Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your
information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the
collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The
following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to VIP
Response, Oudenoord 325 Utrecht Netherlands 3513EP.
For the purpose of the GDPR, the Company is the Data Controller.
Cookies are small files that are placed on Your computer, mobile device or any other device by a
website, containing the details of Your browsing history on that website among its many uses.
Country refers to: Netherlands
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the
Company as the legal person which alone or jointly with others determines the purposes and means of
the processing of Personal Data.
Privacy Policy for VIP Response
LANGUAGES
Device means any device that can access the Service such as a computer, a cellphone or a digital
tablet.
Personal Data is any information that relates to an identified or identifiable individual.
For the purposes for GDPR, Personal Data means any information relating to You such as a name, an
identification number, location data, online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company.
It refers to third-party companies or individuals employed by the Company to facilitate the Service, to
provide the Service on behalf of the Company, to perform services related to the Service or to assist the
Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are
considered Data Processors.
Third-party Social Media Service refers to any website or any social network website through which a
User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from
the Service infrastructure itself (for example, the duration of a page visit).
Website refers to VIP Response, accessible from www.vipresponse.nl
You means the individual accessing or using the Service, or the company, or other legal entity on behalf
of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the
User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that
can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Bank account information in order to pay for products and/or services within the Service
Usage Data
When You pay for a product and/or a service via bank transfer, We may ask You to provide information to
facilitate this transaction and to verify Your identity. Such information may include, without limitation:
Date of birth
Passport or National ID card
Bank card statement
Other information linking You to an addressWhile using Our Service, We may ask You to provide Us with certain personally identifiable information that
can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Bank account information in order to pay for products and/or services within the Service
Usage Data
When You pay for a product and/or a service via bank transfer, We may ask You to provide information to
facilitate this transaction and to verify Your identity. Such information may include, without limitation:
Date of birth
Passport or National ID card
Bank card statement
Other information linking You to an address

Usage Data

Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address),
browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the
time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information
automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID,
the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You
use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You
access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain
information. Tracking technologies used are beacons, tags, and scripts to collect and track information and
to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your
browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept
Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser
setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to
collect and store information about Your preferences or Your activity on our Service. Flash Cookies are
not managed by the same browser settings as those used for Browser Cookies. For more information on
how You can delete Flash Cookies, please read “Where can I change the settings for disabling, or
deleting local shared objects?” available at https://helpx.adobe.com/flash-player/kb/disable-localshared-objectsflash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known
as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company,
for example, to count users who have visited those pages or opened an email and for other related
website statistics (for example, recording the popularity of a certain section and verifying system and
server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or
mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web
browser. You can learn more about cookies here: All About Cookies by TermsFeed.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to
enable You to use some of its features. They help to authenticate users and prevent fraudulent use of
user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We
only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as
remembering your login details or language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter your preferences every time You
use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use
the Website. The information gathered via these Cookies may directly or indirectly identify you as an
individual visitor. This is because the information collected is typically linked to a pseudonymous
identifier associated with the device you use to access the Website. We may also use these Cookies to
test new pages, features or new functionality of the Website to see how our users react to them.
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies
Policy or the Cookies section of our Privacy Policy

Use of Your Personal Data

The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You
provide can give You access to different functionalities of the Service that are available to You as a
registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase
contract for the products, items or services You have purchased or of any other contract with Us
through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic
communication, such as a mobile application’s push notifications regarding updates or informative
communications related to the functionalities, products or contracted services, including the security
updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and
events which we offer that are similar to those that you have already purchased or enquired about
unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether
as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data
held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying
usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve
our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and
analyze the use of our Service, for payment processing, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or
during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion
of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those
affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries,
joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain
products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with
other users, such information may be viewed by all users and may be publicly distributed outside. If You
interact with other users or register through a Third-Party Social Media Service, Your contacts on the
Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity.
Similarly, other users will be able to view descriptions of Your activity, communicate with You and view
Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your
consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this
Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal
obligations (for example, if we are required to retain your data to comply with applicable laws), resolve
disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for
a shorter period of time, except when this data is used to strengthen the security or to improve the
functionality of Our Service, or We are legally obligated to retain this data for longer time periods

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other
places where the parties involved in the processing are located. It means that this information may be
transferred to — and maintained on — computers located outside of Your state, province, country or other
governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your
agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in
accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization
or a country unless there are adequate controls in place including the security of Your data and other
personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We
will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy
Policy

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do
so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over
the Internet, or method of electronic storage is 100% secure. While We strive to use commercially
acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect,
store, use, process and transfer information about Your activity on Our Service in accordance with their
Privacy Policies.

Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic.
Google uses the data collected to track and monitor the use of our Service. This data is shared with
other Google services. Google may use the collected data to contextualize and personalize the ads of
its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing
the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript
(ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web
page: https://policies.google.com/privacy

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party
services for payment processing (e.g. payment processors).
We will not store or collect Your payment card details. That information is provided directly to Our third-party
payment processors whose use of Your personal information is governed by their Privacy Policy. These
payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards
Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS
requirements help ensure the secure handling of payment information.

PayPal

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full
When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide
information to facilitate this transaction and to verify Your identity.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:
Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an
agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to
which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of
another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or
in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests
pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing,
and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can
exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have
on You. Whenever made possible, you can access, update or request deletion of Your Personal Data
directly within Your account settings section. If you are unable to perform these actions yourself, please
contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about
You.
Request correction of the Personal Data that We hold about You. You have the right to to have any
incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate
interest as the legal basis for Our processing and there is something about Your particular situation,
which makes You want to object to our processing of Your Personal Data on this ground. You also have
the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal
Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have
chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that
this right only applies to automated information which You initially provided consent for Us to use or
where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If
You withdraw Your consent, We may not be able to provide You with access to certain specific
functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please
note that we may ask You to verify Your identity before responding to such requests. If You make a request,
We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal
Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data
protection authority in the EEA.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally
identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware
that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from anyone under the age of 13 without verification of parental consent, We take
steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires
consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link,
You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site
You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any
third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new
Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming
effective and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are
effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:
By email: [email protected]