Privacy & Cookies
Updated: 29 October 2026
This notice covers the VIP Capital website and private portal, including company clients, private introducers/brokers, enquiries, agreements, identity information and commission administration. It explains our processing; reading this notice is not consent to marketing or a signature on an agreement.
1. Controller and contact
VIP Capital, Oude Apeldoornseweg 45-067, 7333 NR Apeldoorn, The Netherlands. Email: info@vipcapital.eu. Telephone: +31 (0)85-200 9082. Contact us about your file, identity verification, retention or privacy rights.
2. Applications, accounts and profiles
Company applications contain company name, registration number, registered address, country, contact person, position, email and telephone; a website is optional. Private applicants provide first and last names, residential address, postcode, city, country, email, telephone and passport number. A private applicant is classified as Introducer / Broker. We record the selected portal/email language, application time, review and invitation status, account identifiers, access rights and profile changes. VIP Capital reviews applications; applying does not itself grant document access. Administrators can prepare or correct a profile and link registered brokers to a client/company. Some details can therefore originate from an authorised business contact or VIP Capital administrator rather than directly from you.
3. Identity verification and passport copies
Identity information supports checking who enters into a personal MCNDA or commission agreement, preventing impersonation and administering broker fees, including recurring payments. A passport number is collected with the private application. A signed passport copy is requested inside the authenticated portal after invitation and sign-in, before personal MCNDA submission. The copy is stored separately from ordinary shared documents. This is our current verification workflow; it does not mean that every broker is subject to a statutory passport-copy requirement.
We must assess whether identification can be achieved with less information or without retaining a copy. Unless a specific law requires an unredacted copy, obscure your BSN/national personal number, photograph and other irrelevant information, including such information in machine-readable zones. Keep only the details specifically needed for the stated check readable. A purpose/date watermark is permitted. Do not enter a BSN in the passport-number field. Contact info@vipcapital.eu before uploading if you cannot provide a suitably redacted copy or want to discuss an alternative verification method. We do not use passport photos or signature images for automated biometric identification.
4. Agreements, signatures and commission information
We process assigned documents, profile snapshots, contract terms, fee arrangements and any payment/bank details supplied in the relevant agreement. Signing records can contain names, capacities, signature/stamp images, dates, timestamps, document hashes, explicit acceptance and approval records. A personal MCNDA contains the signer's personal details and passport number. The signed passport copy is a separate identity file, not automatically appended to the agreement. Saved signing images are used in the signing workflow only with the required confirmation. Client signature and VIP Capital approval/countersignature are separate steps. Documents, agreements, offers and SPAs remain in English; choosing another portal language does not change their terms or existing signatures.
5. Who can see a file
Portal permissions determine access. The assigned signer and authorised VIP Capital administrators can access their agreement. Linking an introducer/broker to a client does not automatically give either party access to the other's private agreements, identity copies, commission or bank details. Passport copies are restricted to the relevant account and authorised administrators. Necessary providers process data for their service tasks. Professional advisers, payment providers or authorities may receive relevant information when necessary for a transaction, payment, legal obligation or claim. We do not sell personal data. A recipient may retain a downloaded document; withdrawing portal access cannot recall that copy.
6. Contact and account enquiries
We process correspondence, contact details and relevant attachments to answer questions and administer access, MCNDAs and commission agreements. This client portal does not issue product offers, SPAs or JVAs. Links to email, telephone or WhatsApp open external services with their own privacy notices. Do not send passport copies through ordinary enquiries or include passport details in document titles or email subjects.
7. Purposes and legal bases
Depending on the activity, processing is necessary for a contract with you or steps you request before a contract; for legitimate interests in managing business relationships, identifying counterparties, preventing fraud, protecting commissions, secure document exchange and handling legal claims; or for a specific applicable legal obligation. Where you act for a company, business-contact processing will commonly rely on legitimate interests rather than a contract with you personally. We must assess necessity and balance those interests against your rights. A general reference to KYC, an NDA or future payments is not by itself proof that an unredacted passport copy or a fixed retention period is legally required. If a separate activity relies on consent, we explain it and you may withdraw that consent without affecting earlier lawful processing.
8. Language and service emails
The selected language is stored with the account and can be changed in Company Profile; authorised administrators can also update a client's preference. Invitations, recovery and workflow messages use the relevant stored language. Internal recipients use their own preference. Legacy accounts without a preference are asked to choose; essential legacy messages may use English until then. Service messages cover access requests, invitations, password recovery, document availability, draft review, signature release, submitted signatures, final approval, withdrawal/cancellation, uploads and enquiry status. Standard templates do not attach passports or disclose passport numbers. Delivery queues retain recipient, language, event, timestamps, retry/error information and technical delivery identifiers. These operational messages are not a marketing subscription.
9. Providers
Supabase provides authentication, databases and private file storage; TransIP provides email; GitHub Pages hosts the public website. The authentication library loads from esm.sh. These providers may receive technical connection data, including IP addresses, and process necessary information under their roles and service arrangements. VIP Capital and Nexora International have separate portal databases and account administration. An account for one portal does not grant access to the other.
10. Cookies and browser storage
Our website code does not use advertising or third-party analytics cookies. The portal uses sessionStorage to retain the authentication session in the current tab. Signing out removes the local session; closing the tab normally ends this storage, although browser session restoration can affect it. The key vip-portal-language in localStorage stores the chosen language until changed or cleared by you. The preference is also stored with an authenticated account for portal and email use. Clearing browser storage removes the device copy, not the account preference or server records. Hosting/authentication providers also process technical security and delivery information. If optional tracking is introduced, the notice and any required choice mechanism must be updated first.
11. Retention
Applications and enquiries are kept while needed for review, follow-up, fraud prevention or a resulting relationship. Account/profile data is kept while necessary for access and relationship administration. Closing or disabling an account does not automatically erase records that must still be retained.
MCNDAs and the related signing evidence, including account identity, acceptance and approval records, confirmation timestamps and document hashes, are retained while necessary to administer and enforce the agreement and its surviving obligations, or to establish, exercise or defend legal claims. The standard MCNDA term is two years; confidentiality continues for five years after expiry or termination. The specific non-circumvention restrictions run for two years from the first documented introduction for the relevant transaction. Retention is therefore not limited to the two-year agreement term. We review the need for retention when the relevant obligations end; any longer retention for a legal obligation or claim requires a separately documented justification.
Commission agreements, recurring payments and payment/accounting records follow their own contractual duties and applicable statutory retention requirements. Their retention is not automatically shortened or extended by the MCNDA term.
Passport copies and separately stored identity information do not automatically follow the MCNDA retention period. The necessity of retaining a copy or individual fields must be assessed and documented separately. Unnecessary copies or information must be removed earlier, particularly where a limited identity-verification record is sufficient. A specific legal obligation or live dispute may justify a separate period where necessary. Ask info@vipcapital.eu about the retention applicable to your file. This notice does not claim that deletion is already automated. Provider backups and technical logs may have separate, limited deletion cycles.
12. Security and international processing
Private storage, authenticated sessions and role-based permissions help protect information. Security is not an absolute guarantee. Administrative access, providers or their subprocessors may involve processing outside the EEA. Where required, an international transfer needs an applicable adequacy decision or appropriate safeguards, such as standard contractual clauses and any necessary supplementary measures. Contact us for the locations, providers and safeguards relevant to your file; this notice does not claim that all processing stays in the Netherlands or EEA.
Administrator access requires an authenticator app. The authentication provider processes enrolled factor identifiers, verification status, device labels and security-event timestamps to secure accounts and support controlled recovery. The app generates temporary login codes. Do not share these codes, enrollment QR codes or setup keys. A backup authenticator may be registered on a separate trusted device. A password reset does not remove the authenticator requirement.
13. Your rights and complaints
Depending on the circumstances you can request access, correction, erasure, restriction, portability and object to processing based on legitimate interests. You can withdraw consent where it is the basis for a separate activity. Email info@vipcapital.eu. We verify requests proportionately and do not routinely need a full passport copy for a privacy-rights request. We normally respond within one month; if a lawful extension is needed, we explain it. You may complain to the Dutch Autoriteit Persoonsgegevens or your competent supervisory authority. Refusing unnecessary data does not waive these rights; if essential information is missing we will explain which service or step cannot proceed and discuss applicable alternatives.
14. Human review and changes
VIP Capital administrators review access and final document approval. Technical validation, security checks, rate limits and notifications are automated; they do not themselves sign or accept a commercial agreement for you. This notice is updated when processing changes. The date above identifies this version.
