Privacy Policy

Draft — not yet reviewed. Replace every [PLACEHOLDER] below and have this page checked by a qualified adviser before the site goes live. Then delete this notice.

Last updated: [DATE]

Who is responsible for your data

[COMPANY LEGAL NAME], [STREET ADDRESS], [POSTCODE, CITY], [COUNTRY], registered at the Chamber of Commerce under [KVK NUMBER], is the controller of the personal data described here. Contact us at [EMAIL: privacy@vernista.com].

What we collect, and why

If you subscribe to the newsletter or create an account: your email address, and your name if you give it. We use it to send you the newsletter you asked for and to run your account. Lawful basis: your consent, and performance of a contract where you hold a paid subscription.

If you pay for a subscription: billing details are handled by our payment processor, [PAYMENT PROCESSOR, e.g. Stripe]. We do not see or store your full card details.

If you comment: your name, your comment, and the account it is attached to.

When you simply read the site: technical data such as your IP address, browser and device type, the pages you visit and where you arrived from. Lawful basis: our legitimate interest in keeping the site secure and understanding what people read. See our Cookie Policy.

If you write to us: your message and contact details, so we can reply.

Who else processes it

• [HOSTING / PUBLISHING PLATFORM — e.g. Ghost(Pro), or your own hosting provider] — runs the site and stores member records
• [EMAIL PROVIDER — e.g. Mailgun] — delivers the newsletter
• [PAYMENT PROCESSOR] — handles payments
• [ANALYTICS PROVIDER, if any] — measures traffic

We do not sell your personal data, and we do not share it for anyone else's marketing.

Where your data is held

[Describe where your providers store data, and if any transfer happens outside the EEA, the safeguard relied on — for example EU Standard Contractual Clauses.]

How long we keep it

Member and subscriber records: for as long as you have an account, and [PERIOD] after you delete it. Comments: until you or we delete them. Technical logs: [PERIOD]. Correspondence: [PERIOD].

Your rights

Under the GDPR you can ask us to give you a copy of your data, correct it, delete it, restrict or object to how we use it, or hand it to another provider. Where we rely on consent — the newsletter — you can withdraw it at any time, either from the link at the foot of every email or from your account page. Withdrawing consent does not affect what we did with it beforehand.

To exercise any of these, write to [EMAIL: privacy@vernista.com]. We will reply within one month.

Complaints

If you think we have handled your data badly, please tell us first so we can put it right. You also have the right to complain to your data protection authority — in the Netherlands that is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). [Replace with the authority for your country if you are not established in the Netherlands.]

Children

Vernista is not intended for children under [AGE]. We do not knowingly collect their data.

Changes

If we change this policy we will update the date above, and tell subscribers directly where the change is significant.