Privacy Focchi Ltd

General Data Protection Regulation : Privacy Policy

Welcome to Focchi Ltd’s privacy policy. We are committed to maintaining the security and privacy of your data.
This policy outlines the way in which we manage any personal data obtained or otherwise provided by or about individuals (“you”, “your”) in the course of you or your organisation engaging our services as a customer, supplier or a referral partner (our “Services”). It explains:

  • what personal data we collect about you in the course of your engagement with our Services,why we collect it, who it goes to and how long we keep it
  • how we use your personal data
  • how we protect your personal data
  • your legal rights in respect of your personal data, including how to access and update theinformation we hold about you.

Please note that this policy covers the personal data policies of the UK-based Focchi Ltd only. If you have accessed this policy from the website (the “Focchi Spa Website”), please note that this policy has been linked on the Focchi Spa Website for reference and ease of communication only, and does not cover the activities of Focchi Spa or any of Focchi’s other group entities. The personal data policies of Focchi Spa and all personal data collected through the Focchi Spa Website (including in relation to cookies) are governed by the separate Focchi Spa privacy policy here [ for which Focchi Ltd has no responsibility.
You can navigate to the relevant sections of the policy by clicking the links below:

  • About us
  • What information do we collect about you?
  • Why do we collect your personal information and on what grounds?
  • Who do we share your information with?
  • Will my data be sent abroad?
  • How long do you keep my personal data?
  • Your rights in respect of your personal data
  • Security of your data
  • Changes to this policy
  • Contact us

By continuing to engage our Services, you agree to our use of your personal data on the terms outlined in this policy.

About us
For the purposes of applicable data protection laws, Focchi Ltd, a company registered in England and Wales (No. 02997625) with its registered address at Sherlock House, 7 Kenrick Place, London W1U 6HE (“Focchi”, “we”, “us” or “our”) is the controller of your data. This means that we are the primary entity who decides the purposes and means for dealing with your personal data.

What information do we collect about you?
When you engage our Services, we may collect a variety of personal information about you, including:
Personal information we collect directly from you

  • Your business contact information (e.g. name, email, phone number, job title at organisation,affiliated organisation name, delivery address) in order to provide you with the Services andmanage our relationship with you.
  • Your payment information (e.g. bank account details) in order to process any payments for ourServices.
  • If you are a referral partner of Focchi, any personal information you provide us which may bedisclosed in the process of us liaising with potential new customers or providing recommendationsfor you.
  • If you are a visitor to our business premises at Sherlock House, images of you that may be capturedon our CCTV surveillance system. We have strict CCTV policies to to comply with data protectionlaws and you can obtain further information about this by contacting us at the email address below:
  • Any personal information you disclose in your communications and queries to us (e.g. in emailcorrespondence regarding product enquiries).


Information received from other sources

  • Any relevant personal information that you may have submitted to our third party serviceproviders in the course of them providing the Services on our behalf, including for example,business partners and sub-contractors in technical, payment and delivery services.

We will let you know at the point of collecting your information whether this is optional, or whether it is necessary for you to provide this information to meet certain statutory or contractual requirements. If the latter and you do not wish to provide us with this information, this may limit the services we are able to provide you.
If the data we hold about you is inaccurate in any way, please contact us to have your personal information corrected.

Why do we collect your personal information and on what grounds?
We will only use your personal data if we have a permitted lawful basis to do so. Generally we collect your personal data because is it necessary for:
Performing our contract for the Services with you, i.e

  • to sell and supply the Services to you
  • provide customer care services and provide you with the information
  • products or services that you request from us.

The pursuit of our legitimate interests, i.e.

  • for market research and analytical purposes to improve and develop our Services
  • effectively handle any legal claims or regulatory enforcement actions taken against Focchi
  • protect Focchi and our employees/customers by taking appropriate legal action against third partieswho have committed criminal acts or are in breach of legal obligations to Focchi
  • for promoting and marketing our Services.

For complying with our legal obligations, i.e.

  • To help prevent fraudulent activity
  • To comply with our legal and regulatory obligations (including under applicable data protection laws)
  • For preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecutingoffenders, including working with law enforcement agencies
  • To fulfil our duties to our customers, colleagues and other stakeholders.


Who do we share your information with?

We do not sell, trade or rent your personal information to any third parties. However, in order to provide our Services to you we may need to share your information with the following third parties:

  • Our parent company in Italy, Focchi Spa.
  • Our suppliers and contractors where necessary to provide the Services, including our providers ofbanking and accounting services.
  • Any potential or actual third party buyer of our business and/or assets in the event that we sell,trade or licence ownership of any part of the Focchi business or assets
  • Third parties we may be required to disclose such personal data to in order to comply with ourlegal obligations or enforce our legal rights, e.g. any relevant authority or enforcement body andfraud protection and credit risk reduction agencies.


Will my data be sent abroad?
No, we only process your personal data within the EU for the purposes outlined above. If this position changes in the future, we will update this privacy policy with further information about these and the appropriate safeguards in place (as required by applicable data protection laws to ensure a similar degree of protection to your personal data).

How long do you keep my personal data?
We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorised use or disclosure of your
personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.
In particular, we will retain copies of our customer legal contracts, agreements, complaints requests and disputes for 6 years.

Your rights in respect of your personal data
In certain circumstances you have rights under data protection laws in relation to the personal data we hold about you. You can request to:

  • access information held about you.
  • rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal information we hold about you is accurate, complete and current. If the data we holdabout you is inaccurate in any way, please contact us to have your personal information corrected.
  • delete, restrict or remove the data we hold about you.
  • transfer the data we hold about you to another party.
  • object to any further processing of your data.

You can make all such requests via email to


We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:

  • refuse your request based on the exemptions set out in the applicable data protection laws.
  • request for proof of your ID to process the request or request further information
  • charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests

If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision.
If you have any concerns about how we handle your data, please contact us. If you are not satisfied after we’ve tried to resolve your issue, you’ll be entitled to lodge a complaint with the data protection regulator for your country of residence.

Security of your data
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Changes to this policy
We may from time to time review and amend this Privacy Policy to take into account changes in law, technology and our operations. We will post any changes to this Privacy Policy on the Focchi Spa Website from time to time and, where appropriate, notify you by e-mail. All personal information held by us will be governed by the most recent Privacy Policy communicated by us by email or posted on the Focchi Spa Website.

Contact us
If you have any queries relating to this privacy notice (including any requests to exercise your legal rights in respect of your data, you can contact us at

Signed Date 24 April 2020
Raymond P Phillips - Managing Director
Focchi Ltd.