Privacy Policy

Last Updated: 1 August 2026

1. Introduction

This Privacy Policy explains how Vergento LLC, a company incorporated in the State of Delaware, United States of America ("Company", "we", "us" or "our"), collects, uses, stores, retains and protects personal information provided by users of our website and services.

This Privacy Policy applies to personal information collected through our website, including information provided when you:

• contact us directly;
• submit an enquiry or request;
• request information about our services;
• communicate with us by email or through other contact facilities made available on our website;
• create or maintain an account, where applicable;
• upload or submit files, documents or other materials through our website; or,
• otherwise voluntarily provide personal information to us.

This Privacy Policy does not govern the use of cookies or similar technologies. Our use of cookies and similar technologies is addressed separately in our Cookie Policy.

We do not sell, rent, trade or otherwise supply your personal information to third parties. We also do not use third-party service providers to process your personal information on our behalf.

Personal information collected through our website is stored on systems located in Germany and Cyprus.

We are committed to handling personal information responsibly, transparently and securely, and to complying with applicable data protection and privacy laws.

2. Who We Are

The data controller responsible for your personal information is:

For the purposes of applicable European data protection legislation, including the General Data Protection Regulation ("GDPR") and, where applicable, the UK GDPR, we are the data controller in respect of personal information collected directly from you through our website, unless we expressly state otherwise.

If you have any questions about this Privacy Policy or the way in which we handle personal information, you may contact us using the details above.

3. What Information We Collect

Depending upon how you interact with our website and services, we may collect the following categories of personal information.

3.1 Information You Provide to Us

This may include:

• your name;
• email address;
• telephone number;
• postal or business address;
• company or organisation name;
• job title or professional position;
• information contained in enquiries or correspondence;
• information you provide when requesting or discussing our services;
• information contained in documents or files that you voluntarily upload; and,
• any other personal information that you voluntarily choose to provide to us.

You should not upload or provide sensitive personal information unless it is necessary for the purpose for which you are communicating with us or using our services.

Where you upload files or documents, those files may contain personal information relating to you or other individuals. You are responsible for ensuring that you have an appropriate lawful basis or other legal authority to provide such information to us.

4. Information Collected Through File Uploads

Our website may provide functionality allowing you to upload files, documents or other materials directly to us.

Files uploaded through this functionality are treated as confidential information and are handled in accordance with this Privacy Policy and any applicable contractual terms governing our relationship with you.

Uploaded files may contain personal information relating to you or third parties. We may process the personal information contained within uploaded files for purposes including:

• responding to your enquiry;
• reviewing or assessing the information you have provided;
• providing requested services;
• communicating with you about the information or documents submitted;
• administering and managing our relationship with you;
• complying with legal or regulatory obligations; and,
• establishing, exercising or defending legal claims.

You should only upload files that are relevant to your enquiry or the services you are requesting.

We may reject, delete or restrict access to files that we reasonably consider to be unlawful, malicious, technically unsafe or unrelated to the purpose for which the upload facility is provided.

5. How We Use Personal Information

We may use personal information collected through our website for the following purposes:

1. To respond to enquiries and requests for information.
2. To communicate with you about your enquiry, correspondence or relationship with us.
3. To provide, develop and administer our services.
4. To review and process documents and files submitted through our website.
5. To establish and manage commercial or professional relationships.
6. To maintain appropriate business and administrative records.
7. To comply with applicable legal, regulatory and professional obligations.
8. To establish, exercise or defend legal claims and protect our legal rights.
9. To protect the security, integrity and functionality of our website and information systems.
10. To prevent, detect and investigate fraud, abuse, unlawful activity or security incidents.
11. To maintain records necessary for accountability and regulatory purposes.
12. To communicate with you about matters directly relevant to your relationship with us.

We will not use your personal information for purposes that are incompatible with the purposes described in this Privacy Policy unless we are permitted or required to do so by applicable law.

6. Direct Contact and Marketing

We may use contact information that you provide to communicate with you directly in connection with your enquiry, request, account, transaction, services or existing relationship with us.

Where permitted by applicable law, we may also send you information about services or developments that we reasonably consider relevant to your existing relationship with us.

Where applicable law requires your consent before we send direct marketing communications, we will obtain that consent before doing so.

You may opt out of receiving direct marketing communications at any time by contacting us or by using an unsubscribe mechanism provided in the relevant communication.

Opting out of marketing communications will not prevent us from sending you non-marketing communications that are necessary for the administration of your relationship with us or that we are legally required to provide.

7. Legal Bases for Processing

Where the GDPR, UK GDPR or another similar data protection law applies, we process personal information on one or more of the following legal bases:

7.1 Performance of a Contract

We may process personal information where processing is necessary to enter into or perform a contract with you, or to take steps at your request before entering into a contract.

7.2 Legitimate Interests

We may process personal information where processing is necessary for our legitimate interests, provided those interests are not overridden by your rights and interests.

Our legitimate interests may include:

• responding to enquiries;
• managing and developing our business;
• maintaining business records;
• communicating with clients and prospective clients;
• protecting our systems and information;
• preventing fraud and misuse;
• establishing, exercising or defending legal claims; and,
• ensuring the effective operation and security of our website and services.

7.3 Legal Obligations

We may process personal information where necessary to comply with a legal, regulatory, professional or other statutory obligation.

7.4 Consent

Where required by applicable law, we may rely on your consent to process personal information for a particular purpose.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

7.5 Vital Interests

In limited circumstances, we may process personal information where necessary to protect someone's vital interests.

8. Special Categories of Personal Information

Depending upon the nature of communications or files submitted to us, we may receive information that falls within special categories of personal data under the GDPR or sensitive personal information under other applicable laws.

We do not generally request such information through our website unless it is relevant to the services or enquiry concerned.

Where we receive such information, we will process it only where permitted by applicable law and, where required, on the basis of an appropriate additional legal condition.

9. Information We Do Not Sell or Supply to Third Parties

We do not sell, rent, lease, trade or otherwise monetise personal information.

We do not supply personal information to third parties for their own marketing, advertising or commercial purposes.

We also do not provide personal information to third-party data brokers or similar organisations.

Personal information collected through our website is used by the Company for the purposes described in this Privacy Policy.

10. Third-Party Processing

At no point do we intentionally arrange for personal information collected through our website to be processed by a third party acting as a processor on our behalf.

We do not outsource the processing of personal information to third-party data processing companies.

However, nothing in this section prevents us from disclosing or transferring information where we are required or permitted to do so by applicable law, court order, regulatory authority or other lawful process.

Similarly, if the Company undergoes a merger, acquisition, restructuring, sale of assets or similar corporate transaction, personal information may be transferred as part of that transaction where permitted by applicable law and subject to appropriate safeguards.

11. Disclosure Required by Law

We may disclose personal information where we reasonably believe that such disclosure is:

• required by law;
• required by a court, tribunal or other judicial authority;
• required by a governmental or regulatory authority;
• necessary to comply with a legal process;
• necessary to protect the rights, property or safety of the Company, our clients or other individuals; or,
• necessary to establish, exercise or defend legal claims.

Where legally permitted, we will take reasonable steps to ensure that any disclosure is limited to the information reasonably necessary for the relevant purpose.

12. International Data Transfers

The Company is incorporated in Delaware, United States of America, and provides services to clients internationally.

Personal information collected through our website is stored on systems located in Germany and Cyprus.

Germany and Cyprus are both members of the European Union and are subject to the GDPR.

Where personal information is transferred from the European Economic Area ("EEA"), the United Kingdom or another jurisdiction to a jurisdiction that does not provide an equivalent level of data protection, we will ensure that the transfer is made in accordance with applicable data protection law and using an appropriate lawful transfer mechanism where required.

Depending on the circumstances, this may include:

• an adequacy decision;
• standard contractual clauses;
• an applicable derogation; or,
• another lawful transfer mechanism recognised under applicable law.

13. Data Storage and Security

We take reasonable and appropriate technical and organisational measures designed to protect personal information against:

• accidental or unlawful destruction;
• accidental loss;
• alteration;
• unauthorised disclosure;
• unauthorised access; and,
• other unlawful or unauthorised forms of processing.

Personal information collected through our website is stored on systems located in Germany and Cyprus.

Access to personal information is restricted to authorised personnel who require access for legitimate business, administrative, legal or operational purposes.

However, no method of transmitting or storing information electronically can be guaranteed to be completely secure. While we take reasonable measures to protect personal information, we cannot guarantee absolute security.

If we become aware of a personal data breach that is subject to a notification requirement under applicable law, we will take the steps required by that law.

14. File Security

Files uploaded through our website may contain confidential or sensitive information.

We take reasonable measures to protect uploaded files against unauthorised access, alteration, disclosure or destruction.

You should nevertheless ensure that files uploaded through the website are transmitted using an appropriate and secure connection and that you do not upload information that you are not authorised to disclose.

You should also maintain your own copies of important documents after uploading them to us.

15. Data Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected, subject to the specific retention period described below.

Unless a longer period is required by law or is otherwise justified by a legitimate legal or business requirement, personal information that we have collected and that has not been made use of will be retained for six (6) years from the date on which it was last used.

For the purposes of this policy, "use" includes a substantive use of the information for a legitimate business, contractual, legal, administrative or service-related purpose.

Each substantive use of personal information resets the six-year retention period.

Accordingly, where personal information continues to be actively used for a legitimate purpose, the six-year retention period will run from the date of its most recent use.

When the applicable six-year retention period expires, and the personal information is no longer required for any lawful purpose, we will securely delete, destroy or otherwise irreversibly anonymise the information.

We may retain information for longer where this is necessary:

• to comply with a legal or regulatory obligation;
• to comply with professional record-keeping requirements;
• to establish, exercise or defend legal claims;
• to resolve disputes;
• to enforce contractual rights; or,
• where otherwise permitted or required by applicable law.

Where information is retained beyond the standard six-year period for one of these reasons, it will be retained only for as long as reasonably necessary for the relevant purpose.

16. Your Rights

Depending on your location and the applicable data protection laws, you may have rights in relation to your personal information.

These may include the right to:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete personal information;
• request deletion of your personal information;
• request restriction of processing;
• object to certain processing;
• request portability of certain personal information;
• withdraw consent where processing is based on consent; and,
• lodge a complaint with an appropriate data protection or supervisory authority.

These rights are not absolute and may be subject to legal limitations or exemptions.

For example, we may be entitled or required to retain certain information to comply with legal obligations or to establish, exercise or defend legal claims.

17. Exercising Your Rights

If you wish to exercise any applicable privacy or data protection right, or if you have a question about how we process your personal information, please contact us at:

We may need to request additional information from you to verify your identity before responding to certain requests.

We will normally respond to valid requests within the time period required by applicable law.

If you are located in the EEA, the United Kingdom or another jurisdiction that provides a right to complain to a data protection authority, you may also contact the relevant supervisory authority if you believe that your personal information has been processed unlawfully.

18. Children's Privacy

Our website is not intended for children, and we do not knowingly collect personal information from children where prohibited by applicable law.

If you believe that a child has provided personal information to us without appropriate consent or authorisation, please contact us so that we can investigate and, where appropriate, delete the information.

19. Links to Other Websites

Our website may contain links to websites or services operated by third parties.

This Privacy Policy does not apply to those external websites or services.

We are not responsible for the privacy practices, security or content of third-party websites. You should review the privacy policies applicable to those websites before providing them with personal information.

20. Cookies and Similar Technologies

Our use of cookies and similar technologies is governed by a separate Cookie Policy.

The Cookie Policy explains what cookies and similar technologies we use, the purposes for which they are used, and how you can manage your cookie preferences.

The Cookie Policy forms a separate document from this Privacy Policy.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, services, legal requirements or data protection practices.

When we make changes, we will update the "Last Updated" date at the beginning of this Privacy Policy.

Where required by applicable law, we will provide additional notice or obtain consent before implementing material changes.

We encourage you to review this Privacy Policy periodically to remain informed about how we handle personal information.

22. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or our handling of personal information, please contact us:

23. Governing Language

This Privacy Policy may be made available in multiple languages.

In the event of any inconsistency between translated versions, the English-language version shall prevail, unless applicable law requires otherwise.