Privacy policy

Who is responsible for your data

The data controller is OFO Ltd, a company registered in England and Wales under company number [COMPANY NUMBER], trading as Freehold Software.

Registered office
[REGISTERED ADDRESS — LINE 1]
[TOWN], [POSTCODE]
United Kingdom

For anything about your personal data, write to privacy@freeholdsoftware.co.uk. For anything else, hello@freeholdsoftware.co.uk.

We are not required to appoint a Data Protection Officer and have not appointed one. Data protection enquiries go to the address above and are answered by a director.

What we collect

When you send an enquiry through the form on this site we collect your name, your company if you give one, your email address, your phone number if you give one, the rough size of your portfolio, and anything you choose to tell us in the message box.

That is the only personal data this website collects. There is no account system, no newsletter, no advertising pixel and no analytics profile.

If you go on to become a client, we hold the contact and billing details needed to run the agreement, plus whatever data sits inside the system we build for you. That data stays yours — we process it on your instructions as your processor, and the terms of that arrangement live in your build agreement, not in this policy.

Why we collect it, and our lawful basis

UK GDPR requires us to name a lawful basis for each purpose, not just describe the purpose. Ours are:

• To reply to your enquiry and follow up about the work. Legitimate interests, Article 6(1)(f). Our interest is responding to someone who has asked us to get in touch, which is plainly within your expectations since you initiated the contact.
• To perform a contract with you, once you are a client. Article 6(1)(b).
• To keep financial records. Legal obligation, Article 6(1)(c) — HMRC requires business records to be kept for six years.

We do not sell data. We do not share it with advertisers. We do not send marketing you have not asked for, and we do not add enquirers to a mailing list.

Who else processes it

We use two suppliers to run this site and deliver your enquiry. Both act as our processors under written data processing terms.

Nothing you submit is written to a database on our side. The form composes an email and sends it — the record of your enquiry is the email in our inbox.

Transfers outside the UK

Your enquiry itself is processed in the EU rather than the United States. We are telling you about the transfer anyway, because both suppliers are US-incorporated companies: storing data in Ireland does not by itself stop a US parent being able to access it, and UK GDPR treats that possibility as a transfer.

Those transfers are covered by each supplier's data processing agreement, which incorporates the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. You can ask us for a copy of the relevant terms at any time.

How long we keep it

• Enquiries that do not become work: 24 months from your last contact with us, then deleted.
• Client records: for as long as the agreement runs, then six years for tax purposes.
• Data inside a system we have built for you: for as long as your agreement runs. On termination it is exported to you and deleted on the schedule set out in that agreement.

Cookies and tracking

This website sets no analytics, advertising or profiling cookies, and stores nothing in your browser local or session storage. That is why you are not seeing a cookie banner — there is nothing non-essential to consent to.

It also loads nothing from anyone else. Every file the page needs — the stylesheet, the one script, the images and the fonts — comes from this domain. Web fonts are the usual exception, because loading them from a font service hands your IP address to that service before you have agreed to anything; ours are served from here instead, specifically so that does not happen.

The one company that unavoidably sees your visit is Cloudflare, because they host the site — serving you this page is something they have to do to deliver it. They are listed as a processor above. Nothing beyond that hosting relationship is shared with anyone.

As things stand our host sets no cookie of any kind. If security features such as bot filtering are switched on later, Cloudflare may set a strictly necessary cookie (for example __cf_bm) to tell automated traffic from real visitors. That kind of cookie is exempt from consent under the Privacy and Electronic Communications Regulations reg. 6(4), because it is required to deliver the service you asked for. It would carry no advertising identifier and we could not read it.

If we ever add traffic measurement it will be a cookieless product that stores no personal data. If that ever changes, this section changes first and a consent banner appears with it.

Your rights

Under UK GDPR you have the right to:

• Be told what we hold about you and get a copy of it (access)
• Have inaccurate data corrected (rectification)
• Have your data deleted (erasure)
• Have us pause processing while a dispute is resolved (restriction)
• Receive your data in a portable, machine-readable format (portability)
• Object to processing carried out under legitimate interests — including any direct marketing, which we would stop immediately and unconditionally
• Withdraw consent at any time, where we have relied on consent
• Not be subject to a decision based solely on automated processing. We do not make any such decisions.

Write to privacy@freeholdsoftware.co.uk. We will respond within one month, which is the statutory deadline, and usually much sooner. There is no charge.

Complaints

If you are not satisfied with how we have handled your data, please tell us first so we have a chance to put it right. You also have the right to complain to the Information Commissioner at any time:

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
Helpline 0303 123 1113 · ico.org.uk

Changes to this policy

If this policy changes materially we will update the date at the top. We do not keep a public archive of previous versions, but we will send you the version that applied at the time on request.