Privacy Policy

The data controller responsible for the processing of your personal data is Volari Group B.V. If you have any questions about this privacy policy or the processing of your personal data, you can reach us at legal@volarileads.com.

Volari Group B.V.
Wollefoppenweg 2R
3059 LG Rotterdam
KvK: 42049166
BTW: NL869473396B01

We collect the following categories of personal data:

Contact form

When you submit our contact form, we collect your first name, last name, email address, phone number, and company name.

Technical data

We automatically collect your IP address, browser type and version (user agent), language preference, and the date and time of your visit. This data is collected for security, rate limiting, and to provide our services in your preferred language.

Customer portal

If you become a customer and use our portal, we additionally collect your account credentials (hashed password), company details (registration number, address, legal form), campaign preferences, and billing information.

SMS notifications (optional)

If you enable SMS lead-availability notifications in the portal, we process your mobile phone number along with a timestamp of when you verified that number via a one-time SMS code. The number is used solely to alert you to a new lead matching your subscriptions. You can disable these notifications at any time from your portal settings.

We process your personal data for the following purposes:

Responding to your inquiry

When you contact us via the contact form, we process your data to respond to your request and assess whether our services are a good fit. Legal basis: performance of a contract or pre-contractual measures (Article 6(1)(b) GDPR).

Providing our services

If you become a customer, we process your data to provide our lead generation services, manage your account, and fulfil our contractual obligations. Legal basis: performance of a contract (Article 6(1)(b) GDPR).

Communication

We may send you service-related communications such as welcome emails, account notifications, and updates about your campaigns. Legal basis: performance of a contract (Article 6(1)(b) GDPR) and our legitimate interest in providing quality service (Article 6(1)(f) GDPR).

SMS notifications about new leads

If you have enabled SMS notifications in your portal settings, we send you a short SMS the moment a new lead matching your subscriptions becomes available. To do so we process your verified mobile phone number. Legal basis: your explicit consent (Article 6(1)(a) GDPR), given by toggling the setting on and confirming the one-time SMS code. You can withdraw that consent at any time by turning the toggle off again in your portal settings, without affecting the lawfulness of prior processing.

Security and fraud prevention

We process technical data such as IP addresses to protect our platform against abuse, enforce rate limits, and maintain a secure audit trail. Legal basis: our legitimate interest in maintaining the security and integrity of our services (Article 6(1)(f) GDPR).

Legal obligations

We may process your data to comply with legal obligations, such as tax and accounting requirements. Legal basis: compliance with a legal obligation (Article 6(1)(c) GDPR).

We do not sell your personal data to third parties. We share your data only with the following categories of service providers, who act as data processors on our behalf:

• Email delivery: we use a third-party email service for transactional emails such as welcome messages and account notifications.
• SMS delivery: we use Vonage (Vonage Holdings Corp., based in the United States) to send the one-time verification code and, if you have enabled it, SMS notifications about new leads. Vonage acts as a processor and processes your phone number only on our instructions. Transfers to the United States are made under the European Commission's Standard Contractual Clauses.
• Hosting and infrastructure: our application and database are hosted by third-party cloud providers within or with adequate protections outside the EEA.
• We may also share your data with competent authorities if required by law or a valid legal order.

All our service providers are contractually bound to process your data only according to our instructions and in compliance with the GDPR.

Some of our service providers may process your data outside the European Economic Area (EEA). In such cases, we ensure that appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses (SCCs) or an adequacy decision by the European Commission.

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Contact form submissions: data is retained for the duration of any resulting business relationship, plus the statutory retention period required by Dutch tax law (7 years for financial records).
• Customer account data: retained for the duration of the customer relationship and the statutory retention period thereafter.
• Technical logs (IP addresses, rate-limiting data): retained for a maximum of 90 days.
• GDPR audit logs (consent records): retained for a minimum of 5 years to demonstrate compliance.

Under the GDPR, you have the following rights regarding your personal data:

Right of access

You have the right to request a copy of the personal data we hold about you.

Right to rectification

You have the right to request correction of inaccurate or incomplete personal data.

Right to erasure

You have the right to request deletion of your personal data, subject to legal retention obligations.

Right to restriction

You have the right to request restriction of the processing of your personal data in certain circumstances.

Right to data portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format.

Right to object

You have the right to object to the processing of your personal data based on legitimate interests.

Right to withdraw consent

Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at legal@volarileads.com. We will respond to your request within 30 days.

If you believe we have not handled your personal data correctly, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.

Our website uses only strictly necessary (functional) cookies. We do not use tracking, analytics, or advertising cookies.

Session cookie

Used to maintain your login session when you are signed in to the customer portal. This cookie is essential for the portal to function.

Language preference cookie

Stores your preferred language (Dutch or English) so the website displays content in the correct language on subsequent visits.

Because we only use strictly necessary cookies, we are not required to ask for your consent for these cookies under Article 11.7a of the Dutch Telecommunications Act (Telecommunicatiewet).

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit (TLS), secure password hashing, rate limiting, IP-based access controls, and regular security reviews.

We may update this privacy policy from time to time. When we make material changes, we will update the "last updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of our services after changes to this policy constitutes acceptance of the updated policy.

If you have any questions, concerns, or requests regarding this privacy policy or the processing of your personal data, please contact us at:

legal@volarileads.com