Privacy and Cookie Policy
Last updated: [DATE]
This policy explains how QUOVARNE SERVICES LLC ("Quovarne", "we") collects and uses personal data when you visit quovarne.com, use the portal or deal with us as a customer or prospect.
1. Who is responsible
QUOVARNE SERVICES LLC, a limited liability company organized under the laws of Wyoming, USA, with its registered office at [ADDRESS], is the controller of the personal data described here. Contact: privacy@quovarne.com. [Counsel: assess whether an EU/UK representative under GDPR Art. 27 is required.]
The Service is for businesses. We process only the limited data of the people who work for our customers and prospects.
2. What we collect, why and on what basis
| Data | Source | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|---|
| Name, work email, company, job title | You or your employer | Create and manage portal accounts; send alerts, digests and service messages | Contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)): providing the Service to business customers | Duration of the subscription plus 90 days |
| Billing contact, invoices, payment status; offer details, tax residence and VAT number; record of your acceptance | You or your employer; Stripe | Preparing offers, concluding the Agreement, invoicing, collection, accounting and tax. Payment-method data, tax numbers and consent records are collected and held by Stripe; we hold the offer number, invoices and payment status | Contract; legal obligation (Art. 6(1)(c)) | As the law requires, at least 6 years |
| IP address, browser type, access times, pages requested | Collected automatically | Security, abuse prevention, rate limiting, troubleshooting | Legitimate interests (security of the Service) | Up to 30 days in provider logs |
| Name, work email, company, requested modules and scope, notes (offer request form) | You | Prepare and send you an offer; reply to your request | Steps prior to a contract (Art. 6(1)(b)); legitimate interests | 12 months if no contract follows [Counsel: confirm period]; otherwise as for customer data |
| Messages you send us | You | Reply to enquiries, support, contract administration | Legitimate interests; steps prior to a contract | 3 years after last contact |
We do not collect special-category data. We do not sell or rent personal data. We do not use it for advertising or for automated decision-making that produces legal effects.
3. Who receives your data
- Service providers that help us run the Service, under contract: Cloudflare (hosting, DNS and sign-in), Stripe (invoicing and payments) and Resend, Inc. The current list is in our sub-processor list at
[URL]. - Professional advisers (legal, tax, accounting) bound by confidentiality.
- Authorities, where the law requires.
- A successor if we sell or reorganize the business, on the same terms.
4. International transfers
We are based in the United States and our providers operate in the United States and elsewhere. Where we transfer personal data from the EEA, the UK or Switzerland, we rely on the EU-US Data Privacy Framework where the recipient is certified, or on the European Commission's Standard Contractual Clauses (and the UK Addendum). You can request a copy of the safeguards at privacy@quovarne.com.
5. Your rights
Depending on where you live, you may ask us to give you access to your personal data, correct it, delete it, restrict its use, or send it to you in a portable format, and you may object to processing based on legitimate interests. Where we rely on consent you may withdraw it at any time. Write to privacy@quovarne.com; we will reply within one month. You may also complain to your data protection authority (for example, the Agencia Española de Protección de Datos in Spain or the ICO in the UK). [Counsel: add US state-law rights language only if applicable to B2B contact data.]
6. Security
We use technical and organizational measures appropriate to the data we hold, including encryption in transit, one-time-passcode sign-in, access limited to the operator and vetted providers, and data minimization. No system is completely secure. Where the law requires, we will notify you and the authorities of a breach.
7. Cookies
The public website uses no advertising, analytics or tracking cookies and no third-party trackers. We only use cookies and local storage that are strictly necessary to provide the Service you request. These do not require consent under the ePrivacy rules. [Operator: confirm after the final build.]
Cookies in use
| Name | Provider | Purpose | Duration |
|---|---|---|---|
CF_Authorization |
Cloudflare Access | Keeps you signed in to the portal after you enter your one-time passcode | Up to the session length set for the portal (set to match the session length configured in Cloudflare Access; [Operator: state the exact value]) |
__cf_bm (if present) |
Cloudflare | Bot management and protection against abuse | 30 minutes |
theme (if present; local storage) |
Quovarne | Remembers your light or dark display setting. Stays in your browser and is not sent to us | Until you clear your browser data |
Managing cookies
You can block or delete cookies in your browser settings. If you block the sign-in cookie you will not be able to use the portal.
If we add any non-essential cookie or analytics tool, we will update this policy and ask for your consent before it is set.
8. Children
The Service is for businesses and is not directed at anyone under 18.
9. Changes
We will post changes on this page with a new date and, for material changes, notify account holders by email.
10. Contact
privacy@quovarne.com · QUOVARNE SERVICES LLC, [ADDRESS].