Privacy Policy

Introduction
Welcome to our privacy policy. This is our plan of action when it comes to protecting your privacy. We respect your privacy and take the protection of personal data very seriously. The purpose of this policy is to describe the way that we collect, store, use, and protect data that can be associated with you or another specific natural or juristic person and can be used to identify you or that person (personal data).

Audience
This policy applies to you if you are:
– a registered user on Vault; or
– a customer who has administration rights

Personal data
Personal data includes:
– certain information that we collect automatically when you visit our website;
– certain information collected on registration (see below);
– certain information collected on submission; and
– optional information that you provide to us voluntarily (see below);

Personal data excludes:
– information that has been made anonymous so that it does not identify a specific person;
– permanently de-identified information that does not relate or cannot be traced back to you specifically;
– non-personal statistical information collected and compiled by us; and

Common examples
Common examples of the types of personal data which we may collect and process include your:
– identifying information – such as your name, organisation, country and role within the organisation
– contact information – such as your phone number or email address;
– role information – such as your title and funds managed

Acceptance
Acceptance required
You must accept all the terms of this policy when you register as a user or administrator on our website.

Deemed acceptance
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

Your obligations
You may only send us your own personal data or the personal data of another data subject where you have their permission to do so.

Changes
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website, and our goods or services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.

Collection
On registration
Once you register on our website, you will no longer be anonymous to us, or to the administrator of the company groups you join.

You will provide us with certain personal data.
This personal data may include:
– your name and surname;
– your email address;
– your telephone number;
– your company name;
– your username and password

We will use this personal data to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.

Supplied by company
Your details may also be stored on our website if they were provided to us by a customer (listed company).  In this instance the company has committed to us that they have your express authority to store your details and issues alerts to you.

Optional details
You may also provide additional information to us on a voluntary basis (optional information). This includes your role, responsibilities, funds managed, event attendance, and dietary preferences.

Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Cookies
We may place small text files called ‘cookies’ on your device when you visit our website.These files do not contain personal data, but they do contain a personal identifier allowing us to associate your personal data with a certain device. These files serve a number of useful purposes for you, including:
– tailoring our website’s functionality to you personally by letting us remember your preferences;
– improving how our website performs;

Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary. Many websites use cookies and you can find out more about them at www.allaboutcookies.org.

How we use collected non-personal identification information

The Vault may collect and use Users non-personal information for the following purposes:
– To personalise user experience : We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
– To improve our Site : We may use feedback you provide to improve our products and services

Unauthorised disclosure
We cannot accept any liability whatsoever for unauthorised or unlawful disclosure of your personal data by third parties who are not subject to our control.

Security
We take the security of personal data very seriously and always do our best to comply with applicable data protection laws. We will implement and maintain appropriate technical and organisational measures to protect the security and confidentiality of the personal data. We host on a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. All personal data is securely stored in our customer database. We authorize access to personal data only for those employees who require it to fulfil their job responsibilities. We implement disaster recovery procedures where appropriate.

How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

Law enforcement
We may disclose personal data if required:
– by a subpoena or court order;
– to comply with any law;
– to protect the safety of any individual or the general public; and
– to prevent violation of our terms of service.

No selling
We will not sell personal data. No personal data will be disclosed to anyone except as provided in this privacy policy.

Accurate and up to date
We will try to keep the personal data we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal data on the website. You are able to review or update any personal data that we hold on you by accessing your account online or emailing us. Please note that in order to better protect you and safeguard your personal data, we take steps to verify your identity before granting you access to your account or making any corrections to your personal data. Throughout your interaction with us you retain the right to rectify personal data that is incorrect or inaccurate. This does not apply if we process your personal data in our capacity as a processor on behalf of you when you act as the data controller.

Retention
We will only retain your personal data for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
– retention of the record is required or authorised by law; or
– you have consented to the retention of the record.

During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal data.

Transfer to another country
You consent to us processing your personal data in a foreign country whose laws regarding processing of personal data may be less stringent.

Updating or removing
You may choose to correct or update the personal data you have submitted to us by contacting us via email or via the website.

You are entitled to a right to be forgotten. We will delete any personal data that you don’t want us to have. If you are a data subject of one of our customers (who is the data controller), then you must submit your request to the relevant data controller who will then delete your personal data.

Restriction of processing
You may request that we restrict the use of your personal data. When we restrict your personal data, we still have the right to store it but not use it.

Data portability
If you should wish to transfer your data from us to another data controller we will facilitate this transfer. We will pass on all of our personal data to the data controller.

If you are a data subject of one of our customers (who is the data controller), then you must submit your request for your personal data to the relevant data controller, who will then export your personal data.

Data breaches
We will notify our customers of any confirmed data breaches that has occurred. It is our customers’ responsibility to notify relevant supervisory authority and any affected data subjects of the data breach.

Limitation
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.

Contacting us
If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

shammerton@thevault.exchange

This document was last updated on May 25, 2018