1. Who we are
Proper Foundations is a trading name of Inner Circle Corporate Brokers LLC FZ, based at Meydan Freezone, Dubai, United Arab Emirates. We help UK trade businesses with websites, business setup coordination and agreed enquiry and follow-up services.
Where we decide why and how personal information is used, Inner Circle Corporate Brokers LLC FZ is the data controller. You can contact us at hello@properfoundations.co.uk.
This policy covers visitors to properfoundations.co.uk, people who contact us, prospective and existing clients, and their business contacts. Business contact details can be personal information even when used for work.
Information handled for a client
When we handle a trade business’s customer information solely on that business’s documented instructions, the business is the controller and we act as its processor. The client’s privacy notice and our agreement with it cover that processing. Contact the trade business about its use of your information. If you contact us, we will help route your request and assist the client as required.
Independent providers, such as a company formation provider, Google or WhatsApp, also have their own privacy notices for their own processing.
2. Information we collect
Website enquiries
Our form collects your name, business or proposed business name, email address, trade and starting point. These fields are required. It also submits your selected service or plan and the main problem you would like help with, including the default choices if you do not change them.
You can optionally provide a phone number, existing website address and additional details. You are not legally required to make an enquiry. The required fields help us understand and respond to your request. You can email us instead if you prefer. Without enough contact or enquiry information, we may be unable to respond meaningfully.
Submitting the form requests a conversation. It does not reserve an appointment, place an order or start a paid service.
Messages and service administration
When you contact us, we receive your contact details, what you tell us and the associated correspondence. If you become a client, we use the information needed for the agreed service, such as your brief, business details, instructions, approvals, support requests, contract and billing records.
Website and digital setup work may involve business addresses or service areas, public contact details, copy, logos, photographs and account permissions you provide or authorise. Please provide only material you are entitled to use. Our website does not contain a payment-card checkout or a file-upload field.
Company formation and client workflows
For company formation coordination, you approve the company details and complete the formation provider’s identity checks directly with that provider. Do not send identity documents, passwords, bank details or payment credentials through our general enquiry form.
For agreed client workflows, information can include customer names and contact details, job or enquiry details, a quote-visit address, appointment times, message history, quote status, invoice-payment status and follow-up instructions. This is handled on the client’s instructions for the agreed work, not as a list of contacts for our own marketing.
Ordinary phone calls and unconnected WhatsApp messages are not automatically captured by the website form workflow. The advertised service does not include working call forwarding, voicemail transcription or missed-call texts.
Technical information
Website and form providers receive technical information when your browser requests a page or submits a form, including your IP address and request details. Hosting, security and form-processing records can also include request times, browser information, referring pages and spam indicators.
Information comes from you, someone authorised to act for your business, a client for whom we provide an agreed service, or the browser and infrastructure involved in your request.
Our services are for business users and are not directed at children. Please keep free-text enquiries to the business information we need and do not include health information, identity documents or other sensitive personal information.
3. How and why we use information
Where the UK GDPR applies, the lawful basis depends on the purpose and our relationship with you.
- Responding to enquiries and arranging a conversation. We use your details to understand and answer your request and discuss the services you ask about. Necessary steps at the request of an individual considering a contract, including a sole trader, use the pre-contract basis. For general enquiries and a company’s representatives, we rely on our legitimate interest in responding to relevant requests and conducting business communications.
- Delivering and managing an agreed service. We use the information needed to carry out the work, obtain approvals, provide support and manage the relationship. This relies on performance of a contract where the contract is with you as an individual, or our legitimate interest in administering the relationship where the client is a company.
- Operating and protecting the website. Necessary technical and spam-prevention information supports our legitimate interest in delivering a working, secure website, processing genuine enquiries and diagnosing faults.
- Business administration, requests and disputes. Relevant records support the administration of charges and accounts, handling of privacy requests and complaints, and establishment, exercise or defence of legal claims. Depending on the activity, the basis is contract, compliance with an applicable legal obligation recognised under the UK GDPR, or our legitimate interest in running the business and protecting legal rights.
When relying on legitimate interests, we must balance our interests against your rights and use no more information than necessary. You can object as explained below. If we rely on consent for an additional activity, we will explain the activity and how to withdraw consent.
4. Enquiry replies and marketing
The enquiry form lets us respond to your request. It has no separate newsletter or marketing opt-in, and submitting it is not consent to unrelated marketing.
If we introduce separate promotional communications, we will provide the required information and choice or consent mechanism for that activity. You can ask us to stop direct marketing by emailing hello@properfoundations.co.uk or using the opt-out route in the message.
Messages sent as part of a client’s service are governed by the client’s instructions and applicable messaging permissions. Their purpose, content, recipient and channel determine the rules that apply.
5. Providers and overseas processing
Website form, email and CRM
The website enquiry form is configured for Netlify Forms. Submitted fields are processed through Netlify so the enquiry can be received and managed, with the service’s spam filtering. Netlify’s documentation describes automated filtering using Akismet.
Our business inbox is hello@properfoundations.co.uk. Email providers process the correspondence we exchange with you. Attio is our selected customer relationship management system. The automatic connection between this website’s enquiry form and Attio has not yet been set up.
Other recipients
Information is handled by people authorised to work for us who need it for the relevant purpose. Depending on your agreed service, recipients can include providers of hosting, domains, email, storage, client records, booking and messaging; an agreed company formation provider; platforms used for your setup; and professional advisers or authorities where a disclosure is necessary and lawful.
Providers acting on our instructions require appropriate processing terms. Some organisations act as independent controllers for their own account administration, legal duties or platform services, to which their own notices apply.
Processing outside the UK
The company behind Proper Foundations is based in Dubai, United Arab Emirates, so information you give us may be handled outside the UK. Our website, email and other providers may also store or access information in other countries. Being based in Dubai does not mean all information is stored only in Dubai.
International data protection requirements depend on the route, recipient and purpose of a particular transfer. Contact hello@properfoundations.co.uk to ask about where your information is handled and the arrangements relevant to it.
7. How long we keep information
We retain personal information only for the purpose for which it is needed. The relevant criteria are:
- Enquiries and correspondence: whether your request remains open, whether there is meaningful ongoing contact and whether the record is still needed to explain an agreed decision or resolve a dispute.
- Client records: the duration of the service, the need to carry out agreed support or handover, and any continuing contractual, accounting or legal requirement.
- Website, form and security records: the need to deliver and protect the service, investigate an incident or resolve a submission problem, taking account of the relevant provider’s retention arrangements.
- Privacy requests and complaints: the need to handle the matter and keep appropriate evidence of the response and any resulting legal obligation or dispute.
- Client customer information: the client’s documented instructions and the return, deletion and backup arrangements in the applicable processing agreement.
- Marketing opt-out records, where applicable: the minimum information needed to honour the person’s choice and avoid contacting them again for that purpose.
Where a legal requirement or particular dispute requires longer retention, it is limited to the relevant records and purpose. Copies in form storage, email, a CRM, exports and backups must be considered when responding to deletion requests. Contact us if you would like information about retention of your particular records.
8. Protecting your information
We are responsible for applying security measures appropriate to the information and the risks. No website or transmission method can be guaranteed completely secure.
Please do not send passwords, access tokens, identity documents or payment credentials through the public enquiry form. If you believe information has been exposed or sent to the wrong person, contact hello@properfoundations.co.uk.
9. Your rights
Where the UK GDPR applies, you may, subject to the legal conditions and exceptions:
- Ask whether we hold information about you and request a copy.
- Ask us to correct inaccurate or incomplete information.
- Ask us to delete information or restrict its use.
- Receive relevant information you provided in a structured, commonly used format and request its transfer where the portability conditions apply.
- Withdraw consent at any time where consent is the basis for processing, without affecting processing before withdrawal.
Your right to object
You can object to processing based on legitimate interests for reasons relating to your situation. We must stop unless the law allows us to continue, for example for compelling legitimate grounds or legal claims. You can object to direct marketing at any time, including related profiling, and that use must stop.
Making a request
Email hello@properfoundations.co.uk and tell us what you would like us to do. We may need reasonable information to verify your identity or understand the request. We respond without undue delay and normally within one month, subject to the timing rules and permitted exceptions in the law. Requests are normally free; where the law permits a fee or refusal, we will explain the reason and your options.
Some records may need to be kept for legal obligations, the rights of others or legal claims. If we cannot fulfil part of your request, we will explain why. For information controlled by a client, we will direct the request appropriately and assist the client as required.
Automated decisions
The website form does not itself make decisions with legal or similarly significant effects. Prefilling a service choice and the illustrative follow-up journeys are not automated credit, eligibility or pricing decisions. The advertised client workflow leaves job selection, quotes and prices with the trade business.
10. Questions and complaints
Email hello@properfoundations.co.uk with your concern and preferred contact method. You can ask someone with appropriate authority to act for you.
Where the UK data protection complaints requirements apply, we acknowledge complaints within 30 days, make appropriate enquiries without undue delay, and keep you informed of progress and the outcome.
You can also complain to the UK Information Commissioner’s Office. Visit ico.org.uk/make-a-complaint for current options. Contacting us first can help resolve an issue, but does not remove your right to contact the regulator.
11. Changes to this policy
We update this policy when the information practices it describes change or need clarification. The date above identifies the latest version. Where a change requires additional information, a new choice or fresh consent, that must be provided before the affected processing begins.