Privacy Policy

Last updated: 18 May 2026

This Privacy Policy describes how VP Consulting (“A11yRisk”, “we”, “us”, “our”) processes personal data when you visit our website, create an account, or use our automated accessibility scanning services. It is issued pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).

1. Identity and Contact Details of the Controller

Controller:
VP Consulting
Keurenplein 41, Box C3577, 1069CD Amsterdam, The Netherlands
E-mail: [email protected]

If you have any question about how we handle your personal data, please contact us at the email address above.

Data Protection Officer: We are not currently required to appoint a DPO. Should this change, contact details will be published here.

2. Categories of Personal Data We Process

We process the following categories of personal data:

CategoryExamplesSource
Identity & contact dataName, email addressProvided by you at registration (via Clerk)
Authentication dataSession tokens, OAuth tokensGenerated by Clerk on your behalf
Billing dataCredit balance, Stripe transaction reference IDsStripe processes payment; we store only confirmation references and credit balance
Submitted URLsWebsite addresses you submit for scanningProvided by you
Scan contentWebpage content retrieved during a scan (may include publicly visible personal data on the scanned site)Fetched automatically from URLs you submit
Scan results & reportsAccessibility violations, page metadata, PDF and JSON reportsGenerated by our scanning engine
Usage dataFeatures accessed, scan history, timestampsGenerated automatically
Technical dataIP address, browser type, device typeGenerated by your connection to our servers
Support communicationsMessages you send to our support teamProvided by you

3. Legal Bases for Processing

We rely on the following legal bases under Article 6 GDPR:

  • Performance of a contract (Art. 6(1)(b)): creating your account, delivering scan results, generating reports, managing your credits, and processing payments.
  • Legitimate interests (Art. 6(1)(f)): security monitoring, fraud and abuse detection, service reliability, and statistical improvement of our scanning algorithms. We have assessed that our interests do not override your fundamental rights and freedoms.
  • Legal obligation (Art. 6(1)(c)): retaining financial records as required by applicable accounting and tax law.
  • Consent (Art. 6(1)(a)): where indicated at the point of collection (for example, optional marketing communications, if offered). You may withdraw consent at any time without affecting prior processing.

4. Purposes of Processing

PurposeLegal basis
Account registration and managementContract
Running accessibility scans you requestContract
Generating, storing, and delivering PDF/JSON reportsContract
Processing credit purchases through StripeContract
Detecting and preventing fraud and abuseLegitimate interests
Monitoring platform availability and performanceLegitimate interests
Improving scan accuracy and rule coverageLegitimate interests
Responding to support requestsContract / Legitimate interests
Complying with legal obligations (e.g. accounting records)Legal obligation

5. Third-Party Service Providers (Processors)

We engage the following third-party processors who act on our instructions and are bound by data processing agreements:

ProcessorPurposeLocationTransfer safeguard
Clerk, Inc.Authentication and user managementUnited StatesStandard Contractual Clauses (Commission Decision 2021/914)
Stripe, Inc.Payment processing and fraud preventionUnited StatesStandard Contractual Clauses (Commission Decision 2021/914)
Cloudflare, Inc. (R2)Secure object storage for PDF/JSON reportsUnited States / EEA edge nodesStandard Contractual Clauses (Commission Decision 2021/914)
Supabase, Inc.Hosted PostgreSQL databaseEU Central (Frankfurt, eu-central-1)EEA — no transfer
Railway (Redis service)Task queue and in-memory cachingEU West (Amsterdam)EEA — no transfer

We do not sell your personal data to any third party. We do not use your data for advertising or profiling for third-party purposes.

An up-to-date sub-processor list is available on request at [email protected]. We will notify you of material sub-processor changes with reasonable advance notice.

6. International Data Transfers

Some of our service providers are located outside the European Economic Area (EEA). Where we transfer personal data to third countries not covered by an adequacy decision of the European Commission, we rely on Standard Contractual Clauses (SCCs) adopted pursuant to Commission Implementing Decision (EU) 2021/914 as the appropriate transfer mechanism. Copies of applicable SCCs are available on request.

7. Retention

Data typeRetention period
Account data (name, email)For the duration of your account, plus 30 days after deletion to allow recovery
Scan results and reportsWhile your account is active; you may delete individual scans at any time from your dashboard
Payment transaction references7 years (EU accounting law requirement)
Server and access logs30 days
Support communications2 years from last contact

8. Your Rights Under the GDPR

As a data subject under the GDPR you have the following rights. To exercise any of them, contact us at [email protected]. We will respond within one month (extendable by two further months for complex requests). We may request proof of identity before processing your request.

  • Right of access (Art. 15): Obtain confirmation of whether we process your data and receive a copy.
  • Right to rectification (Art. 16): Have inaccurate data corrected.
  • Right to erasure (Art. 17): Request deletion of your data where no overriding legal basis applies.
  • Right to restriction (Art. 18): Restrict processing in defined circumstances (e.g. while accuracy is contested).
  • Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
  • Right to object (Art. 21): Object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds.
  • Right to withdraw consent: Where processing is based on consent, withdraw at any time without affecting the lawfulness of prior processing.

You also have the right to lodge a complaint with your national supervisory authority. The supervisory authority for our place of establishment is Autoriteit Persoonsgegevens (AP) (autoriteitpersoonsgegevens.nl).

9. Automated Decision-Making and Profiling

We do not make decisions about you that produce legal or similarly significant effects based solely on automated processing (Article 22 GDPR). The scan results we generate are purely informational and do not automatically affect your account status or any other decision about you.

10. Cookies and Tracking Technologies

We use only essential cookies required for authentication, secure session management, and fraud prevention. We do not use advertising, analytics, or behavioural tracking cookies. A cookie notice is displayed on your first visit explaining this. No consent is required for essential cookies under Article 5(3) of Directive 2002/58/EC (ePrivacy Directive).

11. Children

The Service is not directed at individuals under 18 years of age. We do not knowingly collect personal data from children. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

12. Changes to This Policy

We may update this policy to reflect changes in our practices or applicable law. For material changes, we will notify registered users by email at least 30 days before the updated policy takes effect. The current version is always available at this URL, dated at the top.

13. Contact

VP Consulting
Keurenplein 41, Box C3577, 1069CD Amsterdam, The Netherlands
E-mail: [email protected]