1. Data controller
Varde Advisory is the data controller for the personal data we process.
Varde Advisory — Philipp Classen, Eenmanszaak
- KvK: 42146175
- BTW: NL005536442B25
- Registered address: Salland 1, 1948 RE Beverwijk
- Contact email: contact@vardeadvisory.com
2. What data we collect
We collect only the data necessary to respond to enquiries, manage engagements, and meet legal obligations:
- Name, job title, and organisation
- Business email address and phone number
- Correspondence history related to our services
- Technical and usage data from our website (IP address, browser and operating system, pages visited, referring page, time on page, and approximate country) for security and to understand how the site is used
We do not collect sensitive personal data (special categories under GDPR) unless explicitly required for a specific engagement and with your explicit consent.
3. How we use your data
- To respond to enquiries and provide our services
- To manage contracts, billing, and regulatory compliance
- To maintain the security and integrity of our website and IT systems
- To communicate updates relevant to an ongoing engagement
We do not use your data for automated decision-making or profiling.
4. Legal basis for processing
We process personal data based on:
- Contractual necessity — to perform our services
- Legitimate interests — to operate our business and secure our systems
- Legal obligation — to comply with tax, accounting, and regulatory requirements
- Consent — where explicit consent is obtained (e.g., for marketing communications)
5. Website analytics
We use a self-hosted analytics tool (Page Insights) to understand which pages are read and to detect abuse of the website. When you visit a page, our server records your IP address, browser and operating system, the page visited, the page you came from, the date and time, the approximate country derived from your IP address, and how long the page stays open.
This data is stored only on our own web server in the Netherlands and is not shared with third parties or used to follow you across other websites. No cookies are set and nothing is stored on your device. We rely on our legitimate interest (Article 6(1)(f) GDPR) in operating, improving and securing our website. You can object at any time by contacting us at contact@vardeadvisory.com.
6. Data sharing and third parties
We do not sell your data. We share data only with:
- Professional advisers (legal, accounting) bound by confidentiality
- Regulatory or law enforcement authorities when required by law
- Cloud service providers who host our email and document storage, under data processing agreements compliant with GDPR
7. Data retention
We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Typically:
- Client data: retained for the duration of the engagement plus seven years (statutory limitation period)
- Enquiry data: retained for two years unless a contractual relationship is established
- Website logs and analytics: IP addresses are shortened after 7 days so they no longer identify you; the remaining analytics records are deleted after 12 months
8. Your rights
Under the GDPR, you have the right to:
- Access the personal data we hold about you
- Request correction of inaccurate data
- Request erasure ("right to be forgotten") in certain circumstances
- Object to or restrict processing
- Request data portability
- Withdraw consent at any time
To exercise these rights, contact us at contact@vardeadvisory.com.
9. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. This includes encryption in transit, access controls, and regular security reviews.
10. Changes to this policy
We may update this privacy policy from time to time. Any changes will be posted on this page with an updated effective date.
11. Third-party services
This site loads webfonts from Google Fonts (Google LLC). When you visit a page, your browser may establish a connection to Google servers to download font files. This connection may involve the transfer of your IP address and browser information to Google. We use Google Fonts because self-hosting these specific typefaces is not covered by our current font licence. If you prefer, you can block Google Fonts via your browser or a content blocker without affecting site functionality, as system fallback fonts are provided.
12. Contact
If you have questions about this privacy policy or how we handle your data, please contact us at contact@vardeadvisory.com.
Last updated: October 2026
