Who we are
Dopomoga is a practical guide for Ukrainians in the European Union. The controller of your personal data is MaxVera (eenmanszaak — sole proprietorship, trading as Dopomoga), KvK 99672332, Seisplein 9, 4331NP Middelburg, the Netherlands. For any questions regarding this policy, write to support@uadopomoga.eu.
What data we collect
We collect the minimum necessary to operate the service:
- Email — for logging into your account and technical notifications.
- Password — stored in hashed form (bcryptjs, cost factor 12). We cannot see your password in plaintext.
- Personal settings: selected country (for example, NL), document drafts (rental, work, KvK), ZZP preparation progress, activity log (the last 100 events).
- Registration date and the date of acceptance of the terms of use.
- Profile and contact details you provide: first/last name, phone number, city.
- Login history — for your account security we record each successful sign-in (time, browser/operating system, and a one-way salted hash of your IP, never the raw IP). It is included in your data export.
- Change log: when you or an operator edit your seller profile, invoices, customer contacts, quotes or credit notes, we keep a before/after record (with a hashed IP, never the IP itself) for up to 90 days and then in an archive for up to 2 years, so a wrong change can be reverted. These records are part of your data export and are deleted with your account.
- Business and bookkeeping data, if you use the ZZP Pro tools: invoices, expenses, quotes, credit notes, customer contacts, VAT/BTW figures and your KvK number. Some fields you fill in yourself may contain a BSN (yours or, where a tax form requires it, a client's). Finalized invoices and accounting records are kept for 7 years to meet Dutch tax-law obligations, and are therefore retained even after you delete your account; everything else is erased with your account.
- Marketplace data, if you use the marketplace: your seller profile, listings, bookings, reviews, and the content of in-app messages you send.
- AI-tool inputs: the text or images you submit to the AI chat, letter analyzer, translator, receipt scanner and invoice assistant (see “AI chat and data transfer”).
- CV: the draft lives in your browser, but when you generate the PDF while signed in we store the latest CV content on our server (to re-render the PDF and to help with support — a Dopomoga operator can view it). It is deleted with your account.
- Google sign-in: if you sign in with Google, we receive your email address, name and profile-picture link from Google (see “Sign-in with Google”).
- Accountant bookings: name, email, phone, the chosen service, language and consultation time, plus operator-only notes (see “Accountant bookings”).
We do not use third-party analytics, advertising trackers, or third-party cookies (no Google Analytics, Meta Pixel, Hotjar, etc.).
We do run our own cookieless analytics, stored only in our EU database and never shared or sold. It records: page views with a daily-rotating visitor hash (sha-256 of IP and browser, re-salted every day, so visits cannot be linked across days or back to you), device type, and an approximate country derived from your IP via an offline lookup — the IP address itself is not stored. We also count key events (registrations, published listings, bookings, ZZP Pro payments) and store normalized search queries with personal data removed (any query containing an email, phone number, or long digit sequence is discarded) in order to find and fill content gaps. Page-view data is kept for 180 days and search queries for 90 days, then deleted automatically.
Cookies & local storage
We use only strictly necessary cookies — they are required for the site to work, so they need no consent and are not used for advertising or tracking. That is precisely why we deliberately show no cookie-consent banner: we set no advertising or analytics cookies at all.
- Authentication session cookie (NextAuth) — keeps you signed in after login.
- CSRF token — protects forms against cross-site request forgery (CSRF).
- NEXT_LOCALE — remembers your chosen interface language.
- Anti-bot cookie — set by Cloudflare Turnstile on the sign-up, login, password-reset and contact pages (see the “Anti-abuse protection (Cloudflare Turnstile)” section below).
- One-time link cookie (ua_reset_token / ua_verify_token) — temporarily (up to 60 minutes) holds the single-use token from a password-reset or e-mail-verification link so that it is not part of the address of the page you open; not readable by scripts (httpOnly) and cleared as soon as the token is used.
In your browser we also keep small functional data (localStorage and sessionStorage): a CV draft, bookmarks saved before you sign in, and interface-hint state. Bookmarks and hint state stay only on your device. The CV draft also lives in your browser, but when you create the PDF its content is sent to our server and, if you are signed in, stored there (see “What data we collect”). Our cookieless analytics is described above in the “What data we collect” section.
Legal basis for processing
We rely on different legal bases depending on the purpose: providing your account and the service you ask for (ZZP bookkeeping, marketplace participation) — performance of a contract (Art. 6(1)(b)); authentication, security and abuse-prevention, and our cookieless analytics — our legitimate interests (Art. 6(1)(f)); transferring data to AI tools outside the EU — your explicit consent (Art. 6(1)(a) and 49(1)(a)); and keeping invoices and payment records for the statutory period — a legal obligation under Dutch tax law (Art. 6(1)(c)). By accepting at registration you also confirm you are at least 16, the age required to consent validly under Dutch data-protection law.
Your business and tax data. For the bookkeeping records you create — invoices, expenses, customer details and any tax identifiers such as a BSN — you are the data controller and Dopomoga acts as your processor, providing the tools. You are responsible for entering accurate data and for having a lawful basis to store any third party's personal data (for example a client's BSN) that you input.
Security. We apply appropriate technical and organisational measures (Art. 32 GDPR) — password hashing, PII scrubbing before error reports, and EU-region hosting. However, no method of transmission over the internet or electronic storage is completely secure, so while we work to protect your data we cannot guarantee absolute security.
Your rights
Under the GDPR you have the right to:
Storage and region
Most data (the Neon Postgres database, authorization sessions, server authentication logs) is hosted in the eu-central-1 (Frankfurt, EU) region. Specific categories of data are transferred to the processors (sub-processors) we use, including outside the EU — the full list and legal bases are set out below in the “AI chat and data transfer” (OpenRouter), “Email and mailings” (Resend), “Payments and subscriptions” (Stripe), “Anti-abuse protection” (Cloudflare Turnstile) and “Backups” (Cloudflare R2) sections.
Logs and login history. Server authentication logs are retained for up to 30 days via pm2-logrotate; email addresses in logs are hashed (sha-256, first 16 characters), and full addresses and passwords are never logged. Your login history (recent logins — time, browser/OS and a salted one-way hash of your IP) is kept for up to 180 days, after which it is automatically deleted; it is also included in your data export.
Contact-form submissions: contact-form messages (the message text, email/phone) are retained for up to 180 days, after which the record is automatically anonymized. The form does not accept document uploads. If you have an account, this data is also deleted when you delete your account.
AI chat and data transfer
For the AI chat feature, Dopomoga uses the external service OpenRouter(OpenRouter Inc., registered in the USA). When you send a message to the AI chat, the text of your question and the context of recent messages are transferred to OpenRouter to generate a response. OpenRouter in turn may use one or more model providers (for example, Google, OpenAI) to process the request.
Dopomoga does not store AI chat history on the server. Only anonymous usage counters are stored (number of messages per day, time of the last request) — this is necessary for the technical limit (100 messages per UTC day, a 5-second interval between requests).
Your rights: You may at any time request the deletion of all data via the “Delete account” function in the Account section — this will delete the AI chat usage counters and all tokens for email verification / password reset associated with your account.
Email and mailings (Resend)
For sending emails Dopomoga uses the service Resend (Resend, Inc., registered in the USA; the sending server is hosted in the Ireland region, eu-west-1). Resend is used to send, among others: email confirmation and password reset, marketplace new-message notifications, accountant-booking emails, review notifications, and replies to your contact-form enquiries.
What data is transferred: your email address and the content of the email itself (for example a confirmation link or a short notification text). Legal basis: performance of a contract and our legitimate interest in operating the service (Art. 6(1)(b) and 6(1)(f) GDPR).Transfer: the email content is sent from servers in the EU (Ireland); the Resend account metadata (our settings, sending statistics) may be processed in the USA under the EU Standard Contractual Clauses (SCC).
Rule-update emails. If you subscribed to updates on the “Updates” page, we store your email address, your chosen topic and municipality, and your language, in order to email you about rule changes matching that choice. This is not a transactional email: the legal basis is your consent (Art. 6(1)(a) GDPR), given when you confirm the subscription via the link in the first email (double opt-in). You can withdraw consent at any time — every email carries an “Unsubscribe” link, and after unsubscribing we stop sending them.
Payments and subscriptions (Stripe)
For processing payments — the ZZP Pro subscription, accountant services (consultation, yearly return, bookkeeping plan) and the tax-refund packages — Dopomoga uses Stripe(Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Dublin 2, Ireland — the processor for EU customers; the parent company Stripe, Inc. is registered in the USA). Stripe is a regulated payment service provider (an authorised payment institution in the EU). Available payment methods: card and SEPA Direct Debit for the subscription; card and iDEAL for one-off services.
Legal basis: The transfer of payment data to Stripe is based on the performance of a contract (Art. 6(1)(b) GDPR) — the ZZP Pro subscription you take out.
Processing region and transfer: Stripe Payments Europe processes data within the European Economic Area. Certain data may be processed by the parent company Stripe, Inc. (USA) on the basis of the EU Standard Contractual Clauses (SCCs), which provide an adequate level of protection.
What data is transferred to Stripe: Your name, email address, payment method type, and the last 4 digits of the card or IBAN (for display in your dashboard), as well as the Stripe customer and Stripe subscription identifiers. Dopomoga never stores the full card number or full IBAN — this data is processed exclusively on Stripe's side in tokenized form.
Storage on our side: We store the Stripe customer and Stripe subscription identifiers (for managing the subscription lifecycle) — they are deleted together with the account (cascade deletion).
Storage at Stripe: Stripe stores payment data in accordance with its own privacy policy and Dutch tax requirements (7 years for accounting documents). For more details: stripe.com/privacy.
Tax refund (tax-return filing)
The Tax refund service (Belastingteruggave) comes in two packages: “I file myself” (€39/year) — we verify your documents and prepare a personal step-by-step instruction, and you file the return yourself via Mijn Belastingdienst; “Accountant files” (€89/year) — a registered accountant partner files the return for you after a scheduled call and a DigiD Machtigen authorization. For both packages, Dopomoga is the data controller — unlike the ZZP bookkeeping tools, where you are the controller.
What data we collect (both packages): your name, e-mail, phone, the tax years, your family situation (marital status, children, joint filing with a fiscal partner), a note about your situation, and the documents you upload (primarily the jaaropgaaf — note that the document itself contains your BSN). “Accountant files” only: your BSN (persoonsnummer) and refund IBAN (the accountant needs them to file and to state the refund account) and, for a joint return, the name and BSN of your fiscal partner. In the “I file myself” package we deliberately do not ask for your BSN or IBAN (data minimization, Art. 5(1)(c) GDPR): you file via your own DigiD and enter your IBAN directly in the return.
Legal basis: the processing is based on performance of the service contract (Art. 6(1)(b) GDPR). BSN processing (the “Accountant files” package) is based on a legal obligation under Dutch tax law, which requires the BSN to be stated on a tax return (Art. 6(1)(c) GDPR).
Recipients: in the “I file myself” package your documents are seen only by the Dopomoga operator who verifies them and prepares your instruction — they are not shared with anyone outside Dopomoga. In the “Accountant files” package your data is shared with a registered accountant partner (with a Beconnummer) who files the return with the Belastingdienst (the Dutch tax authority), which pays out any refund; the authorization is arranged in the government’s own DigiD Machtigen system — we never see or store your DigiD credentials. The service fee (€39 or €89 per year, plus the fiscal-partner add-on) is processed via Stripe (see the “Payments and subscriptions” section above).
Security: your BSN, IBAN, fiscal-partner BSN and situation note are stored with field-level encryption; uploaded documents are stored in a private server location and are never reachable via a public URL.
Retention: uploaded documents and the sensitive fields are deleted automatically within a few months after your request is completed or cancelled; abandoned unpaid requests are purged automatically as well. The payment record is kept for the statutory fiscal period under Dutch law.
Your rights: as with the rest of your data, you can request access or erasure (Account → Data export / Delete account, Art. 20 and 17 GDPR) or write to us at support@uadopomoga.eu.
Business registration verification (KvK Handelsregister)
To verify marketplace sellers who are registered as legal entities or ZZP'ers in the Netherlands, Dopomoga queries the official registry KvK Handelsregister (Kamer van Koophandel, Den Haag, Netherlands). The query occurs only at your explicit initiative — when you press “Verify via KvK API” in the seller profile settings.
Processing region: KvK is a state registry of the Netherlands, registered and physically located within the European Union. Transfer of data to countries outside the EU does not occur, so separate consent under Art. 49 GDPR is not required.
Legal basis: The transfer of data to KvK is based on contractual necessity (Art. 6(1)(b) GDPR) — without verifying the status of your business in the Handelsregister, we cannot provide you with the “Verified business” badge in the marketplace.
What data is transferred to KvK: Only your 8-digit KvK number. No other information (email, name, IP address) is transferred. In response, KvK returns publicly available information from your business registration: trade name, legal name, registered business address, and registration status (active / inactive / deregistered).
Storage on our side: The KvK response is cached on the server for 30 days (reducing the volume of API queries), after which it is automatically re-queried. Your KvK number in the seller profile is stored as long as your account remains active; it is deleted together with the account (cascade deletion under Art. 17 GDPR). Once a month we check whether the status of your KvK registration has changed — if so, we automatically remove the “Verified business” badge and send you a notification.
Storage at KvK: KvK, as a state registry of the Netherlands, stores your business registration data in accordance with the Handelsregister Act (Handelsregisterwet 2007). For more details: kvk.nl/privacy.
Error monitoring (Sentry)
To detect technical errors, Dopomoga uses the service Sentry (Functional Software, Inc., d/b/a Sentry; parent company Sentry GmbH — Berlin, Germany, EU). Data is sent to a Sentry instance in the Frankfurt, EU region (DSN host *.ingest.de.sentry.io). Telemetry is not transferred outside the EU.
Processing region: Sentry EU (Frankfurt). Transfer of data to countries outside the EU does not occur, so separate consent under Art. 49 GDPR is not required.
Legal basis: The transfer of error telemetry to Sentry is based on our legitimate interest in ensuring the security and reliability of the service (Art. 6(1)(f) GDPR); the relationship with Sentry as a sub-processor is governed by Art. 28 GDPR.
What data is transferred to Sentry: The technical stack of the error (trace, files, lines of code), browser / operating system type, the URL path (on the client side query parameters are removed). Email, phone number, BSN, KvK number, and IP address are hashed (sha-256, first 16 characters for email, first 8 for the rest) BEFORE being transferred to Sentry using the server-side PII scrubber — Sentry itself stores only sentinels of the form [email:<hash>], [phone:<hash>], etc.
Storage on our side: No Sentry events are stored locally — telemetry is transmitted directly to the Sentry EU instance via a network request at the moment the error occurs. On the Dopomoga server we store only the authorization log (authLog, separate from Sentry, with its own rotation rule of 30 days × 10 MB).
Storage at Sentry: Sentry stores error telemetry for 90 days (the standard free-tier period), after which it automatically deletes it. For more details: sentry.io/privacy.
Your rights: You may at any time request the deletion of your account via the “Delete account” function — after deletion, new Sentry events that could be associated with your account are physically impossible to create (the account no longer exists); events sent earlier are deleted automatically after 90 days under Sentry's policy.
Anti-abuse protection (Cloudflare Turnstile)
To protect the sign-up, login, password-reset and contact forms against bots and automated abuse, Dopomoga uses Cloudflare Turnstile (Cloudflare, Inc., USA). When you open one of these forms, the Turnstile widget loads in your browser and passes Cloudflare your IP address and technical browser signals to assess whether you are human. Turnstile is not used for advertising or cross-site tracking.
Legal basis: our legitimate interest in preventing abuse and protecting the service (Art. 6(1)(f) GDPR). Transfer: data is processed by Cloudflare, including in the USA, under the EU Standard Contractual Clauses (SCC). More: cloudflare.com/privacypolicy.
Backups (Cloudflare R2)
To protect your data against loss, every night we create a backup of the database and uploaded files (including tax-refund documents) and store it in the Cloudflare R2 object-storage service (Cloudflare, Inc.) with encryption at rest on Cloudflare's side. The most sensitive fields (BSN, IBAN) are additionally field-level encrypted before they reach the backup. Backups are kept for a limited time (no longer than 30 days) and then overwritten.
Legal basis: our legitimate interest and duty to ensure the integrity and recoverability of data (Art. 6(1)(f) and Art. 32 GDPR). Transfer: the backup storage is provided by Cloudflare; transfer to the USA takes place under the EU Standard Contractual Clauses (SCC).
Sign-in with Google
Besides email and password, you can sign in with Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland — for users in the EU). Google then sends us your email address, name and a link to your profile picture; we never receive or see your Google password. If an account with that email address already exists, the Google sign-in is linked to it. Legal basis: performance of the contract — providing the account you request (Art. 6(1)(b) GDPR). Google processes the data about your sign-in as an independent controller under its own policy: policies.google.com/privacy.
Accountant bookings
If you book an accountant service (consultation, yearly return or the bookkeeping plan), we store your name, email, phone, the chosen service, language and preferred consultation time, the status of the booking and operator-only notes (visible to Dopomoga operators only), plus the Stripe payment identifiers. You can book without an account. Recipients: the partner accountant who delivers the service, and Stripe for the payment (card or iDEAL; the bookkeeping plan is a monthly subscription). Legal basis: performance of the contract (Art. 6(1)(b) GDPR). Retention: the contact details of completed and cancelled bookings are anonymised automatically after 6 months, abandoned unpaid bookings after 12 months; the anonymised payment record is kept for the statutory tax period. Bookings linked to an account are anonymised when the account is deleted.
Push notifications
Browser push notifications only work if you enable them yourself under Account → Notifications. Your browser then creates a subscription address at its vendor's push service — Google (Chrome/Android), Mozilla (Firefox), Apple (Safari) or Microsoft (Edge) — and we store that address and its encryption keys. Notifications (for example a reminder about an unpaid invoice with the client name and amount) go through that service encrypted: the service sees that a notification exists, not its content. Legal basis: your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time by disabling notifications in your account or browser — the subscription is then deleted. Transfer: the browser vendor's push service may process the subscription data outside the EU under the EU standard contractual clauses (SCC). The subscription is deleted with your account.
What we do NOT do
- We do not show advertising.
- We do not use third-party advertising or analytics trackers (Google Analytics, Meta Pixel, Hotjar, etc.).
- We do not transfer data to third parties other than the processors (sub-processors) we engage — each is described in this policy (OpenRouter, Resend, Stripe, KvK, Sentry, Cloudflare) and acts under a data-processing agreement (Art. 28 GDPR). We do not pass your data on for their own purposes.
- A few recipients act as independent controllers rather than our processors: Google (only if you sign in with Google), your browser's push service (only if you enable notifications) and the partner accountant (only if you book their service) — each is described in its own section above.
- We do not sell your data.
Contact
For requests regarding personal data: support@uadopomoga.eu.
Anonymous survey
On the page “Ukrainians in the Netherlands 2026” we run an anonymous survey with fixed answer options — no free-text field anywhere. What is stored: the chosen answer options, the language the form was filled in and the time of submission, to the hour. What is NOT stored: IP address, name, email, phone, browser or device identifier, any link to your account (even if you are signed in). The record holds nothing that points to you, and we do not link survey records to individual people or to any other server logs.
Abuse protection: to limit submissions from one address (up to 30 per day) we temporarily keep — separately from the answers — a one-way truncated hash of the IP address (sha-256, first 16 characters). It expires after 24 hours and is deleted on the next form submission. The fact that a response was recorded (without the IP and without the answers themselves) is written to the server logs described under “Storage & region”.
Legal basis: your consent (Art. 6(1)(a) GDPR), given with the checkbox before sending. Because the record contains nothing that identifies it, we cannot find or delete your specific response after submission (Art. 11 GDPR). Publication: aggregated figures only (percentages and counts), and only after 30 responses; individual records are neither published nor passed to third parties. The aggregated statistics may be reused under the CC BY 4.0 licence. The anonymous records are kept without a deletion deadline so that the statistics can be recalculated.
Changes to the policy
If we update this policy, you will see a notification at your next login asking you to confirm acceptance of the new version.