LOCK
01
03
04
06
07
08
09
10
11
12
13
17
18
20PrivacyPolicy
How si-lock.com and the Founding Preview handle your data. The product is local-first; the site collects the minimum it needs.
This Privacy Policy explains how VF Empire Corp Ltd, a limited liability company registered in Malta (“we”, “us”), processes personal data when you visit si-lock.com (the “Site”) and when you apply to the S◉LOCK Founding Preview programme. We process personal data in accordance with Regulation (EU) 2016/679 (“GDPR”), the Maltese Data Protection Act (Cap. 586 of the Laws of Malta), and applicable ePrivacy rules.
S◉LOCK, the product, is designed local-first: prompts and files on a S◉LOCK system are intended to stay on hardware you control unless you choose otherwise. This Site is a marketing and enquiry surface, not the product runtime; section 13 explains the distinction.
1. Summary (plain English)
- We collect what you type into the access form, standard web logs, and your cookie choices. Browsing requires no account.
- We use this to answer you, evaluate Programme fit, protect the Site, and keep aggregate visit counters. Nothing else.
- We do not sell personal data, run third-party ad trackers, or use your form data to train AI models.
- You can access, correct, delete or export your data, object, and withdraw consent at any time by emailing info@vfempire.com.
2. Personal data we process
| Category | Data | Source |
|---|---|---|
| Access-form data | Email address (required); name (optional); interest category; free-text note (e.g. hardware, region); consent flag; submission timestamp; page of origin | You, via the form |
| Correspondence | Your email address and the content of messages you send us | You, via email |
| Technical log data | IP address, user-agent string, timestamps, requested URLs, referrer — standard web-server and CDN logs | Your browser, via our hosting provider (Cloudflare) and our intake API |
| Counter events | Aggregate visit / interest / application counts. Stored as numbers; not linked to a profile of you | Your browser, only with analytics consent |
| Consent record | Your cookie-banner choice and its timestamp | Your browser |
We do not knowingly collect special categories of personal data (Art. 9 GDPR), and we ask you not to include such data in free-text fields.
3. Purposes and legal bases (Art. 6 GDPR)
| Purpose | Data used | Legal basis |
|---|---|---|
| Contacting you about the Founding Preview, seat availability and Programme updates you requested | Access-form data | Consent — Art. 6(1)(a); withdraw at any time |
| Taking steps prior to entering a contract (evaluating fit, preparing an Invitation) and performing any contract we conclude with you | Access-form data, correspondence | Contract / pre-contractual steps — Art. 6(1)(b) |
| Site security, abuse and bot detection, rate limiting, incident investigation | Technical log data | Legitimate interests — Art. 6(1)(f): keeping the Site and intake API secure |
| Aggregate demand counters (open pulse) | Counter events | Consent — Art. 6(1)(a), via the cookie banner (analytics category) |
| Answering general and business enquiries | Correspondence | Legitimate interests — Art. 6(1)(f): responding to people who write to us |
| Establishing, exercising or defending legal claims; compliance with legal obligations | Any of the above, as strictly needed | Art. 6(1)(c) and (f) |
Where we rely on legitimate interests, we have assessed that the processing is necessary and that your interests and fundamental rights do not override ours. You may object at any time (section 10).
4. Open counters
The public counters shown on the Security page are aggregates: total visits, expressions of interest, applications, and refused scraper traffic. They are stored and published as plain numbers. They are not used to build profiles of identified visitors, and the visit counter only increments when you have allowed analytics in the cookie banner.
5. Cookies and similar technologies
Details of every cookie and storage key, categories, durations and your controls are in the Cookie Policy. Non-essential categories run only with your consent, and “reject” is offered with the same prominence as “accept”. You can change your choice at any time on that page.
6. Recipients and processors
- Cloudflare, Inc. — hosting, CDN and network security for the Site (processor). Cloudflare processes technical log data under its data-processing addendum.
- Our intake service — form submissions and counter events are received by our own intake API (operated by us on our infrastructure at the-os.ai). No third party controls this data.
- Email infrastructure — when we correspond with you, our mail provider processes the messages.
- Authorities and advisers — where required by law, or as strictly necessary to establish, exercise or defend legal claims.
We do not sell personal data, share it with data brokers or advertising networks, or use access-form content to train foundation models — ours or anyone else’s.
7. International transfers
We are established in Malta (EU). Our CDN provider operates a global network, so technical data may be processed at edge locations outside the EEA. Where personal data is transferred to a third country, we rely on the safeguards of Chapter V GDPR — an adequacy decision where available (including the EU–US Data Privacy Framework for certified US providers) or the European Commission’s Standard Contractual Clauses. You may request a copy of the relevant safeguards via the contact address below.
8. Retention
| Data | Retention |
|---|---|
| Access-form submissions | For the duration of the Founding programme and up to 24 months after its close or your last interaction, then deleted or anonymised — unless a contract follows (then for the contract’s life and statutory limitation periods) or you ask us to delete sooner |
| Correspondence | As long as needed to handle the matter, then per statutory limitation periods where relevant |
| Technical logs | Short operational windows set by our hosting configuration |
| Consent records | Consent choice up to 12 months (then we ask again); proof of consent as long as required to demonstrate compliance |
| Counter aggregates | Indefinitely — they contain no personal data |
9. Security
We apply technical and organisational measures appropriate to the risk (Art. 32 GDPR): TLS encryption in transit, access controls on the intake service, data minimisation (the form asks only for what the Programme needs), edge filtering of abusive traffic, and separation between the public Site and internal systems. No internet service can guarantee absolute security; if a breach affecting your rights occurs, we will notify the authority and, where required, you, in accordance with Arts. 33–34 GDPR.
10. Your rights
Under Arts. 15–22 GDPR you have the right to:
- Access the personal data we hold about you, and receive a copy;
- Rectify inaccurate or incomplete data;
- Erase data (“right to be forgotten”) where the conditions of Art. 17 are met;
- Restrict processing in the cases of Art. 18;
- Data portability — receive data you provided in a structured, commonly used, machine-readable format (Art. 20);
- Object to processing based on legitimate interests, and to direct marketing at any time (Art. 21);
- Withdraw consent at any time, without affecting processing before withdrawal (Art. 7(3)).
To exercise any right, email info@vfempire.com with the subject line “Privacy”. We respond within one month (extendable by two further months for complex requests, in which case we will tell you). Exercising these rights is free of charge unless requests are manifestly unfounded or excessive.
Automated decision-making: we do not subject you to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects (Art. 22).
11. Complaints
If you believe our processing infringes the GDPR, you may lodge a complaint with the Maltese supervisory authority — the Information and Data Protection Commissioner (IDPC), idpc.org.mt — or with the supervisory authority of the EU member state where you habitually reside or work. We would, however, appreciate the chance to address your concern directly first.
12. Children
The Site and the Programme are directed at professionals and organisations. We do not knowingly collect personal data from children under 16, and the access form must not be submitted by them. If you believe a child has provided us personal data, contact us and we will delete it.
13. The product on your machine
When you run S◉LOCK Software on your own hardware, processing of your files and prompts is designed to happen on-device by default. For that processing, you are the controller of your own data; we receive nothing unless a feature you explicitly enable sends it. Licensed software is accompanied by its own product privacy notice describing any optional network features (such as update checks). This Policy covers the public website and Founding enquiries only.
14. Changes to this Policy
We may update this Policy as the Site or Programme evolves. The effective date and version number above will change, and material changes will be highlighted on this page or notified to applicants by email where appropriate.
15. Contact
VF Empire Corp Ltd (Malta) · info@vfempire.com (subject “Privacy”)
See also Cookie Policy · Terms of Use · Home