Privacy Policy

1. Who we are

This privacy policy is issued by Internet Nederland B.V., trading as Virtual Assistant International ("VAI", "we", "us").

Registered address: Willem Elsschotlaan 1, 1187WP, Amstelveen, the Netherlands
Chamber of Commerce (KvK) number: 42063743
E-mail address for privacy matters: support@virtualassistantinternational.com

We are the controller for the processing of personal data as described in this policy. We process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy legislation.

2. Who this policy applies to

This policy applies to:

• Visitors of our informational websites about working as a virtual assistant, which we operate in various countries, who sign up there for more information.
• Recipients of our e-mails.
• Customers and users of the Virtual Assistant International platform (main website, course environment and jobs platform).
• Representatives of companies looking for a virtual assistant via the platform.

3. Which personal data we process

When you sign up on one of our informational websites

Name, e-mail address, country or language of the website on which you sign up, date and time of sign-up, IP address.

When you purchase a package and use the platform

Name, address, e-mail address, account details (username, password in encrypted form), purchased package and payment status, billing details, country, course progress and certificates obtained, profile information you add yourself (such as CV, portfolio, skills, profile photo), applications and messages you send via the platform.

Payment data

Payments are processed by our payment service provider Stripe. We do not have access to full card or bank account details; we receive from Stripe the status of the payment and the data needed for our administration and tax remittance.

Automatically collected data

IP address, browser type, device information, pages visited and click behaviour, collected via PostHog (hosted in the EU) for aggregated statistics. This runs only after you click Accept on the cookie bar: we then set one first-party analytics cookie (vai_analytics_id, kept for 1 year), and no browser analytics event is sent before you accept or if you decline (see the Cookie Policy for our cookie categories). We also send events about your account activity from our server, such as starting a checkout, identified by a customer ID without your name or e-mail address.

We do not collect special categories of personal data (such as data concerning health or beliefs) and ask you not to include such data in your profile or messages.

4. Purposes and legal bases

We process personal data for the following purposes, in each case with the corresponding legal basis:

• Sending you the requested information and offers about our platform after you have signed up via one of our websites. Legal basis: your consent (Article 6(1)(a) GDPR). You can withdraw your consent at any time via the unsubscribe link in every e-mail.
• Concluding and performing the agreement: creating your account, providing courses, certificates and platform access, processing your payment and customer service. Legal basis: necessary for the performance of the agreement (Article 6(1)(b) GDPR).
• Administration and tax obligations, including invoicing and VAT remittance. Legal basis: legal obligation (Article 6(1)(c) GDPR).
• Improving and securing our websites and the platform, preventing fraud and abuse, and producing anonymised statistics. Legal basis: legitimate interest (Article 6(1)(f) GDPR).
• E-mails to existing customers about similar products and services of our own. Legal basis: legitimate interest; you can unsubscribe in every e-mail.
• Showing your profile to companies looking for a virtual assistant via the platform, insofar as you choose to do so by making your profile visible or by applying for a vacancy. Legal basis: performance of the agreement and your own action.

We do not take decisions with legal effects based solely on automated processing or profiling.

5. E-mail communication

When you sign up on one of our websites for more information, we use your e-mail address to send you that information and an offer for the Virtual Assistant International platform. The sign-up form clearly states what you are signing up for. We record the moment and manner of your sign-up so that we can demonstrate that consent was given. Every e-mail contains an unsubscribe link that lets you opt out with one click. After you unsubscribe, we keep your e-mail address only on a suppression list to ensure you no longer receive e-mails from us.

6. Who we share personal data with

We never sell your personal data. We share data only with:

• Processors that support us. These include in any case: Learnhouse (our course and learning environment; upon purchase an account is created for you there automatically, for which we pass on your name and e-mail address), Brevo (our e-mail platform for sending information, offers and service e-mails, which receives your name and e-mail address) and the providers listed below. We conclude data processing agreements with these parties where the law requires it; they may use your data only on our instructions.
• PostHog (analytics, hosted in the EU). Measures which pages are visited and how the site is used. Analytics cookies are set only after you accept them. We also send events about your account activity from our server, such as starting a checkout, identified by a customer ID without your name or e-mail address. We never send your name, e-mail address or message contents to PostHog.
• Sentry (error monitoring, hosted in the EU). Receives technical error data such as the page address, browser type, device information and IP address, so that we can find and fix faults.
• Cloudflare Turnstile (bot protection on forms). Checks that a form is filled in by a person. Cloudflare receives your IP address and browser and device signals and may set a cookie for this purpose. See our Cookie Policy.
• Chatwoot (customer support). Our support inbox, which runs on our own server in the European Union (hosted by Contabo GmbH). It stores your name, e-mail address, messages and attachments when you contact us.
• OpenAI (the chat assistant for visitors on our website). The questions you type and related help articles are sent to OpenAI to produce an answer and to check content for abuse. OpenAI does not use data sent through its API to train its models and may keep it for up to 30 days to detect abuse. Please do not enter sensitive personal data.
• Upstash (rate limiting). Keeps a short-lived counter linked to a hashed form of your IP address, so that we can slow down bots and abuse. It holds no names or e-mail addresses. It is hosted in the EU (Belgium).
• Stripe, for processing payments and calculating tax. Stripe processes your payment data partly as an independent controller; see Stripe's privacy policy for more information.
• Companies looking for a virtual assistant via the platform, only insofar as you make your profile visible or respond to a vacancy. These companies are themselves responsible for their further use of your data.
• Authorities, only where we are legally required to do so.

7. Transfers outside the EEA

Most of our providers host data in the European Union (PostHog, Sentry, Upstash and Contabo). Some providers are based in the United States or can process data there: Cloudflare (Turnstile), OpenAI (chat assistant) and Stripe (payments). For these transfers we rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework where the provider is certified, and otherwise on the European Commission's Standard Contractual Clauses. You can ask for a copy of the safeguards at support@virtualassistantinternational.com.

8. Retention periods

We do not keep personal data longer than necessary:

• Sign-ups for information that do not lead to a purchase: a maximum of 24 months after the last contact, or until the moment you unsubscribe.
• Account and course data: for as long as your account exists. We also retain certificate data afterwards so that certificates can be verified, unless you request deletion.
• Invoice and payment data: 7 years, based on the statutory tax retention obligation in the Netherlands.
• Applications and messages: for as long as your platform access is active, and thereafter for a maximum of 12 months.
• Suppression list after unsubscribing: for as long as necessary to ensure you do not receive e-mails.
• Analytics data: 1 year.
• Error reports: 90 days (performance data: 30 days).
• Support messages: a maximum of 24 months after the last contact.
• Rate-limit counters: a few minutes, then deleted automatically.

9. Security

We take appropriate technical and organisational measures to protect personal data against loss and unlawful processing, including encrypted connections (TLS), encrypted storage of passwords, access restrictions and regular updates. Payments are processed in Stripe's secure environment; we do not store full payment card details ourselves.

10. Cookies

Cookies and similar technologies are covered separately in our Cookie Policy, which explains the categories we use. Use Cookie settings in the footer to change your choice.

11. Your rights

Under the GDPR, you have the following rights:

• The right of access to the personal data we process about you.
• The right to rectification of inaccurate or incomplete data.
• The right to erasure ("right to be forgotten"), insofar as we are not legally required to retain the data.
• The right to restriction of processing.
• The right to data portability.
• The right to object to processing based on legitimate interest and to direct marketing.
• The right to withdraw consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

You can submit a request via support@virtualassistantinternational.com. We will respond within one month. To verify that the request was made by you, we may ask you to substantiate your identity. Exercising these rights is free of charge, except in the case of manifestly unfounded or excessive requests.

12. Complaints

If you have a complaint about how we handle your personal data, please contact us first via support@virtualassistantinternational.com. If we cannot resolve the matter together, you have the right to lodge a complaint with the supervisory authority. In the Netherlands this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). If you live in another EEA country, you can also contact the supervisory authority of your own country.

13. Users outside the European Economic Area

We serve visitors and customers in multiple countries. In addition to the GDPR, local privacy laws may grant additional rights, for example in the United Kingdom (UK GDPR), the United States (including the California Consumer Privacy Act) or other countries. Insofar as those laws apply to you, you can exercise the rights they contain (such as access, deletion and the right to opt out of the sale or sharing of data; we do not sell data) via support@virtualassistantinternational.com. We do not discriminate against anyone for exercising privacy rights.

14. Minors

Our services are aimed at persons aged 18 and over. We do not knowingly collect data from minors. If you suspect that a minor has provided us with data, please contact us and we will delete that data.

15. Changes

We may amend this privacy policy, for example in the event of new features or changed legislation. The current version is always available on our website. In the event of significant changes, we will inform you actively, for example by e-mail.

16. Contact

Questions about this privacy policy or about your data? Contact us via:

Internet Nederland B.V. trading as Virtual Assistant International
Willem Elsschotlaan 1, 1187WP, Amstelveen, the Netherlands
support@virtualassistantinternational.com
Or use our contact form.