Privacy Policy
Last updated: 25 June 2026
This policy explains how we collect, use, and protect personal data when you use this site or engage our services. It is written to be transparent under both the EU General Data Protection Regulation (GDPR) and China's Personal Information Protection Law (PIPL). This is a prototype; entity-specific details below are placeholders.
Who is responsible for your data
The data controller is Raubourg Capital Ltd, a company established in Cyprus, EU, with registered address at Diagorou 4, Kermia Building, 3rd Floor, Office 301, 1097 Nicosia, Cyprus. For any privacy matter, including the requests described below, contact our data protection contact at hello@veloriaib.com.
What we collect
We collect details you provide directly — such as your name, company, job title, email, phone number, the services you are interested in, and the content of your inquiry or order. We also process limited technical data needed to operate the site and complete purchases, including your country for tax purposes and information from our payment processor. We do not seek sensitive personal information.
How and why we use it (legal bases)
Under the GDPR we rely on: performance of a contract (to provide services and process orders); your consent (for inquiries you submit and any optional communications); and our legitimate interests (to operate, secure, and improve our services), balanced against your rights. Under the PIPL, where it applies, we process your personal information on the basis of your consent or as necessary to conclude or perform a contract to which you are a party.
Cross-border transfers (China and the EU)
As a Cyprus (EU) company serving clients in China, your personal information may be transferred between the EU and China. Where the PIPL applies, we will provide the required notice and obtain separate consent before transferring personal information outside China, and rely on a lawful transfer mechanism such as the China SCCs, certification, or another route recognised under the PIPL. For transfers out of the EEA we rely on adequacy decisions or the EU Standard Contractual Clauses. Details of the specific mechanism are a placeholder in this prototype.
How long we keep it
We retain personal data only as long as needed for the purpose it was collected, to provide the service you requested, and to meet legal, tax, and accounting obligations. Inquiry data is kept for as long as needed to respond and for a reasonable follow-up period; transaction records are kept for the period required by law. Specific retention periods are a placeholder in this prototype.
Your rights
Subject to applicable law, you may request access to your personal data, correction of inaccurate data, erasure, restriction or objection to certain processing, and portability of data you provided to us. Where processing is based on consent, you may withdraw it at any time without affecting prior processing. Under the PIPL you also have rights to access, copy, correct, and delete your personal information and to ask us to explain our processing rules. To exercise any right, contact our privacy contact above; you also have the right to complain to your local supervisory authority.
Security
We apply reasonable technical and organisational measures appropriate to a prototype service. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.