Privacy Policy

Privacy Policy

This information has been produced to help you understand everything you need to know about the way Vardags collects, uses, and shares personal data, what your legal rights are, and how to exercise them.

Please take some time to read this document. We have tried to keep it all as simple as possible and to avoid jargon in our communications. We will make our best efforts to keep you informed if there are anu changes to the way we process your personal data in the future.

Vardags takes its responsibility for protecting your data very seriously. We advise you to read through our processes to confirm that you are clear on our practices. If there is anything that you do not understand, or if you want to ask any questions, please feel free to contact us. 

Who is the data controller?

Vardags Limited and Vardags S.t.a.r.l. (“Vardags”).

In this document Vardags may be referred to as “we”, “us”, or “our”.

What kinds of personal data does Vardags process?

We collect personal data for various purposes; with that in mind we have created a non-exhaustive list of the types of personal data that we may collect, either directly from yourself or from other sources, in order to achieve those purposes.

What are the reasons Vardags collects Personal Data?

Performance of a contract with you

We use personal data to fulfil any contractual obligations that exist between us and yourself. Where we request that you provide personal data in order to enter into, or meet, the terms of any such contract, you will be required to provide the relevant personal data or we will not be able to deliver the goods or services you want. In such cases, the lawful basis of us processing the personal data is that it is necessary for the performance of a contract.

Legal obligations

We are required by law to process personal data for purposes relating to our legal obligations, these include:

• To provide for our financial commitments, or to relevant financial authorities.

• To comply with regulatory requirements and any self-regulatory schemes.

• To carry out required business operations and due diligence.

• To cooperate with relevant authorities for reporting criminal activity, or to detect and prevent fraud.

• To investigate any insurance claims, claims of any kind of harassment or of discrimination, or any other claim whereby the organization may have to defend itself.
• To act for individuals in ongoing litigation.

Consent

We may process personal data for the following purposes where we have sought your consent to do so:

• For referring clients to other firms
• To send references to potential future employers
• For future marketing purposes

Legitimate interests

We may process personal data for any of the following purposes, which are considered to be within our legitimate business interests:

• To provide services, where they have been requested.

• To inform people of other goods and services we provide or offers that may be of interest.
• To send information to people who have asked to be kept informed.
• To invite people to participate in research in fields and disciplines they are interested in.
• To improve the quality of services offered and to better understand customers’ needs by requesting feedback or reviews of the services provided, or by sending survey forms.
• To send notifications of any changes to the goods and/or services provided that may affect people.
• To understand the scale of our customer base; for statistical analysis and market research.
• To recognise when people re-engage with us.
• To allow us to support and maintain our products in active service.
• To provide reference information to third party organisations when necessary.
• To improve our website so content is delivered more efficiently.
• To enhance the security measures in place that protect data we are responsible for.
• To protect our assets.
• To maintain lists of specialist services known as the ‘Blackbook’.

Special Category Personal Data

Personal data that is considered sensitive in nature are given special consideration in when they may be processed.

We may process the following types of special category personal data, under the included lawful basis.

Where does Vardags obtain Personal Data from?

We collect personal data directly in various ways. This could include when you complete an online form, or if you provide the data directly to a representative of Vardags.

Where it is necessary for us to achieve our business objectives, we may collect personal data from publicly accessible sources, such as:

• Professional Networking Sites
• Social Media
• Companies House
• Company Websites

We may also gather personal data by any of the following methods:

• By systems that gather data automatically from your computer equipment when visiting our online platforms.
• From systems that allow geographical location tracking, such as IP Address mapping, WiFi, GPS signals and cell tower positioning.
• From third-party organisations, where it is necessary to deliver a product or service that has been requested.

Who does Vardags share Personal Data with?

To achieve the above stated purposes for which we process your personal data, we may have to share information with certain third-party organisations. This may include where we are legally required to do so, or where it is strictly necessary in order to deliver a particular product or service.

We will make all reasonable efforts to ensure any third-party with whom we share personal data is compliant with data protection law.

The kinds of third-parties we may share your information with include:

• Organisations where it is necessary to provide goods and services or to achieve our business purposes.
• Government institutions or authorities.
• Third party controllers where clients have been referred.

Will Vardags transfer your Personal Data to other jurisdictions?

As part of our standard business practice, we may transfer your personal data to organisations based in countries which are not considered by the UK and / or the EU to afford adequate protection to personal data.

This might include where the data transfer is necessary in order to fulfil a contract between us and yourself, or where we have received your specific consent after having made you aware of any risks involved.

Wherever possible, we shall maintain contracts between us and the third-parties involved that ensure the recipient organisation has suitable standards of data protection in place.

How long will Vardags keep your Personal Data?

We will keep your personal data only for as long as required to achieve the purposes for which it is gathered.

The following criteria determine the period for which we retain personal data:

• Until we are no longer required to do so to comply with regulatory requirements or financial obligations

• Until we are no longer required to do so by any law we are subject to.

• Until all purposes for which the data was originally gathered have become irrelevant or obsolete.

• Until it is requested that we no longer process the data and that it is erased.

Your rights, Our responsibility

The Right of Access

This grants you the right to confirm whether or not your personal data is being processed, and to be provided with relevant details of what those processing operations are and what personal data of yours is being processed.

If you would like access to the personal data we have about you, we ask that you contact us using the details below.

The Right to Rectification

This one is fairly straightforward; if you notice that the data we have about you is inaccurate or incomplete, you may request that we rectify the mistake. We will make every effort to respond to requests of this type immediately.

The Right to Erasure

Otherwise known as the ‘right to be forgotten’, this gives you the right to request your personal data be deleted.

This is not an absolute right; if you were to request that we erase your personal data, we would erase as much of that data as we could, but may need to retain some information if it is necessary.

Where we have received a request for personal data to be erased, if it is necessary for us to retain some of that information we shall ensure that the remaining data is used only when and where it is absolutely necessary.

The Right to Objection

The right to object is a basic freedom all democracies enjoy. If you wish to object to the way we use, or have used, your personal data, you may do so freely.

The Right to Portability

This is a legal right afforded to you that states we must pass on all the details you have provided to us in a machine-readable format, either to you or to another provider of your choosing.

The Right to Complain

We will always try to maintain the highest standards and encourage the confidence our customers have in us as an organisation. To achieve this, we request that any complaints be brought to our attention so we can properly investigate matters. If you would like to complain about Vardags to a regulatory body, you may do so by contacting your local data protection supervisory authority. For the UK, this is the ICO (Information Commissioner’s Office) and for Italy this is Garante per la protezione dei dati personali (Italian Data Protection Authority).

Contact Details

ICO Contact Details

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

0303 123 1113

Italian Data Protection Authority Contact Details

Piazza Venezia 11 - 00187 Roma, Italy

+39 06.69677

For European Supervisory Authorities, please visit https://www.gdprregister.eu/gdpr/dpa-gdpr/

Vardags Contact Details

Vardags Limited:

10 Old Bailey, London, EC4M 7NG

0203 608 7741

[email protected]

Vardags S.t.a.r.l.:

Milan, Galleria Passarella n. 1

[email protected]

Vardags Limited’s EU Representative

 Vardags S.t.a.r.l.

June 2026