Friends Reconnected Ltd Enterprise House, Building 52, Wrest Park, Silsoe, Bedfordshire, MK45 4HS Email: friendsreconnecteduk@gmail.com ICO registration reference: ZB039277

Last updated: [DATE]

This Privacy Policy explains how we handle personal data collected through this website, for example when you get in touch, fill in a form, or use our chat feature. It sits alongside three other documents: our Data Protection notice, which covers how we handle information about the person you are asking us to locate; our Cookie Policy, which covers cookies and tracking tools; and our Terms and Conditions, which cover the service itself. Where this policy and those documents overlap, the more specific document applies.

1. Who we are

Friends Reconnected Ltd is the data controller for the personal data described in this policy. We are registered with the Information Commissioner’s Office, reference ZB039277.

2. What we collect

Depending on how you interact with the site, we may collect:

  • Contact form and lead form submissions: your name, email address, phone number, and whatever you write in the message field, including, where relevant, initial details about the person you are hoping to trace.
  • Chat feature: if you use the chat feature on the site, we collect whatever you type into it, in order to respond to you.
  • Direct correspondence: anything you send us by email, phone, or WhatsApp.
  • Payment details, if you pay an invoice through the site. Card details themselves are handled by our payment provider, [PAYMENT PROVIDER NAME], not stored by us directly.

[Confirm with the business: what do the lead forms actually offer, for example a free case assessment, a downloadable guide, or a callback request? The description above assumes general enquiry-style forms; if any form is tied to a specific lead magnet or mailing list signup, this section and section 4 below should say so explicitly.]

3. How we use it

We use this information to:

  • respond to your enquiry and assess whether we can help with your search;
  • carry out a search you have instructed us to do (see our Data Protection notice for how that specific information is handled);
  • take payment for a service you have agreed to;
  • keep records of our correspondence with you.

We do not use information submitted through our forms or chat feature for marketing purposes unless you have separately agreed to that. [Confirm: do any leads get added to an email marketing list, and if so, is that opt-in made clear at the point of form submission? If yes, this line needs updating and a consent mechanism needs to exist on the relevant form.]

4. Our lawful basis for processing

We rely on the following legal bases, depending on the situation:

  • Contract: where you have instructed us to carry out a search, to communicate with you and deliver that service.
  • Legitimate interests: to respond to general enquiries and assess whether we can help, which we consider a reasonable and expected part of running this service.
  • Consent: where you have opted in to anything beyond the above, for example marketing communications, if applicable.

5. Who we share it with

We do not sell personal data. We may share it with:

  • Google, since we use Gmail to receive enquiries sent by email;
  • Meta (WhatsApp), if you contact us via WhatsApp;
  • [PAYMENT PROVIDER NAME], if you make a payment through the site;
  • Amazon Web Services (AWS), which hosts the chat feature and processes messages sent through it. This is hosted in the United States, in Phoenix, Arizona.

Each of these acts as a data processor for the limited purpose of the service they provide. Where a search itself is concerned, see our Data Protection notice, since we do not share search case information electronically at all.

6. International transfers

Some of the third parties listed above, including Google, Meta, and Amazon Web Services, may process data outside the UK. In particular, our chat feature is hosted on a server in the United States, in Phoenix, Arizona, which means any message sent through it is transferred to and stored in the US. Where this happens, it takes place under a recognised legal transfer mechanism, such as the UK-US Data Bridge, the EU-US Data Privacy Framework, or a supplier’s standard contractual clauses. [Confirm that AWS’s UK International Data Transfer Addendum (or equivalent standard contractual clauses) has been accepted for this account, since that is the safeguard this transfer would rely on. This is usually agreed as part of AWS’s own Data Processing Addendum, but it needs to be actively in place rather than assumed.]

7. How long we keep it

We keep website enquiry and form data for as long as reasonably necessary to respond to you and, if you become a client, for the duration of our engagement and a reasonable period afterwards for our records. [Confirm a rough retention period with the business, for example enquiries that don’t convert into a case being deleted after a set number of months.] Search case information itself is handled as described in our Data Protection notice.

8. Security

We take reasonable steps to protect personal data submitted through this website, including using a secure (HTTPS) connection. No method of transmission over the internet is completely secure, but we aim to use commercially reasonable means to protect the information you share with us.

9. Children

This website and our services are not directed at children. You must be at least 18 years old to submit a form, use the chat feature to instruct a search, or otherwise provide us with personal data for the purpose of engaging our services.

10. Your rights

Under data protection law, you have the right to request access to, correction of, erasure of, or restriction of the personal data we hold about you, to object to our processing of it, to request portability of it, and, where the lawful basis is consent, to withdraw that consent at any time.

You can read more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

To exercise any of these rights, or if you have any concerns about how we handle your data, email us at friendsreconnecteduk@gmail.com. If you remain unsatisfied, you also have the right to complain to the Information Commissioner’s Office at ico.org.uk.

11. Changes to this policy

We may update this Privacy Policy from time to time, for example if we start using a new tool or service on the website. Please check back periodically for the latest version.

12. Contact

Friends Reconnected Ltd Enterprise House, Building 52, Wrest Park, Silsoe, Bedfordshire, MK45 4HS Email: friendsreconnecteduk@gmail.com Call: 07561698453