Legal Documentation
Last updated: 1 November 2024 — Effective immediately upon publication
This Privacy Policy sets out the basis on which FAMORENOVO LIMITED ("the Company", "we", "us", or "our") collects, processes, stores and discloses personal data relating to visitors to our website at famorenovolimited.digital ("the Website"), to prospective clients who contact us with enquiries, and to clients with whom we enter into service agreements. We are committed to protecting the privacy and confidentiality of personal information in accordance with the United Kingdom General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 ("DPA 2018"), the Privacy and Electronic Communications Regulations 2003 ("PECR") and any other applicable data protection legislation in force in the United Kingdom.
FAMORENOVO LIMITED is a company registered in England and Wales. Our registered office and principal place of business is at Flat 1 Royal Wells Court, 41 Church Road, Tunbridge Wells, TN1 1JT, United Kingdom. We act as a data controller in respect of the personal data described in this Privacy Policy. Our contact email for data protection enquiries is it@famorenovolimited.digital.
We encourage you to read this Privacy Policy in full before submitting any personal information to us. By using the Website or by corresponding with us, you acknowledge that you have read and understood the contents of this policy.
We collect personal data in several distinct contexts. Each context is described below, along with the categories of personal data typically involved.
When you submit an enquiry through the contact form on our Website, we collect the following categories of personal data: your full name, your email address, your telephone number (if provided), the name of your employing organisation (if provided), your chosen service area (if selected), and the content of the message you submit. We use this information for the sole purpose of responding to your enquiry and, where applicable, initiating a commercial engagement.
When you contact us directly by email or telephone, we collect the personal data you provide in that correspondence. This may include your name, contact details, professional role and the substantive content of the communication. We retain records of this correspondence for the purposes described in Section 4 of this policy.
Where you enter into a service agreement with FAMORENOVO LIMITED, we collect and process personal data in connection with the delivery of those services. This may include personal data contained in: project documentation and specifications, meeting notes and technical briefing records, invoicing and financial records, contractual correspondence, and any other documentation exchanged in the course of the engagement. The precise scope of personal data processed in connection with any particular engagement will depend on the nature of the services provided.
When you access the Website, certain technical data is automatically collected by our web server or third-party analytics tools. This data includes your IP address (in truncated or anonymised form where applicable), the type and version of browser you are using, your operating system, the referring URL, the pages visited and the duration of your visit. This information is collected in aggregate form for the purposes of understanding how the Website is used and improving its performance and content. Please refer to our Cookie Policy for more information about the specific cookies and tracking technologies used on the Website.
Where we engage third-party suppliers, subcontractors or professional services providers in connection with our business operations, we collect and retain personal data relating to key contacts at those organisations, including names, job titles, email addresses and telephone numbers. This data is processed for the purposes of managing those commercial relationships.
We process personal data only where we have a lawful basis for doing so under the UK GDPR. The legal bases upon which we rely are as follows:
Where you have entered into a service agreement with us, or where you have taken steps preliminary to entering into such an agreement (such as requesting a proposal or scoping consultation), we process your personal data as necessary for the performance of that contract or in order to take steps at your request prior to entering into it. This legal basis applies to the processing of client engagement data and to the processing of enquiry data where a commercial engagement follows from the enquiry.
We process certain personal data on the basis that such processing is necessary for the purposes of our legitimate interests, provided that those interests are not overridden by your fundamental rights and freedoms. Our legitimate interests in this context include: operating and maintaining the Website, responding to enquiries from prospective clients, managing ongoing client relationships, maintaining records of commercial interactions for business administration purposes, and improving the services we provide. Where we rely on legitimate interests as our legal basis, we have conducted a legitimate interests assessment confirming that the processing is proportionate and that our interests do not override your rights.
We process personal data where we are required to do so to comply with a legal obligation to which we are subject, including obligations under the Companies Act 2006, HMRC regulations relating to financial record-keeping, and any applicable court orders or regulatory requirements.
Where we rely on consent as a legal basis for processing — for example, in connection with certain non-essential cookies or for direct marketing communications — we will obtain your consent in a clear and specific manner before processing your data for that purpose. You have the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
We use the personal data we collect for the following specific purposes:
We do not use personal data for automated decision-making or profiling in ways that produce legal effects or otherwise significantly affect individuals. We do not use personal data for unsolicited direct marketing purposes except with explicit prior consent. We do not sell, rent or otherwise commercially exploit personal data relating to individuals who have contacted us or engaged our services.
We retain personal data only for as long as necessary for the purposes for which it was collected, subject to any overriding legal or regulatory obligations to retain data for longer periods. Our general retention approach is as follows:
Personal data submitted through enquiry forms or correspondence that does not result in a commercial engagement is retained for a maximum period of twelve months from the date of last interaction, after which it is securely deleted. If an engagement commences following an enquiry, the enquiry data is retained as part of the client file for the period specified in Section 4.2 below.
Personal data processed in connection with client engagements is retained for a period of six years from the termination of the relevant service agreement or the completion of the relevant project, in accordance with the standard limitation period for commercial contract claims under English law. Financial and invoicing records are retained for a period of seven years in accordance with HMRC requirements. Project documentation and technical deliverables may be retained for longer periods where this is necessary to protect the legitimate interests of the Company in connection with potential disputes or professional indemnity claims.
Anonymised website analytics data is retained for a period of up to twenty-six months, in accordance with standard analytics platform data retention periods. IP addresses are anonymised prior to storage where technically feasible.
Personal data relating to supplier and contractor contacts is retained for the duration of the commercial relationship and for a period of three years following its termination.
When personal data is no longer required for the purposes for which it was collected and the applicable retention period has elapsed, it is securely deleted, destroyed or anonymised in accordance with our data disposal procedures.
We do not share personal data with third parties except in the following limited circumstances:
We engage certain third-party service providers who process personal data on our behalf in the course of providing services to us. These providers act as data processors under the UK GDPR and are bound by data processing agreements that require them to process personal data only on our documented instructions, to implement appropriate technical and organisational security measures, and not to engage sub-processors without our prior written consent. Our data processors may include providers of web hosting services, email communication platforms, document management systems and professional accounting software.
We may share personal data with our legal, financial and professional advisers where necessary for the provision of their services, including in connection with the negotiation and execution of contracts, the management of disputes or regulatory matters, and the fulfilment of statutory obligations.
We may disclose personal data to law enforcement authorities, regulatory bodies, courts or other public authorities where we are required to do so by applicable law, court order or regulatory direction, or where disclosure is necessary for the establishment, exercise or defence of legal claims.
In the event that FAMORENOVO LIMITED undergoes a business sale, merger, acquisition, restructuring or insolvency proceeding, personal data may be transferred to the relevant successor entity as part of that transaction, subject to the successor entity agreeing to process personal data in accordance with applicable data protection legislation.
We do not share personal data with commercial partners, advertisers, data brokers or other third parties for marketing or commercial purposes.
FAMORENOVO LIMITED is based in the United Kingdom. We process personal data within the UK and the European Economic Area ("EEA"). Where personal data is transferred to a country outside the UK or the EEA, we ensure that appropriate safeguards are in place in accordance with UK GDPR requirements for international transfers. These safeguards may include the use of standard contractual clauses approved by the UK Information Commissioner's Office ("ICO"), reliance on an adequacy decision in respect of the recipient country, or other appropriate transfer mechanisms.
Where third-party service providers that we engage store or process data in countries outside the UK or EEA, we conduct due diligence to verify that adequate safeguards are in place before transferring personal data to those providers.
We implement and maintain technical and organisational measures appropriate to the nature of the personal data processed and the risks associated with its processing. These measures are designed to protect personal data against accidental or unauthorised access, disclosure, alteration, loss or destruction. Our security measures include, without limitation:
Notwithstanding these measures, we draw your attention to the inherent limitations of electronic communications and internet-based data transmission. We cannot guarantee the absolute security of personal data transmitted to or from the Website or communicated by email. Where a data breach occurs that is likely to result in a risk to the rights and freedoms of individuals, we will notify the ICO within 72 hours of becoming aware of the breach in accordance with our obligations under the UK GDPR, and will notify affected individuals where the breach is likely to result in a high risk to their rights and freedoms.
As a data subject under the UK GDPR, you have the following rights in respect of personal data that we hold about you:
You have the right to request confirmation of whether we process personal data about you and, where we do, to receive a copy of that data together with information about the purposes of the processing, the categories of data processed, the recipients to whom data has been disclosed, the retention period applied and your rights in respect of the data. We will respond to access requests within one calendar month of receipt, and within three calendar months in cases of exceptional complexity or volume.
You have the right to request that we correct personal data held about you that is inaccurate or incomplete. Where we cannot rectify data that forms part of documents created in the course of an engagement, we will annotate the record with a note of the inaccuracy identified.
You have the right to request the deletion of personal data held about you in certain circumstances — including where the data is no longer necessary for the purpose for which it was collected, where you have withdrawn consent upon which processing was based, or where the data has been unlawfully processed. This right is subject to exceptions where we are required to retain data to comply with a legal obligation or for the establishment, exercise or defence of legal claims.
You have the right to request that we restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing pending verification of whether our legitimate grounds override your rights.
Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another controller.
You have the right to object at any time to the processing of personal data about you where that processing is based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you. As noted above, FAMORENOVO LIMITED does not engage in automated decision-making of this nature.
To exercise any of the above rights, please contact us at it@famorenovolimited.digital or in writing to our registered office address. We may need to verify your identity before processing a rights request. We will not charge a fee for responding to rights requests unless a request is manifestly unfounded or excessive.
If you are dissatisfied with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office ("ICO"), the supervisory authority for data protection in the United Kingdom. The ICO can be contacted at:
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113
Website: https://ico.org.uk
We would ask, however, that you contact us in the first instance to allow us the opportunity to address your concern before escalating a complaint to the ICO.
We use cookies and similar tracking technologies on the Website for a variety of purposes, including ensuring the technical functionality of the Website, analysing usage patterns and improving the Website's content and performance. For full details of the cookies we use, the purposes for which they are used and the options available to you in respect of their use, please refer to our Cookie Policy.
The Website may contain hyperlinks to third-party websites and services that are operated independently of FAMORENOVO LIMITED. The inclusion of a link to a third-party website does not constitute an endorsement of that website, its content or the data practices of its operator. We have no control over and accept no responsibility for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party websites you access through links on our Website.
The Website and the services offered by FAMORENOVO LIMITED are directed exclusively to business-to-business clients and professional contacts. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected personal data from a person under the age of 18, we will take prompt steps to delete that data.
We review and update this Privacy Policy periodically to reflect changes in our data processing practices, changes in applicable law, or for other operational or legal reasons. Where we make material changes to this policy, we will publish the updated version on the Website with a revised effective date. We encourage you to review this policy periodically to remain informed of how we handle personal data. Your continued use of the Website following the publication of a revised Privacy Policy constitutes your acknowledgement of the updated terms.
If you have any questions, concerns or requests relating to this Privacy Policy or to our data processing practices, please contact us using the details below:
FAMORENOVO LIMITED
Flat 1 Royal Wells Court
41 Church Road
Tunbridge Wells
TN1 1JT
United Kingdom
Email: it@famorenovolimited.digital
Telephone: +44 7702 248 625
We aim to respond to all data protection enquiries within ten working days of receipt.
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