Privacy Policy

1. Who We Are

The VIP Connector is an intelligence network operating internationally. We facilitate participant-driven research, AI testing and behavioural intelligence initiatives within the iGaming industry.

For the purposes of data protection law (including the General Data Protection Regulation (GDPR), UK GDPR, and the Israeli Privacy Protection Law), The VIP Connector is the data controller responsible for your personal information.

If you have any questions about how we handle your data, you can contact us at: tracyk@thevipconnector.com

2. What Information We Collect

When you register as a participant through the TVC Intelligence Network, we collect the following information:

• Full name: to identify you within the network
• Email address: to communicate with you about your registration and future project invitations
• Country of residence: to understand regional representation and for legal compliance purposes
• Age confirmation: a declaration that you are 18 years of age or older
• Primary gaming product: the iGaming vertical most relevant to your experience (e.g. Casino, Sports, Poker)
• Years of iGaming experience: your experience range to assess suitability for research projects
• Participation interests: the types of initiatives you are interested in contributing to (e.g. AI Testing, Behavioural Research)
• Privacy consent status: a record of your agreement to this Privacy Policy
• Future contact consent: your optional preference regarding communications about future projects
• Consent metadata: the date, time, Privacy Policy version and Terms version accepted at registration
• IP address: captured at the point of registration for fraud prevention and legal compliance purposes. Not shared or used for marketing.

We do not collect payment information, government identification, or sensitive personal data (as defined under GDPR Article 9).

3. Why We Collect This Information

We collect and process your personal information for the following purposes:

• Registration and network management: to process your application to join the TVC Intelligence Network and to maintain an accurate register of network participants (Legal basis: Contract / Legitimate interests)
• Project matching: to identify which intelligence projects, research initiatives or AI testing opportunities may be relevant to your profile (Legal basis: Legitimate interests)
• Communications: to contact you about your registration and, where you have given consent, about future project opportunities and network updates (Legal basis: Consent)
• Legal compliance: to maintain records of consent, to respond to data subject requests, and to comply with applicable law (Legal basis: Legal obligation)
• Fraud prevention and security: to detect and prevent fraudulent or misrepresentative registrations (Legal basis: Legitimate interests)

4. How Registrations Are Reviewed

All registrations are reviewed personally by the TVC team. There is no automated decision-making that determines whether your registration is accepted. Acceptance into the Intelligence Network is based on your experience profile, the areas of interest you have indicated and the availability of relevant projects. Submitting a registration does not guarantee acceptance or participation in any specific project.

5. How We Store Your Data

Google Sheets

Registration data is currently stored in a Google Sheets spreadsheet accessible only to authorised TVC personnel. Access is controlled via a Google Service Account and restricted to individuals with a legitimate need to process participant registrations. Google Sheets data is hosted on Google’s infrastructure, which may include servers located outside the European Economic Area (EEA). Where data is transferred internationally, it is protected by Google’s Standard Contractual Clauses approved by the European Commission.

Future HubSpot Integration

We intend to integrate HubSpot CRM as a secondary storage and communication tool. When this integration is active, your registration data will also be stored in HubSpot. HubSpot is a US-based service that transfers data internationally under Standard Contractual Clauses. This policy will be updated when the HubSpot integration is activated.

Internal Systems

Experience metric data (anonymised aggregate totals used for the public-facing network counter) is stored in a server-side JSON file. No individual registration data is exposed through this counter.

6. Analytics and Tracking

We do not currently use third-party analytics tools (such as Google Analytics). No behavioural tracking, advertising pixels or retargeting technologies are active on this website. If we introduce analytics in the future, this policy and our Cookie Policy will be updated and consent will be requested before any tracking begins.

7. Cookies

This website uses only essential cookies required for its basic operation. These include your cookie consent preference stored in your browser’s local storage. No marketing, advertising or third-party tracking cookies are currently in use. For full details, please read our Cookie Policy.

8. How Long We Retain Your Data

• Active participants: data is retained for as long as your participation in the Intelligence Network is active
• Inactive participants: if you have not engaged with or been invited to a project within 3 years of registration, your data will be reviewed for deletion unless you have indicated a preference to remain on the network
• Consent records: retained for a minimum of 6 years to comply with legal obligations relating to consent management
• Deletion requests: processed within 30 days of receipt. Consent records may be retained for the minimum legal period even after deletion of registration data

9. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including the United States and other countries where our service providers operate. Where such transfers occur from the EEA, UK or Israel, we ensure appropriate safeguards are in place including:

• Standard Contractual Clauses approved by the European Commission
• UK International Data Transfer Agreements (IDTAs) where applicable
• Adequacy decisions by the relevant supervisory authority where available

10. Your Rights

Depending on your country of residence, you may have some or all of the following rights regarding your personal data:

• Right of access: to request a copy of the personal data we hold about you
• Right to rectification: to request correction of inaccurate or incomplete data
• Right to erasure: to request deletion of your personal data (subject to legal retention obligations)
• Right to restriction: to request that we limit how we use your data in certain circumstances
• Right to data portability: to receive your data in a structured, machine-readable format
• Right to object: to object to processing based on legitimate interests
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal
• Right not to be subject to automated decision-making: we do not use automated decision-making that produces legal or similarly significant effects

To exercise any of these rights, please contact us at tracyk@thevipconnector.com or use our Privacy Requests page. We will respond to requests within 30 days. We may ask you to verify your identity before processing a request.

11. Security

We take the security of your personal data seriously. Measures in place include:

• HTTPS encryption across all pages and API endpoints
• Google Sheets access restricted via Service Account credentials stored as encrypted environment variables
• Participant data never exposed in publicly accessible URLs or API responses
• Access to registration data limited to authorised TVC personnel only

No internet transmission is completely secure. While we implement strong protections, we cannot guarantee absolute security of data transmitted to us.

12. Complaints

If you have concerns about how we handle your personal data, we ask that you contact us in the first instance so we can attempt to resolve the matter. You also have the right to lodge a complaint with your national data protection authority:

• EEA residents: your national supervisory authority (e.g. DPA, CNIL, BfDI)
• UK residents: the Information Commissioner’s Office (ICO) at ico.org.uk
• Israel residents: the Privacy Protection Authority (PPA)

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the version number and effective date at the top of this page. For material changes that affect how we use your data, we will notify registered participants by email where we have consent to do so.

14. Contact

For all privacy-related enquiries, data subject requests or complaints, please contact us at:

tracyk@thevipconnector.com

Or use our Privacy Requests page.