Privacy Policy

Last updated: 18 June 2026

Vespera Capital LLP ("we", "our", "us"), Partnership No. OC460617, registered at 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom, is committed to protecting and respecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and, where applicable, Regulation (EU) 2016/679 (EU GDPR).

1. Data Controller

The data controller responsible for your personal data is Vespera Capital LLP. For all data protection inquiries, please contact us at vesperacapital.llp@gmail.com.

2. What Data We Collect

We collect only the minimum personal data necessary to respond to your inquiry and provide our services:

• Identity data: full name, job title
• Contact data: email address, telephone number
• Company data: organisation name, country of operation
• Communication data: content of messages submitted via our contact form or email correspondence
• Technical data: IP address, browser type, and device information collected automatically when you visit our website

We do not collect any special category (sensitive) personal data.

3. How We Collect Data

We collect personal data through:

• Our website contact form
• Direct email correspondence
• Telephone conversations
• In-person meetings and consultations

4. Legal Basis for Processing

We process your personal data on the following legal bases under Article 6(1) of the UK GDPR:

• Consent (Art. 6(1)(a)): when you voluntarily submit an inquiry through our contact form
• Contractual necessity (Art. 6(1)(b)): when processing is necessary to perform or negotiate a consulting engagement
• Legitimate interests (Art. 6(1)(f)): for business development, service improvement, and responding to inquiries

5. Purpose of Processing

We use your personal data exclusively for:

• Responding to your inquiries and scheduling consultations
• Providing management consultancy and business support services
• Managing client relationships and contractual obligations
• Complying with legal and regulatory requirements

6. Data Sharing

We do not sell, rent, or share your personal data with third parties for marketing purposes. Data may be shared with:

• Professional advisors (legal, accounting) under confidentiality obligations
• Regulatory authorities where required by law
• Technology service providers who support our website infrastructure, bound by data processing agreements

7. International Transfers

Where personal data is transferred outside the United Kingdom or the European Economic Area, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) or adequacy decisions recognised by the UK Information Commissioner's Office (ICO).

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected. Contact form inquiries are retained for a maximum of 24 months unless a commercial relationship is established, in which case data is retained for the duration of the engagement plus 6 years to comply with statutory obligations.

9. Your Rights

Under the UK GDPR, you have the right to:

• Access your personal data (Art. 15)
• Rectify inaccurate data (Art. 16)
• Erase your data ("right to be forgotten") (Art. 17)
• Restrict processing (Art. 18)
• Data portability (Art. 20)
• Object to processing (Art. 21)
• Withdraw consent at any time (Art. 7(3))

To exercise any of these rights, contact us at vesperacapital.llp@gmail.com. We will respond within 30 days.

10. Cookies

This website uses only essential, non-tracking cookies necessary for basic functionality. We do not use analytics, advertising, or third-party tracking cookies. No cookie consent banner is required as no non-essential cookies are deployed.

11. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, including encrypted communications (TLS/SSL) and access controls.

12. Complaints

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom (ico.org.uk).

13. Changes to This Policy

We may update this Privacy Policy from time to time. The revised version will be published on this page with an updated "Last updated" date. We encourage you to review this page periodically.

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