“Personal Data” means data related to your end-users that allows someone to identify the end-user individually, including, for example, name, email address, IP address, device address or identifier as well as any other non-public information about an end-user that is associated with or linked to any of the foregoing.

“Business Data” means data that allows someone to identify a business or its representative, including, for example, the name, e-mail address, phone number, IP address, IP country address, device address or identifier, VaultN account ID and password as well as any other non-public information about a business that is associated with or linked to any of the foregoing.

“Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to Personal Data or Business Data; Anonymous Data does not, by itself, permit the identification of individual persons or businesses. VaultN collects Personal Data, Business Data and Anonymous Data as described below.

• Information You Provide VaultN
  • When you use the Platform, register for a VaultN account, update your account profile, or contact VaultN, VaultN may collect Personal Data or your Business Data from you, such as IP addresses of the end-users or email address, representative’s name, user or account name, and other information you provide, which will be linked to your account for fraud detection/prevention purposes.
  • The Platform lets you store preferences like how your content is displayed, notification settings, and favorites. VaultN may associate these choices with your ID, browser, or mobile device.

• Information Collected via Technology.

As you navigate through and interact with the Platform, VaultN may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Information Collected by VaultN Servers. To provide the Platform and make it more useful to you, VaultN (or a third-party service provider) may collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.
• Log Files. As is true of most websites and applications, VaultN may gather certain information automatically and store it in log files. This information may include IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. VaultN may use this information to analyze trends, administer the Platform, track users’ movements around the Platform, and better tailor the Platform to the users’ needs. For example, some of the information may be collected so that when you visit the Platform, it will recognize you and the information can be used to personalize your experience.
• Like many online services, VaultN uses cookies to collect information. VaultN may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyze how users or accounts interact with the Platform, make improvements to the product quality, and provide users or accounts with a more personalized experience. You may find more information about cookies on the Cookie Policy.
• Pixel Tag. In addition, VaultN may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow VaultN to analyze how users or accounts find the Platform, make the Platform more useful to you, and tailor your experience with VaultN to meet your particular interests and needs.
• How VaultN Responds to Do Not Track Signals. VaultN systems do not currently recognize “do not track” signals or other mechanisms that might enable users or accounts to opt out of tracking on the Platform.
• Analytics Platform. In addition to the tracking technologies, just like VaultN places Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit a website. This may include third-party analytics services (“Analytics Platform”) that VaultN may engage to help analyze how users or accounts use the Platform. The information generated by the Cookies or other technologies about your use of the Platform (the “Analytics Information”) may be transmitted to the Analytics Platform. The Analytics Platform uses Analytics Information to compile reports on user or account activity, which VaultN may receive on an individual or aggregate basis. If VaultN decides to do so, VaultN will use the information VaultN obtains via the Analytics form to improve the Platform. The Analytics Platform may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Platform’ ability to use and share Analytics Information is restricted by such Analytics Platform’s terms of use and privacy policy. By using the Platform, you consent to the processing of data about you by Analytics Platform in the manner and for the purposes set out above

.

• Information Collected from Third-Party Companies

VaultN may receive Personal, Business, and/or Anonymous Data about you from companies that offer their products and/or services for use in conjunction with the Platform or whose products and/or services may be linked from the Platform. VaultN may add this to the data VaultN has already collected from or about you through the Platform.

• Public Information Observed from Blockchains

VaultN may collect data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding purchases, sales, or transfers of certain crypto assets, which may then be associated with other data you have provided to VaultN.

• End-user or Business Partner Data

VaultN may or may not collect, process, store, and disclose Personal or Business Data of your end-users or business partners.  Such data processed by you may be required in line with the use of the Platform. Such data may include IP Address, IP country or location, user ID, contact information of the end-users engaged directly by you or your business partners related to product transactions throughout your supply chain. You hereby accept and undertake that you will obtain the necessary legal permits from the end-users or business partners and that you are the sole party responsible for the accuracy and proper use of such end-user Personal and Business Data. VaultN may, however, receive Anonymous Data from the data specters that may related to end-users and/or business partners from registered users that are using your services.

VaultN may process Personal and Business Data to run the business, provide the Platform, personalize the experience on the Platform, and improve the Platform. Specifically, VaultN uses Personal and Business Data to:

• facilitate the creation of and secure your account;
• identify you as a user or account in the system;
• provide you with the Platform, including, but not limited to, helping you monitor your data using the tools and, at your own discretion;
• improve the administration of the Platform and quality of experience when you interact with the Platform, including, but not limited to, by analyzing how you and other users or accounts find and interact with the Platform;
• provide customer support and respond to your requests and inquiries;
• investigate and address conduct that may violate the Terms of Use;
• detect, prevent, and address fraud, violations of the terms or policies, and/or other harmful or unlawful activity;
• send you a welcome email to verify ownership of the email address provided when your account was created;
• send you administrative notifications, such as security, support, and maintenance advisories;
• send you notifications related to actions on the Platform;
• send you newsletters, promotional materials, and other notices related to the Platform or third parties’ goods and services;
• respond to your inquiries related to employment opportunities or other requests;
• comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims; and
• act in any other way VaultN may describe when you provide the Personal and Business Data.

VaultN may create Anonymous Data records from Personal and Business Data. VaultN uses this Anonymous Data to analyze request and usage patterns so that VaultN may improve the Platform and enhance Platform navigation. VaultN reserves the right to use Anonymous Data for any purpose and to disclose Anonymous Data to third parties without restriction.

VaultN may disclose your Personal or Business Data and the Personal or Business Data of the end-users as described below and as described elsewhere in this Privacy Policy.

• Third-Party Service Providers. VaultN may utilize or share the Personal or Business Data provided by you, including but not limited to certain Personal or Business Data of end-users or business partners such as account information of the relevant person on third-party platforms, with third party service providers to: confirm the information of the accounts of end-users or business partners on third party platforms where a certain Service may directly be provided to such third party platform account of the relevant end-user or business partner; provide technical infrastructure services; conduct quality assurance testing; analyze how the Platform is used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to VaultN and to the Platform.
• VaultN may share some or all of the Personal or Business Data with any subsidiaries, joint ventures, or other companies under common control (“Affiliates”), in which case VaultN will require the Affiliates to honor this Privacy Policy.
• Corporate Restructuring. VaultN may share some or all of the Personal and Business Data in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of the business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal or Business Data may also be transferred as a business asset. If another company acquires VaultN, business, or assets, that company will possess the Personal or Business Data collected by VaultN and will assume the rights and obligations regarding all Personal and Business Data as described in this Privacy Policy.
• Legal Rights. Regardless of any choices you make regarding the Personal and Business Data (as described below), VaultN may disclose Personal and Business Data if VaultN believes in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served; (c) to protect or defend the rights or property of VaultN or users or accounts of the Platform; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Terms of Use.
• Other Disclosures. VaultN may also disclose any Personal or Business Data: to fulfil the purpose for which you provide it; for any other purpose disclosed by VaultN when you provide it; or with your consent.

The Platform may contain links to third-party websites. When you click on a link to any other website or location, you will leave the Platform and go to another site, and another entity may collect Personal or Business Data from you. VaultN has no control over, does not review, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party websites or their content, or to any collection of your Personal or Business Data after you click on links to such third-party websites. VaultN encourages you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify the endorsement of such third parties or their products, content, or websites.

You have several choices regarding the use of information on the Platform:

• Email Communications. VaultN may periodically send you newsletters and/or emails that directly promote the use of the Platform or third parties’ goods and services. When you receive newsletters or promotional communications from VaultN, you may indicate a preference to stop receiving these communications from VaultN by following the unsubscribe instructions provided in the email you receive or through the settings page. Despite these preferences, VaultN may send you occasional transactional service-related informational communications.
• If you decide at any time that you no longer wish to accept Cookies from the Platform for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Platform or all functionality of the Platform.

VaultN may use Personal and Business Data based on following legal bases:

• To enable VaultN to enter into an agreement with you, after which VaultN will execute this agreement, such as but not limited to the agreement for the delivery of the products and/or services;
• To enable VaultN to meet the statutory obligations;
• VaultN is always looking for ways to make the Platform smarter, faster, more secure, integrated and useful to you. It is in the legitimate business interests to continue to maintain and improve Platform. The processing is necessary for the purposes of the legitimate interests pursued by VaultN, including the interest to perform the business activities, except where such interests are overridden by the interests of fundamental rights and freedoms of the data subjects that require protection of Personal or Business Data. VaultN uses collective learnings about how people or businesses use the Platform and feedback provided directly to VaultN to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Platform.

• Lastly, VaultN may also use the Personal and Business Data you provide to VaultN for marketing purposes, and in particular to offer personalized offers. If you have agreed to receive marketing; you may always opt out at a later date. You have the right at any time to stop VaultN from contacting you for marketing purposes. If you no longer wish to contacted for marketing purposes, please click here.  

Note: When VaultN is processing Personal and Business Data on the basis of prior consent to that processing, the consent may be withdrawn at any time.

Further Note: Where VaultN is using your information because VaultN has a legitimate interest to do so, you have the right to object.

VaultN may retain Personal and Business Data as long as you continue to use the Platform, have an account with VaultN, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. VaultN may process, store and transfer end user Personal or account Business Data for improving the Platform, which may be retained indefinitely. VaultN may continue to retain your Personal and Business Data even after you deactivate your account and/or cease to use the Platform if such retention is reasonably necessary to comply with the legal obligations, to resolve disputes, prevent fraud and abuse, enforce the Terms or other agreements, and/or protect the legitimate interests. Where your Personal or Business Data is no longer required for these purposes, VaultN will delete it.

The security of Your Personal and Business Data is important to VaultN. VaultN takes necessary and proper measures to protect your Personal and Business Data but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While VaultN strives to use commercially acceptable means to protect Your Personal and Business Data, VaultN cannot guarantee its absolute security.

• Your Rights under the CCPA. The CCPA provides California residents with specific rights regarding their Personal Data. If You are a resident of California, You have the following rights:
  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. Under CCPA, You have the right to request that VaultN discloses information to You about collection, use, sale, disclosure for business purposes and share of Personal Data. Once VaultN receives and confirms Your request, VaultN will disclose to You:
• The categories of Personal Data VaultN collected about You
• The categories of sources for the Personal Data VaultN collected about You
• VaultN’s business or commercial purpose for collecting or selling that Personal Data
• The categories of third parties with whom VaultN shares that Personal Data
• The specific pieces of Personal Data VaultN collected about You
• If VaultN sold Your Personal Data or disclosed Your Personal Data for a business purpose, VaultN will disclose to You:
  • The categories of Personal Data categories sold
  • The categories of Personal Data categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct VaultN to not sell Your Personal Data. To submit an opt-out request please contact VaultN.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once VaultN receives and confirms your request, VaultN will delete (and direct VaultN Platform Providers to delete) Your Personal Data from the records, unless an exception applies. VaultN may deny your deletion request if retaining the information is necessary for VaultN or the Platform Providers to:
• Complete the transaction for which VaultN collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of the ongoing business relationship with you, or otherwise perform the contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with VaultN.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
• Denying goods or services to you
• Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
• Providing a different level or quality of goods or services to you
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  • Your Rights Under the GDPR
    • Objection: Depending on the situation, you have the right to consent or object to the processing of your Personal Data and the conditions under which this processing takes place.
    • Access: You have the right to request from VaultN, without constraint, at reasonable intervals and without excessive delay or expense, i) a confirmation as to whether or not Personal Data regarding you is being processed, ii) information on the purposes for which Personal Data is processed, iii) the categories of Personal Data concerned, and iv) the recipients or categories of recipients to whom the Personal Data is disclosed. You have the right to receive, in an intelligible form, a communication of the Personal Data being processed and of any available information as to the source(s). Furthermore, you have the right to knowledge of the underlying logic of the automated processing of Personal Data relating to you.
    • Rectification, erasure, blocking, or deletion: You, where appropriate, have the right to rectification, erasure, blocking, or deletion of your Personal Data that is not processed in compliance with data protection laws and regulations, in particular when the nature of the data is incomplete or inaccurate.
    • Data portability: You have the right to request that VaultN transfers the Personal Data and Business Data that VaultN has collected to another organization, or directly to you, under certain conditions.
    • Notification: You have the right to a notification to third parties to whom your Personal Data has been disclosed, when you have been granted any rectification, erasure, blocking, or deletion as stated above, unless such notification proves to be impossible or requires a disproportionate effort from VaultN.
    • Withdraw consent: where VaultN is processing personal data relating to you on the basis of your prior consent to that processing, you may withdraw your consent at any time.
    • Complaint with relevant authority: You have the right to file a complaint with the relevant data protection authorities.

• The laws of the Netherlands shall apply to this Privacy Policy. Any dispute arising from this Privacy Policy shall be finally resolved through courts and enforcement offices of Amsterdam, arbitration under the UNCITRAL rules of arbitration. The arbitration shall be held through three arbitrators; one being selected by each Party and the third selected by these two. The arbitration shall take place in Amsterdam and shall be held in English. The Party found liable after the arbitration shall cover all costs thereof.
• VaultN may update the Privacy Policy from time to time. VaultN will notify you of any changes by posting the new Privacy Policy on this page
• VaultN will let you know via email and/or a prominent notice on the Platform, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
• You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

If you have any questions about this Privacy Policy, You can contact VaultN:

• By visiting this page on the Platform: https://www.vaultn.com/contact-VaultN/
• By sending VaultN an email: [email protected]

Should you wish to report a complaint or if you feel that VaultN has not addressed Your concern in a satisfactory manner, you may contact the Information Commissioner’s Office:

• By sending an email: [email protected]