1. Overview & Data Controller

This Privacy Policy governs the processing of personal data by Vaultlistrippl Media Publishing S.A. ("Vaultlistrippl", "we", "us", or "our"), a company registered in Belgium with Company Registration No. BE-0894.213.904 and registered office at 42 Rue de l'Étoile, 1000 Brussels, Belgium. We act as the Data Controller under Regulation (EU) 2016/679 (General Data Protection Regulation or "GDPR") and applicable global data protection statutes including the California Consumer Privacy Act ("CCPA/CPRA").

We are dedicated to safeguarding the privacy and digital autonomy of visitors who read our editorial itineraries, download our city dossiers, and interact with our interactive maps. This document explains transparently what personal information we collect, how it is handled, and your statutory rights regarding your data.

2. Categories of Data Collected

We collect and process personal data strictly under principles of data minimization and purpose limitation:

  • Directly Provided Information: When you submit an inquiry through our Contact Desk or subscribe to our editorial newsletter, we collect your full name, email address, inquiry category, and the contents of your message.
  • Technical & Browsing Data: When you navigate our digital pages, our servers automatically record your Internet Protocol (IP) address, browser software type, operating system, referring URL, time stamps, and pages accessed.
  • Interaction & Preference Data: We store client-side preferences—such as your cookie consent election and interactive map selections—utilizing browser localStorage so your choices persist seamlessly across browsing sessions without creating intrusive cross-site tracking profiles.

3. Lawful Grounds for Processing (GDPR Art. 6)

We process your data exclusively where at least one of the following legal grounds applies:

  • Consent (Art. 6(1)(a)): You have granted explicit consent for receiving editorial dispatches or opting into non-essential analytics tracking. You may withdraw consent at any time without detriment.
  • Contractual Performance (Art. 6(1)(b)): Processing is necessary to fulfill inquiries, provide access to curated dossiers, or execute digital services requested by you.
  • Legitimate Interests (Art. 6(1)(f)): Processing is required for our legitimate interests in maintaining network security, preventing fraud, analyzing aggregate server performance, and enhancing our editorial user experience, provided your rights do not override these interests.
  • Legal Compliance (Art. 6(1)(c)): Processing is mandated by European Union or Member State laws, such as financial recordkeeping or response to valid judicial warrants.

4. Data Retention Periods

Personal data is retained only for the duration strictly necessary to fulfill the purposes for which it was gathered. Specifically:

  • Editorial & Contact Inquiries: Retained for twenty-four (24) months following resolution of your communication to ensure continuity, after which they are permanently deleted or fully anonymized.
  • Server Access Logs: Automatically overwritten and purged after ninety (90) days, unless retained temporarily to investigate a suspected security incident.
  • Cookie & Preference Choices: Persisted in your local browser for up to twelve (12) months unless you manually clear your browser cache or reset preferences earlier.

5. Third-Party Processors & International Transfers

We never sell, rent, or trade your personal data to commercial data brokers. We share data only with vetted third-party service providers (processors) who maintain strict technical safeguards and contract under standard contractual clauses (SCCs) approved by the European Commission:

  • Cloud Hosting & CDN Infrastructure: Enterprise-grade hosting partners operating ISO 27001 certified data centers within the European Economic Area (EEA).
  • Email Dispatch & Communications: Secure email relay providers handling editorial inquiries with TLS 1.3 encryption in transit.

6. Your Statutory Rights (GDPR & CCPA/CPRA)

Under European and California data privacy laws, you hold extensive rights concerning your personal information:

  • Right of Access (Art. 15 GDPR): You may request a verified copy of all personal data held about you.
  • Right to Rectification (Art. 16 GDPR): You may correct inaccurate or incomplete data promptly.
  • Right to Erasure / Right to be Forgotten (Art. 17 GDPR): You may request deletion of your personal data where retention is no longer justified.
  • Right to Restrict Processing (Art. 18 GDPR): You may limit how we process your data while a dispute is resolved.
  • Right to Data Portability (Art. 20 GDPR): You may receive your data in a structured, machine-readable format.
  • Right to Object (Art. 21 GDPR): You may object at any time to processing based on our legitimate interests.
  • Non-Discrimination: We will never deny services, charge different rates, or degrade quality for exercising statutory privacy rights.

7. Data Protection Officer (DPO) Contact

To exercise any statutory right, file a privacy inquiry, or submit a formal data request, contact our Data Protection Office directly:

Vaultlistrippl Media Publishing S.A.
Attn: Data Protection Officer
42 Rue de l'Étoile, 1000 Brussels, Belgium
Email: [email protected]

If you believe our processing violates European data protection regulations, you also have the statutory right to lodge a formal complaint with the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit) or your local EU supervisory authority.