DRAFT, pending approval. This privacy policy has not yet been approved or legally reviewed. Items marked [TO CONFIRM] are still open.

House of Seraphim

Privacy policy

Last updated: [TO CONFIRM: date of publication] Version: Draft 0.1 (17 October 2026)


1. Who we are

This Privacy Policy explains how House of Seraphim ("House of Seraphim", "we", "us", "our") collects and uses personal data when you use our websites, contact us, join our waitlist or community, or become a member.

It applies to:

together, the "Websites".

The controller responsible for your personal data is:

[TO CONFIRM: whether a Data Protection Officer or an EU/UK representative is required, and their contact details if so.]

2. The personal data we collect

We only collect what we need for the purposes described in section 3.

2.1 Data you give us

2.2 Sensitive information

Some information you choose to share may be "special category" data under the GDPR, for example:

Please only share this kind of information if you are comfortable doing so. Where we need it (for example, so our chefs can cook around an allergy), we will process it only with your explicit consent or where another legal condition applies, and only for that purpose. You can withdraw your consent at any time (see section 9).

2.3 Data collected automatically

2.4 Data from others

3. How we use your data and our legal basis

Purpose Data used Legal basis (GDPR Article 6)
Responding to your enquiry or waitlist registration, and telling you about the journey, its dates and its pricing when available Form and enquiry details Your consent (given through the consent box on the form), and our legitimate interest in responding to people who contact us
Sending you occasional news from House of Seraphim Name, email, marketing preference Your consent (optional box). You can withdraw at any time
Creating and running your member account and the community Account and profile details, community content Performance of our contract with you (the Terms of Use)
Processing shop orders, delivery, returns and customer service (when available) Order, delivery and contact details Performance of a contract; legal obligation (for tax and accounting records)
Arranging and running tours (when available) Booking details, including any health or dietary details you share Performance of a contract; explicit consent for special category data
Keeping the Websites secure and preventing abuse and fraud Technical data, IP address Our legitimate interest in protecting our services and users
Improving the Websites [TO CONFIRM: analytics data, if any analytics tool is used] [TO CONFIRM: consent, if non-essential analytics cookies are used]
Meeting legal, tax and accounting obligations, and dealing with legal claims Relevant records Legal obligation; our legitimate interest in establishing, exercising or defending legal claims

Where we rely on legitimate interests, we have considered your rights and expectations and believe they are not overridden. You can ask us for more detail about this.

We do not sell your personal data. We do not use your data for automated decision-making that has legal or similarly significant effects on you.

4. Who we share your data with

We share personal data only where necessary, with:

Our service providers act on our instructions under written agreements and must keep your data secure.

5. International transfers

Some of our providers (including Vercel and Supabase) are based in, or may access data from, the United States or other countries outside the European Economic Area (EEA). Tours take place in Egypt, so tour booking details will need to be shared with partners in Egypt.

Where personal data is transferred outside the EEA, we rely on an appropriate safeguard, such as:

[TO CONFIRM: transfer mechanism for each provider, once the entity and the Supabase region are confirmed.] You can ask us for a copy of the relevant safeguards.

6. How long we keep your data

We keep personal data only for as long as we need it:

When data is no longer needed, we delete it or make it anonymous.

7. Cookies and similar technologies

We use a small number of cookies and browser storage items. On the Travel Site, these currently include:

Strictly necessary items do not need your consent. If we introduce analytics, advertising or other non-essential cookies, we will ask for your consent first and you will be able to change your choice at any time. [TO CONFIRM: cookie banner or consent tool, if non-essential cookies are used.]

You can also block or delete cookies in your browser settings, but parts of the Websites may then not work.

8. How we protect your data

We use appropriate technical and organisational measures to protect personal data, including encrypted connections (HTTPS), access controls so that only authorised people can see submissions, database security rules that block public access to stored submissions, and limits on repeated form submissions. No method of transmission or storage is completely secure, but we work to protect your data and will act promptly if something goes wrong, including telling you and the relevant authority where the law requires it.

9. Your rights

Under data protection law you have the right to:

To use any of these rights, email us at [TO CONFIRM: contact email]. We may need to confirm your identity. We will reply within one month, which can be extended in some cases, as the law allows. There is normally no charge.

You can unsubscribe from our news at any time using the link in any email or by contacting us.

Complaints. If you are unhappy with how we have handled your data, please contact us first so we can try to put it right. You also have the right to complain to a data protection authority, in particular in the EU country where you live, work or where you believe the problem happened. [TO CONFIRM: lead supervisory authority, for example the Information and Data Protection Commissioner (IDPC) in Malta, once the entity's location is confirmed.]

10. Children

The Websites and our services are intended for adults. We do not knowingly collect personal data from anyone under 18 [TO CONFIRM: minimum age, and how children travelling with a parent or guardian on a tour will be handled]. If you believe a child has given us personal data, please contact us and we will delete it.

11. Links to other websites

The Websites may link to other sites, such as social media. We are not responsible for how those sites handle your data; please read their privacy policies.

12. Changes to this policy

We may update this policy from time to time. We will post the new version on the Websites with a new "last updated" date and, where the changes are significant, we will tell you by email or on the Websites.

13. Contact us

For any question about this policy or your personal data: