Privacy Policy

1. Data Controller

The data controller responsible for the processing of personal data carried out through the Vip-hunters platform is the owner / operator of Vip-hunters. For any request relating to the protection of your personal data, you may write to privacy.vip-hunters@outlook.it or use the postal contact indicated in the section "15. Contact".

Postal contact for data-protection requests:
Renato Delpopolo Carciopolo – Vip-hunters
Fermo Posta
Ufficio Postale Via Antonio Trivioli 6
29122 Piacenza (PC)
Italy

IMPORTANT: After sending any letter or registered mail to the postal address above, please communicate the shipment or tracking code to privacy.vip-hunters@outlook.it so that the correspondence can be collected at the Post Office.

2. Personal data we process

Vip-hunters processes the following categories of personal data, depending on your role and the features you use:

• Account data (email address) and authentication data used to create and access your account, including your assigned user role.
• Hunter profile data, including your display name / full name / codename, operative zone (city and country), notification preferences, mission participation records, participation status, completed wins and Rank Points awarded. This also includes Hunter statistics, your Hunt history and your Hunter Plus membership / subscription status where applicable.
• VIP profile data, including first name, last name, stage / display name, professional category, management / agency information, social profile link, website and profile photo. VIP profiles are linked to associated Brand requests, to the missions (Bounties) created for that verified VIP, and to any Certified Encounters involving that verified VIP profile.
• Brand / company data, which may include the company name, website and company logo. This is business information and is not, in itself, personal data relating to an individual.
• Contact person data provided by Brands, which may include the contact name and contact email of the individual representing the company. This constitutes personal data relating to that individual contact person. Tax ID / VAT, fiscal / company address and contact telephone are not collected through the application; where such information is necessary for the commercial / contractual relationship, it is handled separately outside the application.
• Mission proximity geolocation data, collected only when you actively take part in a mission. This includes latitude, longitude and the GPS accuracy value declared by your device at the time of a user-triggered proximity check, together with the related mission and the calculated distance / proximity result.
• Certified Cam geolocation evidence, collected when a winning Hunter certifies a new Certified Encounter. This may include capture latitude, capture longitude, GPS accuracy, the device location acquisition timestamp, the trusted Hunt coordinates and radius, the server-side calculated distance from the Hunt location, and the server-generated certification timestamp.
• Mission (Bounty) data, including the verified VIP relationship, mission details, the current Category, the Difficulty tier, the Reward Category, the mission location (country, city and coordinates), the Hunt radius, the deadline, the mission status and the participation and winner relationships. Mission ownership is linked to the relevant VIP and, where applicable, the Brand.
• Mission participation data, including the missions you take part in, the participation status and any Rank Points awarded.
• Points and ranking data, used for the non-monetary ranking system (Points). Selected Hunter performance data may also be displayed to other authenticated users through the Hunter Leaderboard, as described in the section "5. Geolocation, Leaderboard and visibility".
• Notifications generated and stored by the platform to inform you about relevant account and mission events.
• Certified Encounter data, including the certified encounter photo, the related mission, the winning Hunter, the verified VIP, the Brand (where applicable), the VIP / Hunter / Brand display names, the server-generated certification timestamp, the GPS evidence fields described above, the calculated distance from the Hunt location and the share count / sharing activity.
• Hunter feedback data, including difficulty and experience ratings and optional comments. Ratings may contribute to Hunter performance metrics and Leaderboard ranking.
• Membership and payment references, including Hunter Plus membership plan, status, subscription start date, next billing date, cancellation status / date, the Stripe customer identifier and subscription-related identifiers and status, where payments are applicable.
• Technical, security and account-activity metadata related to authentication, proximity events, certification state, fraud prevention and platform operation, including technical security and transaction-state metadata used to prevent duplicate certifications and preserve the integrity of the certification process.

Vip-hunters does not process, store or handle full payment card data. Where payments are involved, card data is handled directly by Stripe as the payment processor.

3. Purposes of processing

Your personal data is processed for the following purposes:

• Account creation, authentication and management of your Vip-hunters account.
• Provision of the Vip-hunters services and the onboarding of Hunters, VIPs and Brands.
• Creation, management and participation in missions (Bounties).
• Geolocation and proximity functionality, including verifying the encounter between a Hunter and a VIP.
• Determination of the mission winner based on geolocated proximity.
• Certified Cam and Certified Encounters, including certification of encounter photos.
• Points, ranking and leaderboard features.
• Operational notifications related to your account and missions.
• Fraud prevention and security of the platform.
• Payment processing where applicable, carried out through Stripe.
• Fulfilment of legal, regulatory and accounting obligations where applicable.

4. Legal bases

The processing of personal data is carried out on the following legal bases, to the extent applicable:

• Performance of a contract to which you are a party, or steps requested by you before entering into a contract, for the provision of the Vip-hunters services and account management.
• Compliance with legal obligations to which the Data Controller is subject, where applicable.
• Legitimate interests of the Data Controller, for example in fraud prevention and platform security, where these are not overridden by your rights and freedoms.
• Consent, only where this is genuinely required for a specific processing activity.

Not all processing carried out by Vip-hunters is based on consent. Where a processing activity relies on consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before withdrawal. Google Analytics is one processing activity that runs on your consent, as described in the section "8. Recipients and service providers".

5. Geolocation, Leaderboard and visibility

Geolocation is used to enable mission and proximity functionality and to verify the encounter between a Hunter and a VIP. Vip-hunters distinguishes two types of location processing:

• Mission proximity data is collected only when you actively take part in a mission and trigger a proximity check. It may include latitude, longitude and the GPS accuracy value declared by your device at that moment, together with the related mission and the calculated proximity result.
• Certified Cam location evidence is collected only when a winning Hunter certifies a new Certified Encounter, and is described in the section "6. Certified Cam and Certified Encounters".

Vip-hunters does not implement permanent or continuous background tracking of your position outside of the user-triggered mission and proximity features described in this Privacy Policy.

To display the Live Radar / Map, the platform may load map tiles from an external map / tile provider. Loading these tiles may result in ordinary technical connection data (such as your IP address and standard browser request metadata) being transmitted to that provider as part of the tile request. The platform does not transmit your precise GPS location to the map provider unless this is technically required by the feature you are using.

Vip-hunters may display selected Hunter performance data to other authenticated users through the Hunter Leaderboard. The information shown may include the public / display Hunter identity, rank, Points, Wins and Rating. Email addresses, phone numbers, Stripe / payment identifiers and internal database identifiers are not displayed on the Leaderboard. The Leaderboard is accessible to authenticated users and is not presented as a public page to non-authenticated visitors.

6. Certified Cam and Certified Encounters

The Certified Cam is used by a winning Hunter to create a Certified Encounter. The flow works as follows: the official Certified Cam performs a live camera capture; the captured image is uploaded and stored; the image is then associated with the winning Hunter, the completed mission (Hunt) and the verified VIP profile linked to that mission. Vip-hunters branding / watermarking may be embedded in the image, and the Certified Encounter record includes a server-generated certification timestamp.

For new Certified Encounters, the platform may process the following location evidence: capture latitude, capture longitude, GPS accuracy, the device location acquisition timestamp, the trusted Hunt coordinates and radius, the server-side calculated distance from the Hunt location, and the server-generated certification timestamp. These data are used to verify that the device submitting the certification is within the permitted Hunt location and radius at the time of certification.

A Certified Encounter record may include the photo, the related mission, the winning Hunter, the verified VIP, the Brand (where applicable), the VIP / Hunter / Brand display names, the certification timestamp, the GPS evidence fields, the calculated distance from the Hunt location and the share count / sharing activity. Access to Certified Encounters is role-restricted according to the platform's authorisation rules. The Hunter may download or share their own Certified Encounter through the current app functions.

The platform verifies technical relationships such as the authenticated winner, the completed mission, the verified VIP profile, the GPS-verified certification location, the server timestamp and the Certified Encounter record. It also uses technical security and transaction-state metadata to prevent duplicate certifications and preserve the integrity of the certification process.

The certification does not constitute biometric identification, facial recognition or legal identity verification from the image, nor absolute proof of the physical presence of the VIP in the photograph. The platform cannot independently verify, at the server level, the live-camera origin of the image bytes submitted. This Privacy Policy does not grant Vip-hunters any commercial exploitation rights over the images beyond what is provided in the Terms & Conditions and the platform functionality.

7. Payments and Hunter Plus

Where payments are provided for within the platform, they are processed through Stripe, a third-party payment processor. This includes, where applicable, the Hunter Plus subscription and the paid VIP code replacement flow. Vip-hunters may process and store payment-related references and status data associated with your account, such as the Stripe customer identifier, checkout / session-related identifiers, subscription status, billing status and payment success / failure events. For Hunter Plus, this may include the membership plan, status, subscription start date, next billing date and cancellation status / date.

Card and payment instrument details are handled by Stripe and are not stored directly in the Vip-hunters application. This section describes the processing of personal data in connection with payments and does not set out commercial conditions.

8. Recipients and service providers

Your personal data may be processed by technical providers that are necessary for the operation of the platform. The technical service providers currently used include:

• Stripe, used for payment and subscription flows, including Hunter Plus and paid VIP code replacement, where applicable.
• Base44, used as part of the technical infrastructure for application hosting, authentication, data storage (database / entities), backend functions and file storage.
• A map / tile provider, used to display the Live Radar / Map. Loading map tiles may involve ordinary technical connection data being transmitted to that provider, as described in the section "5. Geolocation, Leaderboard and visibility".

The platform uses Google Analytics 4 to collect aggregated usage statistics — such as page views and general interaction events — in order to understand how the service is used and to improve it. Google Analytics is non-essential: it is not required for the core operation of Vip-hunters and does not activate until you expressly accept it.

When analytics is accepted, Google Analytics may use cookies or similar browser identifiers and may process technical data — such as IP address, browser and device information, and interaction events — as part of its measurement service. This may involve the transfer of such data to Google, including to infrastructure located outside the European Economic Area. No email, name, account identifier, Stripe identifier, VIP identity, Brand contact identity or precise GPS coordinates are sent to Google Analytics. Vip-hunters does not integrate advertising pixels, remarketing, advertising audiences or cross-site marketing trackers.

Consent mechanism. Before you make a choice, the default state denies analytics (Google Consent Mode is set to denied) and the Google Analytics library is not loaded. On first visit, a banner presents both "Accept analytics" and "Reject analytics" as equally usable choices; neither is preselected, and you may read the Privacy Policy without accepting analytics. Your choice is remembered in your browser. If you accept, Google Analytics loads and operates; if you reject, analytics remains disabled and no analytics cookies are set by Vip-hunters on the basis of that choice.

You can change or withdraw your preference at any time using the "Analytics preferences" control at the bottom of this Privacy Policy page, or by clearing your browser storage, which resets the choice. Withdrawing consent disables analytics going forward; Vip-hunters will also attempt to remove the Google Analytics cookies it is able to remove from its own domain. Some cookies set or controlled by Google may not be removable by Vip-hunters.

Data may also be accessed by authorised personnel acting under the Data Controller's authority to the extent necessary for the operation and security of the service.

9. International transfers

Some of the technical providers described in the section "8. Recipients and service providers" — including Base44, Stripe and Google (for usage analytics) — may process data within their own infrastructure, which may be located outside the European Economic Area. Vip-hunters does not store data in a specific self-selected data centre; processing locations depend on the infrastructure of these providers.

To the extent that personal data is transferred outside the European Economic Area, such transfers take place in compliance with the applicable requirements, including appropriate safeguards where required. This Privacy Policy does not state that international transfers necessarily occur in every case; any transfer is carried out in accordance with applicable data protection law.

10. Data retention

Personal data is retained only as long as necessary to achieve the purposes described in this Privacy Policy and to fulfil applicable legal, regulatory and accounting obligations. The following retention periods are applied automatically by the platform:

• Account and authentication data — retained while your account is active; deleted or de-identified when you delete your account (see "Account deletion" below).
• Notifications — retained for up to 90 days from creation.
• Draft missions — a mission saved as a draft is retained for up to 90 days of inactivity, then automatically removed.
• Mission proximity geolocation (normal Hunt GPS) — retained for up to 30 days after the related mission closes.
• Mission data (mission details, participation records and hunter feedback) — retained for up to 24 months after the mission closes.
• Certified Encounter (including the photograph, GPS evidence and related relationships) — where a Hunter deletes their account, retained for up to 24 months after the account deletion, then removed.
• Hunter Plus operational metadata (plan, status, billing dates and Stripe customer identifier) — retained for up to 12 months after the subscription ends.

Where no fixed technical period applies to a category of data, the data is retained only as long as necessary for the purposes described in this Privacy Policy or to comply with applicable legal, regulatory or accounting obligations.

Account deletion

You can delete your account at any time using the in-app account deletion function. The platform applies the following role-specific behaviour:

• Hunter — your notifications, proximity geolocation and hunter feedback are removed; mission participation records that are not linked to a retained Certified Encounter are removed; your Hunter account record is deleted. Certified Encounters you created are not deleted immediately: they are retained for up to 24 months after your account deletion to preserve the integrity of the certification evidence, and the associated display names are preserved on those records. During that period the remaining records no longer link back to an active account.
• VIP — the personal fields on your VIP profile (names, stage name, social profile, website, management / agency and profile photo) are cleared or de-identified; the profile record is kept so that missions and Certified Encounters remain correctly linked; missions you created and Certified Encounters involving your verified profile are retained according to the periods above, and the associated display names are preserved on those records.
• Brand — the contact person data (contact name and contact email) is de-identified; company-level information and any authorisation status are retained for operational continuity; missions you created and Certified Encounters are retained according to the periods above.

Stripe-related identifiers remain subject to the Hunter Plus retention period above and to Stripe's own record-keeping as the payment processor.

Deletion of uploaded files

Removing a database record, or clearing or replacing a stored file reference, does not by itself delete the underlying uploaded file stored by the infrastructure provider. Vip-hunters does not provide a self-service mechanism to permanently delete individual uploaded files.

To complete deletion, Vip-hunters preserves the minimum technical file reference needed to request deletion before the application reference is removed, submits it to its infrastructure provider (Base44) through a manual procedure, and records the confirmation once the infrastructure provider confirms that the underlying file has been permanently deleted. The technical record used to document this process is retained only as long as necessary to complete and verify it. This applies to uploaded encounter photos, VIP profile photos, company logos and mission avatar images.

Because physical deletion of the underlying stored file depends on the infrastructure provider, Vip-hunters cannot guarantee a specific timeframe for the permanent deletion of an uploaded file.

11. Data subject rights

Where applicable, you have the following rights regarding your personal data:

• Right of access to your personal data.
• Right to rectification of inaccurate or incomplete personal data.
• Right to erasure of your personal data.
• Right to restriction of processing.
• Right to object to processing.
• Right to data portability, where applicable.
• Right to withdraw consent, where processing is based on consent.
• Right to lodge a complaint with the competent supervisory authority.

The Data Controller facilitates the exercise of these rights. The platform provides an in-app account deletion function, and you may adjust your profile information and notification preferences directly within the app. To exercise any other rights, you may use the contact details indicated in the section "15. Contact".

Erasure is subject to the applicable retention periods described in the section "10. Data retention" and, for uploaded files, to the infrastructure provider's deletion process described in the same section. In particular, Vip-hunters cannot guarantee that an underlying uploaded file is physically deleted immediately upon request, as this depends on the infrastructure provider's procedure.

12. Mandatory or optional data, age and permissions

Some personal data is necessary to create and use your account or to perform specific functions of the platform; providing such data is required in order to access the relevant features. Other data is optional: its absence does not prevent the basic use of the platform and is used only to enable the corresponding additional features.

The platform requires users to confirm that they are at least 18 years old during registration. Vip-hunters does not collect or verify an official date of birth and does not perform age identity verification.

Certain features require technical device / browser permissions, such as camera permission (for the Certified Cam) and geolocation permission (for mission proximity and certification). These are technical device / browser permissions and are distinct from legal consent under data protection law. Granting or refusing a device permission does not, by itself, constitute legal consent to the processing of personal data.

13. Security

Vip-hunters adopts technical and organisational measures designed to protect personal data against unauthorised access, loss, destruction or disclosure. No system or transmission method can be guaranteed to be completely secure; this Privacy Policy does not represent an absolute guarantee of security.

The platform uses standard browser storage (such as local storage) to maintain authentication / session state and interface state necessary for the app to function. These are technical storage mechanisms and are not used for cross-site tracking or advertising profiling.

14. Changes to this Privacy Policy

Vip-hunters reserves the right to update this Privacy Policy at any time. Changes take effect upon publication on the platform. The date indicated at the top of this page reflects the most recent update. Continued use of the service after the changes constitutes acceptance of the updated Privacy Policy.

15. Contact

For any question regarding this Privacy Policy or the exercise of your data-protection rights, you may write to privacy.vip-hunters@outlook.it.

For general customer-support matters (not relating to data protection), you may use help.hunters.vip-hunters@outlook.com.

Postal contact for data-protection requests:
Renato Delpopolo Carciopolo – Vip-hunters
Fermo Posta
Ufficio Postale Via Antonio Trivioli 6
29122 Piacenza (PC)
Italy

IMPORTANT: After sending any letter or registered mail to the postal address above, please communicate the shipment or tracking code to privacy.vip-hunters@outlook.it so that the correspondence can be collected at the Post Office.

16. Analytics preferences

You can accept or reject Google Analytics, or withdraw a previous acceptance, at any time using the control below.