VST Enterprises

Privacy Policy

This notice describes VST Enterprise Limited's ("VSTE", "we" or "us") privacy policy (the " Privacy Policy") and shall apply to any personal data that we collect from you, or that you provide to us, when you use the services offered by VSTE through or on our website at https://www.vcode.it ("the Website") and/or the VCode Application for mobile telephones and handheld devices (the "APP"), including all online and wireless services and functions (together "the Services"). This privacy policy sets out the basis on which such personal data will be processed by us.


Information we may collect from you

We may collect and process the following data about you:

  • Information you give us (Submitted information): You may give us information about you by filling in forms when you register to download or register to use the Website and/or the APP and/or use the Services or by corresponding with us (for example, by e-mail). The information you give us may include your name, address, e-mail address and phone number, mobile phone number, age, username, password and other registration information, demographic information, personal description and photograph.
  • Information we collect about you and your device. Each time you visit the Website or use the App we may automatically collect the following information:
    • technical information, including the type of mobile device you use ("Device"), a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting ("Device Information");
    • information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content, checkins (Content Information);
    • details of your use of any of the App or your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access, including the nature of the content that is viewed, related transfer rates, length of viewing, which pages are viewed and other similar data (Log Information).
  • Location information. Our Services will make use of location data sent from the Device. If you use the Services, you consent to us and our affiliates' transmission, collection, retention, maintenance, processing and use of your location data to enable us to provide the Services and the relevant functionality in accordance with our App Terms and Conditions and this Privacy Policy. You will be asked to consent to the use of location services when you download the App for the first time. You may withdraw this consent at any time by turning off the location services settings on your Device's 'location settings' pane; however this may mean that you can no longer access the Services.
  • Information we receive from other sources (Third Party Information). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
  • Unique application numbers: When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us

Uses made of the information

We use information held about you in the following ways:

  • Information you give to us. We will use this information:
    • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and Services that you request from us;
    • to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
    • to provide you with information about third party goods or services we feel may interest you. We will only contact you by electronic means (i.e. via the APP, e-mail or SMS) if you have consented to this at the time that you register to use the APP. If you do not want us to use your data in this way, you can withdraw your consent at any time; however this may mean that you can no longer access some or all of the Services;
    • to notify you about changes to our Services;
    • to ensure that content from the Website and the App is presented in the most effective manner for you and for your computer or Device.
  • Information we collect about you. We will use this information:

to maintain, administer and monitor the Services in order to analyze trends, improve the overall quality of the Services, tailor the Services to your needs and respond to your inquiries. Such analysis and information is aggregated across users, does not identify you as an individual and does not link to any personally identifiable information;

    • to administer the Website and the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    • to improve the Website and the App to ensure that content is presented in the most effective manner for you and for your computer;
    • as part of our efforts to keep the Services safe and secure;
    • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
    • to make suggestions and recommendations to you and other users of the Website and the App about goods or services that may interest you or them.
  • Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may share your information with selected third parties including:

  • business partners, suppliers and sub-contractors who provide Services on our behalf; and
  • affiliate brands, advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our affiliate brands and/or advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have scanned their VCode on any given day). We may also use such aggregate information to help our affiliate brands and/or advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our affiliate brands' and/or advertisers' wishes by displaying their offers, rewards and/or other advertisements to you (if you are part of their target audience.

We may also disclose your personal information to third parties:

  • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if VSTE or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of thetransferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; or
  • in order to:
    • enforce or apply the App Terms and Conditions and other agreements or to investigate potential breaches; or
    • protect the rights, property or safety of VSTE, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Protection of Minors.

VSTE does not permit anyone under the age of 13 to register to use the Website, App or Services or use any of its functionality for which registration is required. If you are under 13 please do not register to use the Website, App or Services. If you do register and we find out that you are under 13 your account will be deleted. If you are between the age of 13 and 18 your registration must be with the permission of your parent or guardian. If you do not have such permission please do not register. If the event that we find out that you are between the age of 13 to 18 and you do not have such permission your account will be deleted. The above relates to direct registration with VSTE or through any third party social media site.

NOTE TO PARENTS AND GUARDIANS. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@VSTE.com. VSTE do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take all reasonable steps to remove such information and terminate the child's account.

Cookies and Log Information.

When you visit certain webpages on the Website and/or use the APP, VSTE sends one or more cookies (which is a small file containing a string of characters), and/or similar tracking technology, to your computer or Device that uniquely identifies your browser. VSTE uses cookies and such other technologies to improve the quality of the Services, including for storing account preferences, improving search results and ad selection, and tracking user trends, such as how people search and interact with VCodes. VSTE servers automatically record information that your browser sends whenever you visit the Website or use the App or the Services. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Marketing Communications.

VSTE may use your username and email address to provide you with email newsletters, announcements, VSTE news about products and/or services and information about your user account. If you do not wish to receive these kinds of marketing communications, you may "opt out" either by: (a) unchecking the email newsletters and announcements during registration; or (b) by doing the same within your user profile.

Linking to third party websites

The Website and/or the APP may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

Where we store your personal data

International data transfers

Under the eighth data protection principle, the transfer of any personal data to countries outside the EEA is only permitted where the receiving country has an adequate level of protection (paragraph 1, Schedule 4, DPA; see Practice note, Cross-border transfers of personal data or where the data subject consents to such transfer. Consent, which in this case can be implied, is the route most often used to legitimise a transfer of data outside the EEA. Accordingly, if data will, or may be, transferred outside the EEA, this should be stated in the privacy policy, together with (as far as this is possible) details of the processing involved. Ideally, the App Owner or Appstore Provider should also specify the countries to which personal data may be transferred (although in practice this may be impossible, since those destinations are likely to be subject to change).

A transfer of data may include the act of using the App to post information to a website that can be accessed from overseas (although the ECJ has established that placing personal data on a website will not always constitute a transfer to a third country (criminal proceedings against Lindqvist (Case C-101/01) [2003] I-12971). This issue is particularly relevant (and problematic) for App Owners or Services Site providers who publish personal data on their sites, as it may be difficult to specify the relevant countries in which the data could be accessed. Examples of such sites are those that enable users to contact one another, such as auction sites, and those that provide instant messaging facilities. Owners of these sites should seek to impose rules of conduct on users in order to protect privacy. Such rules may be included in the privacy policy.

In order to promote confidence in users of the App and the related websites, the privacy policy also includes an assurance that the data will be kept secure. Select and (if appropriate) tailor the appropriate optional wording concerning processing of payment details and the type of encryption technology used. Further assurance might be given if the App Owner provides details of the security procedures and features used, but this is optional.

If personal data collected by the App Owner is stored on the user's mobile device or if services accessible through the App use features that might make any personal data submitted visible to other users, select and (if appropriate) tailor the appropriate optional wording.

The DPA imposes stringent security obligations on the data controllers in any case (paragraph 7, Part 1, Schedule 1, DPA). The assurance is qualified by a statement clarifying that the transmission of information via the internet is never completely secure. The privacy policy is expressed to exclude the website owner's liability for personal data lost in transmission to the website. Consumer legislation may modify the actual position, particularly if the cause can be attributed to the website owner.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may, for example, be engaged in the processing of your payment details and/or the provision of the Services on our behalf. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

All information you provide to us is stored on our secure servers.

On subscribing to use the Services you will able to make purchases of various goods and services. All transactions at this present time are serviced exclusively through our chosen third-party provider of payment processing services using encrypted software. We do not collect or store any of your credit or debit card information.

Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the APP or certain Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or via the Websites and/or the APP; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Changes to our Privacy Policy.

VSTE may update this Privacy Policy from time to time as VSTE's business and services expand and change. Updates to this policy will be posted on this page. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services. VSTE encourages you to review this policy periodically to review any changes that have been posted. VSTE will never change its commitment to your privacy.


If you have any questions, comments or feedback about VSTE's use of your personal information or about this Privacy Policy, please contact us at support@vstenterprises.com and we will use reasonable efforts to promptly investigate any complaint you may have regarding our use of your personal data and to comply fully with the legal and regulatory supervisory authorities responsible for enforcing VSTE's adherence to the privacy principles stated above.

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