Legal
Privacy Policy
This notice applies when you use our Services: our website at vnpmedia.com, our client platform at portal.vnpmedia.app, and any landing page or funnel we operate on a subdomain of vnpmedia.com, including scale.vnpmedia.com. It covers the tracking pixels we place on those pages. Questions? Email [email protected].
01 What information do we collect?
Personal information you disclose to us
In short: we collect personal information that you provide to us.
We collect personal information that you voluntarily provide when you register on the Services, express an interest in our products and Services, participate in activities on the Services, or otherwise contact us. This may include names, phone numbers, email addresses, mailing addresses, job titles, usernames, passwords, contact preferences, contact or authentication data, billing addresses, and company or business name.
Sensitive information. We do not process sensitive information.
Information automatically collected
In short: some information, such as your IP address and browser and device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This includes log and usage data (IP address, device information, browser type, activity in the Services, error reports), device data, and location data. This information is primarily needed to maintain the security and operation of our Services and for internal analytics and reporting. We also collect information through cookies and similar technologies.
Information collected from other sources
In short: we may collect limited data from public databases, marketing partners, and other outside sources.
To enhance our ability to provide relevant marketing and services and to update our records, we may obtain information about you from sources such as public databases, joint marketing partners, affiliate programs, and data providers.
02 How do we process your information?
In short: we process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process it for other purposes with your consent.
- To facilitate account creation, authentication, and manage user accounts.
- To deliver and facilitate delivery of services to the user.
- To respond to user inquiries and offer support.
- To send administrative information, such as updates to our terms and policies.
- To send you marketing and promotional communications (you can opt out at any time).
- To request feedback and to protect our Services (fraud monitoring and prevention).
- To identify usage trends and improve the Services.
- To calculate billing and issue invoices, using your account and usage information to calculate the fees you owe, generate and issue invoices, take payment, and keep accurate billing records.
- To produce anonymized, aggregated benchmarks, using aggregated performance metrics across our customer base to calculate peer benchmarks (such as median cost per show or show rate).
03 What legal bases do we rely on?
In short: we only process your personal information when we have a valid legal reason to do so under applicable law.
If you are located in the EU or UK, we rely on the following legal bases: consent (which you can withdraw at any time), performance of a contract, legitimate interests (such as analyzing how the Services are used, preventing fraud, and showing each customer how their performance compares to an anonymized peer average), legal obligations, and vital interests.
If you are located in Canada, we process your information with your express or implied consent, which you can withdraw at any time, and in certain limited cases permitted by law without consent.
04 When and with whom do we share your information?
In short: we may share information in specific situations and with the third parties below, each bound by a data-processing agreement.
The categories of third parties we may share personal information with include:
- Advertising, direct marketing, and conversion measurement: Meta (Facebook and Instagram Ads plus Conversions API).
- AI service providers: Anthropic.
- Connecting your third-party accounts: Meta and GoHighLevel.
- Cloud database: Neon.
- Website hosting: Vercel.
- CRM and lead management: GoHighLevel.
- Transactional email delivery: Resend.
- Invoicing and payments: Stripe.
- Internal operational alerts to our team: Slack. Some alerts contain a client contact's name or email address.
- Data-subject request form: Termly, which hosts the request form linked below.
- Rate limiting and caching: Upstash. Short-lived counters and aggregates only.
- Session analytics on our own recruitment pages: Microsoft (Clarity). Not used on client landing pages and not used inside the portal. See our Cookie Policy.
We may also share your information in connection with a business transfer (merger, financing, or acquisition) and with business partners to offer certain products, services, or promotions. A full list of our sub-processors is on our Sub-processors & Data Retention page.
05 Do we use cookies and other tracking technologies?
In short: we may use cookies and similar technologies to collect and store your information.
We use cookies and similar tracking technologies (like web beacons and pixels) to maintain security, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. Specific details about the cookies we use and how to refuse them are set out in our Cookie Policy.
Meta Pixel and Conversions API
Our customers landing pages use the Meta Pixel and a server-side Conversions API (CAPI) to measure the performance of advertising and to improve ad targeting and optimization. Through the Conversions API we share hashed (SHA-256) identifiers, such as a hashed email address or phone number, together with event data (for example, that a landing page was viewed or a form was submitted) with Meta Platforms. We never send raw email addresses or phone numbers; identifiers are hashed before they leave our systems. The purpose is conversion measurement and advertising optimization for the campaign that brought you to the page. Where required by law, this tracking is subject to your consent, which you can give or decline through the cookie banner and manage via our Cookie Policy.
06 Do we offer AI-based products?
In short: we offer products and features powered by artificial intelligence and machine learning.
We provide AI products through third-party AI service providers, including Anthropic. Your input, output, and personal information may be shared with and processed by these providers to enable your use of our AI products. Our AI products are designed for content and text generation, a chatbot or virtual assistant, and data analysis, insights, and recommendations. AI-generated insights, chat answers, and rankings are labelled as AI-generated in the platform. To opt out, contact us using the details below.
Lead and applicant scoring (profiling)
Within the platform we use AI to score and prioritize (i) the leads our customers track and (ii) applicants to our own job openings, based only on the screening answers they submit. This is a form of profiling under the GDPR. The score ranks and prioritizes a review queue; it never accepts, rejects, or otherwise decides anything on its own. A person always makes the decision, so we do not take decisions about you based solely on automated processing that produce legal or similarly significant effects. You can object to this profiling, and request human review of, or an explanation of, any assessment, using the contact details below.
07 Is your information transferred internationally?
In short: we may transfer, store, and process your information in countries other than your own.
Our infrastructure and service providers are primarily located in the United States (including our database and hosting), and VNP Media is established in the Netherlands. If you are located in the EEA, UK, or Switzerland, the United States may not have data-protection laws as comprehensive as those in your country. Where personal information is transferred outside the EEA, we rely on appropriate safeguards, such as the European Commission Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework, which can be provided upon request.
08 How long do we keep your information?
In short: we keep your information only as long as necessary, and we publish specific retention periods.
We keep your personal information for as long as you have an account with us, unless a longer retention period is required or permitted by law (such as tax or accounting requirements). In summary: account and workspace data is retained for the life of the engagement and erased on request; financial records (invoices) are kept for the statutory period (in the Netherlands, generally 7 years); the admin audit log, which records which member of our team performed an administrative action together with their IP address and browser, is kept for 12 months; questions and answers in Ask Pulse are kept for 30 days; other operational logs are kept for 90 days (webhook and sync logs); and rate-limit data expires within hours. Full details are on our Sub-processors & Data Retention page. When we have no ongoing legitimate business need, we delete or anonymize your information, or securely store and isolate it until deletion is possible.
09 How do we keep your information safe?
In short: we aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures, including encryption in transit and at rest, per-customer database isolation, hashed passwords, and access controls. However, no electronic transmission or storage can be guaranteed 100% secure, so we cannot guarantee that unauthorized third parties will never defeat our security. You should only access the Services within a secure environment.
10 Do we collect information from minors?
In short: we do not knowingly collect data from or market to children under 18 years of age.
By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to their use of the Services. If we learn that personal information from users under 18 has been collected, we will deactivate the account and delete such data. Contact us at [email protected] with concerns.
11 What are your privacy rights?
In short: depending on where you live, you may have rights that allow you greater access to and control over your personal information.
In some regions (like the EEA, UK, Switzerland, and Canada) you have rights that may include: the right to request access and obtain a copy of your personal information, to request rectification or erasure, to restrict processing, to data portability, and not to be subject to automated decision-making. You may also object to processing. To make a request, contact us using the details below.
Withdrawing your consent: you may withdraw consent at any time. Opting out of marketing: you can unsubscribe at any time via the link in our emails or by contacting us.
If you are in the EEA or UK and believe we are unlawfully processing your personal information, you may complain to your local data protection authority. In the Netherlands, that is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
12 Controls for Do-Not-Track features
Most browsers and some operating systems include a Do-Not-Track (DNT) feature. As no uniform technology standard for recognizing DNT signals has been finalized, we do not currently respond to DNT browser signals. If a standard is adopted that we must follow, we will inform you in a revised version of this notice.
13 Do United States residents have specific privacy rights?
In short: if you are a resident of California, Colorado, Connecticut, Texas, Virginia, and other US states with privacy laws, you may have rights to access, correct, delete, and obtain a copy of your personal information, and to opt out of certain processing.
Categories of personal information we have collected in the past twelve months:
| Category | Collected |
|---|---|
| A. Identifiers (name, address, IP, email, account name) | Yes |
| B. Personal information (California Customer Records) | Yes |
| C. Protected classification characteristics | No |
| D. Commercial information (transactions, payment) | Yes |
| E. Biometric information | No |
| F. Internet or network activity | Yes |
| G. Geolocation data | Yes |
| H. Audio, visual, or sensory information | No |
| I. Professional or employment information | Yes |
| J. Education information | No |
| K. Inferences drawn from collected information | Yes |
| L. Sensitive personal information | No |
We have not sold or shared personal information to third parties for a business or commercial purpose in the preceding twelve months. Your rights include the right to know, access, correct, delete, obtain a copy, non-discrimination for exercising your rights, and to opt out of targeted advertising, the sale of personal data, or profiling. To exercise these rights, submit a data subject access request or email us at [email protected]. We will verify your identity before acting on your request, and you may appeal a declined request by emailing us.
14 Are we a data controller or a data processor?
We act as the data controller for the account and usage data of our customers and their staff. For the prospect and lead data that a customer imports, connects, or tracks through our platform, the customer is the data controller and we act as their data processor, processing that data only on the customer instructions. Customers are responsible for having a lawful basis, and for providing any required notices, to the individuals whose data they bring into the platform.
15 Do we make updates to this notice?
In short: yes, we will update this notice as necessary to stay compliant with relevant laws.
The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes, we may notify you by posting a notice or by sending you a direct notification.
16 How can you contact us about this notice?
If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:
VNP Media (sole proprietorship / eenmanszaak, KvK 94959218)Franciscusweg 10 A 16
1216 SK Hilversum
Netherlands
17 How can you review, update, or delete the data we collect?
Depending on the applicable laws of your country or US state of residence, you may have the right to request access to the personal information we collect, details about how we process it, to correct inaccuracies, to delete your personal information, and to withdraw your consent. To request to review, update, or delete your personal information, please submit a data subject access request.