Privacy and Acceptable Data Policy

This Privacy Notice explains how Verve Partners Ltd(“Verve”, “we”, “us”, “our”) collects, uses, stores, and protects personal data, and outlines your rights under applicable data protection laws, including the UK GDPR, EU GDPR, and, where applicable, the California Consumer Privacy Act (CCPA).

This notice applies to:

• Clients and prospective clients

• Website visitors

• Business partners and suppliers

• Individuals who contact us or engage with our services

Who we are

Verve Partners Ltd
Website: https://www.vervevero.com

Our corporate website is hosted in the United Kingdom and supported by our trusted third-party hosting provider, Framer. Our customer relationship management platform is provided by HubSpot. Please refer to their respective privacy policies for further information:

• https://app.eu.vanta.com/framer.com/trust/ow67ujg7iav0t6qtd1o6r2

• https://legal.hubspot.com/privacy-policy

Our Contact Details

If you have any questions about privacy at Verve, please contact:

Verve Partners Ltd,
Work.Life Bermondsey,
5-7 Tanner Street,
London, SE1 3LE

Or email: grc@vervevero.com

Company number: 06663787
ICO registration number: Z2243429

How we collect personal data

We may collect personal data when you:

• Visit or use our website

• Contact us by email, phone, or online form

• Engage with us on social media

• Attend events, conferences, or meetings

• Enquire about or purchase our products or services

• Provide services to us

Categories of personal data we collect

We may collect and process the following categories of personal data:

• Contact information (e.g. name, email address, telephone number, postal address)

• Business information (e.g. company name, job title)

• Communications you send to us

• Technical data (e.g. IP address, browser type, device information)

• Website usage data and interaction data

• Location data (where enabled or provided

We do not intentionally collect special category(sensitive) personal data. Please do not provide such information to us.

Lawful bases for processing

We process personal data only where we have a lawful basis to do so. These include:

• Legitimate interests – for operating and improving our business, marketing, and customer engagement

• Contract – where processing is necessary to provide services or fulfil contractual obligations

• Legal obligation – where required to comply with applicable laws or regulations

• Consent – where explicitly required, and where consent can be withdrawn at any time

How we use personal data

We use personal data to:

• Provide and manage our products and services

• Respond to enquiries and communications

• Send relevant business communications and marketing (where permitted)

• Improve and develop our products and services

• Secure and optimise our website and systems

• Comply with legal and regulatory obligations

• Administer recruitment and employment applications

You may opt out of marketing communications at any time by using the unsubscribe link in our communications or by contacting us directly.

Use of AI technologies

We may use AI-enabled tools to support data analysis, enhance services, and improve operational efficiency. Any use of AI is subject to appropriate technical and organisational safeguards.

Personally identifiable information is not used to train AI models. Where data is processed using AI tools, we apply data minimisation, pseudonymisation where appropriate, and human oversight. AI tools do not make automated decisions that produce legal or similarly significant effects on individuals.

Cookies and similar technologies

We use cookies and similar technologies to operate and improve our website. Details of the cookies we use and how you can manage your preferences are available in our Cookie Policy.

Public forums

Any information you disclose in public areas of our website (such as blogs or comment sections) becomes public information. Please exercise caution and avoid sharing personal data in these areas.

Data sharing and third parties

We may share personal data with trusted third parties who support our business operations, including:

• IT and communications providers

• Hosting and infrastructure providers

• Marketing and analytics partners

• Professional advisers

All third parties are required to process personal data securely and in accordance with applicable data protection laws.

Survey platforms

Verve uses trusted third-party survey platforms, including QuestionPro, to administer certain research surveys. These platforms may automatically collect technical information such as IP addresses.

IP addresses are used solely for operational purposes, including fraud prevention, quality control, and maintaining the integrity of survey data. Verve does not use IP addresses to directly identify individuals or to profile respondents. IP address data is retained only for as long as necessary for these purposes and is then securely deleted or anonymised in line with our data retention policies.

International data transfers

Where personal data is transferred outside the UK or European Economic Area, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) and International Data Transfer Agreements (IDTAs).

Data security

Verve is certified to ISO 27001 and implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, or alteration.

These measures include access controls, encryption, regular security reviews, and internal policies governing data handling. While no system can guarantee absolute security, we take all reasonable steps to protect personal data.

Data breaches

In the event of a personal data breach, we will take immediate steps to contain and assess the incident and will notify the Information Commissioner’s Office and affected individuals where required by law.

Data retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, contractual, and accounting obligations.

When personal data is no longer required, it is securely deleted or anonymised in accordance with our retention policies.

Anonymised data

We may create anonymised datasets for research, analysis, and service improvement purposes. Anonymisation is performed in line with ICO guidance to ensure individuals cannot be identified.

Your rights

Under data protection law, you have the right to:

• Access your personal data

• Request correction of inaccurate or incomplete data

• Request erasure of your personal data

• Restrict processing of your personal data

• Object to processing

• Request data portability

You may exercise these rights at any time by contacting grc@vervevero.com

Complaints

If you have a concern about how we handle your personal data, we encourage you to contact us first so we can try to resolve the issue.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113

Children’s data

Our services are not intended for children under the age of13, and we do not knowingly collect personal data from children under this age. Where we process personal data relating to minors aged 13–18, we do so in accordance with applicable law and obtain parental consent where required.

Acceptable Data Policy

Purpose

This Acceptable Data Policy governs the types of data and content that may be uploaded to or used with Verve Partners Ltd services, including Verve Maven and private Verve Intelligent Persona & Simulations (VIPS).

Agreement

By using Verve services, entering into a Statement of Work, or otherwise engaging with our products, you confirm that you have read, understood, and agree to this policy and have the authority to bind your organisation.

Definitions

Client Data – Data provided to Verve for use in Verve services or models.
Personal Data – Information relating to an identified or identifiable individual.
User – The organisation or individual authorised to use Verve services.

User responsibilities

Users confirm they have all necessary legal rights and permissions to upload any data to Verve services. Verve strongly recommends that no personal data is uploaded unless strictly necessary.

Prohibited content

Users must not knowingly upload, generate, or allow the generation of content that includes:

• Hate or discriminatory material

• Harassment or abuse

• Violence or threats

• Self-harm or eating disorder content

• Sexually explicit material

• Political campaigning or influence

• Medical or diagnostic advice

• Spam or unsolicited advertising

• Deceptive or fraudulent content

• Malware or harmful code

Contact

Questions regarding this Privacy Notice or Acceptable Data Policy can be directed to: grc@vervevero.com

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