Privacy Policy

Last updated: 15 May 2026

FamoRenovo Ltd. ("FamoRenovo", "we", "us", "our") operates the website famorenovo.com. This Privacy Policy explains what personal information we collect, why we collect it, how it is used, who it may be shared with, and how long we retain it. We are the data controller in respect of personal data processed through this website. Our registered address is

1 Royal Wells Court
Tunbridge Wells
TN1 1JT

. Our ICO registration reference is C1929564.

If you have any questions about this policy or about how we handle your personal data, please contact us at .

1. Who This Policy Covers

This Privacy Policy applies to:

Website visitors who browse famorenovo.com without creating an account;
Eligibility Tool users who use our Client Search Visibility Checker;
Registered users who have created an account on the Website;
Professional Program applicants and approved members; and
Commission clients who have placed a Commission for a Record of Truth.

This policy also describes how we handle personal data relating to Subjects – individuals and organizations who are the subjects of a Record of Truth commission – and third parties named in connection with a legal matter, such as claimants or opposing parties in the underlying proceedings.

2. Information We Collect and Why

2.1 Website Visitors: Server Logs

Like all web servers, our hosting provider automatically records standard server log data when you visit this website. This includes your IP address, browser type, referring URL, pages visited, and the date and time of your visit. These logs are retained for a short period for security and performance monitoring purposes and are not used to build profiles of individual visitors.

Legal basis: Legitimate interests – the operation and security of a web service.

2.2 Website Visitors: Analytics

We use Google Analytics, connected via the Google Site Kit plugin, to collect data about how visitors use this website. This includes pages visited, approximate geographic region, browser and device type, and general interaction patterns. Google Analytics uses cookies to collect this data. We also use Google Search Console and PageSpeed Insights for site performance monitoring. Google’s privacy policy is at policies.google.com/privacy.

Legal basis: Legitimate interests – understanding how our website is used in order to improve it.

2.3 Enquiries

If you contact us by email or through any enquiry form on the Website, we collect your name, email address, and the content of your message. This information is used solely to respond to your enquiry. It is not added to any marketing list without your explicit consent.

Legal basis: Legitimate interests – responding to business enquiries.

2.4 Client Eligibility Tool

The Client Eligibility Tool allows a user to enter the name of one or more individuals (each a “Subject”) in order to obtain an indicative assessment of each Subject’s online search visibility.

Processing of the Subject’s name. When the tool is used, each Subject’s name is transmitted to our search provider (see section 5) solely for the purpose of retrieving current publicly-available search results, and is used to calculate an eligibility grade. The Subject’s name is not retained on FamoRenovo’s systems at this stage, whether the user is logged in or not. It is stored only in the user’s own browser (in local storage on the user’s device), where it remains under the user’s control and can be cleared at any time. This local-storage record exists solely so that, if the user subsequently logs in (or creates an account) and chooses to progress the result, the same Subject can be carried through to the Record of Truth Wizard without having to be re-entered. FamoRenovo does not have access to local storage and cannot read it remotely.

Progression into the Record of Truth Wizard. If a logged-in user actively progresses a Subject into the Record of Truth workflow (which is only offered for grade 3 or 4 results), the Subject’s name is at that point recorded on our systems as Record of Truth Wizard progress data and is thereafter governed by sections 2.6 and 6, because a client engagement is being prepared and a lawful basis for processing exists.

Operational logging. We retain non-identifying operational data about tool usage – the grade returned, a timestamp, and (where applicable) the account identifier of the user who ran the check – for service monitoring, fraud prevention, and aggregate reporting. Operational log entries do not contain Subject names, search queries, or any data derived from search results, and are automatically deleted after 12 months (or such other period as is specified in our current Data Saving configuration).

Third-country transfers. Our search provider is located outside the United Kingdom and European Economic Area. Transfers are governed by the UK International Data Transfer Agreement and/or the European Commission’s Standard Contractual Clauses, together with a data processing agreement with the provider. Further detail is set out in section 5.

Lawful basis.

For transmission of the Subject’s name to the search provider in order to generate an eligibility grade: Legitimate interests – operating a professional assessment tool used by regulated professionals and their clients to evaluate suitability for reputation-rehabilitation services. We have carried out a legitimate interests assessment and concluded that this processing does not materially affect the Subject, given the public nature of the search data returned, the non-retention of the Subject’s name on FamoRenovo’s systems at this stage, and the professional context in which the tool is typically used.
For the Subject’s name, once progressed into the Record of Truth workflow: Performance of a contract / taking steps at the request of the data subject prior to entering into a contract, and (where applicable) legitimate interests in delivering the contracted service.

Confidentiality of professional referrals. Where the tool is used by a regulated professional (such as a solicitor, PR adviser, or insurance representative) on behalf of a client of that professional, FamoRenovo treats the Subject’s identity as confidential and will enter into a mutual non-disclosure agreement with the referring firm on request.

2.5 Account Registration

To create a registered account, you must provide your first name, last name, email address, and professional type (individual, legal, PR and communications, or insurance). You may optionally provide a company or firm name. We also record the date and time of registration and whether your email address has been verified. A temporary email verification token is generated at registration and deleted upon successful verification.

This information is used to operate and manage your account, to personalize your use of the Record of Truth Wizard and other account features, and to communicate with you about your commissions and account status.

Account activity log. For the security of registered accounts and to assist with account-recovery enquiries, we record a log of significant account events: Successful login, logout, profile update, and password change. Each log entry consists of the user account identifier, the event type, a timestamp, and the source IP address. The log is reviewed for suspicious activity and is not used for any other purpose. Retention is set out in section 6.

Legal basis: Contract – processing necessary to perform the agreement between us when you create an account; legitimate interests – account security and fraud prevention.

2.6 The Record of Truth Wizard: Case Assessment and Commission

The Record of Truth Wizard is our multi-step intake tool through which users submit case details, receive a complexity assessment, and place a commission. To use the Record of Truth Wizard, you must have a registered account.

The Record of Truth Wizard collects the following categories of information, which are stored in your account record:

About the Subject: The Subject’s full name, professional role or description, biographical summary, whether the Subject is an individual or organization, public profile status, geographic scope of the legal matter, and known name variations.

About the legal matter: The name of the opposing party (claimant, complainant, or prosecutor), the type of allegation or proceeding, the case number or reference, the dates the case was filed and resolved, the type of resolution (such as dismissal, acquittal, or settlement), a summary of the outcome, and details of any retraction (including date, issuer, and the text of the retraction).

About supporting documentation: The types of outcome documents held (court order, retraction letter, exoneration statement) and an approximate count of documents. Copies of documents are not uploaded through the Record of Truth Wizard; if document review is required, submission arrangements are made separately.

Subject names are transmitted to Serper.dev to retrieve current Google search results as part of the complexity assessment. Subject names may also be transmitted to Anthropic’s API if you use the autofill feature to generate a suggested role description or biography. See section 5 for details of these providers.

This information is stored in your account record as “Record of Truth Wizard progress” throughout the session and is used to produce the complexity score, generate the fee quote, and ultimately to research and write the Record of Truth if a Commission is placed.

Legal basis: Contract – processing necessary to assess and fulfill a commission; legitimate interests – retaining case assessment data in your account so that your progress is not lost between sessions.

2.7 Commission Records

When you confirm a Commission, we create a permanent commission record in our systems containing all the information submitted through the Record of Truth Wizard together with the following additional information:

The date and time of the Commission;
The complexity score and pricing tier;
The Fee, currency, deposit amount, and any Professional Rate applied;
Your invoice details: Legal name, company name, full billing address, VAT number (if provided), and any PO reference or client/matter reference you supply; and
The VAT treatment applicable to your invoice.

Commission records are retained for as long as necessary for the purposes of delivering the service, managing any ongoing obligations (including post-publication activity), handling disputes, and complying with our financial and legal record-keeping obligations.

Legal basis: Contract – processing necessary to deliver the commissioned service and manage the billing relationship; legal obligation – retention of financial records.

2.8 Billing Defaults

When a Commission is confirmed, the invoice details you provide are stored as billing defaults against your account. This means that on your next visit to the Record of Truth Wizard, the invoice section is pre-populated with your previously used billing details to save you time. These defaults are updated on each subsequent commission. Your client/matter reference is also saved as a billing default for Professional Users.

Legal basis: Legitimate interests – providing a streamlined experience for returning users.

2.9 Professional Program

If you apply for the Professional Program, we collect:

Your professional type (legal, PR and reputation management, insurance, or other);
Your firm or practice name;
An approximate indication of the number of matters per year to which this service would apply; and
A brief note about how you intend to use FamoRenovo with your clients (optional).

We also record the date of your application, whether and when it was approved, and the Professional Rate assigned to your account.

This information is used to assess your application, to notify you of the outcome, to manage your account’s Professional Rate, and to maintain our records of Professional Program participants.

Legal basis: Contract – processing necessary to operate the Professional Program; legitimate interests – managing a professional partner relationship.

2.10 Information About Subjects and Third Parties

In the course of delivering our service, we process personal data relating to individuals who are not our registered users. This includes:

Subjects – individuals whose reputation is the subject of a Commission. The Subject may or may not be the same person as the registered user. Subjects’ names, professional details, and legal case histories are processed for the purpose of producing the Record of Truth.
Claimants and opposing parties – individuals named in the underlying legal proceedings may be named in the Record of Truth. Only information drawn from the account holder’s submissions and from publicly available sources is used. We do not independently verify or augment personal data about these individuals beyond what is necessary to accurately describe the documented legal outcome.

Where a registered user is a Professional User acting on behalf of a Client, the registered user is responsible for ensuring that the Subject (their Client) has given informed consent to this processing and has been provided with appropriate privacy information. The registered user acts as a data controller in respect of the information they hold about their Client; we process that information as a processor on the registered user’s behalf in so far as it relates to delivery of the service.

Legal basis (Subjects and third parties): Legitimate interests – producing accurate published documentation of a public legal outcome; where the Subject is the registered user or has given specific consent, contract or consent as appropriate.

3. Cookies

This website uses cookies in the following categories:

Functional cookies are set by WordPress to maintain session state for logged-in users and to remember dismissed notices. These are technical necessities without which the Website cannot function correctly for registered users.

Analytics cookies are set by Google Analytics via the Google Site Kit plugin to collect anonymized usage data as described in section 2.2.

We do not currently use advertising cookies, retargeting cookies, or social media tracking pixels.

You can control cookie settings through your browser. Blocking functional cookies will impair your ability to log in and use account features. Blocking analytics cookies will prevent Google Analytics from recording your visit.

4. How We Use Your Information

In summary, we use the personal information we collect to:

operate and maintain your account;
deliver the assessment, commission, and publication services you have requested;
generate complexity assessments and fee quotes through the Record of Truth Wizard;
process invoices and manage our billing relationship with you;
send you transactional emails relating to your account, commissions, and the Professional Program;
respond to your enquiries;
monitor and improve the performance and security of the Website;
comply with our legal and financial record-keeping obligations; and
assess and manage Professional Program applications.

We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human review.

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

5. Third-Party Service Providers and Data Transfers

We use the following third-party service providers in operating FamoRenovo. Each is engaged under written terms (including, where required, a data processing agreement) and, where they process personal data on our behalf, acts only on our documented instructions and in accordance with applicable data protection law.

Krystal (web hosting – data processor). Role: Hosts the Website, our application database (including user accounts, Record of Truth records, and commission records), and associated server logs. Data processed: All personal data held on FamoRenovo’s systems, including Subject names progressed into the Record of Truth workflow, user account data, and server access logs. Location: United Kingdom. Transfer mechanism: None required (UK-based). Privacy policy: krystal.uk/legal/privacy.

Cloudflare (content delivery and DDoS protection – data processor). Role: Sits in front of the Website to provide content delivery, TLS termination, and protection against malicious traffic. As a result, Cloudflare processes the contents of all requests to and responses from the Website while they are in transit. Data processed: IP addresses, request metadata, and request/response content in transit. Location: Global network, with traffic typically routed via the nearest edge location. Cloudflare’s corporate data processing takes place in the United States. Transfer mechanism: The UK International Data Transfer Agreement / Standard Contractual Clauses, under Cloudflare’s published Data Processing Addendum. Privacy policy: cloudflare.com/privacypolicy.

Serper.dev (search provider – data processor). Role: Retrieves publicly-available Google search results on our behalf. Data processed: Subject names entered into the Client Eligibility Tool or the Record of Truth Wizard, transmitted as search queries. The Subject’s name is not retained by FamoRenovo at the eligibility stage; it is passed to Serper only for the duration of the search request. Location: United States. Transfer mechanism: The UK International Data Transfer Agreement / Standard Contractual Clauses, together with a data processing agreement. Retention: Serper processes queries to return search results and, per their stated practices, anonymises logged queries by removing the search term. We do not permit Serper to use query data for any purpose other than fulfilling our API request. Privacy policy: serper.dev/privacy.

Anthropic (AI text generation – data processor). Role: Powers the optional autofill feature in the Record of Truth Wizard, which suggests descriptive text for a Subject’s professional role and biography. Data processed: The Subject’s name, transmitted only when a user actively invokes the autofill feature. Suggestions are optional and may be accepted, edited, or discarded. Location: United States. Transfer mechanism: Standard Contractual Clauses / UK IDTA, together with Anthropic’s commercial terms and data processing addendum. Retention: Anthropic’s commercial API terms provide that customer inputs and outputs are not used to train Anthropic’s models, and are retained only for a limited period (up to 30 days) for abuse-detection and operational purposes before being deleted. Privacy policy: anthropic.com/privacy.

SMTP2Go (transactional email delivery – data processor). Role: Delivers transactional emails sent by FamoRenovo, including account verification messages, commission confirmations, and Professional Programme notifications. Data processed: Recipient email address, sender address, subject line, and message content for the purpose of delivery. Location: European Union. Transfer mechanism: None required (EEA-based). Retention: Delivery records and message content are retained by SMTP2Go for 30 days for deliverability and troubleshooting purposes, then deleted. Data processing agreement: In place. Privacy policy: smtp2go.com/privacy.

Google (analytics and search performance – independent controller / joint controller). Role: We use Google Analytics and Google Search Console (integrated via the Google Site Kit plugin) to monitor site performance, visitor behaviour, and search indexing. Google acts as an independent controller for some of this processing and, in respect of analytics, as a joint controller or processor depending on the configuration. Data processed: Website usage data, including IP address (with IP anonymisation applied), pages viewed, referrer information, device and browser data. Location: Google processes this data globally, including in the United States. Transfer mechanism: Standard Contractual Clauses, under Google’s published Data Processing Terms and the EU-US Data Privacy Framework. Consent: Google Analytics tracking fires only where you have given prior consent via our cookie consent banner, in accordance with UK and EU law. You may withdraw consent at any time via the “Cookie Settings” link in our footer. Privacy policy: policies.google.com/privacy.

Online payments. We do not process online card payments. Fees for our services are invoiced and settled by direct bank transfer. No card or bank-account data is collected or processed through the Website.

International data transfers. Where the services listed above involve the transfer of personal data outside the United Kingdom or the European Economic Area, such transfers are made on the basis of appropriate safeguards. For transfers from the United Kingdom these are principally the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses; for transfers from the European Economic Area, the European Commission’s Standard Contractual Clauses apply. In each case these safeguards are supplemented by the relevant provider’s data processing agreement with FamoRenovo.

6. Retention Periods

We retain personal data for as long as is necessary for the purposes for which it was collected, subject to the following specific periods:

Account data (name, email, professional type, account preferences) is retained for as long as your account remains active. If you close your account or if we close it for breach of our Terms of Service, account data is deleted within a reasonable period, subject to the retention periods below for commission records.

Account activity log (the login, logout, profile-update, and password-change events described in section 2.5) is retained for 12 months for security and fraud-prevention purposes, then automatically deleted.

Record of Truth Wizard progress data (case details stored during and after the Wizard) is retained as part of your account record. If no Commission is placed, we may delete Record of Truth Wizard progress data that has been inactive for more than 24 months.

Commission records (all data associated with a confirmed Commission, including case details, invoice information, and pricing) are retained for a minimum of 6 years from the date of the final invoice, to comply with our financial record-keeping obligations under applicable law.

Billing default data (your saved invoice address details) is retained for as long as your account is active and is updated each time you complete a new commission.

Professional Program data (application details, approval status, rate) is retained for the duration of your enrollment and for a reasonable period thereafter in case of dispute or audit.

Eligibility Tool operational data (the eligibility grade returned, a timestamp, and the account identifier of any logged-in user who ran the check) is retained for 12 months for service monitoring, fraud prevention, and aggregate reporting, then automatically deleted. No Subject names, search queries, or data derived from search results are recorded on FamoRenovo’s systems at the eligibility stage.

Subject names entered into the Eligibility Tool are not retained on FamoRenovo’s systems. They are held only in the user’s own browser, in local storage on the user’s device, so that the user can carry the result through to the Record of Truth Wizard if they subsequently create an account and log in. Local-storage entries remain under the user’s control and can be cleared at any time through the user’s browser. FamoRenovo does not have access to local storage and cannot read or modify it remotely. If a logged-in user actively progresses a Subject into the Record of Truth Wizard, the Subject’s name is at that point governed by the Record of Truth Wizard progress data retention period set out above.

Server logs are retained for a short period, typically 30 to 90 days, for security and diagnostic purposes.

Enquiry correspondence is retained for as long as is necessary to manage any ongoing communication, typically no longer than 2 years from the last contact.

7. Your Rights

Under UK data protection law (UK GDPR and the Data Protection Act 2018), you have the following rights in respect of your personal data:

Right of access. You have the right to request a copy of the personal data we hold about you.

Right to rectification. You have the right to request correction of any personal data we hold about you that is inaccurate or incomplete.

Right to erasure. You have the right to request deletion of your personal data where there is no overriding legitimate purpose for us to retain it. Note that this right is subject to our legal obligations to retain certain financial records.

Right to restriction. You have the right to request that we restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data.

Right to object. You have the right to object to processing of your personal data based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.

Right to portability. Where processing is based on your consent or on 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 withdraw consent. Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact us at . We will respond within one month. We may need to verify your identity before fulfilling a request.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection. The ICO can be contacted at ico.org.uk or by calling 0303 123 1113.

8. Data Security

We take reasonable technical and organizational measures to protect personal data against unauthorized access, loss, or destruction. These measures include access controls, secure server hosting, and encrypted transmission of data via HTTPS. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

We limit access to personal data to those employees, contractors, and service providers who need it in order to deliver the service, and require those parties to maintain appropriate confidentiality.

9. Links to Other Websites

This Website may contain links to external websites, for example to legal documentation or published news articles. We are not responsible for the privacy practices of those websites and encourage you to review their policies independently.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or applicable law. Any changes will be published on this page with an updated date at the top. We encourage you to review this policy periodically. Where changes are material, we will endeavor to notify registered users by email.

FamoRenovo Ltd.

1 Royal Wells Court
Tunbridge Wells
TN1 1JT

Email:
Website: famorenovo.com