Legal

Privacy Policy

FACTA·Version 1.1 - January 2026

This Privacy Policy explains how CARLOS MATIAS BAGLIERI LTD, trading as FACTA, collects, uses, stores, and protects your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

DATA CONTROLLER

The data controller responsible for your personal data is:

CARLOS MATIAS BAGLIERI LTD

Trading as (t/a): FACTA

Company Number: 14267762

Address: 20-22 Wenlock Road, London, England, N1 7GU

Email: [email protected]

Website: https://facta.dev

INFORMATION WE COLLECT

2.1Information You Provide

We collect personal data that you voluntarily provide when:

•Contacting us via our website, email, or other channels
•Engaging our consulting services
•Signing contracts or statements of work
•Participating in meetings, calls, or workshops

2.1aThis may include

•Name and job title
•Business email address and phone number
•Company name and address
•Payment and billing information
•Project-related communications and documentation

2.2Information Collected Automatically

When you visit our website, we may automatically collect:

•IP address and browser type
•Device information and operating system
•Pages visited and time spent on site
•Referring website or source

2.3Client Data

In the course of providing our services, we may process data provided by our clients. Such data is processed on behalf of and under the instructions of the client, who remains the data controller for that data.

Where required, data processing activities will be governed by a separate Data Processing Agreement (DPA).

HOW WE USE YOUR INFORMATION

3.1Legal Bases for Processing

We process your personal data based on one or more of the following legal bases:

•Contract Performance: Processing necessary to perform our contractual obligations or take pre-contractual steps at your request.
•Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our services, marketing, and business development, provided these interests do not override your rights.
•Legal Obligation: Processing necessary to comply with legal or regulatory obligations.
•Consent: Where you have given explicit consent for specific processing activities.

3.2Purposes of Processing

We use your personal data to:

•Provide and deliver our consulting services
•Communicate with you about projects and engagements
•Process payments and manage billing
•Send relevant updates about our services (with consent)
•Improve our website and service offerings
•Comply with legal and regulatory requirements
•Protect our legitimate business interests

DATA SHARING AND DISCLOSURE

4.1Third-Party Service Providers

We may share your data with trusted third-party service providers who assist us in operating our business, including:

•Cloud hosting and infrastructure providers
•Payment processors
•Professional advisors (accountants, lawyers)
•Communication and collaboration tools

4.1aProvider obligations

All third-party providers are contractually bound to protect your data and process it only as instructed by us.

4.2Legal Requirements

We may disclose your personal data if required by law, court order, or governmental authority, or when necessary to protect our rights, property, or safety.

4.3Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you of any such change.

4.4No Sale of Data

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and processed in countries outside the United Kingdom, including transfers to service providers located in the EU and other jurisdictions. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

•Standard Contractual Clauses approved by the UK Information Commissioner's Office (ICO)
•Transfers to countries with adequate data protection laws
•Other lawful transfer mechanisms under UK GDPR

DATA RETENTION

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

•Duration of our business relationship plus six (6) years for contractual and tax records
•Marketing data until you withdraw consent or opt out
•Website analytics data for up to twenty-four (24) months

After the retention period, data is securely deleted or anonymised.

DATA SECURITY

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

•Encryption of data in transit and at rest, where appropriate
•Access controls and authentication mechanisms
•Regular security assessments and updates
•Staff training on data protection
•Incident response procedures

While we take all reasonable precautions, no method of transmission or storage is completely secure. We cannot guarantee absolute security of your data.

YOUR RIGHTS

Under UK GDPR, you have the following rights regarding your personal data:

•Right of Access: Request a copy of the personal data we hold about you.
•Right to Rectification: Request correction of inaccurate or incomplete data.
•Right to Erasure: Request deletion of your data in certain circumstances.
•Right to Restriction: Request limitation of processing in certain circumstances.
•Right to Data Portability: Receive your data in a structured, machine-readable format.
•Right to Object: Object to processing based on legitimate interests or for direct marketing.
•Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing that significantly affect you.

To exercise any of these rights, please contact us at [email protected]. We will respond within one month of receiving your request.

COOKIES AND TRACKING TECHNOLOGIES

Our website may use cookies and similar technologies to enhance your browsing experience. Where required by law, non-essential cookies will only be used with your consent. You can manage cookie preferences through your browser settings. For more information, please refer to our Cookie Policy.

CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be posted on our website with a revised date. We encourage you to review this policy periodically.

COMPLAINTS

If you have concerns about how we handle your personal data, please contact us first at [email protected]. We will work to resolve your concerns.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Website: https://ico.org.uk

Helpline: 0303 123 1113

CONTACT US

For any questions or requests regarding this Privacy Policy or your personal data, please contact: