Privacy & transparency
Your information.
Handled with care.
How Foster Concepts handles website visits and enquiries, and how to exercise your data protection rights.
01 / Who is responsible
The data controller is Anne Merle Osborne, trading as Foster Concepts, an independent professional practice in Italy. Partita IVA: 14887370964.
For privacy questions or rights requests, email anne@fosterconcepts.com. Postal contact: Via Ferdinando Marescalchi 11, Milano, Italy.
This notice covers the website and initial enquiries. If an engagement involves additional personal data, including school staff or learner information, the relevant arrangements and privacy information will be agreed separately before that data is shared.
02 / Data, purposes and legal grounds
| Activity | Information and purpose | Legal ground |
|---|---|---|
| Website access | Technical request data, such as IP address, request time, requested page, browser information and security events, processed to deliver and protect the public website. | Legitimate interests in a reliable, secure website — Article 6(1)(f). |
| School enquiries | Your name, professional contact details, school or organisation, message and any attachments you choose to send, used to respond and discuss appropriate support. | Legitimate interests in answering requested business enquiries and maintaining professional contact — Article 6(1)(f). |
| Enquiries in your own capacity | Contact details and information needed to consider services you personally request before a contract. | Steps at your request before a contract — Article 6(1)(b). |
| Legal duties and disputes | Relevant correspondence or records retained when required by law or necessary to establish, exercise or defend a legal claim. | Legal obligation — Article 6(1)(c), or legitimate interests in protecting legal rights — Article 6(1)(f). |
Providing an enquiry is voluntary. A working contact address and sufficient information are needed to answer it; without these, a reply may not be possible. Please send only information relevant to the enquiry. Use anonymised examples and avoid sending identifiable pupil records, health information or other sensitive personal data through an initial email.
Enquiries are not used for unsolicited marketing. No profiling or automated decisions with legal or similarly significant effects are used for these activities.
03 / Who may receive information
Information is accessed by Anne and, where necessary for the stated purpose, by the providers used to deliver the website and email, professional advisers, or competent authorities where disclosure is legally required.
- Website hosting and security: Cloudflare Pages delivers this website through Cloudflare’s network, processing technical requests to serve pages and protect the service. See Cloudflare’s data processing terms (opens in a new tab).
- Business email: Zoho Mail hosts anne@fosterconcepts.com using an EU-region account. It processes messages, contact details and attachments to receive, store and deliver correspondence. See Zoho’s privacy statement (opens in a new tab).
- Email application: Anne uses Microsoft Outlook for Mac to read and reply to business email. Microsoft may process account and diagnostic information and, where Microsoft cloud synchronisation is used, mailbox content to provide that service. See Microsoft’s privacy statement (opens in a new tab).
Personal data is not sold. Providers may use subprocessors to deliver their services. You can ask Anne for further information about recipients and applicable data processing arrangements.
04 / International processing
Website and email providers operate internationally, so processing may take place outside the European Economic Area, including in the United States or India. Cloudflare’s global delivery service does not guarantee that all technical data stays within the EU.
Cloudflare describes applicable adequacy mechanisms, including the EU–US Data Privacy Framework, and European Commission Standard Contractual Clauses for international transfers in its privacy policy (opens in a new tab) and data processing terms. Microsoft’s privacy statement describes its international processing and transfer safeguards. You may request information about relevant safeguards, including a copy where applicable, using the privacy contact above.
The Zoho Mail account uses the EU region for mailbox storage. Zoho explains that technical support may involve access from outside the EEA, including India, under Standard Contractual Clauses and supplementary measures. See Zoho’s privacy FAQ (opens in a new tab). An EU account does not mean that every processing activity takes place exclusively within the EU.
05 / How long information is kept
- Enquiries that do not become client work: correspondence is retained for up to 12 months after the last contact, then deleted unless a specific legal duty or an active dispute requires longer retention.
- Enquiries that become client work: necessary records move into the client file and follow the retention arrangements for the engagement and applicable legal obligations.
- Technical and security information: the website does not create a separate visitor database. Cloudflare manages service logs; retention depends on service delivery and security purposes, the nature and sensitivity of the data, and applicable legal obligations. See the retention section of Cloudflare’s privacy policy (opens in a new tab).
When longer retention is necessary, access is limited to that purpose and the need is reviewed. Deletion from provider backups follows their applicable backup cycle. You can contact Anne for information about retention relevant to your enquiry.
07 / Your choices and rights
Depending on the circumstances, you may request access, correction, erasure, restriction or portability of your personal data. You may object to processing based on legitimate interests. If future processing relies on consent, you may withdraw it without affecting prior lawful processing.
Email the privacy contact above. A response is normally provided within one month; a permitted extension will be explained. Limited verification may be requested to protect your information.
You may complain to Italy’s Garante per la protezione dei dati personali (opens in a new tab), or the competent supervisory authority in your place of residence, work or alleged infringement.
08 / Changes to this notice
The date above identifies this version. This notice will be updated when the contact details, providers, purposes or features change. Changes affecting your rights will be communicated appropriately.
Contact Foster Concepts