Privacy Policy

This Privacy Policy applies to the following websites and digital products operated by Very Cool Projects:

Each product may collect different types of data depending on its functionality. Part 1 sets out the principles and rights that apply universally across all properties. Parts 2 through 5 provide product-specific details.

Identity of the Data Controller

The data controller responsible for all personal data collected across VCP's properties is:

Legal Bases for Processing Personal Data

VCP processes personal data only where a lawful basis exists under the General Data Protection Regulation (GDPR) and applicable Dutch data protection law. The legal bases we rely on are:

• Performance of a contract (Art. 6(1)(b) GDPR): Processing necessary to deliver a product or service you have purchased or registered for.
• Legitimate interests (Art. 6(1)(f) GDPR): Processing necessary for our legitimate business interests, such as fraud prevention, security, and service improvement, where these interests are not overridden by your rights.
• Compliance with legal obligations (Art. 6(1)(c) GDPR): Processing required by applicable law, including tax, accounting, and regulatory obligations.
• Consent (Art. 6(1)(a) GDPR): Where we have obtained your freely given, specific, informed, and unambiguous consent, for example for optional analytics cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Categories of Personal Data We May Collect

How We Use Your Personal Data

VCP uses personal data strictly for the purposes for which it was collected. We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects.

How We Share Your Personal Data

VCP does not sell, rent, or trade personal data to third parties for commercial purposes. Data is shared only in the following limited circumstances:

• Payment processors: Your payment data is transmitted directly to our authorised payment processor(s) (such as Stripe, Mollie, or equivalent). VCP does not store full payment card details.
• Hosting and infrastructure providers: VCP's servers and cloud services are operated by trusted third-party providers bound by data processing agreements compliant with GDPR.
• Legal authorities: VCP may disclose personal data to law enforcement, courts, or other authorities only when we are legally required to do so by applicable Dutch or EU law, court order, or valid subpoena.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of VCP's assets, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party processors engaged by VCP are subject to written data processing agreements (DPAs) that comply with GDPR Article 28 and impose equivalent data protection obligations.

International Data Transfers

VCP is based in the Netherlands and operates primarily within the European Economic Area (EEA). Where personal data is transferred outside the EEA (for example, to cloud service providers with servers in the United States), VCP ensures such transfers are protected by appropriate safeguards, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission;
• Adequacy decisions issued by the European Commission; or
• Other legally recognised transfer mechanisms under Chapter V of the GDPR.

Data Retention

VCP retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention principles are:

• Account and transaction data: Retained for the duration of the contractual relationship and for seven (7) years thereafter, in compliance with Dutch tax and accounting obligations.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Analytics and usage data: Retained in aggregated, anonymised form and not linked to individual users after fourteen (14) months.
• Game progress data (The Decree 2): Retained for as long as your account is active. Upon account deletion, cloud-stored data is deleted within a reasonable timeframe.
• Local storage data (The Decree 1 & 2 offline progress): Stored exclusively on your own device. VCP has no access to, and no obligation in respect of, locally stored data.

Your Rights as a Data Subject

Under the GDPR and applicable Dutch law, you have the following rights in respect of your personal data:

To exercise any of the above rights, please contact us at aloha(@)verycoolprojects.com. VCP will respond within a reasonable timeframe in accordance with applicable law.

Cookies and Tracking Technologies

VCP uses cookies and similar tracking technologies across its properties. The types of cookies used are:

• Strictly necessary cookies: Required for the basic functioning of the website (e.g., session management, login persistence). These cannot be disabled.
• Preference cookies: Used to remember your settings and preferences. These are only set with your consent.

You may manage your cookie preferences at any time through your browser settings or via any cookie consent tool displayed on the relevant site. Refusing optional cookies will not affect your ability to use the core features of our products.

Data Security

VCP implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• Encrypted data transmission using HTTPS/TLS across all our websites;
• Access controls limiting personal data access to authorised personnel only;
• Regular security reviews of our systems and third-party processors;
• Password hashing and secure credential storage practices.

No online system is entirely immune to security risks. VCP cannot guarantee absolute security, and you use our services at your own risk in this respect. In the event of a personal data breach, VCP will comply with its notification obligations under applicable law.

Children's Privacy

VCP's services are not directed at children under the age of sixteen (16). VCP does not knowingly collect personal data from children under sixteen (16) without verifiable parental consent. If VCP becomes aware that it has inadvertently collected personal data from a child under sixteen (16), it will take prompt steps to delete that data. If you believe a child has provided personal data to VCP without appropriate consent, please contact us immediately at aloha(@)verycoolprojects.com.

Third-Party Links and Services

Our websites and products may contain links to third-party websites or integrate with third-party services (for example, payment processors, hosting providers, or social platforms). VCP is not responsible for the privacy practices, content, or security of any third-party website or service. We strongly encourage you to review the privacy policies of any third party before providing them with personal data.

Changes to This Privacy Policy

VCP reserves the right to update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or services. The updated version will be posted at verycoolprojects.com with a revised effective date. For material changes, VCP will provide additional notice (for example, via email to registered users or a prominent notice on our websites). Your continued use of VCP's products or services following the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms.

Contact and Data Protection Enquiries

For all privacy-related enquiries, data subject rights requests, or concerns, please contact:

Overview

The main VCP website at verycoolprojects.com serves as a landing page presenting all VCP digital products and services. It does not require account registration or payment.

Data Collected

• Contact enquiries: If you contact VCP via aloha(@)verycoolprojects.com or a web form, we collect your name, email address, and the content of your message.
• Technical and analytics data: IP address, browser type, device type, and anonymised usage statistics.
• Cookies: Analytics and preference cookies, subject to your consent.

No Account Required

Browsing the main site does not require you to provide personal data beyond what is automatically collected by cookies and server logs. You may browse entirely without submitting any contact forms.

Data Sharing

Data collected on the main site is used solely to respond to enquiries and improve the site experience. It is not shared beyond the circumstances described in Part 1, Section 5.

Retention

Contact enquiry data is retained for two (2) years from the date of the last interaction. Analytics data is retained in anonymised, aggregated form only.

Overview

The course platform at designcourse.verycoolprojects.com delivers the "Webdesigner in 30 Minutes" video course. Access requires account creation and purchase.

Data Collected

• Registration and account data: Name, email address, and account credentials created upon purchase.
• Payment data: Billing name and transaction reference, processed directly by our third-party payment processor. VCP does not store full payment card details.
• Video progress data: The course video player automatically tracks how many minutes of course content you have watched. This data is used solely to: (a) determine eligibility for refund requests under the refund policy; and (b) display your personal progress within your account.
• Support communications: Content of any support requests submitted by email or via the membership area.
• Technical and analytics data: Standard server log and anonymised analytics data as described in Part 1.

Why We Track Video Progress

Video progress tracking is a core functional requirement of the Course platform. It serves two purposes: enabling you to resume where you left off, and determining refund eligibility (refunds are only available where less than 10 minutes of content has been viewed). This processing is necessary for the performance of the contract between you and VCP. You cannot opt out of video progress tracking while using the Course.

Community Group

Access to the private community group associated with the Course involves your participation on a third-party platform. Any information you share within the community group is subject to both VCP's community guidelines and the privacy policy of the platform hosting the group. VCP is not responsible for the privacy practices of the third-party community platform.

WordPress Plugins

Plugins provided as part of the Course are installed on your own web hosting environment. VCP has no visibility into, and collects no data from, websites you build using Course materials or plugins. You are solely responsible for the privacy and data security practices of any website you create.

Retention

Account and purchase data is retained for seven (7) years from the date of purchase in accordance with Dutch tax law. Video progress data is retained for the duration of your account. Upon written request for account deletion, VCP will delete personal data within a reasonable timeframe, subject to legal retention obligations.

Overview

The subscription service at subscription.verycoolprojects.com is an ongoing, on-demand design and development service. Clients communicate with their designer primarily via WhatsApp and through a personal Membership Area.

Data Collected

• Account and subscription data: Name, email address, account credentials, subscription plan details, and billing history.
• Payment data: Billing name, address, and transaction reference, processed by our authorised payment processor. VCP does not store full payment card details.
• Project communications: Content of Requests and associated communications submitted via WhatsApp or other agreed channels. This includes text, images, branding assets, and any other materials you provide for the purpose of completing design work.
• Membership Area activity: Request logs, project status updates, and delivery history stored in your personal Membership Area.
• Client-provided assets: Brand materials, logos, photographs, text content, and other assets you supply to VCP for use in Deliverables.
• Support communications: Emails and WhatsApp messages exchanged for support or account management purposes.

Use of Client-Provided Content

Materials and content you provide to VCP for the purpose of completing design Requests (including brand assets, images, and text) are used exclusively to fulfil your Requests. VCP does not use client-provided content for any other purpose without your express written consent. VCP may display completed Deliverables in its portfolio unless you request confidentiality in writing prior to project commencement.

WhatsApp and Third-Party Communication

Communication via WhatsApp is conducted on Meta's platform. VCP uses WhatsApp solely as a communication channel and does not control Meta's data processing. Your use of WhatsApp is subject to Meta's own privacy policy. VCP retains copies of Request-related communications within the Membership Area for project tracking purposes.

Print Services

Where print services are requested, your delivery address and any other information required by the print supplier will be shared with the third-party supplier solely for the purpose of fulfilling the print and delivery order. VCP will not share this information for any other purpose.

Retention

Client account and transaction data is retained for seven (7) years from the date of last transaction in accordance with Dutch tax and accounting obligations. Project files and Deliverables are retained in VCP's systems for up to two (2) years after Subscription termination, after which they may be deleted. Client-provided assets and communications are retained for the same period.

Overview

The Decree and The Decree 2 are browser-based games accessible at thedecree.verycoolprojects.com. The two versions have significantly different data architectures:

The Decree 1: Data Practices

Data Collected

• No in-game data: VCP does not collect, read, or store any in-game progress. All progress is stored in your browser's localStorage on your own device.

LocalStorage (The Decree 1)

Your game progress in The Decree 1 is stored exclusively in your browser's localStorage. This means:

• Your progress is stored on your device, not on VCP's servers.
• VCP has no access to your in-game progress or save data.
• Clearing your browser's localStorage will permanently delete your progress. VCP cannot recover it.
• Your progress is device-specific and browser-specific; it will not transfer to another device or browser automatically.

The Decree 2: Data Practices

Data Collected

• Account data: Name and email address provided upon registration or purchase.
• Payment data (if applicable): Billing details processed by our authorised payment processor. VCP does not store full card details.
• Online Access Key: The Decree 2 connects to VCP's server to verify your Online Access Key at launch. The verification process confirms your licence without transmitting full in-game progress data.
• Cloud progress data: Achievement Points (APs) and Streak digits are automatically saved to VCP's server, allowing you to access your progress (digits) across devices.
• User-generated content: Any content you voluntarily share through the community feed, posts, or club features is transmitted to and stored on VCP's server for the purpose of displaying it to other players in those features.
• LocalStorage (offline progress): All other in-game progress not described above continues to be stored locally on your device, as with version 1.

Legal Basis for Server-Side Processing

Server-side data processing for The Decree 2 (Online Access Key verification, AP and Streak sync, community features) is based on the performance of the contract between you and VCP (GDPR Art. 6(1)(b)). Community-shared content is additionally based on your consent, which you give by voluntarily choosing to use community features.

User-Generated Content in Community Features

By voluntarily sharing content via the community feed, posts, or club features in The Decree 2, you grant VCP a non-exclusive, royalty-free licence to store and display that content to other players within the game. You are responsible for ensuring that any content you share does not infringe third-party rights or violate applicable law. VCP reserves the right to remove content that violates community guidelines without notice.

Retention

Cloud-stored progress data (APs, Streak, community content) is retained for as long as your account is active. Upon account deletion, server-side data will be deleted within a reasonable timeframe. Locally stored progress (localStorage) is not accessible to VCP and is not subject to VCP's retention schedule.

Analytics Across Both Game Versions

VCP uses standard website analytics on The Decree platform to track aggregate metrics such as total registered users and total website visits. This data is anonymised and aggregated; it is not used to track individual player behaviour or to build personal profiles.