PRIVACY NOTICE
This Privacy Notice (the “Notice”) explains how we, VaultN B.V., situated at Nieuwezijds Voorburgwal 292, 1012 RT Amsterdam, Netherlands (“VaultN”), collect and use your Personal Data in connection with your user of the VaultN platform (including add-on features), Mobile App and other software provided on or in connection with our services (collectively: our “Platform”), as further described in our T&Cs. This Notice also informs you about how we protect your Personal Data, and the rights and options you have to control your Personal Data.
V1.00 (Last Updated: 08 October 2024)
1. Types of Data VaultN Collects
Depending on how you use our Platform and/or services, we collect and process the following types of Personal Data:
- Business Account Data, which is the Personal Data you provide to us when using our Platform, such as your name, email address, phone number, your VaultN Account ID and password and potential associated data such as your user preferences, notification settings, the business you’re associated with and/or representing;
- Device Data, which is data we collect automatically when you’re using our Platform and/or services, such as the device address or identifier, IP address, IP country address, and date and time stamps;
- Log File Data, which is data we collect automatically when you’re using our Platform and/or services, such as IP addresses, browser type, resolution, device model, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data;
- Technical data, which is data we collect automatically when you’re using our Platform and/or services, such as certain device or network information, analytical data relating to your use of the Platform and logging data; and
- Third Party Data, which is data on your end-users you may provide to us when using our Platform and/or services. This Third Party Data can also contain data on purchases from your customers, such as their IP Address, Order Reference, User Reference (User ID, Email Address), Account Name and Order ID. Although VaultN does not require you to provide any Personal Data about your end-users, we cannot prevent that you may share certain information with us that would be considered Personal Data under applicable Data Protection Laws.
Please note that VaultN reserves the right to aggregate and de-identify your Personal Data for its internal business purposes. Any use of anonymous data falls outside of the scope of this Privacy Notice.
2. Why VaultN collects your Personal Data
Purpose of Processing | Type(s) of Personal Data | Legal Basis |
Creating, managing and updating your Business Account | Business Account Data | We process this information in order to fulfill our contract with you |
Providing our Platform and services | Business Account Data, Device Data, Technical Data, Third Party Data | We process this information in order to fulfill our contract with you |
Providing our services to your end-users | Business Account Data, Third Party Data | We process this information in order to fulfill our contract with you |
Developing and improving our services | Device Data, Technical Data, Log Files | Legitimate business interest |
Marketing endeavors and business opportunities | Business Account Data | We process this information with your consent |
3. Cookies
VaultN uses cookies, pixel tags and other technical means (“Cookies”) to store and access data on your device to make our website and Platform work. Please refer to our Cookie Notice to learn more about how we use and store cookies. Where necessary under applicable laws, we will obtain your consent for storing and using these Cookies on your device(s).
4. Information Collected from Third-Party Companies
VaultN may receive information 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. Where possible, VaultN will use anonymized data.
5. How we store and transfer Personal Data
VaultN processes your Personal Data within the EU as much as possible. However, it may be necessary to transfer your Personal Data outside the EU to a country which does not provide for the same level of data protection as is provided in the EU, for example, if a third-party service provider is located elsewhere. When we transfer your data outside the EU, we ensure that this is done in accordance with applicable data protection laws and that the protection of your Personal Data is adequately safeguarded.
6. Disclosure of Your Personal Data
VaultN may disclose your Personal Data as described below:
- Third-Party Service Providers. VaultN may utilize or share your Personal Data with third party service providers as and when required to provide our services to you. This includes sharing of Personal Data to confirm the information provided by you; 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.
- Affiliates. VaultN may share Personal Data with any subsidiaries, joint ventures, or other companies under common control (“Affiliates”), in which case VaultN will ensure compliance with applicable data protection laws and will require the Affiliates to honor this Privacy Notice.
- Corporate Restructuring. VaultN may share Personal 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.
- Legal Rights. VaultN may disclose Personal 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 Notice, or the Terms & Conditions.
- Other Disclosures. VaultN may also disclose Personal Data to fulfil the purpose for which you provide it, for any other purpose disclosed by VaultN when you provide it and/or with your explicit consent.
7. Third-Party Websites.
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 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 Notice do not apply to these third-party websites or their content, or to any collection of your Personal Data after you click on links to such third-party websites. VaultN encourages you to read the privacy notices 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.
8. Your Preferences
- 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.
9. Cookie Preferences.
If you decide at any time that you no longer wish to accept Cookies from the Platform for any of the purposes described above, 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.
Retention of Personal Data
VaultN may retain Personal 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 Notice. VaultN may continue to retain your Personal 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 T&Cs or other agreements with you, and/or protect its legitimate interests, but we will not retain your Personal Data longer than reasonably necessary.
VaultN may also process, store and transfer aggregated and anonymous data for improving the Platform, which may be retained indefinitely.
10. Security of Your Personal Data
The security of Your Personal Data is important to VaultN. We have implemented physical, technical and organizational measures to protect your Personal Data, as required by applicable laws. VaultnN evaluates and updates these measures on a regular basis. While VaultN strives to use commercially acceptable means to protect Your Personal Data, VaultN cannot guarantee its absolute security.
11. Your Legal Rights
We respect the rights granted to you under applicable data protection laws. Depending on your location and such applicable laws, these may include: i) the right to access the Personal Data we hold about you; ii) to rectify or erase certain Personal Data; iii) to restrict (further) processing of your Personal Data (including the right to object to sale of your Personal Data); and iv) to obtain an electronic copy of the Personal Data we hold about you for purposes of transmitting it to another company.
Where we rely on our legitimate interest to process Personal Data, you may have the right to object to such processing depending on your particular situation and in accordance with applicable laws. For example, you may have a right to opt-out of marketing communications via an opt-out link in the respective marketing message.
Where we rely on your consent to process your Personal Data, you have the right to withdraw your consent at any time.
To exercise your rights, please use contact us through our contact form located at https://www.vaultn.com/contact/, or by sending an email to [email protected] (referencing “privacy request”).
You are also entitled to lodge a complaint with your local data protection authority.
12. Changes to this Privacy Policy
- VaultN may update the Privacy Notice from time to time. VaultN will notify you of any changes by posting the new Privacy Notice 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 Notice.
- You are advised to review this Privacy Notice periodically for any changes. Changes to this Privacy Notice are effective when they are posted on this page, unless communicated otherwise.
13. Contact VaultN
If you have any questions about this Privacy Notice, you can contact VaultN:
- By visiting this page on the Platform: https://www.vaultn.com/contact/
- 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 also contact your local data protection authority.