Privacy Policy, Terms of Service and Cookie Notice

1. Who We Are

1.1. Data Controller

The data controller in respect of personal data collected through this website and in connection with our services is:

2. What Personal Data We Collect

2.1. Data you provide directly

When you contact us, submit an enquiry form, request a consultation, or engage our services, we may collect:

• Full name and preferred form of address
• Email address and telephone number
• Company name, job title, or professional role (where relevant)
• Nature of your enquiry or service request
• Any additional personal information you voluntarily provide in correspondence

2.2. Data collected automatically

When you visit this website, we may collect certain technical data automatically, including:

• IP address and approximate geographic location derived from it
• Browser type, version, and language settings
• Device type and operating system
• Pages visited, time spent on pages, and referral source
• Analytics data where you have consented to the use of analytics cookies

2.3. Data we do not collect

We do not collect special categories of personal data (including health, biometric, or financial data) through this website. If any such information becomes relevant to a specific service engagement, it will be governed by a separate service agreement with enhanced safeguards.

3. How We Use Your Personal Data

3.1. Lawful basis for processing

We process your personal data on the following lawful bases under the Data Protection Act, 2019:

• Consent — where you have given clear and informed consent (e.g. analytics cookies)
• Legitimate interests — for responding to enquiries, preventing misuse, and maintaining website security, where such interests are not overridden by your rights
• Contractual necessity — where processing is required to fulfil a service engagement
• Legal obligation — where processing is required to comply with applicable law

3.2. Purposes of processing

• Responding to your enquiries and consultation requests
• Managing and delivering our concierge and lifestyle management services
• Operating, maintaining, and improving this website
• Preventing fraud, unauthorized access, and other misuse
• Complying with legal, regulatory, and record-keeping obligations
• Measuring website performance where analytics consent has been granted

3.3. Marketing communications

We will only send you marketing or promotional communications where you have expressly requested or consented to receive them. You may withdraw consent at any time by contacting us at inquiry@velar-prive.com.

4. Cookies and Tracking Technologies

4.1. Essential cookies

This website uses essential cookies necessary for core site functions, including storing your cookie consent preference. These cookies do not require your consent as they are strictly necessary for the website to operate.

4.2. Analytics cookies

Where you provide consent through our cookie banner, we may use Google Analytics 4 (GA4) to collect anonymized data about how visitors use this website. Analytics cookies are activated only after your consent is recorded and remain blocked if you reject or withdraw consent.

4.3. Managing your cookie preferences

You may update your cookie preferences at any time by clearing your browser storage or by contacting us. Withdrawing analytics consent does not affect the lawfulness of any prior processing carried out on the basis of that consent.

5. How We Share Your Personal Data

5.1. Third-party service providers

We may share your personal data with trusted third-party service providers who assist us in operating this website and delivering our services, including hosting providers, analytics platforms, and communication tools. These providers are contractually required to process personal data only on our instructions and to maintain appropriate security standards.

5.2. Vetted partner network

Where the delivery of a specific service request requires engaging a third-party partner (for example, a travel provider, hospitality venue, or specialist vendor), only the information strictly necessary to fulfil your request will be shared, subject to appropriate confidentiality undertakings.

5.3. Legal disclosures

We may disclose personal data to competent authorities or courts where required to do so by applicable law, legal process, or to protect the rights, property, or safety of Velar Privé, our clients, or third parties.

5.4. We do not sell personal data

We do not sell, rent, or trade your personal data to any third party for their own commercial purposes.

6. International Data Transfers

6.1. Transfers outside Kenya

Where we use third-party service providers located outside Kenya (for example, cloud hosting or analytics platforms), your data may be transferred to and processed in other jurisdictions. Such transfers will only occur where appropriate safeguards are in place in accordance with the Data Protection Act, 2019, including through standard contractual clauses or equivalent mechanisms recognized under Kenyan law.

7. Data Retention

7.1. How long we keep your data

We retain personal data only for as long as is reasonably necessary for the purposes for which it was collected, including:

• Responding to enquiries: up to 12 months after the enquiry is resolved, unless an ongoing service engagement requires longer retention
• Active service engagements: for the duration of the engagement and a reasonable period thereafter for dispute resolution and record-keeping
• Legal and regulatory compliance: as required by applicable law
• Website security logs: up to 90 days

Analytics data retention is configured to the shortest reasonable period within GA4 settings.

8. Your Rights

8.1. Rights under the Data Protection Act, 2019

As a data subject under Kenyan law, you have the following rights in relation to your personal data:

• Right to be informed — to receive clear information about how your data is processed
• Right of access — to request a copy of the personal data we hold about you
• Right to rectification — to request correction of inaccurate or incomplete data
• Right to erasure — to request deletion of your data in appropriate circumstances
• Right to object — to object to processing based on legitimate interests
• Right to restriction — to request that we restrict processing in certain circumstances
• Right to data portability — to receive your data in a structured, commonly used format

8.2. How to exercise your rights

To exercise any of the above rights, please contact us in writing at inquiry@velar-prive.com. We will respond within the timeframe required by the Data Protection Act, 2019. We may ask you to verify your identity before processing your request.

8.3. Right to complain

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the Office of the Data Protection Commissioner of Kenya (ODPC) at www.odpc.go.ke.

9. Data Security

9.1. Security measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures are proportionate to the nature and sensitivity of the data we process.

9.2. Limitation

No method of electronic transmission or storage is entirely secure. While we take our obligations seriously, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify the ODPC and, where required, affected data subjects, in accordance with the Data Protection Act, 2019.

10. Third-Party Links

This website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites and recommend that you review their privacy policies independently.

11. Children

This website and our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that personal data of a minor has been submitted without appropriate consent, we will take steps to delete it promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the services we offer, or applicable law. The "Effective date" at the top of this page will be updated accordingly. Continued use of this website after any update constitutes acceptance of the revised policy.

13. Contact

1. About Velar Privé

Velar Privé is a private concierge and lifestyle management service providing executive, travel, lifestyle, and personal support services to individuals and organizations. Our registered place of business is in Nairobi, Kenya. All enquiries: inquiry@velar-prive.com.

2. Use of This Website

2.1. Permitted use

You may use this website for lawful purposes only — specifically, to learn about our services, submit genuine enquiries, and communicate with us in good faith. This website is intended for adults aged 18 and over.

2.2. Prohibited conduct

You must not:

• Use this website for any unlawful, fraudulent, or harmful purpose
• Submit false, misleading, or fabricated information
• Attempt to gain unauthorized access to any part of this website or its underlying systems
• Upload or transmit malicious code, viruses, or disruptive material
• Interfere with the availability, integrity, or performance of this website
• Harvest, scrape, or collect data from this website without our prior written permission
• Use automated tools to access or interact with this website

2.3. Website availability

We reserve the right to suspend, restrict, or withdraw access to this website or any part of it at any time and without notice, including for maintenance, security, or commercial reasons. We do not warrant that the website will be uninterrupted, error-free, or free from technical issues.

3. Enquiries and Consultations

3.1. No binding contract on enquiry

Submitting an enquiry form, requesting a consultation, or contacting us through this website does not create a binding service contract. A service engagement only comes into effect when expressly agreed in writing between you and Velar Privé, typically through a signed service agreement or accepted service schedule.

3.2. Response times

We endeavour to respond to all genuine enquiries promptly. Response times are not guaranteed and may vary depending on the nature and complexity of the request. Priority response times apply only to active members holding a retainer engagement at the applicable tier.

3.3. Discretion and selectivity

Velar Privé reserves the right to decline any enquiry or engagement at its sole discretion without being required to provide a reason. We accept new clients and engagements selectively to maintain service quality and confidentiality standards.

4. Service Engagements

4.1. Governing terms

The specific terms of any service engagement — including scope, deliverables, timescales, fees, retainer arrangements, and third-party costs — are governed by the service agreement or corporate service schedule agreed with you in writing. These Terms of Service apply to your use of this website and form part of the general framework for our relationship.

4.2. Third-party costs

Unless expressly stated otherwise in a service agreement, third-party costs incurred in the delivery of your requests (including but not limited to travel bookings, reservations, procurement, and vendor fees) are payable by you in addition to any retainer or service fee. We will communicate such costs to you in advance wherever reasonably practicable.

4.3. Limitations of service

Velar Privé will not accept, facilitate, or carry out any request that is unlawful under Kenyan law or the laws of any relevant jurisdiction, that presents a legal, reputational, or security risk, or that requires us to act in breach of any third party's rights. We reserve the right to decline or discontinue any request on these grounds without liability.

5. Membership Tiers

5.1. Membership model

Membership at Velar Privé is available at three tiers — Basic, Gold, and Black — as described on our memberships page. Membership is subject to availability and is accepted at our sole discretion. Membership does not guarantee the availability of any specific service or third-party resource.

5.2. Retainer terms

Gold and Black memberships are provided on a retainer basis. Retainer fees secure availability, priority access, and service continuity; they are not fees for specific tasks. Third-party costs and out-of-scope requests are billed separately. Retainer terms, renewal, and termination provisions are set out in the applicable membership agreement.

5.3. Member obligations

Members agree to:

• Provide accurate and complete information necessary for service delivery
• Communicate requests in good faith and within reasonable timescales
• Pay all agreed fees and approved third-party costs promptly
• Comply with these Terms of Service and the applicable membership agreement

6. Intellectual Property

6.1. Ownership

All content on this website — including text, design, graphics, layout, branding, photography, and any other material created by or for Velar Privé — is the property of Velar Privé or its licensors and is protected by applicable intellectual property laws.

6.2. Permitted use

You may view and print content from this website for your own private, non-commercial purposes. You may not copy, reproduce, republish, distribute, transmit, modify, or exploit any content from this website for commercial purposes without our prior written consent.

6.3. Trademarks

The name "Velar Privé", associated logos, and brand elements are the intellectual property of Velar Privé. Nothing on this website grants any license to use these marks without express written permission.

7. Confidentiality

7.1. Our commitment

Discretion is fundamental to everything we do. We treat all client information — including identity, the nature of requests, personal details, and any information shared in the course of an engagement — as strictly confidential. We do not discuss, disclose, or reference client engagements to any third party, except as strictly necessary to fulfil a request or as required by law.

7.2. Your obligations

Any non-public information about Velar Privé, its partners, or its operations that you may come into possession of through your engagement with us should be treated as confidential and must not be disclosed to third parties without our prior written consent.

8. Disclaimers and Limitation of Liability

8.1. Website provided "as is"

To the maximum extent permitted by applicable law, this website is provided on an "as is" and "as available" basis. We make no warranties, express or implied, regarding the accuracy, completeness, or fitness for purpose of any content on this website, or that access will be uninterrupted or error-free.

8.2. Limitation of liability

To the fullest extent permitted by Kenyan law, Velar Privé shall not be liable for any indirect, incidental, consequential, or special loss or damage arising out of or in connection with your use of this website or our services, including but not limited to loss of profit, loss of data, or loss of opportunity.

8.3. Non-excludable liability

Nothing in these Terms of Service limits or excludes any liability that cannot lawfully be excluded under the Consumer Protection Act, 2012 or any other applicable Kenyan law, including liability for fraud, gross negligence, or willful misconduct.

8.4. Third-party services

Where we engage third-party vendors, suppliers, or partners on your behalf, we act as your agent in coordinating those services. We are not responsible for the acts, omissions, quality, or performance of third parties, except to the extent of any negligence on our part in selecting or instructing them.

9. Indemnity

You agree to indemnify and hold harmless Velar Privé, its officers, employees, and partners from and against any claims, losses, costs, or liabilities (including reasonable legal fees) arising out of or relating to your use of this website in breach of these Terms of Service, any false or misleading information you have provided, or your breach of any applicable law.

10. Links to Third-Party Websites

This website may contain links to third-party websites for your convenience. These links do not constitute our endorsement of those sites or their content. We are not responsible for the accuracy, legality, or content of any third-party website, and we recommend you review their own terms and privacy policies.

11. Changes to These Terms

We may update these Terms of Service from time to time. The "Effective date" at the top of this document will reflect the date of the most recent revision. Continued use of this website after any update constitutes your acceptance of the revised terms. Material changes will be communicated through a notice on this website.

12. Governing Law and Jurisdiction

12.1. Governing law

These Terms of Service and any dispute arising out of or in connection with your use of this website are governed by and shall be construed in accordance with the laws of Kenya.

12.2. Jurisdiction

Subject to any mandatory consumer protection provisions, you agree to submit to the exclusive jurisdiction of the competent courts of Kenya in respect of any dispute arising under or in connection with these Terms of Service.

13. Contact