Privacy Policy

1. Who we are

VERO PRIVÉ GROUP LIMITED is a private limited company registered in England and Wales. Company number: 17135095. Registered office: Midway, Twyford, Evesham, England, WR11 4TP.

We provide private asset and lifestyle stewardship services, including estate management and automotive technical stewardship, to private clients in the United Kingdom and in Spain (Marbella), through our two divisions, Vero Privé and Vero Circuit.

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, VERO PRIVÉ GROUP LIMITED is the data controller for personal data processed in connection with this website. Because the site is directed at clients in Spain as well as in the United Kingdom, we also apply the EU General Data Protection Regulation (Regulation (EU) 2016/679, “EU GDPR”) and Spain's Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD) to the personal data of individuals in the European Union. You can contact us about privacy matters at [email protected].

2. Scope of this policy

This policy explains how we handle personal data in connection with the website veroprive.com. It does not cover the processing of personal data under a client engagement, which is governed by the terms of that engagement and by any separate privacy notice we provide to clients.

This website is informational. It does not host contact forms, user accounts, newsletter sign-up, e-commerce functionality or advertising technology. It uses privacy-friendly, cookieless audience statistics, described in section 10.

3. Personal data we collect through this website

We do not ask you to submit any personal data through this website, and we do not operate any form, login or subscription mechanism on it.

The only personal data associated with your visit is the technical data automatically generated when any device connects to a web server, described in the following section.

If you choose to contact us using the telephone numbers or email address displayed on the site, we will receive the contact details and the content of your message. We use that information solely to respond to your enquiry and, where relevant, to consider whether we are able to act for you.

4. Hosting and technical logs

The website is hosted as a static site on Cloudflare Pages, provided by Cloudflare, Inc., which acts as our hosting and content delivery processor.

In delivering and protecting the site, Cloudflare processes technical data such as your IP address, the approximate region derived from it, the pages requested, the date and time of the request, and your browser and device type. This information is used for the secure and reliable operation of the site, including protection against attacks and abuse.

Typefaces used on the site are hosted on our own infrastructure. The site therefore makes no requests to external font providers when you view a page.

5. Booking an introductory consultation

Where the site invites you to arrange an introductory consultation, the booking link takes you to Proton Calendar, a third-party scheduling service operated by Proton AG (Switzerland).

Any details you enter into that booking page, such as your name, email address and chosen appointment time, are collected through Proton Calendar. Proton AG processes that information under its own privacy policy, which should be reviewed before a booking is completed. We receive the booking details in order to prepare for and attend the consultation.

Following the booking, we act as controller in respect of the appointment details we hold, and we use them only to arrange, conduct and follow up on the consultation.

6. Legal bases for processing

Technical and security log data, and the aggregated audience statistics described in section 10, are processed on the basis of our legitimate interests in operating a secure, available and functioning website, understanding how it is used in aggregate, and preventing misuse of it (Article 6(1)(f) of the UK GDPR and the EU GDPR).

Enquiries received by telephone, email or through a consultation booking are processed on the basis of our legitimate interests in responding to prospective clients and, where an engagement is being discussed, on the basis of steps taken at your request prior to entering into a contract.

Where we retain records to satisfy a legal or regulatory obligation, the processing is based on compliance with that obligation.

7. Disclosure and international transfers

Personal data is not sold, rented or used for advertising purposes. It is disclosed only to our service providers acting on our instructions, principally Cloudflare, Inc. and Proton AG, to our professional advisers, and to any authority or party where disclosure is required by law.

Our service providers may process data outside the United Kingdom, including in the United States. Where personal data is transferred outside the UK, appropriate safeguards recognised under UK data protection law are relied upon, such as the International Data Transfer Agreement or the UK Addendum to the European Commission's standard contractual clauses.

Because our services are also delivered in Spain, correspondence relating to an enquiry may be handled by personnel located there. Transfers between the United Kingdom and the European Economic Area rely on the adequacy decisions adopted by the European Commission and the United Kingdom in respect of each other.

8. Retention

Technical and security logs generated by our hosting provider are retained for the limited period applied by that provider for security and diagnostic purposes.

Enquiry correspondence is retained for as long as is necessary to deal with the enquiry and, where no engagement follows, for a reasonable period afterwards to maintain a record of the contact. Records relating to an engagement are retained in line with our professional and statutory obligations.

9. Your rights

Under the UK GDPR and the Data Protection Act 2018 and, for individuals in the European Union, under the EU GDPR and the LOPDGDD, you have the right to request access to the personal data we hold about you, to have inaccurate data corrected, and to request erasure of your data in certain circumstances.

You also have the right to request restriction of processing, to object to processing carried out on the basis of legitimate interests, and, where applicable, to receive your data in a portable format or have it transmitted to another controller.

Requests should be sent to [email protected]. We respond within one month, which may be extended where a request is complex. There is no charge for a request unless it is manifestly unfounded or excessive.

10. Cookies and similar technologies

This website sets no cookies of its own and uses no profiling or advertising technologies. To understand how the site is used, we use Cloudflare Web Analytics, which records aggregated statistics such as page views, referring sites, country and device type without setting cookies, without using local storage and without creating a profile of individual visitors. No consent banner is therefore presented.

Our hosting provider may set strictly necessary cookies or equivalent identifiers for security purposes, for example to distinguish genuine visitors from automated traffic. Cookies of this kind are exempt from the consent requirement under the UK Privacy and Electronic Communications Regulations and Article 22.2 of Spain's Law 34/2002 on Information Society Services and Electronic Commerce (LSSI-CE).

Following a booking link takes you to a third-party site which may set its own cookies under its own policy.

11. Complaints, changes and contact

If you are concerned about how we handle your personal data, please contact us first at [email protected] so that we may address the matter.

You also have the right to lodge a complaint with a supervisory authority: in the United Kingdom, the Information Commissioner's Office (ico.org.uk); in Spain, the Agencia Española de Protección de Datos (aepd.es); or the supervisory authority of the EU member state where you live or work.

Where Article 27 of the EU GDPR requires a controller established outside the European Union to appoint a representative in the Union, we will designate one and publish its details in this policy.

This policy may be updated from time to time to reflect changes in our practices or in the law. The date at the top of this page indicates when it was last revised.