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1   PRIVACY POLICY

This policy relates to the privacy of your information at Vaultavo. Vaultavo is committed to keeping your information private. By ‘your information’ we mean any information about you that you or third parties provide to us. This policy explains the principles that Vaultavo applies to the processing of personal information, the rights that you have pertaining to your personal information, what personal information is collected, why we are processing it and who we are sharing it with.

2   PRIVACY PRINCIPLES

Vaultavo is committed to safeguarding the privacy of your information in the following ways:

• We will only collect and use your information where we have lawful grounds and legitimate business reasons to do so;
• We will be transparent in our dealings with you and will tell you about how we will collect and use your information;
• If we have collected your information for a particular purpose, we will not use it for anything else unless you have been informed and, where relevant, your permission obtained;
• We will not ask for more information than we need for the purposes for which we are collecting it;
• We will update our records when you inform us that your details have changed;
• We will continue to review and assess the quality of our information;
• We will implement and adhere to information retention policies relating to your information, and will ensure that your information is securely disposed of at the end of the appropriate retention period;
• We will observe the rights granted to you under applicable privacy and data protection laws, and will ensure that queries relating to privacy issues are promptly and transparently dealt with;
• We will train our staff on their privacy obligations;
• We will ensure we have appropriate physical and technological security measures to protect your information regardless of where it is held;
• We will ensure that when we outsource any processes, the supplier has appropriate security measures in place and will contractually require them to comply with these privacy principles; and
• We will ensure that suitable safeguards are in place before personal information is transferred to other countries.

3   CONTACT US

If you have any questions about privacy at Vaultavo please contact us at: [email protected]

If you are a European resident and you believe that we have not adequately resolved any privacy issues, you have the right to contact your local supervisory authority.

4   YOUR RIGHTS

4.1 Right to be Informed

You have the right to be informed regarding what personal information is collected, why we are processing it and who we are sharing it with. In the most part, this information will be provided to you at the time that we establish a relationship with you by opening an account. This information will be supplemented by any additional specific communications that are necessary at that time or shortly thereafter. We will also publish our privacy policy on the Vaultavo website and this will be updated periodically.

4.2 Right of Access to Your Personal Data

You have the right to access information held about you. In order to exercise this right, you must complete a subject access request that should be submitted to [email protected]. Once received, Vaultavo will respond within 28 days confirming whether or not we are processing your personal data and will give you access to that data in electronic format. No fee will apply for such requests.

4.3 Right to Rectification of Your Personal Data

Vaultavo endeavors to ensure that all personal information is complete and accurate at all times. If, however, you determine that the personal information we hold about you is incomplete or inaccurate, you have the right to request correction of that personal information.

4.4 Right to Have Your Personal Data Erased

You have the right to be forgotten and can request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

4.5 Right to Restrict Processing of Your Personal Data

You have the right to request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

4.6 Right to Portability of Your Personal Data

You have the right to request the transfer of your personal information to another party in certain formats, if practicable. This allows you to obtain and reuse your personal data for your own purposes across different services.

4.7 Right to Object

You have the right to object to processing of your personal information where there is something about your particular situation which makes you want to object to processing. You also have the right to object where we are processing your personal information for direct marketing purposes.

You can at any time tell us not to send you marketing communications by e-mail by clicking on the unsubscribe link within any marketing e-mails you receive from us.

4.8 Right to Make a Complaint

If we fall short of your expectations in processing your personal information or you wish to make a complaint about our privacy practices, please tell us because it gives us an opportunity to fix the problem. You may contact us by submitted your complaint to [email protected]. To assist us in responding to your request, please give full details of the issue you wish us to address.

If you are a European resident and you believe that we have not adequately resolved any such issues, you have the right to contact your local supervisory authority.

5   PERSONAL INFORMATION THAT WE COLLECT

As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is being associated with an identified or reasonably identifiable individual.

Personal Information we collect from you

We may collect the following categories of Personal Information directly from you:

• Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number etc.);
• Commercial Information, such as trading activity, order activity, deposits, withdrawals, account balances;
• Financial Information, such as bank account information, routing number;
• Correspondence, such as information that you provide to us in correspondence, including account opening and customer support;
• Sensory Information, such as images collected for identity verification, audio recordings left on voicemail;
• Employment Information, such as job title, source of wealth; and
• Institutional Information, such as for institutional customers, we may collect additional information, including: institution’s legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government, and proof of legal existence (which may include articles of incorporation, certificate of formation, business license, trust instrument, or other comparable legal document).

Personal Information we collect automatically

We may collect the following categories of Personal Information automatically through your use of our services:

• Online Identifiers, such as IP address; domain name;
• Device Information, such as hardware, operating system, browser;
• Usage Data, such as system activity, internal and external information related to Vaultavo pages that you visit, clickstream information; and
• Geolocation Data.

Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail in section 11 below.

Personal Information we collect from third parties

We may collect and/or verify the following categories of Personal Information about you from Third Parties:

• Identification Information, such as name, email, phone number, postal address, government identification numbers (which may include Social Security Number or equivalent, driver’s license number, passport number);
• Financial Information, such as bank account information, routing number;
• Transaction Information, such as public blockchain data (bitcoin, ether, and other Digital Assets are not truly anonymous. We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you); and
• Additional Information, at the discretion of our Compliance Team to comply with legal obligations, which may include criminal records or alleged criminal activity.

Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned.

Accuracy and retention of Personal Information

We take reasonable and practicable steps to ensure that your Personal Information held by us (i) is accurate with regard to the purposes for which it is to be used, and (ii) is not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.

6   THE PURPOSES OF PROCESSING OF PERSONAL INFORMATION WE COLLECT AND LEGAL BASIS

Where the provision of personal data is a statutory requirement for purposes of Vaultavo meeting its obligations under applicable Anti- Money Laundering and Terrorist Financing Regulations; or other applicable regulations; or is a requirement necessary for Vaultavo to fulfill its contractual obligations, the possible consequences of failure to provide such data include Vaultavo terminating our relationship with you.

Processing personal data by Vaultavo for the purposes of preventing Money Laundering and Terrorist Financing is considered to be necessary for the exercise of (a) a function of a public nature in the public interest and (b) a function conferred by or under an enactment i.e. the relevant national money laundering regulations. Vaultavo will make no other use of such personal data unless (a) use of the data is permitted by or under an enactment other than the applicable National Money Laundering and Terrorist Financing Regulations, for example relevant National Payment Services Regulations; or (b) Vaultavo has obtained your express consent to the proposed use of the data.

Vaultavo does not process personal information in a manner that constitutes the existence of automated decision-making, including profiling.

We use the information we collect about you for the following purposes or in the following ways:

6.1 To Provide and Maintain Vaultavo Services

We use the information collected to deliver, maintain and provide better Vaultavo Services (including but not limited to processing transactions) and verify Users’ identities.

We use the IP address and unique identifiers stored in your device’s cookies to help us authenticate your identity and activities and provide Vaultavo Services. Given our legal obligations and system requirements, we cannot provide you with all or some of Vaultavo Services without data like Identification Information, Supervision Information, Service Usage Information, Communication Information, and Transaction Information.

6.2 To Protect Our Users

We use the information collected to protect our platforms, Users’ accounts, and archives.

We use IP addresses and cookies to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.

We analyze transaction activities with the goal of detecting suspicious behaviors as early as possible to prevent potential fraud and loss of funds or assets to bad actors.

6.3 To Comply with Legal and Regulatory Requirements

With respect to the privacy and security of personal information, we will use the information in compliance with our legal obligations, government requests, and reasonable user-generated inquiries. In cases where it is strictly necessary, such as to protect the vital interests of the Users or other natural persons, to fulfill the purpose of public interest, to pursue our reasonable interests (but not to damage the interests of the Users), we may process your personal information without your consent. Except for the situations stated in this Privacy Policy or the Terms and Conditions of Use, we will not disclose or provide any of your personal information to third parties without a review from our legal team and/or prior consent from the User.

6.4 For Measurement, Research and Development Purposes

We actively measure and analyze data to understand the way you use and interact with Vaultavo Services. This review activity is conducted by our operation teams to continually improve our Platforms’ performance and to resolve issues with the user experience. In addition, we use such information to customize, measure, and improve Vaultavo Services and the content and layout of our websites and apps, and to develop new services.

We continuously monitor activity information within our systems and our communications with users to look for and quickly fix problems.

6.5 To Communicate with You

We use personal information collected, like your phone number or email address to interact with you directly when providing customer support on a ticket or to keep you informed on logins, transactions, account security and other aspects. Without collecting and processing your personal information for confirming each communication, we will not be able to respond to your submitted requests, questions, and inquiries. All direct communications are properly kept at Vaultavo or the service provider designated by Vaultavo, to be reviewed for accuracy, to be kept as evidence, or to be used to perform other statutory or contractual obligations.

6.6 To Enforce Our Terms and Conditions of Use and Other Agreements

The collected information is also used to continually and actively enforce our terms and conditions of use and other agreements with our Users, including but not limited to reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate the foregoing provisions, or disclose the relevant information to a third party in accordance therewith.

The collected information is also used to continually and actively enforce our terms and conditions of use and other agreements with our Users, including but not limited to reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate the foregoing provisions, or disclose the relevant information to a third party in accordance therewith.

6.7 For Marketing and Advertising

We may share your personal information with our marketing partners for the purposes of targeting, modeling, and/or analytics as well as marketing and advertising.

6.8 For Rebates

We may share the information collected, including but not limited to your Identification Information and Transaction Information, with your referrer for the purposes of rebates and other benefits.

6.9 For Any Other Purpose

We may disclose your personal information for any other purpose you consent to. We may also use personal information in other lawful ways for which we will provide specific notice at the time of collection.

7   WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We will not sell personal information we collect about you.

We will not otherwise disclose personal information we collect about you, except as described in this Vaultavo Privacy Policy or as we disclose to you at the time the data is collected.

We share personal information with third party providers of due diligence and screening services in order to verify customer identity and manage exposures to money laundering and terrorist financing risks.

We share personal information with third party providers of transaction processing services and transaction monitoring services in order to process payment transactions and guard against exposures to fraud and money laundering and terrorist financing risks.

Where we share information with our service providers, who perform services on our behalf, we authorize these service providers to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements. We require these service providers under contract to safeguard the privacy and security of personal information they process on our behalf.

We may share personal information we collect with our affiliates.

We may disclose information about you (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, or (iii) in connection with an investigation of suspected or actual fraudulent or illegal activity.

8   INTERNATIONAL DATA TRANSFERS

To offer our services, we may need to transfer your personal information to affiliated entities in several countries. We use group Data Protection Policies and Procedures as a means of ensuring consistent Data Protection Standards are operational throughout all affiliated entities. We also provide adequate safeguards for the transfer of personal information to countries outside of the European Economic Area (“EEA”) by using standard enforceable clauses in any inter-company legal agreements that are compliant with the requirements of EEA Data Protection Regulations.

9   HOW LONG WE KEEP YOUR PERSONAL INFORMATION

Vaultavo stores personal information only for as long as it is necessary for the fulfillment of the purpose for which the personal information was collected, unless otherwise required or authorised by applicable law. We take measures to destroy or permanently de-identify personal information if required by law or if the personal information is no longer required for the purpose for which we collected it.

We will keep your personal information for as long as you are a customer of Vaultavo. After you stop being a customer, we may keep your data for up to 5 years for one of these reasons:

• To respond to any questions or complaints;
• To show that we treated you fairly; and
• To maintain records according to regulations that apply to us.

We may keep your data for longer than 5 years if we cannot delete it for legal, regulatory or technical reasons.

10  HOW WE HOLD AND PROTECT PERSONAL INFORMATION

The security of your personal information is important to Vaultavo. We are committed to protecting the information we collect. We maintain administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

11  COOKIES

We use cookies or similar technologies on this Site. Please refer to our Cookie Policy below for details.

Cookie Policy

By accessing the website(s) and any other platform or web or mobile app (“Site”) operated by Vaultavo and its group of companies (“Vaultavo”, “we”, “us” “our”), registering to receive our alerts or updates, corresponding with us and/and using our services, you agree to be bound by this cookie policy (“Cookie Policy”).

The Cookie Policy explains how Cookies are used on the Site. If you do not agree with this Cookie Policy you must discontinue the use of the Site and our services or opt out of our alerts and updates. This Cookie Policy may be updated from time to time, we recommend you review it on a regular basis.

A cookie and similar technologies such as local storage, web beacons, and pixel tags (“Cookie”) is a text file that is stored on your computer or other mobile devices for the purpose of gathering information about your use of the Site. Cookies are used to collect standard internet log information and visitor behavior information. When you visit Vaultavo, we can automatically collect information from you through cookies or similar technologies.

For more information, please visit: www.allaboutcookies.org

Vaultavo uses Cookies to improve user experience and statistical knowledge on its actual use. This can include but is not limited to pages you consult, menu choices, and any specific information you have entered the forms and the date and time of your visit.

Our Cookies do not collect or store your personal information (for example your name or address) so this information can’t be used to identify who you are.

Analytic Cookies are also used on Site to gather statistics about the use of the Site to improve the performance and design of our services. For these purposes, we use analytic Cookies to collect information like the number of visitors to the Site, where visitors have come to the Site from, etc.

How Do We Use Cookies?

We use cookies in a range of ways to make your experience on our Platforms more enjoyable, including but not limited to:

• to keep you signed in;
• to record your habits and preferences when browsing Vaultavo;
• to record our performance and verify the effectiveness of online advertising.

What Types of Cookies Do We Use?

We use different types of cookies, including but not limited to:

a. Functional Cookies

We use such cookies to help us identify you and remember your previous preferences and settings, which may include your device, your operating system, your preferred language, your location, and other session data. We use a mix of first-party and third-party cookies.

b. Marketing Cookies

We use these cookies to collect information about your visit to Vaultavo, the content you view, the links you follow, and other information about your browsers, devices, your IP addresses and referral URLs. We sometimes share certain parts of the collected information with third parties for marketing purposes. We may also share online data collected through cookies with our marketing partners. This means that when you visit another website, you may also be shown advertisements based on your browsing patterns on Vaultavo.

How you can manage your cookie?

Please note that most web browsers accept Cookies automatically. You can change setting of your browser to not save any or certain Cookie on your device or to always display a warning before receiving a new Cookie. If Cookies are disabled, however, you may experience reduced functionality on the Site.

Third party websites

This Site might provide third party links to you for informational purposes, the operators of these websites will use cookies in accordance with their own cookie policy, which may differ from ours. You can manage third party cookies through your browser settings.

12  UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on relevant websites to notify you of any significant changes to our Privacy Policy and indicate at the top of the Policy when it was most recently updated. If we update our Privacy Policy, in certain circumstances, we may seek your consent.