1. Introduction

At VPS, we are committed to protecting your personal information and respecting your privacy. This Privacy Policy sets out how VPS (“we,” “us,” or “our”) collects, uses, stores, shares, discloses, and protects personal information in connection with the operation of our platform and related services.

The purpose of this policy is to provide clear and transparent information about our data processing practices, including what types of personal data we collect, why we collect it, the lawful bases on which we process it, how long we retain it, and the rights and choices you have in relation to your personal information.

For the purposes of applicable data protection legislation, VPS is the data controller responsible for determining the means and purposes of processing your personal data.

This Privacy Policy applies to all users of the VPS platform, including candidates, agencies, academies, and families as well as visitors to our website. It applies to all personal data processed by VPS in connection with our online platform, communication channels, and related services, regardless of how you access them (for example, via computer, mobile device, or other means).

By accessing or using our website, registering an account, or otherwise interacting with our services, you acknowledge that you have read and understood this Privacy Policy and that we will process your personal data in accordance with it.

2. Information We Collect

Personal information may be collected when you create an account, complete your profile, purchase a service, or interact with other users. VPS uses this information to operate and improve the platform, deliver personalised services, verify user identity, process payments and ensure the safety and integrity of all users. In order to provide and improve our services, VPS collects and processes personal information from users in several ways, including information you provide directly, information collected automatically, and information received from third parties. The following section explains the types of information we collect, how it is obtained, and the legal bases on which we process it.

2.1 Information You Provide Directly

We collect information that you voluntarily provide when interacting with the VPS platform. This includes, but is not limited to:

• ● Registration and account information: name, email address, phone number, profile photo, professional details, and other personal data submitted when creating or updating your profile.
• ● Forms and applications: information you submit when applying for jobs or courses, or when completing any forms on our platform.
• ● Uploads and documents: CV’s, cover letters, certificates, or other documents you upload to the platform.
• ● Communications: messages, enquiries, or other information you send to VPS or other users through our platform.
• ● Billing and payment information: information necessary to process payments and manage subscriptions, including payment card or bank account details, billing address, and other related information you provide. Please note that payment card details are processed securely through trusted third-party payment processors and are not stored on VPS servers.

2.2 Information Collected Automatically

When you use the VPS platform, we automatically collect certain information to help improve our services and ensure the security and functionality of the platform. This may include:

• ● Device and connection information: IP address, browser type and version, operating system, and device identifiers.
• ● Usage data: pages visited, time spent on pages, clicks, navigation paths, and other activity on the platform.
• ● Cookies and similar technologies: information collected through cookies, local storage, or other tracking technologies, which help us understand user behaviour, improve functionality, and provide personalised experiences.
• ● Analytics and performance data: aggregated statistics about platform usage and performance, collected via third-party analytics services.

2.3 Information from Third Parties

We may receive personal information about you from third-party sources to enhance our services or verify certain data. Examples include:

• ● Integrations and service providers: information shared by partners or service providers that facilitate certain platform features, such as payment processing or communication tools.
• ● Professional networks or public sources: information obtained from publicly available databases, social media profiles, or other sources relevant to your professional profile.
• ● Referrals or connections: information provided to VPS by other users or organisations in connection with your use of the platform.

We only collect information that is necessary to provide our services, improve the platform, and comply with legal obligations. All information collected, whether directly, automatically, or from third parties, is processed in accordance with this Privacy Policy and applicable data protection laws.

3. How We Use Your Information

VPS processes the personal information we collect in order to provide, operate, and improve our platform and related services. The following explains the purposes for which your information may be used.

• ● To operate and improve the platform: We use the information you provide, as well as information collected automatically or from third parties, to facilitate registration and account management; process job and course applications, subscriptions, or other services you request; and maintain and improve the overall functionality, performance, and usability of the VPS platform. Additionally, this information helps us identify areas for improvement; develop new features, products and services; and create a more seamless and personalised user experience.
• ● To communicate with users: We may use your information to send important updates regarding your account, administrative notices, and platform-related information. This includes responding to enquiries or requests you submit, as well as sending notifications related to job or course applications, services or events you have expressed interest in. Where you have provided explicit consent, we may also send marketing communications about relevant products, services, or events tailored to your preferences.
• ● To personalise content or services: Your information allows us to tailor the content, recommendations, services and advertisements presented to you. For example, we can offer relevant job or course suggestions based on your profile and preferences, or provide features and functionality specific to your user type, whether you are a candidate, agency, academy, or family. Personalisation helps us deliver a more relevant and engaging experience on the VPS platform.
• ● For security, legal, or compliance purposes: We use your information to monitor and protect the security and integrity of our platform and users; detect, prevent or investigate fraudulent, illegal, or unauthorised activities; and comply with applicable laws and our legal or regulatory obligations. This includes responding to lawful requests from public authorities or regulators and taking appropriate action to ensure the safety and reliability of our services.
• ● For research and analytics: We may use anonymised or aggregated data derived from your information to analyse trends, evaluate platform performance, and improve our services. This allows us to understand user behaviour, optimise features, and make informed decisions about platform development and enhancements.
• ● For legal claims or dispute resolution: Your information may be used to protect our rights, enforce our terms and conditions, or respond to legal claims and disputes. This ensures VPS can address contractual, regulatory, or other legal obligations effectively.

All uses of personal information are carried out in accordance with this Privacy Policy and applicable data protection laws.

4. Legal Basis for Processing

VPS processes your personal information in accordance with applicable data protection laws. For each type of processing, we rely on one or more lawful bases, which are described below:

• ● Consent: In certain situations, we rely on your explicit consent to process your personal information. This includes, for example, receiving marketing communications, newsletters, or promotional materials. You may withdraw your consent at any time by following the instructions provided in our communications or by contacting us directly. Please use the contact form available on the platform, selecting the “Customer Support” category.
• ● Contractual necessity: Some processing is necessary to perform a contract you have with VPS. This includes processing information to create and manage your account, handle job or course applications, process subscriptions or payments, and provide the services you have requested. Without this processing, we would not be able to fulfil the obligations of our agreement with you.
• ● Legitimate interests: VPS may process your personal information when it is necessary for our legitimate interests, provided such processing does not override your rights and freedoms. This includes using your data to operate and improve the platform, personalise content, provide security, detect and prevent fraud, and perform analytics to enhance our services. You have the right to object to processing based on legitimate interests in certain circumstances.
• ● Legal obligations: VPS may process personal information to comply with applicable laws, regulations, or legal obligations. Examples include maintaining accounting and payment records for auditing purposes, responding to lawful requests from public authorities or regulators, and taking steps to enforce our legal rights.

In addition to the above, VPS does not use your personal information for automated decision-making or profiling that produces legal or similarly significant effects. VPS ensures that only the minimum personal information necessary for the stated purposes is collected and processed. All processing carried out by VPS is performed in accordance with these lawful bases and is documented to ensure compliance with data protection principles.

5. Information We Share and Display

VPS may share or display certain information in order to operate our services, comply with legal obligations, and facilitate interactions between users. We respect your privacy and we value the safety of every user so we only share your personal information in accordance with applicable data protection laws. The following explains the circumstances under which your information may be shared:

• ● Other users: Certain information you choose to include in your profile or activity on the platform is displayed publicly or may be visible to other users, depending on your account type, privacy settings and the features you use. VPS determines which parts of your profile are visible publicly or to other users. You remain responsible for understanding how your information may be displayed or shared on the platform (including any updates or changes you make to your profile) and for reviewing the details you choose to include in your profile. By providing this information, you acknowledge that it may be visible to others as part of your use of the platform. We encourage you to review your profile regularly and ensure it reflects your preferences and that any information you include reflects what you are comfortable sharing.
• ● Service providers or partners: We may share your information with trusted third-party service providers or partners who perform services on our behalf to operate the platform, such as payment processors, hosting providers, communication tools, or analytics services. These service providers are only permitted to use your information to provide the services requested by VPS and are required to maintain appropriate safeguards to protect your data.
• ● Legal compliance or protection of rights: VPS may disclose personal information where required by law, regulation, legal process, or court order, or when necessary to protect our legal rights, enforce our Terms and Conditions, or investigate fraudulent, illegal, or unauthorised activities. This includes responding to lawful requests from public authorities or regulators and taking steps to protect the safety, security, and integrity of the platform.
• ● Business transfers: In the event of a merger, acquisition, restructuring, or sale of assets, user information may be transferred as part of that transaction, subject to the same privacy protections.

VPS ensures that all data sharing of information is conducted securely and only to the extent necessary for the intended purpose. We do not sell your personal information to third parties for marketing or any other purposes.

5.1 Information Visible to Other Users

• ● Candidate profiles: For your privacy, only key profile details from your profile will be displayed publicly (photo, full name, job category and title, location, first language and additional languages). Your full profile (including CV and contact details) will remain private and accessible only to professional accounts with an active membership. We value the privacy and security of every candidate on our platform. By allowing access only to professional accounts, we ensure that personal details are shared only with agencies, academies and families offering exclusive training and meaningful career opportunities.
  You are not required to upload a CV when creating your profile, although doing so is strongly recommended to showcase your qualifications and skills and improve your chances of being considered by prospective employers. However, when submitting a job application through the platform, you will be required to upload your most recent CV to ensure that employers can assess your profile based on your experience and background. Your CV will only be shared with the employer to whom you are submitting the job application and will not be disclosed to other users or third parties. Candidates are responsible for any personal or sensitive information included in their CVs, reference letters, or job applications, including details related to families they have previously worked for. VPS does not assume liability for such information, and candidates should ensure that the privacy and security of others is respected when submitting materials through the platform.
  Candidates have the option to hide or unhide their profiles at any time. When a profile is hidden, it will not be publicly displayed or discoverable by other users on the platform, and when it is unhidden, it becomes visible according to the platform’s general visibility rules. This feature allows candidates to control when their information is accessible to others—for example, keeping it hidden while updating their profile or managing their job search. However, hiding a profile means it will no longer be visible on the platform, so employers won’t be able to discover you and you may miss out on job opportunities. We encourage candidates to review their profile visibility regularly to ensure it reflects their current preferences and goals.
  If a featured profile is hidden, it will no longer appear in the Featured Carousel or Featured Spotlight. However, it will automatically be featured again if you unhide your profile before the package expires.
  Please note that when your profile is hidden, limited information such as your name and, where applicable, your profile photo, may continue to appear in certain historical interactions (including job and course applications, messages, saved items and email alerts or notifications sent before your profile was hidden) where this is necessary to preserve the context of those interactions and maintain a clear and complete record for the users involved. This limited retention helps ensure that platform activity remains understandable and coherent and is carried out in accordance with applicable data protection regulations.
• ● Agency and academy profiles: The full profile of agencies and academies is publicly displayed to enhance brand recognition, build reputation on the platform, and attract exclusive clients, top talent, and prospective students. Although some fields are optional when creating a profile, agencies and academies are encouraged to provide as much detail as possible to create a complete and accurate profile that effectively promotes their businesses and services. Providing more information increases visibility and the overall impact of their presence.
  The full name of the agency or academy representative is required for account management or verification purposes but is not displayed publicly; however, representatives may choose to share their names with candidates when initiating contact or communication.
  The primary purpose of these publicly displayed profiles is to promote the prestige, recognition, and professional reputation of the agency or academy on the platform, highlighting their strengths and expertise.
• ● Family profiles: For your privacy, your personal details will never be displayed publicly on the platform (only your name will be visible). We collect this information solely for internal purposes, such as verifying your account, gathering informative statistics to improve our services, ensuring platform security, and maintaining the quality and trust of our community. Your privacy is important to us, and we take all necessary measures to keep your information secure and strictly confidential. While your personal information is kept private, providing complete and accurate details helps us ensure a safe and high-quality experience for all users and supports effective interactions through the platform. You are responsible for ensuring that the personal information you provide is accurate and up-to-date.
  When creating a family profile, families are not required to provide a photo. A default image—a golden diamond—will be assigned to the profile. You will be asked to provide the name of the family representative, either a parent or someone acting on their behalf, such as a personal assistant or other authorised person. Your name will appear only in two situations: (1) when you post a job, it will be displayed publicly together with the job description and details, and (2) within the secure chat window, where it will only be visible to the specific candidate you are communicating directly with. No other family information is ever displayed.
• ● Communications and applications: Messages, applications, and other direct interactions on the platform are private and shared only between the parties involved. VPS does not disclose the content of these communications to third parties except as required by law. Information exchanged through communications and applications may be processed internally, in exceptional cases, to support platform functionality, ensure security, and assist with dispute resolution when necessary.
  Users are responsible for the content of their messages and applications and must not include sensitive personal information of third parties without consent. Communications and applications are stored securely and retained only for as long as necessary to provide platform services and comply with legal obligations. VPS does not access, monitor, or review the content of communications except to ensure compliance with platform policies, prevent abuse, or respond to legal requests.

6. Third-Party Services and Links

VPS may use third-party services to enhance platform functionality, including analytics, integrations, social media features, and payment processing. These services may collect certain technical or usage information about users, such as interactions with the platform or device-related data. VPS does not control how third parties process or store this information and encourages users to review the privacy policies of any such services they interact with.

Additionally, the platform may contain links to external websites, resources, or services for convenience or reference. VPS is not responsible for the content, privacy practices, or security of these external sites, nor does it endorse or guarantee the accuracy of any information provided. Users access external links at their own discretion and are encouraged to review the privacy policies of those sites before providing any personal data.

7. Cookies and Tracking Technologies

VPS uses cookies and similar tracking technologies to enhance platform functionality, improve user experience, analyse platform usage, and provide personalised content and services. These technologies help measure engagement, support platform operation, and may also include cookies set by third parties for analytics, social media features, or other purposes.

Users can manage or disable cookies through their browser settings or via platform options, though some features may be affected. For detailed information about the types of cookies and tracking technologies used, as well as instructions for managing them, please refer to our separate Cookie Policy .

8. Data Retention

VPS retains personal information only for as long as necessary to fulfil the purposes for which it was collected, including the provision of services, compliance with legal obligations, resolution of disputes, and enforcement of agreements. The specific retention period may vary depending on the type of data, the nature of the services provided, and applicable legal or regulatory requirements.

When information is no longer required for these purposes, VPS takes appropriate steps to delete, anonymise, or securely store it in accordance with applicable data protection laws. Certain information may be retained for a longer period if necessary to protect VPS’s legitimate interests, prevent fraud or abuse, or comply with tax, accounting, or legal record-keeping obligations.

Some data may remain stored in secure backups for a limited time before being permanently deleted, and inactive accounts may be archived or removed after a period of inactivity in line with VPS’s internal retention policy. In such cases, users will be notified in advance and given the opportunity to reactivate their accounts or request data deletion.

9. Data Security

VPS takes the security of user information seriously and implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. These measures may include encryption, access controls, secure data storage, and regular monitoring of systems to maintain the integrity and confidentiality of user information. Access to personal data is restricted to authorised personnel who are required to handle such information in a confidential and secure manner.

Users are encouraged to take reasonable steps to protect their own accounts and credentials. You are solely responsible for safeguarding your account credentials, including your username and password, and for all activities that occur under your account. You agree to notify VPS immediately of any unauthorised use of your account or any other security breach. VPS shall not be liable for any loss or damage arising from your failure to comply with these obligations. You may not share your account credentials with any third party or permit any third party to access the platform using your account. VPS reserves the right to suspend or terminate any account suspected of unauthorised use or breach of these terms.

Personal data may be stored or processed on secure servers located within or outside the user’s jurisdiction. VPS ensures that appropriate safeguards are in place to maintain an equivalent level of data protection, regardless of location. VPS also conducts periodic reviews of its security procedures to ensure continued compliance with industry best practices and data protection standards.

While VPS strives to maintain a high level of security, no system or transmission of data over the internet can be guaranteed to be completely secure. Users acknowledge that there are inherent risks associated with online data transmission, including potential cyberattacks, unauthorised access, or system failures. VPS will act promptly to investigate and mitigate any suspected data breach in accordance with applicable data protection regulations.

10. Your Rights and Choices

Users have certain rights regarding their personal information, subject to applicable data protection laws. VPS is committed to ensuring that these rights can be exercised in a clear and accessible manner. Depending on your location and the applicable laws, you may have some or all of the following rights:

• ● Right of access: You have the right to request confirmation as to whether we process your personal information and, if so, to obtain a copy of that information, along with details about how and why it is used. We will provide this information in a clear and accessible format unless doing so would adversely affect the rights or freedoms of others.
• ● Right to correction (rectification): You have the right to request the correction or updating of any inaccurate, incomplete, or outdated personal information. On the VPS platform, you can exercise this right directly through your account by using the “Edit” function to update your details. For personal data that cannot be edited through your account, VPS will assist you upon request to ensure that your information remains accurate and up to date.
  For security and integrity reasons, the email address used to register on the VPS platform cannot be edited directly through your account “Edit” function. This registered email address serves as a unique identifier for your account and is linked to your login credentials, profile information, and any associated account activities. Changing your email would break the linkage between your login credentials and your account profile, which could compromise access to your account.
  If you wish to update your email address, you may contact VPS to request an account migration. VPS will securely transfer your account and all associated data, including login credentials and profile information, to the new email address, ensuring that your account history and identification credentials are preserved.
• ● Right to deletion (erasure): You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when the processing is otherwise unlawful. VPS will take reasonable steps to erase your personal data in a secure manner, while taking into account any legal obligations or legitimate business purposes that require the retention of certain information, such as record-keeping, tax, or compliance requirements.
  Users may delete their account at any time through their account settings on the platform. When you delete your account, or if your account is deleted or suspended for any reason, all your personal data and all the content you have submitted or created on the platform (including your profile, posts, applications, and any other data associated with your account) will be permanently removed, and you will lose access to your account, its services, and features.
  However, limited information such as your name and, where applicable, your profile photo, may continue to appear in certain historical interactions (including job and course applications, messages, saved items and email alerts or notifications sent before your account was deleted) where this is necessary to preserve the context of those interactions and maintain a clear and complete record for the users involved. This limited retention helps ensure that platform activity remains understandable and coherent and is carried out in accordance with applicable data protection regulations. No other personal information will be retained for public display or shared with other users. Please note that any information you have shared directly with other users (such as your CV, messages, or other content) may remain visible to them. It is your responsibility to consider this before sharing personal information on the platform. Once your account is deleted, VPS will cease all communications with you, except where required to retain information for legal or regulatory purposes. You will no longer receive emails, notifications, alerts, or other communications from VPS.
• ● Right to restriction of processing: You have the right to request that VPS limits or restricts the processing of your personal information in certain circumstances. This may include situations where you contest the accuracy of your data, object to processing based on legitimate interests, or request a temporary restriction while VPS reviews a deletion or correction request. When processing is restricted, VPS will retain your personal data but will not use it for any purpose other than storing it, unless you provide consent or it is necessary for legal or compliance reasons.
• ● Right to data portability: Where processing is based on your consent or on a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format. You may also request that VPS transmit your personal data directly to another service provider or controller where technically feasible. This right allows you to move, copy, or transfer your personal data between service providers in a secure and efficient manner, helping you maintain control over your information while ensuring continuity of service.
• ● Right to object: You have the right to object at any time to the processing of your personal data where such processing is based on VPS’s legitimate interests or is carried out for direct marketing purposes. Upon receiving your objection, VPS will stop processing your personal data for the specified purposes, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or where processing is necessary for legal compliance. Exercising this right helps you maintain control over your personal data and ensures that VPS respects your preferences regarding the use of your information.
• ● Right to withdraw consent: Where VPS processes your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawal applies only to processing activities that rely solely on your consent and does not affect the lawfulness of any processing carried out prior to withdrawal. Exercising this right allows you to maintain control over your personal data and ensures that you can revoke permission for processing activities that are based solely on your consent.
• ● Right to lodge a complaint: You have the right to lodge a complaint with your local data protection authority if you believe that your data protection rights have been infringed. We encourage you to contact VPS first so that we may address and resolve your concerns directly and promptly. Exercising this right does not affect any of your other rights under applicable data protection laws, and it ensures that you can seek independent oversight and enforcement of your rights.

You may exercise any of your rights described in this section by contacting VPS using the contact form available on the platform and selecting the “Customer Support” category. To ensure the security of your information and that it is not disclosed to any unauthorised person, VPS may need to verify your identity before responding to your request. We may also contact you to request additional information if necessary to clarify your request and facilitate a prompt response.

VPS will process your request without undue delay and in accordance with applicable data protection regulations. In general, we aim to respond within the standard statutory timeframe, but complex requests may require additional time to complete. Please note that VPS may refuse to comply with your request if it is unreasonable, abusive, or if fulfilling it would compromise the security, integrity, or legal obligations of the platform.

11. Data Transfers

VPS may process or store your personal data in countries or regions outside your own. These locations may have different data protection laws from those in your jurisdiction. These transfers may be necessary for purposes such as platform hosting, data storage, analytics, communication tools, payment processing, or other essential services that support the operation and functionality of the VPS platform.

Whenever such transfers occur, VPS ensures that appropriate safeguards are in place to provide an equivalent level of protection for your personal data. These safeguards may include the use of legally recognised transfer mechanisms, contractual data protection clauses, or other measures required under applicable data protection legislation to ensure the security, confidentiality, and lawful handling of your information.

By using the VPS platform, you acknowledge that your personal data may be transferred to, stored in, or accessed from locations outside your country or region, and that VPS will take all necessary steps to ensure that such transfers comply with relevant legal requirements and maintain adequate protection of your information.

12. Children’s Privacy

The VPS platform is not intended for use by children, and we do not knowingly collect personal data from individuals under the minimum age required to use our services. Users must meet the minimum legal age (18 years old) to create an account and use the VPS platform.

VPS does not offer services directed to children and does not knowingly process personal data belonging to minors without appropriate parental or guardian consent where required by law. If we become aware that personal data has been collected from a child without the necessary consent, we will take steps to delete that information and, where appropriate, delete the associated account. Parents or legal guardians who believe that their child has provided personal data to VPS without consent may contact us so that we can take appropriate action.

13. Changes to This Policy

VPS may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or the features of the platform. When updates are made, the revised policy will be published on the VPS platform for users to review. Changes shall take effect immediately upon posting on the platform or as otherwise indicated. Significant changes that may affect your rights or the way your information is handled will be communicated through the platform, via email or by other appropriate means.

Users are responsible for reviewing this Privacy Policy periodically to stay informed about how VPS collects, uses, and protects personal data. Continued use of the VPS platform after any updates constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated Privacy Policy, you must cease using the platform immediately.

VPS reserves the right, at its sole discretion, to deny access to, suspend, or terminate the accounts of any user who breaches or fails to comply with the updated or modified Privacy Policy or any applicable laws. Such actions may be taken without prior notice, and VPS shall not be liable for any losses, damages, or inconveniences resulting from the suspension or termination of a user account.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data on the VPS platform, you may contact us using the contact form available on the platform. Please select the “Customer Support” category when submitting your enquiry to ensure it is directed to the appropriate department and relevant team.

VPS will review your request and respond as promptly as possible, although complex requests may take longer to process. For security reasons, we may need to verify your identity before taking any action in response to your request and we may need to contact you for additional information if needed to address your enquiry effectively.