Privacy Policy
Data processing via the HelpingHands platform
Effective: 4 September 2026 Version 1.13 Published by VDGT Consultancy BV
1. Data Controller and DPO
VDGT Consultancy BV (hereinafter: "we"), CBE 1004820426, registered office Kerkestraat 34, 3971 Heppen, Belgium, is the data controller within the meaning of the GDPR (Regulation (EU) 2016/679) for all personal data processed via HelpingHands. VDGT Consultancy BV has not appointed a formal Data Protection Officer (Art. 37 GDPR does not currently require one given our scale of processing). For privacy inquiries, data-subject-rights requests and any data protection matter, the contact point is: [email protected]. Lead supervisory authority: Data Protection Authority (APD/GBA) — gegevensbeschermingsautoriteit.be
2. About the platform
HelpingHands is a mobile marketplace (iOS/Android) for video help sessions, operated by VDGT Consultancy BV. Offered to residents of the European Union (EU).
3. What data do we process?
3.1 Account data
- Email address, first name, last name;
- Profile photo (optional — base64 in PostgreSQL);
- Bio, catchphrase, language preference, spoken languages;
- Account type and business data (business helpers: CBE, VAT, name, address, billing email);
- Timestamp and version of the Terms you last accepted;
- Account status information (suspension reason, scheduled deletion date).
3.2 Authentication
- Password (hashed — never readable);
- Google or Apple account ID (social login).
3.3 Financial data
- Transaction amounts and Stripe PaymentIntent IDs (no card data);
- Payout transfer IDs.
3.4 Platform activity
- Help requests, helper responses, reviews, tips, badges, session quality surveys;
- Support tickets and replies (message body, author, timestamps);
- Correspondence you send us by email, including via the contact form on our website — that form composes a message in your own email app and stores nothing on the website itself, so we receive only what you choose to send;
- Blocks and abuse reports you submit or that are submitted against you (user IDs, timestamp, category, optional reason);
- Your helper skills (category, subcategory, self-declared skill level).
3.5 Technical and operational data
- FCM device token (push notifications — no location data, no tracking);
- Notification preferences.
3.5.1 Operational logging (security and fault diagnosis)
For the security, stability and fault diagnosis of the platform, operational logs are maintained. This covers three layers:
- Custom application logs via Better Stack (Better Stack s.r.o., Czech Republic, EU; data region eu-central-1a, Germany): contain only user IDs (integers), action descriptions and error messages — no email addresses, names or other direct personal identifiers. Retained for a maximum of 30 days.
- Serverpod session logs (framework level): the backend framework automatically processes session and authentication data for internal fault diagnosis. Retained per the framework default.
- nginx ingress access logs (reverse proxy): contain IP addresses, request paths and HTTP status codes. No account data. Retained for 30 days in our log store.
Legal basis for all operational logging: legitimate interest (Art. 6.1.f GDPR) — necessary for platform security, fraud prevention and technical continuity. No user profiles are built from log data and the data is not used for marketing purposes.
3.5.2 Last known activity and location
We store on your account when you last made a signed-in request, the IP address that request came from, and the country derived from it (MaxMind GeoLite2 — country level only, no city and no precise location). Unlike the logs in art. 3.5.1, this data is linked to your account.
The timestamp is updated at most once every fifteen minutes: it indicates recent activity rather than being a detailed record of your visits. We do not build a profile from it and do not use it for marketing.
Purpose: account security, fraud and abuse investigation, and customer support. Legal basis: legitimate interest (art. 6.1.f GDPR).
Retention: the IP address is erased automatically 90 days after your last activity. The derived country and the timestamp are kept for as long as your account exists.
3.6 Tax compliance data (helpers only)
For helpers, additional data is collected and processed to comply with EU/Belgian tax-reporting obligations (notably DAC7 — Council Directive 2021/514 transposed in Belgium by the Law of 21 December 2022). Where you are not a helper, none of these fields apply.
- Date of birth (private helpers — for DAC7 identity verification);
- Tax Identification Number ("TIN") and the country that issued it;
- Country of tax residence (ISO-3166-1 alpha-2);
- Home address (private helpers): line 1, line 2, postal code, city, country;
- Structured registered/legal address of the business entity (business helpers);
- VAT number, country of VAT registration, and VAT-classification status (business helpers);
- VIES validation evidence — the date the VAT number was last cross-checked against the European Commission VIES registry, the registered name and address as returned by VIES, and the raw VIES response (kept for audit and dispute-resolution purposes);
- KYC ("Know Your Customer") status and the timestamp of its last change — a platform-level state machine independent of Stripe Connect's own checks.
Legal basis: legal obligation (Art. 6.1.c GDPR) — DAC7 transposition and Belgian VAT law.
3.7 Tax statement acceptance audit (helpers only)
When a helper accepts a tax-related statement at onboarding (e.g. acknowledgement of personal tax responsibility, or VAT classification confirmation), an append-only audit row is recorded:
- The exact statement and its version that was accepted;
- Timestamp (UTC);
- IP address used at the moment of acceptance;
- User-Agent string used at the moment of acceptance;
- The helper's country of residence at the moment of acceptance.
This audit is necessary to evidence the validity of the helper's declarations to the Belgian tax authority (FOD Financien) under DAC7. Material changes to the helper profile (e.g. account-type flip, change of residence) cause the statement-version to bump and require renewed acceptance — earlier rows are never modified, only superseded. Legal basis: legal obligation (Art. 6.1.c GDPR).
3.8 Reminder communications log (helpers only)
When the platform sends a helper an email reminder for missing tax-compliance data (e.g. missing TIN, missing date of birth, pending VIES validation), the following is recorded:
- The recipient (user ID), the template key, the locale and the subject line of the email sent;
- The timestamp (UTC).
The body of the email is templated and reproducible from the template key plus the locale; the rendered body text is not separately stored. This log enforces the per-template cooldown so helpers are not over-mailed, and supports dispute resolution if a helper claims they were never reminded. Legal basis: legitimate interest (Art. 6.1.f GDPR) — operational coordination of statutory reminders.
4. Legal bases and purposes
- Performance of contract (Art. 6.1.b GDPR): account management, sessions, payments;
- Legitimate interest (Art. 6.1.f GDPR): security, fraud prevention, push notifications, operational logging (see Art. 3.5.1), reminder communications log (see Art. 3.8);
- Legal obligation (Art. 6.1.c GDPR): financial retention obligation of at least 7 years under Belgian bookkeeping law (Art. III.86 Code of Economic Law); for helpers also DAC7 reporting (Council Directive 2021/514, transposed in Belgium by the Law of 21 December 2022) covering tax compliance data (Art. 3.6) and the statement acceptance audit (Art. 3.7), and VAT compliance under the Belgian VAT Code;
- Consent (Art. 6.1.a GDPR): optional profile content, marketing.
4.1 Whether you have to provide data, and what happens if you don't
Some of the data described in art. 3 you must provide; the rest is optional.
- Contractually required. Email address, first name, last name and country of residence are needed to conclude and perform the user agreement. Without them we cannot create an account, and you cannot use the platform. For a session we also need the description of your help request and, for seekers, a valid payment method — without these the session cannot be arranged or paid for.
- Legally required (helpers only). Date of birth, tax residence, TIN and TIN country, home or registered address, and — for business helpers — VAT number, are required from us by law: DAC7 (Council Directive 2021/514, transposed in Belgium by the Law of 21 December 2022) and Belgian VAT and bookkeeping law. If you do not provide them we must withhold payouts and, where the obligation cannot otherwise be met, suspend the helper account. We have no discretion here.
- Optional. Profile photo, bio, catchphrase, spoken languages and any other profile content are entirely voluntary. Not providing them has no consequence beyond a less complete profile.
Where the platform requires a field, the app says so at the point where it is asked for.
5. Retention periods
- Account data: until deletion + 30-day grace period;
- Transaction data: at least 7 years (Belgian bookkeeping obligation, Art. III.86 Code of Economic Law); longer where required by applicable law;
- Tax compliance data (Art. 3.6) and statement acceptance audit (Art. 3.7): 10 years from the end of the calendar year to which the data relates, in accordance with the Belgian DAC7 transposition;
- VIES validation payload (Art. 3.6): retained for as long as the helper account remains active and for the bookkeeping retention period thereafter;
- Reminder communications log (Art. 3.8): 24 months;
- Help request descriptions: anonymised upon deletion;
- Server logs: max. 30 days (custom and framework/proxy);
- Last known IP address (art. 3.5.2): 90 days after last activity; the derived country and timestamp remain for as long as the account exists;
- Data exports: expire after 48 hours.
6. Processors and data transfers
6.1 Processors
- Thalassa Cloud (Netherlands, EU) — hosting of all production systems: managed Kubernetes and the managed PostgreSQL database (region nl-01), including its automated backups. Every category of personal data described in this policy is processed on this infrastructure. Any storage Thalassa uses for those backups is its own sub-processor, covered by its DPA;
- Stripe, Inc. (US) — payments and Stripe Connect. Transfer on the basis of SCCs and EU-US Data Privacy Framework (DPF). Stripe DPA applies;
- Google LLC / Firebase (US) — FCM push notifications only. Transfer on the basis of SCCs and DPF. Google DPA applies;
- Agora, Inc. — video calling via server-side tokens; no PII transferred;
- AWS SES (eu-west-1) — transactional emails. Processing in EU. AWS DPA + SCCs;
- Better Stack s.r.o. (Czech Republic, EU; data region eu-central-1a, Germany) — operational log aggregation, error tracking and uptime monitoring. Logs contain user IDs and IP addresses, no email addresses or names. Processing within the EU; DPA in place;
- Amazon Web Services, Inc. (eu-west-1) — help-request photo storage via S3. Data stays within the EU region. AWS DPA applies;
- Plausible Insights OU (Estonia, EU) — cookieless visitor statistics for the public website only. Processing within the EU; no cookies, no cross-site tracking, no profiling. See art. 6.2.
6.2 Website analytics
The public website (helping-hands.world) uses Plausible Analytics for aggregated visitor statistics. Plausible is cookieless: it places no cookies and stores no identifier on your device.
Per page view it records the page address, the referring page, and the device, browser and country derived from your user agent and IP address. The IP address itself is not stored — it is used only momentarily to compute a salted hash that rotates daily and cannot be reversed or linked from one day to the next. We additionally record which app-store link is clicked.
The script and the events are proxied through our own domain, so your browser makes no direct request to a third party. Processor: Plausible Insights OU (Estonia), processing within the EU.
There is no cross-site tracking, no profiling, no advertising network and no sale of data. Legal basis: legitimate interest (art. 6.1.f GDPR) — understanding how the site is used in order to improve it. Because nothing is stored on or read from your device, no prior consent is required.
The HelpingHands mobile app contains no analytics SDK, tracking pixel or advertising network.
6.3 Summary of transfers outside the EEA
Only to processors that comply with: an adequacy decision, SCCs, or the EU-US Data Privacy Framework (DPF).
6.4 Disclosures to public authorities (helpers only)
Once per calendar year, on the schedule set by the Belgian tax authority, we transmit a DAC7/DPI XML report to the Federal Public Service Finance (FOD Financien / SPF Finances). The report contains, per reportable helper, identification data (name, TIN, address, date of birth where applicable, VAT number) and the aggregated transaction totals attributable to that helper for the reporting year. Helpers receive a copy of their annual statement. This disclosure is a legal obligation (Art. 6.1.c GDPR; Council Directive 2021/514 as transposed in Belgium) and is not based on a processor relationship — FOD Financien acts as an independent controller of the data once received.
6.5 Outbound queries to public registries (business helpers only)
When a business helper enters a VAT number, we perform a synchronous lookup against the European Commission VIES service (https://ec.europa.eu/taxation_customs/vies/) to verify validity. The query contains only the VAT number and country code; no other personal data is sent. We store the result (validity flag, registered name, registered address, raw response payload, timestamp) as set out in Art. 3.6. The European Commission may itself log such queries; we have no influence on that retention.
7. Your rights
- Access (Art. 15 GDPR): Settings → Download my data;
- Rectification (Art. 16 GDPR): via Settings;
- Erasure (Art. 17 GDPR): Settings → Delete account (30-day grace period);
- Portability (Art. 20 GDPR): JSON export;
- Restriction (Art. 18) and objection (Art. 21): via [email protected].
For requests that cannot be processed directly through your account (e.g. objection, restriction, or access on behalf of someone else), we may verify your identity before releasing, rectifying or erasing data. Confirmation from the email address linked to your account is usually sufficient; in case of doubt we may request a copy of a valid ID document (you may redact the national register number and photo).
You may withdraw a previously given consent at any time via [email protected] or the app settings. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. After withdrawal, certain features that rely on that consent may no longer be available to you.
Requests answered within 30 days.
8. Automated decision-making
The platform applies the following automated logic, without taking decisions that produce legal effects on you within the meaning of Art. 22 GDPR:
- Matching of help requests to helpers (visibility, ranking, surfacing);
- VAT-classification of business helpers (REVERSE_CHARGE_B2B vs OSS) on the basis of declared country, VAT status and VIES validation outcome;
- KYC status transitions on the basis of completeness of identity data and Stripe Connect signals.
Each of the above can be reviewed and overridden manually by an admin via the admin dashboard.
9. Security
- HTTPS via nginx ingress + cert-manager (TLS 1.2+);
- Passwords hashed; Stripe PCI DSS; export tokens 64 characters, valid 48h;
- Webhook HMAC-SHA256 + replay protection; automated daily PostgreSQL backups retained 30 days, within the EU.
10. Complaint to the supervisory authority
Data Protection Authority (APD/GBA) — gegevensbeschermingsautoriteit.be — complaint form: https://www.gegevensbeschermingsautoriteit.be/burger/acties/klacht-indienen
11. Changes
Material changes notified by email. Most recent version: https://helping-hands.world/privacy/
12. Contact
VDGT Consultancy BV — CBE 1004820426 Kerkestraat 34, 3971 Heppen, Belgium [email protected]