SWITCHING AND EXIT: DATA ACT DOCUMENTATION
Version 1.00. Published: 1 October 2026. Applies to VaultN B.V. and, for the FastTrack Services, VaultN Marketplace B.V.
This page is the documentation referred to in Clause 16.4 of the VaultN Terms and Conditions (T&Cs). It sets out how you switch away from VaultN or exit the Platform, which data you can retrieve, in which formats, through which procedures, and which technical limitations apply. It implements Chapter VI of Regulation (EU) 2023/2854 (Data Act), which applies to data processing services from 12 September 2025.
1. SCOPE
1.1 This page applies to every Account holder (Publisher or Retailer) using the VaultN Platform, Services and Add-Ons under the T&Cs. It covers:
- (A) switching to another provider of data processing services;
- (B) switching to on-premises infrastructure;
- (C) exit from the Platform without a destination provider;
- (D) parallel use of another provider alongside VaultN.
1.2 The VaultN Platform is a software service. It is not infrastructure-as-a-service. The Data Act obligation to deliver functional equivalence in the destination environment (Article 30(1)) applies to infrastructure services only. For the VaultN Platform, VaultN provides exports of exportable data in a structured, commonly used and machine-readable format (CSV, XLSX and, for invoices, EN 16931 UBL XML), free of charge, as described below.
2. HOW TO START A SWITCH OR EXIT
2.1 Step 1. Notice. Terminate your Account or the relevant Service via the Platform, or send written notice to [email protected] (T&Cs Clause 4.9 and 15). The notice period for you is zero days, unless your Plan states otherwise. In no case does the notice period exceed two months (Article 25(2)(d)).
2.2 Step 2. Transitional period. From the effective date of termination, VaultN provides continuity support for a transitional period of up to 30 calendar days. During this period the Platform, Services and Add-Ons remain available to you for the purpose of completing pending transactions, retrieving data and migrating to the destination environment. Where a 30-day transitional period is technically unfeasible, VaultN notifies you within 14 working days of the notice, states the reasons, and proposes an alternative period of no more than 7 months (Article 25(4)). You may extend the transitional period once by a period you consider appropriate (Article 25(5)).
2.3 Step 3. Retrieval period. After the transitional period, you have a data retrieval window of 30 calendar days (T&Cs Clause 16.3 and Article 25(2)(g)) in which all exportable data remains available for retrieval through the procedures in Clause 4.
2.4 Step 4. Deletion. After the retrieval period, VaultN deletes your data, except where and for as long as retention is required by applicable law, the DPA, or a statutory retention period (T&Cs Clause 16.3, DPA Clause 11). Invoices and self-billing records are retained for the statutory period under Articles 244 to 247 of Council Directive 2006/112/EC and equivalent national law; for VaultN this period is ten years.
3. EXPORTABLE DATA
3.1 The following categories of data are exportable. “Exportable data” means the input and output data, including metadata, directly or indirectly generated or co-generated by your use of the Platform, and excludes the assets and data listed in Clause 3.3 (Article 2(38)).
3.2 Categories
| Category | Content | Format |
|---|---|---|
| Account and User data | Account details, User names, email addresses, roles and permissions, security settings | CSV, on request (Clause 4.3) |
| Connections and configuration | List of Connections, connection status, distribution restrictions (territory, channel, timing), Specific Terms parameters as configured on the Platform, self-billing activation status per Connection | Price lists and promotions: CSV via the Platform (Clause 4.1). Other configuration: CSV, on request (Clause 4.3) |
| Digital Inventory | Keys held in your vaults that have not been transferred to a Connection, inventory allocations, key batches and their status, restrictions attached to inventory | Inventory and revoked Key reports: CSV via the Platform (Clause 4.1). Keys: plain text, in a report requested through the Platform, under the same access controls that apply to key download on the Platform (Clause 4.4) |
| Transaction Data | Orders, reservations, transfers, extractions, deliveries, fulfillment confirmations, Key on Demand and Just-in-Time retrieval records, order identifiers (clientOrderReference, orderGuid), timestamps, quantities, prices | Key-by-key reports (every movement of each Key) and finance reports (all sales and orders): CSV or XLSX via the Platform (Clause 4.1). Other Transaction Data: CSV, on request (Clause 4.3) |
| Invoices and self-billing records | Self-billed Invoices, credit notes and replacement Invoices generated on the Platform, and FastTrack invoices issued by VaultN Marketplace B.V. | EN 16931 UBL 2.1 XML (source of record) and PDF rendered from the stored XML, downloadable through the Platform once self-billing is available on the Platform. Until then, on request (Clause 4.3) |
| Product Information and Metadata | Product details, catalog entries, descriptive, organizational and relational Metadata, and media assets you uploaded | CSV, on request (Clause 4.3). Assets in their original uploaded format, bundled as a ZIP archive on request. Metadata synchronized from the Publisher’s storefront listings remains available at that source |
| Reports | Reports and analytics generated for your Account, at the granularity available on the Platform at the time of export | CSV or XLSX, depending on the report, via the Platform (Clause 4.1) |
| Collection Services records | Instructions you issued through the Platform to the Payment Service Provider, and the related settlement references held on the Platform | CSV, on request (Clause 4.3) |
| Audit and access logs | Login and access events and key download events relating to your Account, for 12 months | CSV, on request (Clause 4.3) |
3.3 Not exportable
- (A) VaultN Content: the Platform software, layouts, source code, interfaces and all other VaultN Content (T&Cs Clause 7.1). These are VaultN’s IP Rights and are not exportable data.
- (B) Derivative Data: aggregated or anonymized data generated by VaultN across the Platform (T&Cs Clause 8.2), because it does not identify any individual Account and is not your data.
- (C) Other Accounts’ data: data belonging to your Connections is exported by those Connections under their own Accounts. Transaction Data relating to a transaction between you and a Connection is exportable by both parties to that transaction.
- (D) Funds and payment processing records held by the Payment Service Provider. VaultN does not hold, control or possess funds at any time (Collection Terms). Statements and settlement records are obtained from the Payment Service Provider under its terms.
- (E) Keys already transferred, delivered or redeemed. A Key transferred to a Connection or delivered to an end user is no longer in your Digital Inventory and cannot be retrieved or revoked through export. The transaction record of the transfer remains exportable.
4. RETRIEVAL PROCEDURES
4.1 Export via the Platform. Price lists, promotions, inventory, revoked Keys, key-by-key reports showing every movement of each Key, finance reports covering all sales and orders, and other reports can be downloaded from the relevant section of the Platform, using the export or download button in that section.
4.2 API retrieval. VaultN does not currently offer export of exportable data through its API. Data not available under Clause 4.1 is exported on request under Clause 4.3. An export interface is in development; this page will describe it when it becomes available.
4.3 Export on request. Data not available under Clause 4.1 can be requested through the Platform. VaultN generates the requested data as individual reports, which you download from the Platform. Reports requested through the Platform are usually available in near real time. For a switch or exit, VaultN makes all requested reports available within 10 Business Days where this is possible with reasonable effort, and in any case within the transitional and retrieval periods in Clause 2. Exports on request are free of charge.
4.4 Key export. Unredeemed Keys are requested through the Platform and downloaded as a report. Key export is subject to the same authorization and multi-factor authentication controls as key download on the Platform. VaultN logs every Key export.
4.5 Migration to a destination provider. Where your destination provider supports a direct import of the export formats above, VaultN provides the exports in those formats. VaultN does not operate connectors to specific third-party systems.
5. SWITCHING CHARGES
5.1 VaultN imposes no switching charges. This applies from the publication of this page, ahead of the prohibition on switching charges from 12 January 2027 (Article 29(1)).
5.2 The following are not switching charges and remain payable under your Plan: Charges for Services and Add-Ons used during the notice and transitional periods; Externalization Charges for the ongoing externalization of Product Information to third parties under Clause P3.3 of the Product Information terms during normal operation. Data retrieval at exit under this page is not Externalization.
5.3 Early termination penalties do not apply to termination for the purpose of switching (Article 25(3)).
6. TECHNICAL LIMITATIONS
- (A) Key on Demand and Just-in-Time Keys are generated at the moment of retrieval by a Connection. There is no stored inventory to export beyond the transaction record.
- (B) Historical data is exportable for the period VaultN retains it. Transaction Data is retained for at least seven years, the statutory retention period applicable to VaultN. Audit and access logs are retained for 12 months. Invoices are retained for ten years.
- (C) Media assets are exported in the format in which they were uploaded. VaultN does not transcode or resize assets at export.
- (D) Report definitions are exported as data output, not as reusable report templates.
- (E) Connections’ acceptance state. Whether a Connection has accepted a self-billing arrangement or Specific Terms is exported as a status flag with a timestamp. The underlying acceptance record is a Platform record and is exportable by both parties.
- (F) In-flight transactions are completed or unwound during the transitional period (T&Cs Clause 16.3). A transaction that cannot be completed within the transitional period is unwound and recorded as such in the export.
6.1 Data exported by you remains subject to any Distribution Terms, Publisher Terms, IP Rights and confidentiality obligations that applied to it on the Platform. Export does not enlarge your rights to the data of a Connection.
7. INFRASTRUCTURE LOCATION AND INTERNATIONAL ACCESS
7.1 The VaultN Platform is hosted on Microsoft Azure in the West Europe (Netherlands) region. Backups are held in the same region (Article 28(1)(a)).
7.2 VaultN maintains technical, organizational and contractual measures to prevent international and third-country governmental access to non-personal data held on the Platform where that access would conflict with Union or Member State law (Article 28(1)(b) and Article 32). Requests from third-country authorities are assessed against Article 32; VaultN discloses only the minimum data required and informs the affected Account holder before disclosure where legally permitted. Personal data is governed by the DPA and its Standard Contractual Clauses.
7.3 The current list of sub-processors, with their locations, is published at https://vaultn.com/subprocessor-list/.
8. ONLINE REGISTER OF DATA STRUCTURES AND FORMATS
8.1 Article 26(b) requires an online register of the data structures, data formats and relevant standards and interoperability specifications in which exportable data is available. That register is the format table in Clause 3.2, together with the exports themselves: each CSV and XLSX export carries column headers that identify every field, and invoices follow the EN 16931 schema.
9. CONTACT
9.1 Switching and exit requests and questions on this page: [email protected]. Exports on request are requested through the Platform (Clause 4.3). Personal data matters: [email protected].
10. VERSION HISTORY
| Version | Date | Change |
|---|---|---|
| 1.00 | 1 October 2026 | First publication, together with T&Cs v2.00 |
Related documents: Terms and Conditions - Data Processing Agreement - Service Level Agreement