Background:
Saryo Projects Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.rukokuga.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. You accept this Privacy Policy when you contact Us using the details provided on Our Site, and when you submit personal data to Us through any form or booking link accessible from Our Site.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended, relating to the use of cookies and similar technologies;
Information About Us
Our Site is owned and operated by Saryo Projects Limited, a limited company registered in England under company number 17386918.
Registered address: 4th Floor Office, 205 Regent Street, London, England, W1B 4HB.
Main trading address: 4th Floor Office, 205 Regent Street, London, England, W1B 4HB.
What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site and explains how any personal data collected through Our Site is used, as well as your rights and how to raise concerns or complaints.
What Is Personal Data?
Personal data is defined by the UK GDPR and the Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025 and other applicable legislation relating to data protection and privacy (“the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
The right to access the personal data we hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to complain to us using the contact details provided in Part 15 (or by any other method). We will do our best to resolve your complaint. We will acknowledge your complaint within 30 days and will respond to it without undue delay.
You also have the right to lodge a complaint with the Information Commissioner’s Office. You may wish to raise your concerns with us first, so that we can try to resolve them. If you are not satisfied with our response, you can complain to the Information Commissioner’s Office.
What Data Do You Collect and How?
Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children, or data relating to criminal convictions and/or offences.
Our Site uses Framer Analytics, a privacy-focused analytics service provided by the platform on which Our Site is built. Framer Analytics does not use Cookies and does not create any persistent identifiers. It collects your IP address and browser user agent, but these are immediately converted into an anonymous, hashed value using a secret which is reset and deleted every day. This means that you cannot be identified from that value, and that you cannot be tracked from one day to the next or across other websites. We do not use any other analytics or tracking technologies on Our Site.
Data Collected / B. How We Collect the Data
Identity information including your name and, where you provide it, your title.
B. Provided directly by you when you email us or book a call with us.
Contact information including your email address and, where you provide it, your telephone number.
B. Provided directly by you when you email us or book a call with us.
A. Business information including your business or organisation name, job title, and profession.
B. Provided directly by you when you email us or book a call with us.
Enquiry information including the content of your message and any other information you choose to send us.
B. Provided directly by you when you email us or book a call with us.
Technical information including your IP address and browser user agent.
B. Collected automatically by Framer Analytics when you visit Our Site. This data is immediately anonymised by hashing and is not used to identify you.
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
What We Do / B. What Data We Use / C. Our Lawful Basis
Communicating with you and responding to your enquiries.
B. Identity information, contact information, business information, and enquiry information.
C. Our legitimate interests, namely responding to people who contact us and dealing with enquiries about our services.
Supplying our services to you.
Identity information, contact information, business information, and enquiry information.
The performance of a contract with you, or taking steps at your request before entering into a contract.
Administering our business, including record-keeping, invoicing, and accounting.
Identity information, contact information, and business information.
The performance of a contract with you; compliance with our legal obligations; and our legitimate interests, namely the proper running and administration of our business.
Understanding how Our Site is used, and administering and maintaining Our Site.
Technical information, in the anonymised form described in Part 6.
Our legitimate interests, namely understanding how Our Site is used and keeping it secure and working properly.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. In some cases, the law may treat certain further uses of personal data as compatible with the original purpose, subject to appropriate safeguards. If we rely on compatibility in this way and you want us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Type of Data / B. How Long We Keep It
Identity information including your name and, where you provide it, your title.
Where your enquiry does not lead to a working relationship, for up to 36 months from our last contact with you. Where we enter into a working relationship, for the duration of that relationship and for 6 years afterwards, in order to meet our legal, accounting, and tax obligations.
Contact information including your email address and, where you provide it, your telephone number.
Where your enquiry does not lead to a working relationship, for up to 36 months from our last contact with you. Where we enter into a working relationship, for the duration of that relationship and for 6 years afterwards, in order to meet our legal, accounting, and tax obligations.
Business information including your business or organisation name, job title, and profession.
Where your enquiry does not lead to a working relationship, for up to 36 months from our last contact with you. Where we enter into a working relationship, for the duration of that relationship and for 6 years afterwards, in order to meet our legal, accounting, and tax obligations.
Enquiry information including the content of your message and any other information you choose to send us.
Where your enquiry does not lead to a working relationship, for up to 36 months from our last contact with you. Where we enter into a working relationship, for the duration of that relationship and for 6 years afterwards, in order to meet our legal, accounting, and tax obligations.
Technical information including your IP address and browser user agent.
This data is anonymised at the point of collection and is never stored in a form which identifies you. Anonymous, aggregated statistics are retained by our website platform for as long as Our Site remains published.
How and Where Do You Store or Transfer My Personal Data?
We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
storing personal data only on reputable, access-controlled cloud services which are protected by strong, unique passwords and multi-factor authentication; keeping devices, operating systems, and software up-to-date; and deleting personal data once it is no longer needed.
Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply certain services. The following third parties may receive your personal data:
Recipient / B. Activity Carried Out / C. Sector / D. Location
Framer B.V., Rozengracht 207B, 1016 LZ Amsterdam, the Netherlands (Dutch Chamber of Commerce number 59920637) (data processor).
B. Providing the platform on which Our Site is built, hosting and delivering Our Site, and providing Framer Analytics.
C. Technology – website building and hosting software.
D. The Netherlands, with hosting infrastructure provided by Amazon Web Services on servers located in the United States of America and other countries.
Google Ireland Limited and Google LLC (data processor).
Providing the calendar booking service used to schedule calls, and the form service used to collect website feedback.
Technology – online productivity and communication services.
Ireland and the United States of America.
Google Ireland Limited and Google LLC (data processor).
Providing our business email service.
Technology – email and productivity services.
Ireland and the United States of America.
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out in Part 5, you can control our use of your personal data by choosing what information you send to us when you contact us or book a call with us, and by asking us at any time to stop contacting you or to delete the information we hold about you, using the details in Part 15. We do not send marketing emails or newsletters.
Can I Withhold Information?
You may access Our Site without providing any personal data at all. You only need to provide personal data if you choose to contact us by email, book a call with us, or complete a form linked from Our Site.
Our Site does not place any Cookies on your computer or device, so there is nothing for you to restrict. For more information, see Part 14.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
When responding to a subject access request, we will carry out reasonable and proportionate searches for the personal data covered by your request.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
How Do You Use Cookies?
Our Site does not place or access any Cookies on your computer or device. References to Cookies in this Part 14 include similar technologies that store information on your device or access information stored on your device.
Our Site is built and hosted using the Framer platform, which does not set Cookies on visitors’ devices. Framer Analytics, which we use to understand how Our Site is used, also does not use Cookies or create persistent identifiers, as explained in Part 6.
Because no Cookies are placed on your computer or device by Our Site, you will not be shown a Cookie consent prompt when you visit Our Site, and no Cookie consent is required.
Some links on Our Site take you to websites operated by other organisations, for example in order to book a call with us or to complete a feedback form. Those websites are not covered by this Privacy Policy and may place their own Cookies on your computer or device. We recommend that you read the privacy and cookie policies of any website that you visit through a link on Our Site.
If we add any feature or service to Our Site in the future which places Cookies on your computer or device, we will update this Privacy Policy and, where required by Cookie Law, we will seek your consent before those Cookies are placed.
You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request or a data protection complaint, please use the following details (for the attention of Ruko Kuga):
Email address: hello@rukokuga.com.
Postal Address: 4th Floor Office, 205 Regent Street, London, England, W1B 4HB.
Changes to this Privacy Policy
We may review and update this Privacy Policy from time to time to ensure continued compliance with the law and best practice. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 8 September 2026.