Privacy Policy
Data processing via the HelpingHands platform
Effective: 15 May 2026 Version 1.8 Published by VDGT Consultancy BV
1. Data Controller and DPO
VDGT Consultancy BV (hereinafter: "we"), CBE 1004820426, 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);
- 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 OpenObserve Cloud (eu1-api.openobserve.ai, EU region per our deployment configuration): contain only user IDs (integers), action descriptions and error messages — no email addresses, names or other direct personal identifiers. Retained for a maximum of 90 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.
3.6 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.
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. 90 days (custom) / 30 days (framework/proxy);
- Data exports: expire after 48 hours.
6. Processors and data transfers
6.1 Processors
- 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;
- OpenObserve Cloud (eu1-api.openobserve.ai, EU region per our deployment configuration) — operational log aggregation. Logs contain user IDs and IP addresses, no email addresses or names;
- Amazon Web Services, Inc. (eu-west-1) — encrypted database backups (PITR) and help-request photo storage via S3. Data stays within the EU region. AWS DPA applies.
6.2 No analytics or advertising
HelpingHands uses no analytics SDKs, tracking pixels or advertising networks.
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; PostgreSQL PITR backups to S3 (EU, 30 days).
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://app.helping-hands.world/legal/privacy_en.pdf
12. Contact
VDGT Consultancy BV — CBE 1004820426 — [email protected]