Privacy Policy

1. Introduction and Identity of the Controller

FAVLORA MARKS LTD ("we", "us", "our", or "the Company") is a company registered and incorporated in Scotland under the laws of the United Kingdom. Our registered office is located at 5 South Charlotte Street, Edinburgh, EH2 4AN, Scotland. We operate the website at favloramarks.co and provide services in the fields of software publishing, computer systems design, media streaming distribution, social network and content platform development, digital design, mobile application development, and cloud infrastructure.

This Privacy Policy explains how we collect, use, store, share, and protect personal data relating to visitors to our website, prospective clients, current clients, business partners, suppliers, and any other individuals whose personal data we process in the course of our business activities. It has been prepared in accordance with the United Kingdom General Data Protection Regulation (UK GDPR) as retained in UK domestic law by the European Union (Withdrawal) Act 2018, and the Data Protection Act 2018.

For the purposes of UK GDPR, FAVLORA MARKS LTD is the Data Controller in respect of the personal data described in this policy. You may contact our data handling team at it@favloramarks.co or by writing to us at our registered office address above.

2. Scope of This Policy

This Privacy Policy applies to all personal data collected by FAVLORA MARKS LTD through the following channels and activities:

• Visits to our website at favloramarks.co, including all subpages and landing pages operated by us;
• Submission of enquiry, contact, or fitting request forms on our website;
• Direct communications by email, telephone, or postal correspondence;
• Pre-contractual negotiations and client onboarding procedures;
• Execution and performance of client service agreements;
• Supplier and contractor relationship management;
• Recruitment and employment activities to the extent applicable;
• Attendance at events, conferences, or meetings where we are represented;
• Any other context in which we obtain personal data about you in connection with our business.

This policy does not apply to third-party websites or services that may be linked from our website. We are not responsible for the privacy practices of those third parties and encourage you to review their policies independently.

3. Categories of Personal Data We Collect

We collect and process several categories of personal data depending on the nature of your interaction with us. The categories include:

3.1 Identity and Contact Data

This includes your first and last name, job title, company or organisation name, business email address, personal email address, telephone number, postal address, and any other identifying information you provide to us voluntarily in the course of an enquiry or engagement.

3.2 Communication Data

Records of correspondence between you and us by email, telephone, or other means, including the content of fitting request submissions, project briefs, meeting notes, and follow-up communications. We retain these records to manage our client relationships and maintain an accurate record of agreed requirements and commitments.

3.3 Technical and Usage Data

When you visit our website, we may automatically collect certain technical information about your device and browsing behaviour, including your IP address (in truncated or pseudonymised form where feasible), browser type and version, operating system, referring website URL, pages visited on our site, time and duration of visits, and device identifiers. This data is collected through cookies and similar technologies, as described in our Cookie Policy.

3.4 Contractual and Commercial Data

In the course of providing services to clients, we process commercial data relating to the engagement, including project scope documentation, technical specifications, invoicing information, payment records, and correspondence relevant to the service agreement. Where this data relates to an identified individual, it constitutes personal data for the purposes of UK GDPR.

3.5 Professional and Background Data

For certain engagements, we may collect professional background information relevant to the service, including publicly available profile information, professional credentials, or technical capability information where relevant to the project. We do not collect this type of data unless it is necessary for the purpose of the engagement.

4. How We Collect Personal Data

We collect personal data through the following mechanisms:

• Direct submission: When you complete a contact or fitting request form on our website, send us an email, call our office, or otherwise communicate with us directly;
• Automated technical collection: Through cookies, web analytics tools, and server logs when you visit our website (subject to your consent preferences where required);
• Third-party referral: Where a mutual business contact introduces you to us, we may receive your name and contact details from that third party;
• Publicly available sources: We may collect contact or professional information from publicly available business directories, professional networking platforms, or company registries where relevant to a potential service engagement;
• Contract execution: During the course of an active client engagement, we collect data necessary to deliver the agreed services and manage the commercial relationship.

5. Legal Bases for Processing

Under UK GDPR, we are required to identify a valid legal basis for each processing activity. We rely on the following legal bases:

5.1 Performance of a Contract

Where you have entered into or are taking steps to enter into a service agreement with us, we process personal data that is necessary to perform our obligations under that agreement, including delivering the agreed services, managing project communication, and administering billing and payment.

5.2 Legitimate Interests

We process certain personal data on the basis of our legitimate business interests, where those interests are not overridden by your rights and interests. Our legitimate interests include: responding to business enquiries and fitting requests; managing and developing our client relationships; operating and improving our website; maintaining accurate business records; protecting our legal rights and assets; and communicating with existing clients and contacts about service updates, where they have a reasonable expectation of such communication. We conduct a proportionality assessment for each legitimate interest processing activity.

5.3 Legal Obligation

We process personal data where we are required to do so to comply with a legal obligation, including tax and accounting requirements under UK law, Companies House filing obligations, and any other statutory duty imposed on us as a registered UK company.

5.4 Consent

Where we rely on your consent, for example in relation to the placement of non-essential cookies on your device, we will obtain that consent in a clear and specific manner and provide you with the ability to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6. Purposes for Which We Use Personal Data

We use personal data for the following specific purposes:

• Responding to fitting requests, enquiries, and contact form submissions;
• Providing, managing, and improving our services to clients;
• Managing pre-contractual negotiations and preparing service proposals;
• Invoicing and administering payments and financial records;
• Communicating with you about project status, scope adjustments, and delivery milestones;
• Maintaining accurate records of client requirements and agreed adjustments;
• Analysing website usage to improve the performance and usability of our site;
• Complying with legal and regulatory obligations applicable to our business;
• Protecting our legal rights and defending against claims;
• Conducting background checks or verification as required for specific engagements;
• Managing our supplier and contractor relationships.

7. Disclosure of Personal Data to Third Parties

We do not sell personal data to third parties. We may share your personal data in the following circumstances:

7.1 Service Providers and Data Processors

We engage third-party service providers who process personal data on our behalf in the capacity of data processors. These include cloud hosting and infrastructure providers, email and communication services, website analytics providers, accounting and financial management software, and project management tools. We require all processors to operate under a data processing agreement that imposes appropriate security and confidentiality obligations consistent with UK GDPR requirements.

7.2 Professional Advisers

We may share personal data with our legal advisers, accountants, auditors, and insurers where necessary for the provision of their professional services to us, subject to applicable professional confidentiality obligations.

7.3 Legal and Regulatory Authorities

We may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other public authorities where we are legally required or compelled to do so, or where we determine in good faith that such disclosure is necessary to protect our legal rights, comply with legal process, or prevent harm.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, personal data held by us may be transferred to the acquiring entity as part of that transaction, subject to appropriate safeguards and notification to affected individuals where required.

8. International Transfers of Personal Data

FAVLORA MARKS LTD is based in Scotland, United Kingdom. In the course of our service delivery, personal data may be processed by our third-party service providers in countries outside the United Kingdom. Where such transfers occur, we ensure that appropriate safeguards are in place in accordance with UK GDPR Chapter V, including the use of standard contractual clauses approved by the UK Information Commissioner's Office, adequacy decisions, or other lawful transfer mechanisms. We do not transfer personal data to countries without an adequate level of protection unless appropriate safeguards are in place.

9. Retention of Personal Data

We retain personal data for as long as is necessary to fulfil the purposes described in this policy and to comply with our legal obligations. Our standard retention periods are as follows:

• Client engagement records and contractual documents: six years from the completion of the engagement, in accordance with the UK Limitation Act 1980 and tax record-keeping requirements;
• Pre-sales enquiry and fitting request data: two years from the date of the enquiry where no engagement proceeds, or from the date of last contact;
• Financial and accounting records: six years from the end of the relevant financial year, as required under UK tax legislation;
• Website technical and analytics data: up to thirteen months depending on the specific tool and configuration, after which it is aggregated or deleted;
• Email and communication records relating to an engagement: retained for the duration of the engagement plus six years;
• Cookie and consent records: up to three years to demonstrate compliance.

At the end of the applicable retention period, personal data is securely deleted or anonymised. Where data cannot be immediately deleted due to system limitations, it is restricted from active use until deletion is completed.

10. Security of Personal Data

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, where appropriate: encryption of data in transit and at rest; access controls and authentication requirements for systems containing personal data; regular security assessments and testing of our infrastructure; staff training on data protection obligations; incident response procedures; and contractual security requirements imposed on our third-party processors.

Despite these measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but will notify you and the relevant supervisory authority in the event of a data breach that is likely to result in a risk to your rights and freedoms, as required by UK GDPR Article 33 and 34.

11. Your Rights Under UK GDPR

Subject to the conditions and exceptions set out in UK GDPR, you have the following rights in relation to personal data we hold about you:

• Right of access: You have the right to request a copy of the personal data we hold about you and information about how we process it (a "subject access request");
• Right to rectification: You have the right to request that we correct inaccurate or incomplete personal data we hold about you;
• Right to erasure: In certain circumstances, you have the right to request that we delete personal data we hold about you, subject to exceptions where retention is required for legal compliance or legitimate business purposes;
• Right to restrict processing: In certain circumstances, you have the right to request that we restrict the processing of your personal data;
• Right to data portability: Where processing is based on consent or the performance of a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format;
• Right to object: You have the right to object to processing based on our legitimate interests, and to object to processing for direct marketing purposes;
• Rights in relation to automated decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on you. We do not currently engage in automated decision-making of this nature.

To exercise any of these rights, please contact us at it@favloramarks.co or write to us at our registered office. We will respond to your request within one calendar month, or notify you if an extension is required. We may need to verify your identity before processing certain requests. There is no charge for exercising your rights, except in cases of manifestly unfounded or excessive requests.

12. Right to Complain to the Supervisory Authority

If you have concerns about how we handle your personal data and are not satisfied with our response to a complaint you have raised with us, 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: ico.org.uk. We would, however, appreciate the opportunity to address your concern directly before you contact the ICO.

13. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit a website. We use both strictly necessary cookies (which do not require your consent) and optional cookies (which require your consent before being set). For full information about the cookies we use, their purposes, and how to manage your preferences, please refer to our Cookie Policy, available at cookie-policy.html.

14. Children's Privacy

Our website and services are directed at business professionals and organisations. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take prompt steps to delete it. If you believe we have collected personal data from a child, please contact us at it@favloramarks.co.

15. Links to Third-Party Websites

Our website may contain links to third-party websites, services, or resources. These links are provided for convenience and information purposes only. We do not endorse, control, or accept responsibility for the privacy practices or content of any third-party site. We encourage you to read the privacy policy of any website you visit through a link on our site.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data processing activities, legal requirements, or business practices. When we make material changes, we will update the "Last updated" date at the top of this document and, where appropriate, notify affected individuals by email or by a prominent notice on our website. Continued use of our website or services following such notification constitutes acceptance of the updated policy.

We recommend reviewing this policy periodically to stay informed about how we protect your information. The most current version will always be available at favloramarks.co/privacy-policy.html.

17. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our data processing activities, please contact us using the following details:

FAVLORA MARKS LTD
5 South Charlotte Street
Edinburgh, EH2 4AN
Scotland, United Kingdom
Email: it@favloramarks.co
Telephone: +44 7890 112233

We are committed to addressing your concerns promptly and transparently. All data protection enquiries are handled by our designated data handling team.