Privacy Policy

1. Who we are

The Verification Circle is operated by Steve Butler, trading as Luminary Diagnostics, of 4 Woodside Cottage, Stockbridge Road, North Waltham, Hampshire, RG25 2BA.

We are the data controller for personal data processed in connection with your membership. For questions about this policy or your data, contact us at hello@verification-circle.com.

We process personal data in accordance with UK GDPR and the Data Protection Act 2018.

2. What we collect

When you sign up for emails or free content

• Email address
• Name (if provided)

When you become a paying member

• Name and email address
• Payment information — processed and stored by Stripe; we never see or store your card details
• Authentication credentials — managed by Netlify Identity; your login is stored securely by Netlify
• Conversation content — when you interact with QUORO (see Section 4)

Automatically collected

• Basic usage data to maintain and improve the service
• Functional cookies for authentication and payment (see Section 7)

We do not collect sensitive personal data, special category data, or data about children.

3. How we use your data

Our lawful bases for processing are:

• Contract performance — to provide and manage your membership, process payments, and give you access to member content
• Legitimate interests — to send relevant updates, improve the service, and maintain security
• Legal obligation — where required by law

We use your data to:

• Provide and manage your membership access
• Process payments and send billing communications
• Send you community updates, new content, and service announcements
• Operate and improve QUORO and the member experience
• Respond to your enquiries and support requests
• Comply with legal and regulatory obligations

We do not use your data for automated decision-making or profiling that produces legal or significant effects.

4. QUORO and Chatbase

QUORO is powered by Chatbase, which acts as a data processor on our behalf. Conversation data is used to generate QUORO's responses and may be retained by Chatbase in accordance with their own data retention policies.

We do not share individual conversation content with other members or third parties beyond Chatbase's processing role. We have entered into appropriate data processing arrangements with Chatbase.

If you do not wish your conversations to be processed by Chatbase, you should not use the QUORO chat interface. All other membership features remain fully available to you.

5. Third-party processors

We use the following third-party services as data processors. Each operates under their own privacy policy and appropriate data processing agreements:

We do not sell your personal data to any third party, ever.

6. International transfers

Some of our processors (notably Chatbase and Netlify) are based in the United States. Where personal data is transferred outside the UK, we rely on appropriate safeguards including standard contractual clauses and, where applicable, the UK's adequacy regulations.

The most significant transfer is QUORO conversation data to Chatbase Inc. (US). This is disclosed in Section 4 and in our membership terms.

7. Cookies

We use only functional cookies — those necessary to operate the service. We do not use advertising, tracking, or analytics cookies.

By using this site and its member features, you consent to these functional cookies. You can disable cookies in your browser settings, though this will prevent you from logging in or using QUORO.

8. How long we keep your data

• Active members — we retain your data for as long as your membership is active
• After cancellation — we retain basic account and billing records for 7 years to comply with financial record-keeping requirements
• Email subscribers (non-members) — until you unsubscribe
• QUORO conversations — retained by Chatbase in accordance with their own retention policy; we do not control this retention period

After the relevant retention period, your personal data is securely deleted or anonymised.

9. Your rights

Under UK GDPR you have the following rights:

• Access — request a copy of the personal data we hold about you
• Rectification — ask us to correct inaccurate data
• Erasure — ask us to delete your data (subject to legal retention requirements)
• Portability — receive your data in a structured, machine-readable format
• Objection — object to processing based on legitimate interests
• Restriction — ask us to restrict processing in certain circumstances

To exercise any of these rights, email hello@verification-circle.com. We will respond within 30 days. We will not charge a fee for reasonable requests.

10. Contact and complaints

For any questions about this privacy policy, your data, or to exercise your rights:

This policy was last updated June 2026. We will notify members by email of any material changes before they take effect.