tax, accounting or other legislation requires | Legal obligation |
| Dealing with complaints, payment disputes, insurance matters and legal claims | Legitimate interests in resolving concerns and establishing, exercising or defending rights; legal obligation where a specific duty applies |
| Protecting the website and our systems, preventing abuse and detecting security incidents | Legitimate interests in keeping our services secure and protecting users and the business; legal obligation where applicable |
| Reviewing job applications, communicating with candidates and organising recruitment | Legitimate interests in recruiting suitable staff; necessary pre-contractual steps where applicable to an applicant’s request. Any additional employment checks or sensitive information require the appropriate further basis and privacy information |
| Sending the email marketing you choose to receive through our website opt-in | Consent |
| Using optional analytics, advertising or similar tracking where consent is required or is the basis we have chosen | Consent |
Where we rely on legitimate interests, we must consider whether using the information is necessary and balance our interests against your rights and reasonable expectations.
You can ask us for information about the basis for a particular use of your information.
5. Enquiry contact and optional marketing
When you ask us to respond to an enquiry, we use your details to deal with that request. This is separate from choosing to receive marketing.
The website’s email-marketing box is optional and starts unticked. Leaving it unticked does not prevent you from making an enquiry or receiving a response.
If you opt in, we use your email address to send occasional information about SE Commercial Services’ services, company news and offers. Emma Maginn manages email marketing, subscription preferences and unsubscribe requests through HubSpot. We keep a record of the choice you made so that we can evidence the permission relied on.
You can withdraw your consent or object to direct marketing at any time. Email info@secommercialservices.co.uk or use the unsubscribe facility in a marketing email. Withdrawing consent does not affect processing that was lawful before withdrawal.
We will not treat a request for a quotation, provision of a telephone number or acceptance of a privacy notice as permission for unrelated email, telephone or text marketing.
We may retain the minimum information needed to record an opt-out and avoid contacting you again for marketing. An opt-out does not prevent necessary, non-marketing communications about an enquiry, contract or service.
6. Who receives information
Internal access to enquiry, customer and related business systems is restricted to management. Our website is managed by SE management; we no longer use an external web agency. Service providers may still process information as needed to provide their services.
We use service providers to help operate the business, including:
- Microsoft 365 for email, documents and business communications;
- HubSpot for enquiry and customer relationship management;
- Intuit QuickBooks for accounting, invoicing and related financial records;
- Onyx / Krystal Hosting for website hosting, with relevant technical and backup providers where needed;
- Indeed for recruitment applications and employer communications;
- Optimole for website image and asset delivery;
- Google services, including website measurement and reCAPTCHA spam protection, where used;
- website security providers, including Wordfence, where their services process relevant technical or security information.
We occasionally share the necessary customer contact or site information with a subcontractor or supplier to deliver the service. Information should be limited to what that organisation needs for the agreed work.
We may also share necessary information with an accountant, insurer, legal adviser or other professional adviser involved in a relevant matter, and with public authorities where required or permitted by law.
The information shared depends on the purpose. A website-delivery provider does not need the same information as our accounting provider. Some suppliers process data on our instructions; others may act as controllers for particular activities under their own terms.
7. International processing and transfers
Our cloud, recruitment and website services can involve processing outside the UK, including in the United States and other countries in which the providers and their service providers operate. Using a UK business address or a Microsoft 365 account does not mean all processing remains within the UK.
The safeguards relevant to a transfer depend on the provider, the service and the destination. They may include applicable UK adequacy regulations or contractual safeguards, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. Microsoft and HubSpot describe their international-processing arrangements in their published data-protection terms; Intuit and Indeed also explain their international processing in their privacy and service information.
For information about the international processing relevant to your information, the safeguards relied on and how to obtain a copy or further details, contact info@secommercialservices.co.uk. Your use of the website is not treated as consent to international transfers.
Provider information: Microsoft, HubSpot, Intuit and Indeed.
8. Cookies, website measurement and spam protection
Our website uses technologies to deliver pages and images, remember preferences and help protect the website and contact forms. These services can receive technical information such as your IP address, browser/device details and the pages requested.
The services used include:
- Google Analytics 4 and Google tagging: website measurement and measurement-related configuration. The website also contains legacy Analytics and Google Ads tag references. These references alone do not show that an advertising campaign or remarketing audience is active.
- Google reCAPTCHA: spam and automated-abuse protection. Google explains its processing at https://policies.google.com/privacy.
- Optimole: delivery and optimisation of website images and assets.
- Complianz: management of cookie preferences. The consent-preference expiry is configured at up to 365 days; this is not the lifetime of every cookie on the website.
- Website hosting and security services: delivery of requested content, security logging and protection against misuse.
Open Manage consent on the website to accept or deny optional categories and review Statistics and Marketing preferences. You can return to these controls to change your choice. Browser controls also allow you to manage stored cookies, although blocking technologies needed for a requested feature can affect that feature.
Website cookie preferences are separate from the contact form’s email-marketing opt-in. Refusing optional website tracking does not opt you out of a marketing subscription, and accepting website cookies does not subscribe you to marketing emails.
Some services, including reCAPTCHA and the current Google tagging configuration, can load independently of the optional categories. A denied storage setting should not be interpreted as a guarantee that no technical information is transmitted. Contact us if you would like further information about the services or a particular technology used on the website.
9. How long we keep information
Our retention approach applies across the systems in which the relevant information is held, including Microsoft 365 and HubSpot. We review information against the following purposes and criteria:
| Information | Retention approach |
|---|---|
| Closed enquiries and unsuccessful quotations | Review 12 months after the last substantive contact and delete or anonymise when there is no continuing reason to retain them. An active tender or specific dispute may justify longer retention. |
| Core customer contract and service records | Keep for the customer relationship, followed by a normally six-year archive of necessary core records, subject to applicable legal, insurance and contractual requirements and whether particular personal information is still needed. Incidental data need not be retained for the full archive period. |
| Tax, accounting and VAT records | Keep for the applicable statutory periods, with the accountant overseeing financial record keeping. In general, self-employed tax records are kept for at least five years after the relevant 31 January filing deadline, and VAT records for at least six years; specific circumstances can require longer. |
| Marketing subscriptions | Keep while the subscription remains relevant and valid; review inactive subscriptions at least annually and stop marketing on withdrawal or objection. |
| Consent and opt-out evidence | Keep the evidence needed while relying on consent and for a justified period afterwards. Retain minimal suppression information for as long as needed to respect an opt-out, subject to review. Suppression information is not used for promotion. |
| Routine security/server logs | Use a 90-day routine review/deletion target, subject to the actual supplier settings and a documented need to retain incident records longer. |
| Unsuccessful job applications | Review our access and any email correspondence when recruitment ends, retaining only information needed for recruitment follow-up, queries or potential claims. We do not routinely download unsuccessful CVs from Indeed. Indeed’s own retention is governed by its services and privacy terms; our own access and email copies still require review and deletion when no longer needed. |
| Analytics and backups | Retention depends on the service and purpose: the period needed to analyse relevant website use or restore systems after an incident, the provider’s retention/expiry arrangements, and any specific security or legal reason to retain information. Contact us for information about the arrangements relevant to a particular record. |
We retain relevant records longer where a law, dispute or investigation requires this and limit further use appropriately. Where a record is deleted from an active system, backup copies may remain until their scheduled expiry and must not be reintroduced into routine use without accounting for the deletion.
10. How we protect information
We use measures appropriate to the information and risks involved, including secure website connections, multi-factor authentication, access controls and website security tools. Internal access to the relevant systems, enquiries and backups is restricted to management.
No website or electronic communication method is entirely risk-free. If you believe information has been sent to the wrong person or there is a security concern, contact us promptly.
11. Your rights
Depending on the circumstances and the lawful basis used, you can:
- ask for access to your personal information;
- ask us to correct inaccurate or incomplete information;
- ask us to erase information where the right applies;
- ask us to restrict processing in the circumstances provided by law;
- object to processing based on legitimate interests;
- receive certain information in a portable format where the legal conditions apply; and
- withdraw consent where we rely on it.
Your right to object to direct marketing is absolute. You do not have to give a reason.
These rights are not all available for every type of record or purpose. For example, we may need to retain certain financial records to meet legal requirements even if you request deletion.
Contact us using the details in section 1. We may ask for proportionate information to verify your identity or clarify your request. Requests are normally free, and we respond without undue delay and usually within one month, subject to lawful extensions or other applicable rules. If a request cannot be met in full, we explain why and the options available to you.
12. Complaints
If you are concerned about how we use your information, contact us by email, post or telephone using the details in section 1. Please explain the concern and how we can contact you.
Our complaints process is to acknowledge a data protection complaint within the applicable 30-day acknowledgement period, take appropriate steps to investigate, keep you informed and provide an outcome without undue delay. A complaint and a separate information-rights request may have different response deadlines.
You can also raise a concern with the Information Commissioner’s Office (ICO):
Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113
Contacting us does not remove your right to complain to the ICO.
13. Changes and other websites
We review this notice when our services or use of personal information changes. We update the date above and provide additional notice where required.
Other organisations’ websites have their own privacy information. The services loaded within our website are described in this notice; you can also consult the relevant provider’s information or contact us with questions.
