Privacy

Privacy notice

Last updated 15 October 2026

Draft, to be reviewed by a lawyerThis text has not yet been checked by a lawyer and may change.

This notice explains which personal data Revamp processes, where it comes from, why we use it, who receives it, how long we keep it and what rights you have. It gives the information required by Articles 13 and 14 of the General Data Protection Regulation (GDPR), the UK GDPR and the Swiss Federal Act on Data Protection (FADP).

1. Who we are

The controller is Giorgio Orsucci, trading as Revamp, a sole trader (eenmanszaak) at Van Woustraat 10-4, 1073 LL Amsterdam, Netherlands. Email hello@revamp.so, website revamp.so. Chamber of Commerce (KvK) number: To be confirmed (Giorgio).

We are established in the European Union (the Netherlands), so the GDPR applies directly to everything we do, together with the Dutch GDPR Implementation Act (UAVG). For people in Switzerland the Swiss FADP also applies, and for people in the United Kingdom the UK GDPR. Because we are established in the EU, we do not need a representative in the EU. Our representative in the United Kingdom under Article 27 UK GDPR, if we keep writing to businesses in the UK: To be confirmed (Giorgio).

2. Whose data this notice covers

3. A. Businesses we write to

We find businesses whose website could be better, build a private preview of a redesigned site for them, and write to offer our service.

Where the data comes from

Which data

Why

To build a private preview of a redesigned website for the business, and to write to the business once, with one follow-up a few working days later, offering our service.

Legal basis

Our legitimate interest in offering our service to businesses (Article 6(1)(f) GDPR and UK GDPR; recital 47 GDPR recognises direct marketing as a possible legitimate interest). We have weighed this interest against yours:

In Switzerland: we process the data in line with the principles of the FADP. The data was made generally accessible by the business and its use was not expressly restricted (Article 30(3) FADP), and we do not process it against an express objection (Articles 30 and 31 FADP).

4. B. Customers and people who contact us

Which data

Why, and on what legal basis

5. C. Visitors of our customers' sites

When we host a customer's site, we process the data of the people who visit it (for example server logs, and messages sent through a form where the site has one) on the customer's behalf. For this data the customer is the controller and we are its processor (Article 28 GDPR). This is governed by the data processing terms in our terms of service. If you visited a site we host, please contact the business that runs it; we help it answer your request.

6. Who receives the data

We use these service providers, bound by data processing agreements:

Google is used only for our own team to sign in to our tools. We do not give it the data of the businesses we write to.

7. Transfers outside the EU

Some providers are in the USA. Where a provider is certified under the EU-US Data Privacy Framework, the transfer relies on it; otherwise it relies on the European Commission's standard contractual clauses (Article 46(2)(c) GDPR). For data from the United Kingdom we rely on the UK Extension to the Data Privacy Framework or the UK International Data Transfer Addendum, and for data from Switzerland on the Swiss-US Data Privacy Framework or standard contractual clauses recognised by the Federal Data Protection and Information Commissioner (FDPIC).

8. How long we keep the data

9. Your rights

You have the right to:

Right to object (Article 21 GDPR). You can object at any time, free of charge, to the use of your data for direct marketing. This objection is absolute: we then stop. Use the unsubscribe link at the end of our email, reply to it, or write to hello@revamp.so. You can also object to processing based on our legitimate interest for reasons relating to your particular situation.

To use any of these rights, write to hello@revamp.so. We answer within one month. We do not make decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.

10. Complaints

You can complain to the data protection authority in your country. Our lead authority is the Dutch Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). Other authorities include:

11. Changes

When we change this notice, we publish the new version here with a new date.