Privacy Policy & Cookie Policy
Last updated: 30 June 2026
Registered office: The Black Church, St. Mary’s Place, Dublin 7, D07 P4AX, Ireland
Website: www.varto.digital
Support: support@varto.digital
Company registration number: 823505
Privacy Policy
This Privacy Policy explains how VARTO DIGITAL LIMITED (“VARTO”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal data when you use the VARTO mobile application, website and related services.
VARTO is a digital wishlist and gifting platform. Users can create wishlists, save product links, upload content, add gift preferences and share wishlists with others. VARTO does not sell products directly at first launch. Purchases are made through third-party retailer, marketplace, brand or affiliate links.
1. Who controls your personal data
VARTO DIGITAL LIMITED is the controller of personal data processed through VARTO, unless this Privacy Policy explains otherwise.
Contact details:
- VARTO DIGITAL LIMITED, The Black Church, St. Mary’s Place, Dublin 7, D07 P4AX, Ireland
- Email: support@varto.digital
If we appoint a dedicated privacy contact or Data Protection Officer in the future, we will update this Privacy Policy.
2. Who this Privacy Policy applies to
This Privacy Policy applies to:
- people who create a VARTO account;
- people who create, edit or share wishlists;
- people who view wishlists shared with them;
- people who click product, retailer, brand or affiliate links through VARTO;
- people who contact us for support or business enquiries; and
- visitors to our website or other online pages.
3. Age requirement
VARTO accounts are intended for users aged 16 and above. You must be at least 16 years old to create an account. We do not knowingly allow children under 16 to create accounts or submit personal data without any consent required by applicable law.
If we become aware that a child under 16 has provided personal data without the required consent, we will take reasonable steps to delete or restrict that information.
4. Personal data we collect
The personal data we collect depends on how you use VARTO. It may include the following categories:
| Category | Examples |
|---|---|
| Account data | Name, email address, username, password or authentication details, account settings and account status. |
| Profile and wishlist data | Profile photo, wishlist titles, wishlist descriptions, product links, product notes, saved products, categories, preferences, size, colour, birthday, occasion date, gift notes and wishlist visibility settings. |
| Uploaded content | Photos, screenshots, comments, personal notes, links, descriptions and other content you upload or save to VARTO. |
| Address and delivery-related information | Postal address, country, city, delivery instructions or other details you choose to add to a wishlist. VARTO does not require this unless you choose to add it. |
| Product and gifting behaviour | Products saved, wishlists created, items clicked, links opened, categories viewed, occasions selected, price ranges, brands saved and retailer interactions. |
| Sharing and interaction data | Wishlist sharing links, people invited to view a wishlist, reservations or purchase marks, and interactions with shared wishlists. |
| Device, app and usage data | Device type, operating system, app version, browser type, IP address, approximate location derived from IP, log data, session data, crash reports and performance data. |
| Affiliate and attribution data | Product link clicks, retailer redirects, affiliate tracking IDs, campaign identifiers, referral source, timestamps and conversion-related data received from affiliate partners where applicable. |
| Support and communications data | Messages you send us, support requests, feedback, business enquiries and communication preferences. |
| Marketing data | Newsletter sign-ups, campaign engagement, consent preferences and opt-out records. |
5. Personal data you choose to share
VARTO is built around wishlists. This means you may choose to add information that feels personal, such as sizes, birthday, gift preferences, photos, address details, notes or private comments.
You should only add information that you are comfortable sharing in the relevant wishlist context. If you make a wishlist public or share it with other people, those people may be able to see the content you included.
We recommend avoiding highly sensitive information in wishlist notes or public wishlist pages.
6. Special category data
VARTO is not designed to collect special category data, such as health information, religion, political opinions, biometric data, sexual orientation or similar sensitive information. Please do not upload this type of information unless it is strictly necessary and you understand that it may be visible in the context in which you share it.
If we identify special category data that is not needed for VARTO, we may delete or restrict it.
7. How we collect personal data
We collect personal data in the following ways:
- directly from you when you create an account, create a wishlist, upload content, add product links, contact support or sign up for communications;
- automatically when you use the app or website, including through cookies, pixels, software development kits, log files and similar technologies;
- from third-party retailers, affiliate networks and brand partners when you click links or complete qualifying actions;
- from app stores and platform providers where they provide app installation, crash, purchase, subscription, review or analytics information; and
- from other users where they invite you to view a wishlist, reserve an item or interact with a shared wishlist.
8. Why we use personal data and our legal bases
We use personal data only where we have a lawful basis to do so. The table below describes the main purposes for which we process personal data.
| Purpose | Examples of use | Legal basis |
|---|---|---|
| Provide VARTO services | Create and manage accounts, wishlists, saved products, sharing links, wishlist visibility settings and app features. | Performance of a contract with you. |
| Operate wishlist sharing | Show wishlists to people you choose to share them with, generate previews and allow reservations or purchase marks. | Performance of a contract; legitimate interests in operating the service. |
| Personalise the experience | Remember preferences, suggest gift ideas, organise products and improve relevance. | Legitimate interests; consent where required. |
| Affiliate tracking and commercial attribution | Track outbound product clicks, retailer redirects, qualifying purchases, commission eligibility and campaign performance. | Legitimate interests; consent where cookies or similar technologies require consent. |
| Analytics and product improvement | Understand app usage, fix bugs, improve features, analyse product saves, category trends and user journeys. | Legitimate interests; consent where required for analytics cookies or similar technologies. |
| Safety and security | Prevent fraud, protect accounts, detect misuse, investigate suspicious activity and secure the platform. | Legitimate interests; legal obligation where applicable. |
| Customer support | Respond to messages, handle requests, troubleshoot issues and keep records of support interactions. | Performance of a contract; legitimate interests. |
| Marketing communications | Send newsletters, launch updates, gift edits, product news or brand campaign communications where permitted. | Consent where required; legitimate interests for certain existing-user communications where permitted. |
| Brand insights and reports | Create aggregated, anonymised or statistical insights about gifting trends, saved products, categories, brands and campaign performance. | Legitimate interests, provided the information does not identify individual users. |
| Legal and compliance | Comply with laws, respond to lawful requests, maintain records and enforce our Terms. | Legal obligation; legitimate interests. |
9. Affiliate links and partner programmes
VARTO may use affiliate links and partner programmes, including LTK, Awin, Rakuten Advertising, Amazon Associates, direct brand affiliate programmes and similar partners.
When you click a product or retailer link, we or our partners may process information such as the link clicked, timestamp, device or browser information, referral source, campaign ID, affiliate tracking ID and conversion status. This helps us understand whether a click or purchase is eligible for commission and helps us improve VARTO.
Once you leave VARTO and visit a third-party website, that third party may process your personal data under its own privacy policy and cookie policy. VARTO is not responsible for third-party privacy practices.
10. Brand partnerships and insights
VARTO may work with brands, retailers and commercial partners. At first launch, VARTO is focused on wishlists and links. In the future, VARTO may offer brand profiles, paid placements, sponsored gift guides, campaign reports, dashboards or gifting insight reports.
We may share aggregated, anonymised or statistical insights with brands or partners, such as product save trends, category trends, average price ranges, occasion trends or campaign performance. We do not sell individual users’ personal information to brands.
Where any brand-facing feature involves personal data, we will handle it in accordance with this Privacy Policy and applicable law.
11. Who we share personal data with
We may share personal data with the following categories of recipients where necessary and lawful:
- technology providers, hosting providers, database providers and cloud infrastructure providers;
- app stores and platform providers, including Apple, where you download or use the app through their services;
- analytics, crash reporting and performance monitoring providers;
- email, notification and customer support providers;
- affiliate networks, retailers, marketplaces and brand partners when you click product links or participate in relevant features;
- professional advisers, including lawyers, accountants, auditors and insurers;
- regulators, courts, law enforcement or public authorities where required by law;
- successors or potential buyers in connection with a business sale, merger, financing, restructuring or acquisition; and
- other users or recipients where you choose to share a wishlist or make content public.
We require service providers to process personal data only for agreed purposes and to apply appropriate security and confidentiality protections.
12. Public and shared wishlists
You control how you share your wishlists, subject to the features available in VARTO. A wishlist may be private, shared by link, shared with selected people or public, depending on your chosen settings.
If you share a wishlist link, anyone with that link may be able to view the wishlist unless additional restrictions apply. You are responsible for checking what information is included before sharing a wishlist.
If you include an address, birthday, size, personal note or photo in a wishlist, that information may be visible to people who can access that wishlist.
13. International transfers
VARTO is based in Ireland, but some of our service providers, affiliate partners, cloud providers, analytics tools, app platforms or commercial partners may process personal data outside Ireland, the European Union or the European Economic Area.
Where personal data is transferred outside the EEA, we will use appropriate safeguards where required, such as adequacy decisions, standard contractual clauses or other lawful transfer mechanisms.
14. How long we keep personal data
We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
| Data type | Typical retention approach |
|---|---|
| Account data | Kept while your account is active and for a reasonable period after closure where needed for legal, security or operational purposes. |
| Wishlist and User Content | Kept while it remains in your account or on shared/public wishlist pages, unless you delete it or request deletion, subject to backups and legal obligations. |
| Support messages | Kept for as long as needed to respond, resolve issues, maintain records and protect our legal interests. |
| Analytics and app logs | Kept for a limited period appropriate to the purpose, then deleted, aggregated or anonymised where possible. |
| Affiliate and commercial records | Kept as needed for attribution, commission validation, accounting, fraud prevention and contractual records. |
| Consent records | Kept as needed to demonstrate your choices and comply with legal obligations. |
15. Security
We use reasonable technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
No digital service is completely secure. You are responsible for keeping your login details confidential and for using caution when sharing wishlists or personal details.
16. Your data protection rights
Subject to applicable law and certain limitations, you may have the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete personal data;
- request deletion of your personal data;
- request restriction of processing;
- object to processing based on legitimate interests;
- request portability of certain personal data;
- withdraw consent where processing is based on consent; and
- complain to a data protection supervisory authority.
To exercise your rights, contact us at support@varto.digital. We may need to verify your identity before responding.
You also have the right to contact the Irish Data Protection Commission. The DPC can be contacted through dataprotection.ie or by post at Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963, Ireland.
17. Marketing choices
If you subscribe to marketing communications, you can unsubscribe using the link in our emails or by contacting us. You may still receive service, legal, security or account-related messages even if you unsubscribe from marketing.
18. Push notifications
If VARTO offers push notifications, we may send reminders, wishlist updates, gift alerts, product notices or service messages. You can manage push notification permissions through your device settings or in-app settings where available.
19. Automated decision-making
VARTO does not currently make decisions based solely on automated processing that produce legal or similarly significant effects for users.
We may use algorithms or automated tools to suggest products, organise wishlists, recommend categories, detect fraud, improve search or personalise the app experience.
20. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we may notify you by email, in-app notice, website notice or another reasonable method.
Your continued use of VARTO after the updated Privacy Policy becomes effective means you acknowledge the updated policy.
21. Contact us
For questions about this Privacy Policy or your personal data, please contact:
VARTO DIGITAL LIMITED, The Black Church, St. Mary’s Place, Dublin 7, D07 P4AX, Ireland. Email: support@varto.digital. Website: www.varto.digital.
Cookie Policy
This Cookie Policy explains how VARTO DIGITAL LIMITED uses cookies and similar technologies on the VARTO website, mobile application and related services.
For simplicity, this Cookie Policy uses the word “cookies” to refer to browser cookies, pixels, local storage, mobile identifiers, software development kits, tracking links and similar technologies that store information on, or access information from, your device.
1. What cookies are
Cookies are small text files placed on your device when you visit a website. Similar technologies may be used in mobile apps to recognise your device, remember settings, analyse usage, support security, enable affiliate attribution or measure performance.
2. How VARTO uses cookies and similar technologies
VARTO may use cookies and similar technologies to:
- keep you signed in and operate account features;
- remember your privacy choices and app preferences;
- secure the platform and prevent misuse;
- understand how the website and app are used;
- measure app performance, crashes and bugs;
- support wishlist sharing and product link functionality;
- track affiliate clicks and commission eligibility;
- measure marketing campaigns where permitted; and
- improve the VARTO user experience.
3. Types of cookies we may use
| Type | Purpose | Consent approach |
|---|---|---|
| Strictly necessary cookies | Required to operate the website, app, login, security, consent preferences, fraud prevention, load balancing and core wishlist features. | These may be used without consent where legally permitted because the service cannot function properly without them. |
| Functional cookies | Remember preferences such as language, region, display choices, wishlist settings or recently used features. | Used with consent where required. |
| Analytics and performance cookies | Help us understand app usage, website traffic, feature performance, bugs, crashes and aggregated user journeys. | Used with consent where required. |
| Affiliate and attribution cookies | Help track outbound product clicks, retailer redirects, campaign IDs, commission eligibility and affiliate performance. | Used with consent where required. Third-party retailers and affiliate networks may also set their own cookies once you leave VARTO. |
| Marketing and advertising cookies | May be used in the future to measure campaigns, understand referral sources, limit repetition, or support advertising and remarketing. | Used only with consent where required. |
4. First-party and third-party cookies
First-party cookies are set by VARTO. Third-party cookies or similar technologies may be set by service providers, affiliate networks, analytics providers, app platforms, retailers, brands or other partners.
When you click a product link and leave VARTO, the third-party website may use its own cookies and similar technologies under its own cookie policy and privacy policy.
5. Cookie table for launch
The table below is a launch draft. It should be updated once the final technology stack, analytics tools, app SDKs, affiliate tools and consent management solution are confirmed.
| Cookie / technology category | Provider | Purpose | Duration |
|---|---|---|---|
| Account/session technology | VARTO / hosting provider [to confirm] | Login, account security, session management and core app functionality. | Session or limited persistent duration. |
| Consent preference technology | VARTO / consent management provider [to confirm] | Stores your cookie and privacy choices. | Usually 6 to 12 months, to be confirmed. |
| Analytics technology | [insert analytics provider if used] | Measures website/app usage, performance and feature engagement. | [insert duration]. |
| Crash reporting / diagnostics | [insert provider if used] | Detects crashes, bugs and performance issues. | [insert duration]. |
| Affiliate tracking links | LTK, Awin, Rakuten Advertising, Amazon Associates, direct brand affiliate programmes and similar partners | Tracks outbound product clicks, attribution and commission eligibility. | Varies by partner and campaign. |
| Email / notification tools | [insert provider if used] | Supports service emails, wishlist reminders, push notifications and marketing messages where permitted. | [insert duration]. |
| Marketing pixels | [insert provider if used] | Measures campaigns or supports advertising, if introduced. | [insert duration]. |
6. Consent
Where required by law, we will ask for your consent before using non-essential cookies or similar technologies.
You should be able to accept, reject or manage non-essential cookie choices. Refusing non-essential cookies should not prevent you from using core VARTO features, although some personalisation, analytics, affiliate attribution or marketing features may be limited.
7. Managing your cookie choices
You can manage cookies and similar technologies in several ways:
- through VARTO’s cookie banner or cookie settings, where available;
- through your browser settings, which may allow you to block, delete or restrict cookies;
- through your device settings for mobile app permissions, push notifications and tracking preferences;
- through App Store or operating system privacy settings where applicable; and
- by using unsubscribe links or preference settings for marketing communications.
Blocking some cookies or technologies may affect how VARTO works.
8. Affiliate cookies and third-party tracking
VARTO may use affiliate tracking links from LTK, Awin, Rakuten Advertising, Amazon Associates, direct brand affiliate programmes and similar partners.
When you click a product link, an affiliate partner or retailer may receive information about the click and may set or read cookies or similar technologies to determine whether a later purchase is eligible for commission.
Those third parties are responsible for their own cookie notices and privacy practices on their websites or services.
9. Mobile app technologies
Because VARTO is launching first as a mobile app, some tracking and storage may happen through mobile technologies rather than browser cookies. These may include device identifiers, local storage, app analytics SDKs, crash reporting tools, push notification tokens, affiliate tracking parameters and app performance tools.
We will use these technologies in line with this Cookie Policy, our Privacy Policy, applicable law and relevant app platform requirements.
10. Updates to this Cookie Policy
We may update this Cookie Policy when we add, remove or change cookies, app technologies, affiliate partners, analytics tools or marketing tools.
If changes are material, we may notify you by website notice, app notice, email or another reasonable method.
11. Contact us
For questions about this Cookie Policy, contact:
VARTO DIGITAL LIMITED, The Black Church, St. Mary’s Place, Dublin 7, D07 P4AX, Ireland. Email: support@varto.digital. Website: www.varto.digital.