Last updated August 27, 2017

VaultRunner, Inc. (“we” “our”) takes your privacy seriously. Our primary goal is to provide you with exceptional service, and we understand that you may have questions or concerns regarding your personal information and how it will be used. To make this privacy policy easy to find, we make it available from our home page and through our mobile application. You may also email us at legal@vaultrunner.com with any privacy-related questions you may have.

It’s important to know that our application may contain links to third party sites not controlled by us or covered by this notice. We recommend that you check the privacy statements of other sites you visit before providing any personal information.

APPLICABILITY OF THE PRIVACY POLICY

This privacy policy applies to all information we collect through our mobile application and/or website(s) (collectively, “Services”) and is incorporated into our Terms of Service and Client Agreement.

Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been anonymized so that it does not identify a specific user.

1.        THE INFORMATION WE COLLECT

When you use our Services, we collect your cellular/wireless telephone number, the device type, machine or mobile device identification number, IP address, or mobile device ID and other similar information, and standard login information, such as your browser type and the pages you accessed. We also may collect certain geo-location information, time zone, language setting, and browser type. If you do not agree to our collection of this information, you may not be able to use our Services.

If you open an account, depending on the type of Services you use, the information we collect from you may include:

  • Identification & contact information – your name, street address, telephone number, email address, date of birth, your login and password details, and when required by law, your SSN (in whole or in part) or other potential governmental issued verification numbers;
  • Employment information – employer, title, income; and
  • Financial Information – bank account and routing numbers, virtual currency wallet information, and credit cards information linked to your VaultRunner account.
  • Under applicable “know-your-client” rules and other applicable federal and state regulations, we may collect any information necessary to confirm your identity, including background and credit reports.
  • For purposes of processing transactions, identity verification, fraud detection or prevention and other similar purposes, we also may link your machine ID with the machines of others who use your same payment cards.
  • Communications with us, such as emails, requests, chats, questions or comments, and any other communications you have with us by any means.
  • Social Web Information – including but not limited to your Facebook connect credentials (and information that you authorize Facebook share with us) and email account information. If you authorize Facebook Connect, the plug in allows us access to your friends’ contact information. We also allow you to import data from other social web services, including but not limited to Twitter, FourSquare, and email service providers. Social and e-mail contact information helps you connect to friends and contacts for invitation and payment transmission purposes (as well as helping us improve our services and fight fraud). Additionally, another VaultRunner user may mention you in a transaction in which you are not a party to by “tagging” your username in a transaction note. When you are mentioned in a transaction, a link to your profile will appear in the transaction note and you will receive a notification about the mentions. You may manage certain contact preferences and notifications in your account settings.

We are committed to providing a safe, secure and all around great service. Therefore, before permitting you to use our Services, we may require additional information from you we can use to verify your identity, address or other information or to manage risk and compliance throughout our relationship.

When you are using our Services, we collect information about your account transactions and trust relationships and we may collect information about your computer or other access device for fraud prevention and other similar purposes.

Finally, we may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team or store results when you respond to a survey and we may collect and use information for analytic purposes, market research or for marketing purposes, as allowed by law.

SOCIAL SECURITY NUMBER PRIVACY PROTECTION POLICY

In the event that we collect Social Security numbers as necessary to support state and federal legal requirements, to provide our Services, we restrict the access to Social Security numbers only to employees, agents, service providers, and government entities that require such access to meet these purposes. We strive to protect Social Security numbers from unlawful disclosure and keep them confidential by maintaining administrative, technical, and physical safeguards that comply with applicable state and federal regulations.

INFORMATION FROM CHILDREN

YOU MUST BE AT LEAST 18 IN ORDER TO USE OUR SERVICES. We do not knowingly solicit or collect information from any individuals under the age of 18. Visit the Federal Trade Commission website for more information on the Children’s Online Privacy Protection Act (COPPA).

2.        HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary purpose in collecting personal information is to offer you our Services and provide you with a safe, smooth, efficient, fun, customized and best experience. We may use your personal information to:

  • provide the products, services and customer support you request;
  • identify you and process your transactions and send you notices about your transactions or your network activity;
  • invoice, refund and manage your account;
  • resolve disputes, collect fees, and troubleshoot problems;
  • prevent potentially fraudulent, prohibited or illegal activities, and enforce our User Agreement;
  • customize, personalize, measure, and improve our Services and the content and layout of our application;
  • send you updates about new products and services that we are offering to our clients;
  • comply with legal requirements, including those imposed by laws and regulations, policies and procedures and court orders, including, but not limited to tax regulations, Anti-Money Laundering obligations, international electronic fund transfers regulations and reporting obligations;
  • compare information for accuracy and verify it with third parties; and
  • perform other duties as required by law.

3.        HOW WE SHARE PERSONAL INFORMATION WITHIN OUR NETWORK

To provide our Services, we need to share some of your personal information with the person or company that is processing the transaction, verifying your identity or the information you provided, and performing services such as shipping and/or storing your products. Your contact information, date of sign-up, the product or service you ordered and other verification metrics like social graph activity may be provided to users or companies when you transact with, on, or through VaultRunner.

We work with third party vendors to purchase, ship, and store the products, and enable payments from your use of our Services. In doing so, a vendor may share information about you with us, and we may share information with them. We use this information to confirm to that vendor that you are a VaultRunner customer and that the vendor should proceed with the order, shipping and/or storing and payment for your purchase of our products or services. In these circumstances, the personal information that the service provider receives is limited to the personal information it needs to provide such service.

We will not disclose your personal information to anyone else, except with your express permission or if we are required to do so to comply with a subpoena or other legal process. We may also disclose personal information without notice to prevent fraud or abuse, to protect the rights, property or safety of VaultRunner and/or its customers, employees, service providers or the public.

HOW THE INFORMATION IS SHARED WITH THIRD PARTIES

We do not share your personal information with third parties for promotional or marketing purposes. We will not sell, rent, loan or trade your personal information to anyone.

We may share the personal information we collect about you with third parties, such as companies performing services on our behalf to provide the products or services you have requested as provided in the paragraph above.

We may share aggregated, non-personally identifiable information about you with our affiliates and with non-affiliates for analysis, market research and marketing purposes as allowed by law.

When you broadcast information to third-party services, such information is no longer under our control and is subject to the terms of use and privacy policies of such third parties. We do not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so.

Finally, we may disclose your personal information to law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Service and Client Agreement, or as otherwise permitted or required by law.

4.        HOW WE PROTECT & STORE PERSONAL INFORMATION

We store and process your personal information using third party servers located in secure data centers in the United States. This information is protected by physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations. We also use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Additionally, companies that provide online services on our behalf are required by contract to protect our customer information and they are only allowed to use the information they collect for the purpose of providing the services that we have contracted to them.

We make all reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your password with anyone.

If we learn of a security breach, we may attempt post a notice on our site or notify you electronically so that you can take appropriate protective steps. By using our Services, you agree that we may communicate with you electronically. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach), send us an email at legal@vaultrunner.com.

FOR EU CITIZENS AND RESIDENTS

Your personal information may be transferred, processed and stored to companies, employees and servers located outside the European Union. By submitting your personal information thorough our Services, you agree to this processing, storing and transfer. We will retain your personal information for as long as you have an account with us and as required by law. If you wish to terminate your account, we will no longer use your personal information to provide you the Services but will retain copies and data necessary to comply with legal obligations, resolve disputes and enforce our agreements. To receive a copy of the personal information we have collected about you, contact us at legal@vaultrunner.com.

5.        COOKIES & OTHER TRACKING TECHNOLOGIES

When you access VaultRunner, we, may place small data files called “cookies” on your device. For example, we send a “session cookie” any time you log in to your VaultRunner account. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don’t need to ask you for your password on each page. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our Services.

We may also use Flash® objects (sometimes called “Local Shared Objects”) as part of our online authentication to help us recognize your device when you come back to our Services. We do not use Flash objects for any online behavioral advertising purpose.

The third parties we contract with may use cookies or other technologies to gather interest-based information to customize the ads you see. Neither us nor the third parties collects any personally identifiable information through these cookies. We may also use aggregate data to display ads or content that may interest you.

ADVERTISING

We may use device information, particularly in mobile advertising, to help deliver our ads and measure ad campaign effectiveness. We will not collect any personally identifiable information (PII) but may collect your device information when you visit one of our sites or see our ads. Compiling and comparing this information creates a unique ID for individual devices and can be “matched” to the same information on other sites or mobile applications. Some companies we work with are also able to associate related devices into households based on common characteristics, such as IP addresses.

6.        LINKS TO OTHER SITES AND PUBLIC FORUMS AND SOCIAL MEDIA

Public forums are available on our Services, and they may include text, photographs and videos that are accessible to the general public. Unless we tell you otherwise, any information you disclose in these areas may become public information.

We also provide experiences through social media sites such as Facebook, Twitter, LinkedIn and YouTube. Any and all information you share on these Social Media sites is visible to any visitor to these sites. Refer to each social media site for their Terms of Use and Privacy Policies.

The website may contain links to other sites. We do not control the information collection of sites that can be reached through links from our Services. We encourage our users to be aware when they are leaving VaultRunner and to read the privacy statements of any site that collects personally identifiable information.

You should use caution when deciding to disclose personal information in these areas.

7.        HOW YOU CAN ACCESS OR CHANGE YOUR PERSONAL INFORMATION

You can review and update your personal information in your account settings at any time by logging in to your account.

If you have questions about personal information you provided on our Services, please email us at legal@vaultrunner.com.

8.        CONTACT & CHANGES TO OUR PRIVACY POLICY

We are always improving and as our services evolve, we may occasionally update this Privacy Policy. If we modify this Privacy Policy, we will post the revised policy and revise the “last updated date” stated above. If we make material changes in the way we use personal information, we will notify you by posting an announcement on our Services or by sending you an e-mail. It is your responsibility to periodically review this Privacy Policy. Users are bound by any changes to the Privacy Policy by their continued use of our Services.

CONTACT US

If you have questions or concerns regarding this Privacy Policy, or any feedback pertaining to your privacy and our Services that you would like us to consider, please email us at legal@vaultrunner.com.