Legal
Privacy Policy
This policy explains how Farrow (EMEA) Group Limited collects, uses, stores and shares your personal data. We are committed to handling your information lawfully, transparently and with care. If you have any questions, contact us at connor@farrow.agency.
1. Who we are
Farrow (EMEA) Group Limited ("Farrow", "we", "us", "our") is a company registered in England and Wales under company number 16078116. Our registered office is at 86–90 Paul Street, 3rd Floor, London EC2A 4NE.
We are the data controller for personal data we collect directly. Where we process personal data on behalf of our clients (for example, when contacting their leads), we act as a data processor and our clients are the data controller.
We are not currently registered with the Information Commissioner's Office (ICO) as a data controller but will comply with all applicable requirements under UK GDPR and the Data Protection Act 2018. If you have concerns about our data handling, you may contact the ICO at ico.org.uk.
2. What personal data we collect
Data you provide to us directly
- Your name, email address and phone number when you book a call or submit an enquiry
- Company name, job title and website when provided
- Communications you send us by email, phone or through our website
- Information you provide during onboarding as a client
Data collected automatically
- IP address and browser/device information when you visit our website
- Pages visited, time spent and referring URLs (via analytics tools)
- Cookie data (see Section 9)
Data provided to us by clients (lead data)
When clients use our appointment-setting service, they provide us with contact details for their leads (names, phone numbers, email addresses and similar). We process this data solely on our clients' instructions and in accordance with their instructions and this policy.
3. How we use your personal data
| Purpose | Legal basis |
|---|---|
| To respond to enquiries and book calls | Legitimate interests / pre-contractual steps |
| To deliver our appointment-setting service to clients | Performance of a contract |
| To contact leads on behalf of our clients via WhatsApp, SMS, Facebook and Instagram | Legitimate interests of our clients / consent where required |
| To send service-related communications (confirmations, reminders, invoices) | Performance of a contract |
| To improve our website and services | Legitimate interests |
| To comply with legal obligations | Legal obligation |
| To send marketing communications where you have opted in | Consent |
4. Who we share your data with
We do not sell your personal data. We may share it with:
- Service providers: Third-party tools we use to operate our service, including calendar integration platforms, messaging providers (including Meta platforms for WhatsApp, Facebook and Instagram), SMS providers, CRM software and email tools. All providers are contractually required to protect your data.
- Our clients: Where you are a lead being contacted on a client's behalf, relevant conversation data and your booked appointment details will be shared with that client.
- Professional advisors: Lawyers, accountants and insurers, where necessary.
- Authorities: Law enforcement or regulators where we are legally required to disclose information.
5. International transfers
Our service uses infrastructure and third-party platforms that may process data outside the UK and European Economic Area (EEA), including in the United States. Where this occurs, we rely on appropriate safeguards including Standard Contractual Clauses approved by the relevant authority.
Meta platforms (WhatsApp, Facebook, Instagram) operate globally. By using our service, you acknowledge that data may be processed in accordance with Meta's own policies where their platforms are used for outreach.
6. How long we keep your data
| Data type | Retention period |
|---|---|
| Client account and contract data | 7 years after contract end (legal/tax obligation) |
| Lead conversation data | 12 months after last contact, or as directed by the client |
| Website enquiry data | 24 months from date of enquiry |
| Booked appointment records | 24 months |
| Marketing opt-in data | Until you withdraw consent |
| Website analytics data | 26 months (aggregated) |
7. Your rights
Under UK GDPR, you have the following rights in relation to your personal data:
- Right of access: Request a copy of the personal data we hold about you
- Right to rectification: Ask us to correct inaccurate or incomplete data
- Right to erasure: Ask us to delete your data in certain circumstances
- Right to restriction: Ask us to limit how we process your data
- Right to 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 to be subject to decisions made solely by automated means where they significantly affect you
To exercise any of these rights, email connor@farrow.agency. We will respond within one calendar month. You also have the right to lodge a complaint with the ICO at ico.org.uk/make-a-complaint.
8. Data security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction or alteration. These include access controls, encrypted communications and regular review of our data practices.
While we take reasonable steps to protect your data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but will notify you and the relevant authorities without undue delay in the event of a data breach where required by law.
9. Cookies
Our website uses cookies and similar technologies. We use:
- Strictly necessary cookies: Required for the website to function. These cannot be disabled.
- Analytics cookies: Help us understand how visitors use the site (e.g. pages visited, time on site). We use aggregated, anonymised data only.
- Functional cookies: Remember your preferences to improve your experience.
You can control cookies through your browser settings. Note that disabling certain cookies may affect how the website functions. We do not currently use third-party advertising cookies.
10. Third-party links
Our website may contain links to third-party websites including Cal.com (our booking tool) and Google Forms. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies.
11. Children's data
Our services are intended for business use and are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently done so, please contact us immediately.
12. Changes to this policy
We may update this policy from time to time. Material changes will be notified to active clients by email. The current version will always be available at farrow.agency/privacy. The date at the top of this page reflects when it was last updated.
13. Contact us
Farrow (EMEA) Group Limited
86–90 Paul Street, 3rd Floor, London EC2A 4NE
Company No. 16078116
Email: connor@farrow.agency
Tel: +1 (555) 822‑4742