Privacy policy
Last updated: 9 October 2026
This policy explains how Varroy Ltd ("Varroy", "we", "us") uses personal data when you visit varroy.com or join the Varroy waitlist. We're a private limited company registered in England and Wales under company number pending (newly incorporated), with our registered office at 128 City Road, London EC1V 2NX. We're the controller of your data. ICO registration: pending.
Questions or requests: hello@varroy.com.
What we collect
- When you join the list: your email address and country. We also record when and where you signed up (page, form and any campaign tags in the link you followed, such as utm_source) and your consent record (what you agreed to and when).
- When you open our emails: whether a message was delivered, opened or clicked, so we can send less of what you ignore.
- When you browse the site: device and browser information, IP address (used to estimate country), pages viewed and referrer. We collect this through cookies and similar technologies. Anything beyond what's strictly necessary is used only if you agree (see the Cookie Policy).
- When you email us: your message and contact details. We don't knowingly collect data from anyone under 16, and we don't collect payment details (nothing is for sale yet).
Why we use it, and our lawful basis (UK GDPR / EU GDPR)
| Purpose | Lawful basis |
|---|---|
| Sending waitlist emails and launch news | Consent (you opt in; you'll receive a welcome email; you can unsubscribe any time) |
| Keeping proof of consent and honouring unsubscribes | Legal obligation and legitimate interests |
| Analytics and advertising cookies/pixels (e.g. Google Analytics, Meta, TikTok) | Consent via the cookie banner |
| Running and securing the site, strictly necessary cookies | Legitimate interests / strictly necessary |
| Replying to your emails | Legitimate interests |
Who we share it with
We use service providers who process data on our behalf under contract: - Shopify (website hosting and the cookie banner): Shopify International Ltd / Shopify Inc. - Shopify (store hosting, customer accounts and Shopify Email marketing): Shopify International Ltd, Ireland. - Cloudflare (domain, DNS and email forwarding): Cloudflare, Inc., USA. - Apple iCloud Mail (where hello@varroy.com is forwarded). - If you accept the relevant cookies: Google (Analytics), Meta (Facebook/Instagram) and TikTok, to measure and improve our advertising. - Professional advisers, and authorities where the law requires it. We don't sell your personal data for money. Advertising pixels may count as "sharing" or "sale" under some US state laws. You can opt out (see "US residents" below).
International transfers
Some providers are in the US. Transfers rely on the UK–US Data Bridge / EU–US Data Privacy Framework where the provider is certified, or on standard contractual clauses (with the UK Addendum).
How long we keep it
Waitlist data: until you unsubscribe or ask us to delete it, or 24 months after Varroy's launch if you haven't engaged with any message (then deleted). Suppression records (so we never contact you again after you opt out): kept as long as needed for that purpose. Cookie data: see the Cookie Policy. Emails to us: up to 24 months.
Your rights
UK/EU: access, rectification, erasure, restriction, objection, portability, and the right to withdraw consent at any time (unsubscribe link in every email). You can complain to the Information Commissioner's Office (ico.org.uk) or your local EU authority. Please contact us first so we can help.
US residents
Depending on your state (e.g. California, Colorado, Connecticut, Virginia, Texas), you may have the right to know, access, correct and delete your data, and to opt out of "sale", "sharing" or targeted advertising. Use the "Your privacy choices" link in the footer or email hello@varroy.com. We honour Global Privacy Control signals as an opt-out. We won't discriminate against you for using these rights. Authorised agents may contact us with proof of authority.
Changes
We'll post any changes here and update the date above. For significant changes, we'll tell people on the list.