BARYVO
Legal — Privacy

Privacy Policy

Effective date: 2026. Applies to all users of baryvo.com and to data subjects whose personal data is processed by dqpt LLC.

1. About this notice

This Privacy Policy explains how dqpt LLC (“Baryvo,” “we,” “us”) collects, uses, shares and protects personal data. It applies to visitors of baryvo.com, prospects and clients who contact us, and individuals whose data we process on behalf of clients in the course of our engagements.

We operate across jurisdictions. This notice covers obligations under the European Union General Data Protection Regulation (GDPR), the California Consumer Privacy Act as amended by the CPRA (collectively “CCPA”), and applicable US federal and state privacy laws.

2. Data controller / business

dqpt LLC
838 Walker Road Suite 21-2
Dover, Delaware 19901, USA
Operating team based in Barcelona, Spain

Privacy inquiries and rights requests: compliance@baryvo.com
Legal: legal@baryvo.com

For purposes of GDPR, dqpt LLC is the data controller for data collected directly through this website and through our commercial activities. Where we process personal data on behalf of clients (for example, embedded engineering or staffing engagements), dqpt LLC acts as a data processor under a separate Data Processing Agreement with the client (the controller).

3. Personal data we collect

We collect the following categories of personal data:

  • Contact data — name, business email, company name, role, country, message content. Provided directly when you contact us via the form, email, or during the discovery and onboarding stages of an engagement.
  • Engagement data — correspondence, contractual documents, invoicing details, project artefacts and meeting notes generated in the course of work.
  • Technical data — IP address, browser type, device identifiers, pages visited, referrer, approximate location derived from IP. Collected automatically via essential and analytics cookies, subject to your consent where required.
  • Marketing data — communication preferences, prior interactions with our outreach.

We do not knowingly collect sensitive personal data (special categories under GDPR Article 9, or sensitive personal information under CCPA) through our website. If sensitive data appears in client engagement materials, it is processed strictly under the relevant Data Processing Agreement.

4. Purposes of processing

  • Responding to inquiries and managing prospective and existing client relationships
  • Performing contracted services and operating client engagements
  • Invoicing, accounting, tax and statutory record-keeping
  • Securing and maintaining our website and infrastructure
  • Sending business communications about our services to existing and prospective clients
  • Complying with legal obligations and responding to lawful requests

5. Legal basis (GDPR)

For data subjects in the European Economic Area, the United Kingdom or Switzerland, we rely on the following legal bases under GDPR Article 6:

  • Performance of a contract (Art. 6(1)(b)) — processing necessary to deliver contracted services and respond to pre-contractual requests
  • Legitimate interests (Art. 6(1)(f)) — operating our business, B2B outreach to relevant decision-makers, securing our systems
  • Legal obligation (Art. 6(1)(c)) — tax, accounting, anti-money-laundering and statutory retention
  • Consent (Art. 6(1)(a)) — for non-essential cookies and certain marketing communications, where consent is required

6. Disclosure of personal data

We do not sell personal data and we do not share personal data with third parties for their independent marketing purposes. We disclose personal data only to:

  • Service providers we engage to operate our business — hosting, email, accounting, payment processing, productivity and collaboration tools. They process data on our behalf under written agreements.
  • Clients whose engagements you are working on, where you are an embedded specialist or otherwise contractually identified to the client.
  • Professional advisors — legal, audit, accounting and insurance.
  • Authorities — where required by law, court order or to protect our legal rights.
  • Successors in the event of a merger, acquisition or restructuring of dqpt LLC.

7. International transfers

dqpt LLC is incorporated in the United States and our operating team is based in the European Union. Personal data may be transferred between these jurisdictions and to service providers in other countries. For transfers from the EEA, the UK or Switzerland to the United States, we rely on appropriate safeguards, including the EU Standard Contractual Clauses and supplementary measures where applicable.

To request a copy of the safeguards in place for a specific transfer, contact compliance@baryvo.com.

8. Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including any legal, accounting or reporting requirements. Inquiry and prospect data is typically retained for 24 months after last contact. Client engagement data is retained for the duration of the relationship and for seven years thereafter for tax and statutory purposes. Cookie and technical data retention is described in our Cookie Policy.

9. Your rights under GDPR

If you are in the EEA, the UK or Switzerland, you have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate or incomplete data
  • Request erasure of your data, subject to legal retention requirements
  • Object to or restrict processing based on our legitimate interests
  • Request portability of data you have provided to us
  • Withdraw consent at any time where processing is based on consent
  • Lodge a complaint with a supervisory authority in your country of residence

To exercise these rights, contact compliance@baryvo.com. We respond within one month of receipt.

10. Your rights under CCPA (California residents)

If you are a California resident, you have the right to:

  • Know what personal information we have collected about you in the preceding 12 months, including the categories, sources, purposes and third-party recipients
  • Delete personal information we have collected from you, subject to legal retention exceptions
  • Correct inaccurate personal information we maintain about you
  • Opt out of the sale or sharing of personal information — we do not sell or share personal information for cross-context behavioral advertising
  • Limit the use of sensitive personal information — we do not use sensitive personal information beyond purposes permitted under CCPA
  • Non-discrimination — we will not discriminate against you for exercising your rights

To submit a verifiable consumer request, contact compliance@baryvo.com. We will verify your identity before responding. You may also designate an authorized agent to submit requests on your behalf, subject to verification.

11. Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure or destruction. Measures include encryption in transit, access controls, vetted service providers, and incident response procedures. No system is fully secure; we will notify affected individuals and regulators of personal data breaches as required by law.

12. Changes to this notice

We may update this Privacy Policy from time to time. Material changes will be notified through the website. The effective date at the top of this notice reflects the latest version.

13. Contact

Privacy inquiries and rights requests: compliance@baryvo.com
Legal: legal@baryvo.com
Postal: dqpt LLC, 838 Walker Road Suite 21-2, Dover, Delaware 19901, USA