VAULT PRIVACY AND COOKIES POLICY
This Privacy and Cookies Policy is effective as of 07/23/2018.
Vault is committed to respecting your online privacy and recognizes your need for appropriate protection and management of any personally identifiable information ("Personal Information") that you share with us. Personal Information means any information that may be used to identify an individual, including, but not limited to; (1) a first and last name; (2) a home or other physical address; (3) an email address; (4) other contact information, whether at work or at home; (5) telephone numbers; (6) credit/debit card information; (7) bank account information; and (8) website usernames and passwords. Vault collects and uses your Personal Information only for our business purposes which allows us to provide transaction processing services to you or retailers who have contractual agreements with Vault (“Retailers”).
If you choose to provide Vault with your Personal Information through our Website, or by facsimile, mail, or e-mail, Vault may transfer that Personal Information within Vault and transfer your Personal Information to Vault's third-party service providers, Retailers with whom you have made transactions for the purpose of assisting the Retailer in resolving disputes, and from your country or jurisdiction to other countries or jurisdictions around the world if the need arises.
Vault may also collect government-issued identification numbers and other proofs of identity and domicile ("ID Information") to comply with existing Know your Customer government regulations.
Some of the new material in our Policy relates to newly implemented General Data Protection Regulations (“GDPR”) in the European Union regarding the safety of, use of, security of, processing of, and other specific rights regarding your Personal Information.
Vault complies with the California Online Privacy Protection Act (“CalOPPA”) as amended in 2013 and the additional privacy requirements of California AB-370.
Vault’s General Privacy Principles:
Vault is committed to safeguarding the privacy of your Personal Information:
- We will only collect and use your Personal Information where we have lawful grounds and legitimate business reasons to do so;
- We will be transparent in our dealings with you and will tell you about how we collect and use your Personal Information;
- If we have collected your Personal Information for a particular purpose, we will not use it for any other purpose unless you have been informed and, when relevant, your permission has been obtained;
- We will not ask for more Personal Information than we need for the purposes for which we are collecting it;
- We will update our records when you inform us that your details have changed;
- We will continue to review and assess the quality of your Personal Information;
- We will implement and adhere to information retention policies relating to your Personal Information, including GDPR, and will ensure that your Personal Information is securely disposed of at the end of the appropriate retention period;
- We will observe the rights granted to you under applicable privacy and data protection laws, including the GDPR, and will ensure that we promptly and transparently deal with queries relating to privacy issues;
- We will delete your Personal Information when you request us to do so, with the exception of when we are required by law to retain some or all of your Personal Information for certain periods of time;
- We will train our staff on their privacy obligations;
- We will ensure we have appropriate physical and technological security measures to protect your information regardless of how it is processed or where it is stored;
- We will ensure that when we outsource any processes, the supplier has appropriate security measures in place and will contractually require them to comply with our privacy principles;
- We will ensure that suitable safeguards are in place before any of your Personal Information is transferred to any other entities or to any other countries.
To protect your privacy, Vault has adopted the following core areas of focus:
- Access and Accuracy
You may access and browse certain parts of Vault's Website without disclosing any Personal Information. However, if you sign up for a Vault Account which will provide you with the Customer-APP, Vault will require that you supply Vault with some Personal Information. you will be required to input: (1) your full legal name; (2) the address where you reside which includes your street address, apartment number if applicable, your City, State and Zip Code; (3) your telephone number; and (4) your date of birth.
If you attempt to purchase a product or service offered by a Retailer, Vault will request that you voluntarily supply Vault with other Personal Information, specifically your method of payment details. Vault uses a secure transmission method for all of its transmissions. you will be able to allow Vault to store your payment mechanism information (for example, credit card number and expiration date) so that you are not required to reenter this information on a subsequent purchase. If you opt not to allow Vault to store this information you will be required to reenter your payment details during each merchandise process.
Vault receives and stores all information that you enter in Vault's Website or on your Vault-APP, unless you specifically opt-out of providing us your payment method details. In addition, Vault collects information about you during your visit, such as your IP Address, and Vault employs unique software in order to ascertain your physical location when using our Website and/or your Vault-APP. In addition, Vault may collect nonpublic personal information about you from the following sources:
- Information Vault receives from you on applications or other forms; and
- Information about your transactions with our Retailers, or others.
Except as set forth below, Vault does not collect information from sources such as public records, or private organizations. However, Vault does collect Personal Information you submit to its Retailers in order to complete transactions. You are required to provide Vault and its clients with accurate and up-to-date information, and your failure to accurately provide such information could result in the voiding of your agreement with Vault and the cancellation of your Account.
Vault may require you to provide certain Personal Information by scanned e-mail. Only in situations where you cannot scan and upload this certain Personal Information online to Vault, will Vault request or accept Personal Information by any other methods such as copies in the mail or via facsimile message. This Personal Information is only requested to verify your identity, your personal address and the address and financial information you have submitted via Vault's Website. Personal Information collected via facsimile, mail, or e-mail will be scanned and stored in Vault’s computerized databases, and paper copies will be shredded unless Vault is required by law to keep paper copies.
In certain cases, current government regulations require Vault to collect valid government-issued identification numbers ("ID Numbers") such as passport numbers, driver’s license numbers and/or other government issued forms of identification of its Account Holders as a preventative measure against identity theft, money laundering, terrorist financing, and the use of Vault’s products and services for illegal purposes. VAULT WILL NEVER ASK YOU FOR YOUR ID NUMBER OVER INSTANT MESSENGER OR E-MAIL. You may be prompted to enter your ID Number after you log into your Vault account, or upon sign-up for a new Vault account. Vault may ask for a scanned copy of your government-issued identity document and your proof of address in order to confirm your identity.
Vault will not share your ID Number or government-issued identity document with anyone, other than a government institution or authority when required by law, through subpoena by a court of competent jurisdiction, or other regulation.
Vault ensures that your Personal Information will not be disclosed to anyone other than a government institution or authority when required by law or other regulation, except we may disclose your Personal Information to the following parties ("Third Parties"):
- Vault's affiliated Acquiring Bank and payment system processors as required to process transactions on your payment method with our Retailers;
- Retailers affiliated with Vault from which you are purchasing goods and services using Vault.
In addition, Vault may disclose your user name, name, address, phone number, and e-mail address to non-financial companies, such as companies that perform marketing services on Vault’s behalf ("Nonaffiliated Third Parties") to provide you information, special offers, and promotions. You may opt-out from these disclosures at any time by following the Opt-Out procedure below.
Choice to provide Personal Information
You may choose whether or not to provide Personal Information to Vault. If you choose not to provide the Personal Information Vault requests, you can still visit portions of Vault's Website, but you may be unable to access certain options, offers, and services that involve Vault's interaction with you. If you chose to have a relationship with Vault, you will be required to provide certain Personal Information in connection with such relationship in order to maintain that relationship.
In those situations where governmental regulations require you to provide ID Information, if you choose not to provide this ID Information, you will not be able to sign up for an account. If you are a current Vault account holder, and Vault requests your ID Information upon login, if you have not provided the ID Number already, if you choose not to provide the requested ID Information, Vault will terminate your Vault account and you will not be able to use your C-APP to make purchases at our Retailers. Please contact email@example.com for more information.
If you prefer that Vault not disclose non-public Personal Information about you to Nonaffiliated Third Parties, you may opt out of those disclosures; that is, you may direct Vault not to make those disclosures (other than disclosures permitted or required by law). If you wish to opt out of disclosures to Nonaffiliated Third Parties, you may opt-out at www.thevaultapp.com when you login to your Vault Account. Please note that this opt-out process may take up to thirty (30) days to complete.
Vault has implemented best-practices security policies, rules and technical measures to protect the Personal Information and ID Numbers that we have under our control from unauthorized access; improper use or disclosure; unauthorized modification; unlawful destruction or accidental loss. Secure Socket Layer (SSL) software is used when receiving and transmitting electronic payments. The sensitive information that you provide is encrypted. When Vault communicates with its required technology vendors and associated financial institutions, your credit card number is communicated on a private dedicated line of communication.
In addition, Vault protects your Personal Information and ID Information off-line. Access to your Personal Information is restricted. Vault's facilities are only accessible through a process of security clearance. All employees and data processors, who have access to and are associated with the processing of Personal Information and ID Information, are obliged to respect the confidentiality of our customers' Personal Information and ID Information, and your Personal Information and ID Information is restricted to those employees who have a need to know your Personal Information to our provide products or services to you. Vault conducts background and credit checks on all of its employees prior to employment. Vault employs a User ID, password scheme and a random Token process in order to limit and achieve access to our computer networks by our employees and Third Parties.
The Company is and has been in compliance with all applicable portions of the Payment Card Industry Data Security Standard (“PCI-DSS”) in all material respects, as it has been amended from time-to-time. With respect to payment card transactions or information processed in any way (including any processing, storing or communication of transaction data or Cardholder Data (as such term is defined in the PCI-DSS)), by the Company, the Company is in material compliance with the PCI-DSS applicable to service providers and with the requirements related to PCI-DSS in each Agreement pursuant to which the Company provides services of any kind. Each Company product or service that is:
- (i) intended to be used to process financial or payment card transactions (including any processing, storing or communication of transaction data or Cardholder Data (as such term is defined in the PCI-DSS)); and
- (ii) provided by the Company to any person or business, is in compliance with the PCI-DSS
4. Access and Accuracy
You may inquire about your Personal Information or ID Information being held by Vault by sending an e-mail to firstname.lastname@example.org. Within five (5) business days, you shall be provided a copy of the Personal Information and/or ID Information that is kept about you. you will be charged a $25 processing fee to complete the request. Prior to completing your request, you will be required to provide proof of your identity. Vault reserves the right to refuse any request for information, and We will communicate the reason for our decision to you.
To the extent that you provide Vault with Personal Information, it must be accurate and current. Where Vault collects Personal Information from you, Vault's goal is to provide you a means of contact should you need to update or correct that Personal Information. If for any reason those means are unavailable or inaccessible, you may send updates and corrections about your Personal Information to email@example.com or by facsimile, by governmental or private express mail, and all reasonable efforts will be made to incorporate the changes in your Personal Information as soon as practicable.
If you provide Vault with your ID Information, it must be from a currently valid government-issued identification document with picture and current proof of your address. Vault may request a scanned copy of your government-issued identification document to verify your identity at any time. If for any reason your government-issued identification document is not acceptable, Vault may request alternate forms of identification to verify your identity.
III. THIRD PARTIES
Occasionally, Vault receives information from Third Parties to compare to your Personal Information that you have provided to Vault for fraud prevention purposes.
Vault does not request, or knowingly collect Personal Information or ID Numbers from children under the age of eighteen (18) years. Vault takes specific steps to protect the privacy of children by making reasonable efforts to ensure that a child's parent or legal guardian has authorized the collection and/or distribution to Third Parties of a child's Personal Information. Additionally, to ensure that children's privacy is respected on Vault's Website, Vault requires age verification on every inquiry. Furthermore, Vault does not give children the ability to post messages or otherwise distribute information about themselves on Vault's Website.
V. POLICY CHANGES
VI. EFFECTIVE DATE
Vault is committed to the privacy of all customers' Private Information and ID Numbers and are actively involved in and support current industry initiatives to preserve individual privacy rights on the Internet. Protecting your privacy online is an evolving area, and Vault's Website is constantly evolving to meet these demands.
"Cookie" means a small piece of text data stored on the storage drive of a visitor to a website, containing information about the visitor that can only be read by the server that placed the information onto the visitor's storage drive. Vault employs Cookie technology.
Most browsers are initially set up to accept Cookies. You can set your browser to block Cookies entirely, delete Cookies when you leave the website, notify you when you receive a Cookie giving you the chance to decide whether or not to accept it, or limit the subsequent retrieval of Cookies by the website. In addition, there are number of privacy-enhancing tools and software that you may purchase that will enable you to identify and block Cookies on a selective basis. Please note that for some websites that require an authorization, Cookies are not optional. Users choosing not to accept Cookies will probably not be able to access those websites where Cookies are not optional.
Cookies can be "Persistent", "Session" Cookies or "Essential Cookies".
Persistent Cookies, also called a Permanent Cookie, or a Stored Cookie, is a Cookie that is stored on your hard drive until it expires (persistent cookies are set with expiration dates, but that date may be far in the future) or until you delete the Cookie.
Session Cookies are also called a Transient Cookie, and is a Cookie that is erased when you close your Web browser. A Session Cookie is stored in temporary memory and is not retained after your browser is closed. Session Cookies do not collect information from your computer.
Essential Cookies are Persistent or Session Cookies that we may use to authenticate you and prevent fraudulent use of your account(s).
When you use and access the Service, we may place a number of Cookies in your web browser.
We use both Session and Persistent Cookies on the service and we use different types of Cookies to run the service:
II. Thirdparty Cookies
In addition to our own Cookies, we may also use various thirdpartys’ Cookies to report usage statistics of the Service, deliver advertisements on and through the service, and so on.
III. What are Your choices regarding Cookies
Please note, however, that if you delete Cookies or refuse to accept them, you might not be able to use all of the features We offer. You may not be able to store your preferences, and some of our webpages might not display properly.
IV. Where can You find more information about Cookies?
You can learn more about Cookies and the following thirdparty websites: