Our commitment to protecting your privacy

INTRODUCTION

Vaulte Technologies Limited provides Information Technology services to customers, to enable them to achieve technological advancement. Vaulte Technologies acts as the data controller for personal data processed in respect of our Services and is referred to as “our,” “we,” or “us” below. We operate Services, which include websites, software, mobile services, and applications.

We know that you care about how your information is used and shared. This Privacy Policy provides details of how we process personal data in line with their obligations under relevant data protection law, including the European Union’s General Data Protection Regulation (the “GDPR”), the California Consumer Privacy Act (the “CCPA”), and other applicable laws (collectively, “Data Protection Law”).

This Privacy Policy explains what information of yours will be collected by us when you use our Services, how the information will be used, and how you can control the collection, correction and deletion of information. Note that certain third parties may be able to identify you across sites and services and over time using the information they process, however, any such processing not done at our direction is outside the scope of this Privacy Policy. We are not responsible for the privacy policies, content or security of any linked third-party websites or services. We recommend that you check the privacy and security policies of every website and service that you visit.

INFORMATION WE PROCESS.

The types of information we process depend on how you use our Services. Many of our Services require users to set up an account, which involves collecting and processing your name and email address. Other Services may require collecting additional information such as payment data to comply with relevant legal obligations.

The following table explains the types of information we collect and how we collect it. These data categories may collectively be called “Your Information”.

Information You Provide

Automatically-Collected Information

Information Others Provide

Vaulte will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes unless we first notify you or obtain your consent, to the extent required by Data Protection Law.

Sensitive Personal Data

Data Protection Law recognises that certain types of information require additional protection. In particular, the GDPR prohibits the processing of sensitive personal data, other than in certain exceptional circumstances. Sensitive personal data in the EU includes information relating to one’s race or ethnicity, political opinions, religious or philosophical beliefs, membership of a trade union, as well as biometric data and data relating to one’s health or sexual orientation. Certain state laws in the US also have different definitions of sensitive personal data.

We do not knowingly collect or process any sensitive personal data from our users. We may collect this information from our admins and they may delete or amend this information at any time.

HOW WE PROCESS YOUR INFORMATION AND OUR LEGAL BASES FOR DOING SO

We collect and process Your Information whenever you use our Services. Consistent with relevant Data Protection Law, we are required to identify a legal basis for each of our processing activities.

Under EU law there are six different bases, which may be relied upon to enable the lawful processing of Your Information. In particular, data controllers may process personal data:

• where they have received freely given, specific, informed and unambiguous consent from a data subject (“Consent”);

• where processing is necessary to conclude and perform a contract (“Contractual Necessity”);

• where processing is necessary to comply with a legal obligation to which they are subject (“Legal Obligation”); or

• in pursuit of the data controller’s legitimate interests, except where these interests are overridden by the rights and freedoms of individuals (“Legitimate Interests”).

Under the CCPA, we must disclose the purposes for which we collect your information:

• Business Purposes, which include auditing, security, debugging/repair, certain short-term uses, performing services, internal research for technical development, quality and safety maintenance and verification, as well as the use of Your Information for our operational purposes, or other notified purposes that use Your Information as reasonably necessary and proportionate to achieve the operational purpose; and

• Commercial Purposes, which include the use of Your Information to advance our commercial or economic interests, such as encouraging others to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

Vaulte primarily rely on Consent, Contractual Necessity, Legal Obligation and Legitimate Interests when processing Your Information. Below we explain the purposes for which we process this information, along with the relevant categories of data we use and the legal basis we rely on to do so (for purposes of the GDPR) or other permitted reasons for processing (e.g. Business Purposes or Commercial Purposes under the CCPA).

Legal Basis: Consent

Legal Basis: Contractual Necessity

Legal Basis: Legitimate Interests

Legal Obligation

WHO WE SHARE DATA WITH

Vaulte works with third-party service providers who help us to provide our Services. Most of our service providers are located in the US and UK.

Transfers to Third Parties

YOUR RIGHTS

Data Protection Laws around the world, including the GDPR and the CCPA, provide users with certain rights over how their personal data is used by companies. Consistent with these laws, our Group Companies enable users to access, amend and delete the Information You Provide. We also have systems in place to allow you to exercise your rights in respect of Automatically-Collected Information and Information Others Provide, including your rights to object to or restrict the processing of your personal data.

If you would like to exercise any of your rights, please contact the relevant company at the information provided below. Alternatively, you may update or correct certain information, such as your Basic Account Information and email preferences, at any time by logging in to your account settings page.

At any time you may:

• Decline to Submit Information: You may, of course, decline to submit Personal Information through the Service, in which we may not be able to provide certain services to you.

• Update Account Information: You may update or correct your account information and email preferences at any time by logging in to your account settings page.

• Unsubscribe from marketing emails: to unsubscribe from a particular newsletter, click the "unsubscribe" link at the bottom of that email newsletter. When we send newsletters to subscribers we may allow advertisers or partners to include messages in those newsletters, or we may send dedicated newsletters and marketing messages on behalf of those advertisers or partners. We may disclose your opt-out choices to third parties so that they can honour your preferences following applicable laws.

• Blocking cookies: certain browsers may be configured to notify you when you receive cookies, or allow you to restrict or disable certain cookies. If you choose to disable cookies, however, that could affect certain features of the Service that use cookies to enhance their functionality. Please see our Cookie Policy. Further, please note our Services do not respond to your browser’s do-not-track request.

• Disabling local shared objects: we may use other kinds of local storage that function similarly but are stored in different parts of your computer from ordinary browser cookies, including Flash cookies placed on your device or web browser via the Adobe Flash plug-in. Your browser may allow you to disable its HTML5 local storage or delete information contained in its HTML5 local storage. For further details about deleting information contained in "local shared objects" or adjusting related preferences, please click here.

• Withdraw Your Consent: Where we are processing Your Information based on your consent, you may change your mind and withdraw your consent at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you, such as linking to your device or providing certain personalised content to you, that are conditioned on your consent.

EU Residents

Under the GDPR, you have the following rights which may be subject to restrictions under local law: (i) the right to withdraw consent to processing where consent is the basis of processing; (ii) the right to access your personal information and certain other supplementary information, under certain conditions; (iii) the right to object to processing that is based on our legitimate interests, under certain conditions; (iv) the right to deletion of personal information about you, under certain conditions; (v) the right to demand that we restrict processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer necessary, are processing, or believe your personal information is inaccurate; (vi) the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, under certain conditions; (vii) the right object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you, under certain conditions; (viii) the right to lodge a complaint with a data protection authorities.

California Residents

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights:

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you, or that we have sold, or disclosed for a Commercial Purpose.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform the Services.

• 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.)

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provide it.

Minors’ User Content

Individuals under the age of 18 in California can delete or remove their publicly available content using the same deletion or removal procedures described above or otherwise made available through our Services. If you have questions about how to remove your content or if you would like additional assistance with deletion you can contact us by email at vaultetech@gmail.com. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information provided through our Services.

Exercising Access, Data Portability, and Deletion Rights

To exercise access, data portability, and deletion rights, please submit a verifiable consumer request to us by emailing us at vaultetech@gmail.com. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person we collected personal information on.

• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable request does not require you to create an account with us.

Response Timing and Format

We endeavour to respond to verifiable consumer requests within 45 days of receipt. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response to you by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If applicable, we will also provide reasons we cannot comply with your request. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information. We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or unfounded. If we determine a fee is warranted, we will provide you with an estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

For the purposes of CCPA, we do not sell Your Information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you with a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level of quality of goods or services.

Information

California Civil Code Section §1798.83 permits users of the Site and/or Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to vaultetech@gmail.com with “Request for California Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you in your email address in response.

DATA SECURITY AND DATA BREACH

We will keep personal data only for as long as is necessary for the purposes for which that personal data are processed, including to provide our Services. The storage periods are determined on a case-by-case basis and will depend on several factors, including:

• The type of information and the purpose for which it is processed;

• Any legal requirement to retain the data, including where data was processed on the basis of a Legal Obligation or until the Statute of Limitations has elapsed with respect to possible legal claims or investigations;

• Whether the data is required for Trust & Safety purposes. For example, where users breach our Terms of Service, we may terminate their account and prevent them from accessing our Services, to protect other users. In such circumstances, it may be necessary to retain certain personal data, even after account termination.

Following termination or deactivation of your User account, we may retain the Information You Provide for a commercially reasonable time for backup, archival, contract performance and enforcement, or audit purposes but for no longer than is necessary and only where the information is accurate and relevant for our use. Furthermore, we may retain and continue to use indefinitely all information contained in your communications to other Users or posted to public or semi-public areas of the Service after termination or deactivation of your User account. However, we will only keep this information on the Services where it was posted and will not use this information for any other purpose.

PRIVACY POLICY CHANGES

As Vaulte continues to grow, how we process data will evolve. We will update this policy from time to time to reflect changing practices. We will notify you of any material changes in the following ways: i) we will send an email to the address provided to us upon sign-up to our Services, or ii) we will post a notification on the relevant site or app.

FURTHER INFORMATION AND COMPLAINTS

For further information about this Privacy Policy and/or the processing of your personal data by or on behalf of any members of Vaulte, please contact us using the information provided below.

Please visit our Terms of Service for further information about our terms when using our services.

For users based in the EEA, you have the right to lodge a complaint with your competent data protection supervisory authority. The contact details of each supervisory authority are available on the European Data Protection Board’s website.

Notwithstanding this right, we request that you contact us in the first instance to allow us to address any concerns you may have.

Cookie Policy

This Cookie Policy takes effect on January 1, 2024.

Information about our use of cookies and similar technologies

Vaulte Technologies Limited (“Vaulte Technologies,” “we,” “our,” or “us”) wants to make sure you understand how cookies and other similar technologies are used by us on our websites vaulte.tech, vaulte.studio, and any subdomains thereof (which we may refer to as the “Sites”) and by our partners. These technologies have several purposes. Our Sites use cookies and similar technologies to distinguish you from other users of our Sites. This helps us to provide you with a good experience when you browse our Sites and also allows us to improve our Sites. By continuing to browse any of our Sites, you are agreeing to our use of cookies and similar technologies as described in this Policy.

Types of technologies that we use

Cookies: A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device to remember information about you, such as your language preference or login information. Those cookies are set by us and called “first-party cookies”. We also use “third-party cookies” – which are cookies originating from a domain different from the domain of the website you are visiting (e.g., one of our Sites) – generally for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes: to enable our Sites to function and maintain security (for example, shopping cart functionality, security, and customer support); to track, measure, and improve the performance of our Sites; allow personalization of our Sites; and to target our ads to prior visitors of our Sites on third party websites (see below on “Why We Use Cookies and Similar Technologies”).

• A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to one of our Sites until you choose to delete them, and otherwise typically delete themselves at expiration. Persistent cookies can be removed by following your web browser's directions.

• A session cookie is temporary and disappears after you close your browser.

• A third-party cookie is placed by someone other than us and may gather browsing activity across multiple websites and multiple sessions. They are usually a type of persistent cookie and are stored until you delete them or they expire based on the time set in each third-party cookie.

You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of our service may not function properly if the ability to accept cookies is disabled. For more information about cookies, you may visit http://www.allaboutcookies.org.

Here’s a description of Vaulte Technologies Sites’ primary first-party cookies and their purposes:

Log File Information: Log file information is automatically reported by your browser each time you access a web page. When you use one of our Sites, our servers automatically record certain log file information. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Sites, domain names, landing pages, pages viewed, and other such information.

Why We Use Cookies and Similar Technologies

We use cookies and similar technologies described above to recognize your logged-in state on the Sites, to understand what purchases members and visitors are interested in, to make our Sites function for you, and to help your browsing experience and use of the Sites feel more customized, as further described:

• Strictly necessary. These are cookies that are required for the operation of our Sites or to provide the services requested by you. They include, for example, cookies that enable you to log into secure areas of our Sites, use a shopping cart, or make use of e-billing services.

• Functional. These are used to recognize you when you return to our Sites. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Analytical/performance. They allow us to recognize and count the number of visitors and to see how visitors move around our Sites when they are using the Sites. This helps us to improve the way our Sites work, for example, by ensuring that users are finding what they are looking for easily.

Some third-party service providers may provide information that enables us to provide you with the appropriate services. In some cases, this information may have non-marketing performance analytics uses as well. These technologies allow a partner to recognize your computer or mobile device each time you visit our Sites or other websites and mobile applications based on data like a cookie, your IP address, or device ID, but do not allow access to other personal information from our Sites. However, these technologies may allow us or a third party to recognize you, either from a single device or across devices, over time. These third parties are required to follow applicable laws, self-regulatory programs, and our data protection rules where applicable. However, Vaulte Technologies does not have control over these third parties, who each have their own privacy policies and privacy practices.

You can find links to their privacy policies below in the “Managing Cookies Technologies” section.

Consent, Contract, and Legitimate Interests in Processing

Certain Cookie Technologies are employed to make each of our Sites function for its intended purpose and are provided based on contractual necessity based on your agreement with Vaulte Technologies to perform the services you have requested. These include the functions strictly necessary for the service noted above.

By choosing to use our Sites after being notified of our use of Cookie Technologies in the ways described in this Policy, and, in applicable jurisdictions, you agree to such use through notice and unambiguous acknowledgement of your consent.

Managing Cookie Technologies

You can control the use of certain cookies and similar technologies.

Opt-in and Opt-out on Browsers

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Sites.

CONTACT INFORMATION

If you have any questions about this Privacy Policy, or data protection queries concerning Vaulte or any of our Services, reach out to us at vaultetech@gmail.com.