Editional / Vault.io Privacy Policy

Last updated: April 9, 2019

Through https://vault.io, https://editional.com or any other associated websites, APIs, or mobile applications (collectively, the "Vault Site"), Vault.io, Inc. ("Vault") provides a platform for holding, storing, tracking and managing certain supported digital currencies ("Digital Currency") and Digital Currency accounts, and allowing interaction with decentralized apps and smart contracts on the Ethereum blockchain. The Vault Site and any other features, tools, materials, or other services offered from time to time by Vault are referred to as the "Services.

This notice describes our privacy policy (the "Privacy Policy"), including how we collect, use, disclose, transfer, and store various information about you, including your personal information.

By using the Services, you are accepting the practices described in this Privacy Policy.

Vault may amend this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published and we offer access to archived versions for your review. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).

What personal information we collect

When you create a Vault account, download a software update, connect to our services, or contact us, we may collect a variety of information, including your name, mailing address, phone number, email address, identification documents, contact preferences, device identifiers, IP address, location information and credit card information.

How we use your personal information

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. In general, we use personal information to create, develop, operate, deliver, and improve our Services and content, as well as for loss prevention and anti-fraud purposes. Examples of how we may use this information include:

• Providing you with, and improving, our Services and customer support that you request; • Compliance with applicable laws and regulations;
• Prevention of potentially prohibited or illegal activities, and enforcing our Terms of Use;
• Processing and sending notices about transactions;
• Resolution of disputes and collecting fees;
• Identity verification;
• Sending administrative or account-related information to you; and
• Troubleshooting problems, enhancing security, monitoring and verifying identity or Service access, and combating spam or other malware or security risks.

How we protect your personal information

At Vault, we take your personal information seriously, which is why we maintain appropriate physical, technical and administrative safeguards in compliance with applicable United States federal and state regulations to protect the security and confidentiality of the personal information you share with us. We use encryption to keep your data private while in transit and restrict access to your personal information to Vault employees, contractors and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations.

How we share your personal information with third parties

We may share your personal information with the following third parties: • Service providers under contract to help with our business operations (we make sure that these parties have appropriate internal controls in place to protect any personal information that is transferred);
• Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to Vault, or when we believe, in our sole discretion, that the disclosure of your personal data is necessary to report suspected illegal activity or to investigate violations of our Terms of Use;
• In cases
• Troubleshooting problems, enhancing security, monitoring and verifying identity or Service access, and combating spam or other malware or security risks.

Retention of your personal information

We store your personal information securely throughout the life of your Vault account. We will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations.

How you can access your personal information

You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your Vault account. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Vault is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier.

Notwithstanding the foregoing, if you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for the third parties' direct marketing purposes. California law provides that you have the right to submit a request to us at our designated address and receive the following information: (a) the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. You may make such a request by emailing [email protected].

Third-party sites and services

Vault websites, products, applications and services may contain links to third-party websites, products and services. Our Services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

Cookies

Vault's website and Services may use “cookies.” Cookies enable you to use shopping carts and to personalize your experience on our sites, tell us which parts of our websites people have visited, help us measure the effectiveness of ads and web searches, and give us insights into user behavior so we can improve our communications and products.

We treat information collected by cookies and other technologies as non personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies, or delete all cookies. Please note that, if you choose to delete Vault cookies, your access to some functionalities and areas of our website may be degraded or restricted.