PRIVACY POLICY

This Privacy Policy explains how Velin Privé ("Company," "we," "us," or "our") collects, uses, stores, shares, and protects personal data when you visit our website, submit an application, create a profile, purchase services, attend events, communicate with us, or otherwise use our matchmaking, introductions, and related services (collectively, the "Services"). It covers both website visitors and applicants or members because data is collected across consultations, profiles, and introductions.

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with applicable privacy rights, this Policy is intended to provide the transparency required under data-protection laws.

This Privacy Policy applies to personal data collected through:

• The website and any application forms.

• Consultation calls, interviews, intake forms, assessments, and onboarding materials.

• Matchmaking profiles, preference questionnaires, and communications with matchmakers.

• Events, introductions, and member interactions facilitated by the Company.

• Payment, billing, customer support, fraud-prevention, and compliance processes.

BRIEFLY S.L. (NIF ES B75413047), trading as Velin Privé, is the data controller responsible for the personal data described in this Privacy Policy.

Operational and correspondence address: Calle Llobregós 194 ático 4

Email: privacy@velinprive.com

Depending on how you interact with the Services, we may collect the following categories of personal data:

• Identity and contact data: name, title, email address, phone number, postal address, date of birth, age, gender, pronouns, and, where needed for verification, nationality and government-issued identification details.

• Profile data: photos, education, occupation, lifestyle details, values, hobbies, preferences, relationship goals, location preferences, and information you choose to provide in your profile or consultations.

• Verification and diligence data: identity documents, references, publicly available professional or social profile information, and notes from screening or suitability reviews, where permitted by law.

• Communications data: emails, messages, call notes, meeting notes, scheduling records, customer support inquiries, and feedback.

• Transaction data: membership purchases, invoices, payment confirmations, and limited billing information processed by us or our payment providers.

• Technical and usage data: IP address, device data, browser type, log files, cookies, page views, clickstream data, and similar website analytics information.

• Event data: RSVP status, guest preferences, attendance history, and incident or conduct reports connected to Company-hosted events.

• Sensitive or special-category data: where voluntarily provided and legally permitted, this may include information relating to health, religion, ethnicity, political views, sexual orientation, or other sensitive characteristics that may be relevant to your matching preferences.

We may receive personal data about you from:

• Referral partners, introducers, or people who refer you to the Services.

• Publicly available sources such as professional networking profiles or business websites, where relevant to application review or verification.

• Other members or users who provide feedback after an introduction or event, to the extent permitted by law and our legitimate interests in operating a safe service.

• Fraud-prevention, identity-verification, and compliance providers where used.

We use personal data for the following purposes:

• To review applications, assess eligibility, and onboard members.

• To create and manage profiles and internal matchmaking records.

• To identify, evaluate, and facilitate introductions, matches, and event invitations.

• To communicate with you about your membership, consultations, introductions, scheduling, support requests, and service updates.

• To process payments, maintain records, and administer contracts.

• To verify identity, detect fraud, prevent misuse, investigate reports, and protect the safety and integrity of the community.

• To improve the website, user experience, operations, and service quality.

• To comply with legal obligations, resolve disputes, enforce our Terms, and defend legal claims.

• To send marketing or event communications where allowed by law or based on your consent or other valid legal basis.

Where the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), or other data protection laws apply, we process personal data under one or more of the following lawful bases:

• Contract: where processing is necessary to take steps at your request before entering into a contract, or to provide the Services after you become a client or member.

• Legitimate interests: where processing is necessary for legitimate business interests such as reviewing applications, administering the service, making compatible introductions, maintaining records, improving safety, detecting fraud, and protecting the business, provided those interests are not overridden by your rights.

• Consent: where required, including for certain marketing communications, the use of cookies that need consent, and processing of special-category data.

• Legal obligation: where processing is necessary to comply with applicable laws, court orders, tax obligations, regulatory requests, or law-enforcement requirements.

Because matchmaking may involve highly personal preferences and personal background details, some information collected may qualify as sensitive or special-category personal data under applicable law. We will only collect and use sensitive data where you have clearly chosen to provide it and where we have a valid legal basis to do so, including explicit consent where required.

Sensitive data may be used to better understand compatibility preferences, tailor introductions, or accommodate personal requirements, but only within the limits of applicable law and internal access controls. You are not required to provide sensitive data, but choosing not to do so may limit the degree to which we can tailor certain introductions.

We encourage you to provide only the information necessary for us to respond to your inquiry or provide our Services. Unless specifically requested as part of our onboarding or matchmaking process, please avoid including sensitive or special-category personal data (such as information relating to health, religious beliefs, ethnicity, political opinions, or sexual orientation) in contact forms, emails, or initial communications.

If you choose to provide such information voluntarily, you acknowledge that it may be processed in accordance with this Privacy Policy and applicable data protection laws, including on the basis of your explicit consent where required.

To provide the Services, we may prepare a profile, summary, or internal assessment based on the information you provide in applications, interviews, questionnaires, and consultations. We may share selected portions of your profile with potential matches on a limited basis, such as first name, age range, photos, location, professional background, interests, and high-level compatibility details.

We aim to limit disclosure to information reasonably necessary to facilitate an introduction. We do not promise to share all profile details, and we may withhold direct identifiers until there is sufficient mutual interest or another appropriate basis to do so.

We may create internal notes, assessments, compatibility observations, safety flags, and service-quality records based on interviews, interactions, event reports, and feedback from introductions. These records help operate a curated service, protect users, and improve the quality and safety of introductions.

Where permitted by law, such internal materials may be withheld from disclosure to protect the privacy of other individuals, preserve confidential evaluations, or maintain the integrity of the service.

We may share personal data in the following circumstances:

• With selected potential matches or members as reasonably necessary to facilitate introductions, subject to confidentiality expectations.

• With service providers who support payment processing, hosting, analytics, communication tools, scheduling, document management, customer support, security, or professional advisory services.

• With affiliated entities or internal staff who need the information to provide the Services, subject to role-based access controls.

• With legal, regulatory, or law-enforcement authorities where required by law, subpoena, court order, or to protect rights, property, safety, or legal claims.

• In a business transfer such as merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality safeguards.

• With your consent or at your direction.

We do not sell personal data in the ordinary sense of selling member information to unrelated third parties for broad commercial exploitation unless expressly disclosed and legally permitted.

We and certain of our service providers may be located outside your country of residence, including in the United States. As a result, your personal data may be transferred to and processed outside the European Economic Area (EEA) and the United Kingdom.

Where required, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) for transfers from the EEA.

• The UK International Data Transfer Agreement (IDTA) or UK Addendum to SCCs for transfers from the UK.

• Reliance on adequacy decisions where available.

You may request further information about these safeguards at privacy@velinprive.com.

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the Services, maintaining records, resolving disputes, complying with legal obligations, and protecting the business and users.

We use reasonable technical and organizational safeguards designed to protect personal data against unauthorized access, alteration, disclosure, loss, or misuse.

No system can be guaranteed completely secure, and no transmission over the internet is entirely risk-free. You are responsible for maintaining the security of your own devices and communications channels used to interact with us.

When you visit our website, we and our service providers may use cookies (small text files placed on your device) and similar technologies such as pixels and local storage to operate the website, remember your preferences, analyze traffic, improve performance, and support security.

Depending on your jurisdiction, you may have rights to:

• Request access to the personal data held about you.

• Request correction of inaccurate or incomplete personal data.

• Request deletion of personal data in certain circumstances.

• Request restriction of processing in certain circumstances.

• Object to processing based on legitimate interests, including certain profiling or direct marketing uses.

• Request portability of certain data where processing is based on consent or contract and carried out by automated means.

• Withdraw consent at any time where processing is based on consent, without affecting prior lawful processing.

• Lodge a complaint with a supervisory authority or other privacy regulator.

These rights are not absolute, and some exceptions apply. In matchmaking contexts, we may be unable to provide access to personal data that would reveal another person's information, confidential assessments, or protected feedback.

We may send you communications that are necessary for the provision of our Services, including messages related to your account, applications, consultations, introductions, transactions, support requests, important service updates, and matchmaking event invitations.

These communications are essential for the performance of our contract with you or our legitimate interests in operating the Services, and you may not opt out of receiving them where they are necessary.

We may send promotional messages where permitted by law and based on your consent or another valid legal basis. You may opt out of marketing communications at any time by using the unsubscribe link in our emails or by contacting us directly.

The Services are not intended for children, and we do not knowingly collect personal data from anyone under 18 in connection with matchmaking services. If we learn that personal data has been collected from a minor in violation of applicable law, we will take reasonable steps to delete it.

To provide our Services, we apply structured profiling based on the information you provide, combined with professional human assessment. This may include compatibility analysis, preference mapping, and curated match recommendations. These processes are designed to enhance the quality and relevance of introductions.

We do not carry out decision-making based solely on automated processing that produces legal or similarly significant effects within the meaning of Article 22 GDPR. All matchmaking decisions involve human judgment and discretion.

The website or communications may contain links to third-party websites, platforms, social media services, or payment processors. We are not responsible for the privacy practices of third parties, and you should review their privacy notices before sharing data with them.

We may update this Privacy Policy from time to time to reflect changes in the Services, legal requirements, technology, or business practices. When we make material changes, we will post the updated version on the website and update the "Last Updated" date, and we may provide additional notice where required by law.

If you have questions about this Privacy Policy or our data practices, contact:

BRIEFLY S.L. (NIF ES B75413047), trading as Velin Privé

Calle Llobregós 194 ático 4

Email: privacy@velinprive.com