Resources
supporting mass
adoption of crypto
The $200 trillion fiat sector is entering the escalating $3 trillion crypto market, with many of the major banks jumping into crypto; Wall Street banks are on a crypto hiring spree, Citigroup expects most of the large banks to enter in the next three years, and Visa initiated their pilot program to make life easier for cryptocurrency businesses. Visa aims, among others, to eliminate any hurdles for customers looking to convert their cryptocurrency holdings to fiat. The opportunities within crypto asset management are increasing exponentially – for mass acceptance, the customer needs to be able to trust providers and technology, while being able to access and use their assets with the same ease as a regular bank card. As the world’s first biometric compliant digital asset custody smartcard, the Vaultavo Crypto Custody Solution does just that.
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.
WEBSITE TERMS OF USE
This website www.vaultavo.com (hereinafter referred to as “Website” ), is provided by xxx (hereinafter referred to as “Our” , “Us” or “We” ). We provide you access to the use and/or visitation of the Website subject to the terms of use as set forth in this document (hereinafter referred to as “Terms” ). xxx forms part of the group of companies representing the ‘vaultavo’ brand as published on the Website.
Headings used in this document are all for reference only and shall be ignored in construing these Terms.
1 ACCEPTANCE OF THE TERMS
By using and/or visiting the Website, you confirm that you accept these Terms and that you agree to comply with these Terms. In the event where you do not agree with these Terms in full, you should immediately cease using the Website.
2 OTHER TERMS AND CONDITIONS
You acknowledge that: the Privacy Policy as displayed on the Website also applies to your use and/or visitation of the Website; and you have read, understand and agreed to the content of said Privacy Policy, then you should not further use the Website
In the event where you elect to use any of the services provided from the Website, then the relevant agreement and related terms and conditions as published on the Website will apply accordingly in relation to the specific part of the services that you may elect to utilise.
3 CHANGES TO THESE TERMS
We reserve the right to amend these Terms from time to time. Every time you wish to use the Website, you are advised to check the then current Terms to ensure you understand the Terms as they apply at that time.
4 UPDATE, CHANGE, SUSPENSION AND WITHDRAWAL
We reserve the right to update and change our Website from time to time to reflect changes in relation to the products/services made available through the Website, Website users’ needs, the ‘ vaultavo ’ group’s business priorities and/or any regulatory changes.
We may change the content of this Website at any time without notice and without any liability.
We take reasonable care to ensure that the website is kept up to date.
Without derogating from the generality of any of the other provisions under these Terms, We reserve the right to suspend, withdraw and/or restrict the availability of all or any part of the Website for business and operational reasons and We will where reasonably required, endeavour to give reasonable notice of any such suspension or withdrawal.
5 NO WARRANTY
We provide this Website and its contents on an “as is” and an “as available” basis without any representation or endorsement made and without warranty of any kind whether express or implied, including but not limited to the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy. In no event will We be liable for any damages including, without limitation, loss of profits, loss of sales, loss of business, loss of revenue, loss of data, business interruption, indirect or consequential damages, or any other damages whatsoever arising from or in connection with the use of the Website or loss of use suffered by you, whether in action of contract, negligence or other tortuous action, arising out of or in connection with the use of, or inability to use the Website, or reliance on any content displayed on our Website.
We make no warranty or representation that the Website, or any content on it, will always be: available; uninterrupted; full functionality, fully accurate, fully reliable in relation to information provided, and/or free of viruses or similar.
6 LAWFUL USE OF THE WEBSITE
You expressly acknowledge that you may only use the Website for lawful purposes, and not use the Website in any manner that infringes the rights of, restricts and/or inhibits the use and enjoyment of the Website by any third party. The aforesaid restriction or inhibition includes, without limitation, any conduct which is unlawful, which may harass or cause distress or inconvenience to any person and/or entail the transmission of any obscene or any offensive material within this Website.
7 COPYRIGHTS
All Website design, names, images, text, graphics, logo and the arrangement thereof are owned by or licensed to Us or otherwise used by Us as permitted by applicable law. Nothing contained herein shall be construed as conferring by implication, or otherwise on you any licence or any right to any of the above referred Website design, names, images, text, graphics, logo and the arrangement thereof.
By using the Website, you agree that you will not copy, store in any medium (including in any other website, but except for short term caching of web-pages on your local computer), distribute, transmit, re-transmit, broadcast, modify, or show in public any part of the Website without prior written permission from Us or in accordance with applicable copyright, designs and patents laws.
The material contained in the Website must not be copied, reproduced, republished, downloaded, posted, broadcast or transmitted in any way except for your own personal non-commercial home use. Any other use requires Our prior written consent.
You hereby agree that when using the Website you shall not in any manner adapt, alter, copy, reproduce, recompile, decompile, disassemble, reverse engineer or create a derivative work from any of the material contained in the Website or use it for any other purpose, than was intended.
8 INDEMNITY
You agree to indemnify, defend and hold harmless Us, as well as Our employees, representatives and agents from and against any claims, actions demands or other proceedings brought against Us and/or against any of Our employees, Our representatives or Our agents, by a third party, to the extent that such claim, suit action, or other proceeding brought against Us and/or against any of Our employees, Our representatives or Our agents is based on or arises in connections with any of the following:
- your use or visitation of the Website;
- any breach by you of these Terms;
- a claim that any use or visitation of the Website by you: infringes any intellectual property rights of any third party; or infringes any right of personality or publicity; or is false or defamatory, or otherwise results in injury or damage to any third party;
- any deletions, additions, insertions, or alterations to, or any unauthorised use of the Website by you; or
- any misrepresentation or breach of representation or warranty made by you contained under these Terms.
References in this section of the Terms to your use of the Website shall be deemed to include any use by a third party where such third party accesses the Website using your computer.
9 WAIVER
No waiver by Us of any breach of any obligation arising under these Terms shall constitute a waiver of any other breach and no failure to exercise or to partially exercise by Us of any remedy shall constitute a waiver of the right subsequently to exercise that or any other remedy.
10 LOCAL LAWS AND REGULATIONS
The Website is not for use by any person in any jurisdiction where for any reason the publication or availability of the Website or its content is prohibited. You hereby acknowledge that We do not represent that either the Website or its content are appropriate for use or permitted by all local laws in all jurisdictions. Those who access the Website do so on their own initiative and are responsible for compliance with applicable local laws or regulations. In the event of any doubt the user should seek suitable legal advice.
11 NO CONFLICT
If there is a conflict between these Terms and any other rules and/or specific terms and conditions appearing on this Website relating to specific material, products and/or services, then the latter shall prevail. In the event where any of these Terms should be determined to be illegal, invalid or otherwise unenforceable by reason of the laws of any state or country in which these Terms are intended to apply, then to the extent and within the jurisdiction which such term or condition of these Terms is illegal, invalid or unenforceable, it shall be severed and deleted from these Terms and the remaining terms and conditions under these Terms shall survive, remain in full force and effect and continue to be binding and enforceable.
12 GOVERNING LAW AND JURISDICTION
Unless expressly provided otherwise pursuant to any other agreement that you may conclude with any entity representing the ‘ vaultavo ’ brand in relation to any part of the services made available on the Website, these Terms: shall be governed by and construed in accordance with the laws of the Republic of Singapore (hereinafter referred to a “ Singapore ”); and the courts of Singapore are to have exclusive jurisdiction to settle any disputes arising out of or in connection with the use or visitation of Website.
supporting mass
adoption of crypto
The $200 trillion fiat sector is entering the escalating $3 trillion crypto market, with many of the major banks jumping into crypto; Wall Street banks are on a crypto hiring spree, Citigroup expects most of the large banks to enter in the next three years, and Visa initiated their pilot program to make life easier for cryptocurrency businesses. Visa aims, among others, to eliminate any hurdles for customers looking to convert their cryptocurrency holdings to fiat. The opportunities within crypto asset management are increasing exponentially – for mass acceptance, the customer needs to be able to trust providers and technology, while being able to access and use their assets with the same ease as a regular bank card. As the world’s first biometric compliant digital asset custody smartcard, the Vaultavo Crypto Custody Solution does just that.
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.
WEBSITE TERMS OF USE
This website www.vaultavo.com (hereinafter referred to as “Website” ), is provided by xxx (hereinafter referred to as “Our” , “Us” or “We” ). We provide you access to the use and/or visitation of the Website subject to the terms of use as set forth in this document (hereinafter referred to as “Terms” ). xxx forms part of the group of companies representing the ‘vaultavo’ brand as published on the Website.
Headings used in this document are all for reference only and shall be ignored in construing these Terms.
1 ACCEPTANCE OF THE TERMS
By using and/or visiting the Website, you confirm that you accept these Terms and that you agree to comply with these Terms. In the event where you do not agree with these Terms in full, you should immediately cease using the Website.
2 OTHER TERMS AND CONDITIONS
You acknowledge that: the Privacy Policy as displayed on the Website also applies to your use and/or visitation of the Website; and you have read, understand and agreed to the content of said Privacy Policy, then you should not further use the Website
In the event where you elect to use any of the services provided from the Website, then the relevant agreement and related terms and conditions as published on the Website will apply accordingly in relation to the specific part of the services that you may elect to utilise.
3 CHANGES TO THESE TERMS
We reserve the right to amend these Terms from time to time. Every time you wish to use the Website, you are advised to check the then current Terms to ensure you understand the Terms as they apply at that time.
4 UPDATE, CHANGE, SUSPENSION AND WITHDRAWAL
We reserve the right to update and change our Website from time to time to reflect changes in relation to the products/services made available through the Website, Website users’ needs, the ‘ vaultavo ’ group’s business priorities and/or any regulatory changes.
We may change the content of this Website at any time without notice and without any liability.
We take reasonable care to ensure that the website is kept up to date.
Without derogating from the generality of any of the other provisions under these Terms, We reserve the right to suspend, withdraw and/or restrict the availability of all or any part of the Website for business and operational reasons and We will where reasonably required, endeavour to give reasonable notice of any such suspension or withdrawal.
5 NO WARRANTY
We provide this Website and its contents on an “as is” and an “as available” basis without any representation or endorsement made and without warranty of any kind whether express or implied, including but not limited to the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy. In no event will We be liable for any damages including, without limitation, loss of profits, loss of sales, loss of business, loss of revenue, loss of data, business interruption, indirect or consequential damages, or any other damages whatsoever arising from or in connection with the use of the Website or loss of use suffered by you, whether in action of contract, negligence or other tortuous action, arising out of or in connection with the use of, or inability to use the Website, or reliance on any content displayed on our Website.
We make no warranty or representation that the Website, or any content on it, will always be: available; uninterrupted; full functionality, fully accurate, fully reliable in relation to information provided, and/or free of viruses or similar.
6 LAWFUL USE OF THE WEBSITE
You expressly acknowledge that you may only use the Website for lawful purposes, and not use the Website in any manner that infringes the rights of, restricts and/or inhibits the use and enjoyment of the Website by any third party. The aforesaid restriction or inhibition includes, without limitation, any conduct which is unlawful, which may harass or cause distress or inconvenience to any person and/or entail the transmission of any obscene or any offensive material within this Website.
7 COPYRIGHTS
All Website design, names, images, text, graphics, logo and the arrangement thereof are owned by or licensed to Us or otherwise used by Us as permitted by applicable law. Nothing contained herein shall be construed as conferring by implication, or otherwise on you any licence or any right to any of the above referred Website design, names, images, text, graphics, logo and the arrangement thereof.
By using the Website, you agree that you will not copy, store in any medium (including in any other website, but except for short term caching of web-pages on your local computer), distribute, transmit, re-transmit, broadcast, modify, or show in public any part of the Website without prior written permission from Us or in accordance with applicable copyright, designs and patents laws.
The material contained in the Website must not be copied, reproduced, republished, downloaded, posted, broadcast or transmitted in any way except for your own personal non-commercial home use. Any other use requires Our prior written consent.
You hereby agree that when using the Website you shall not in any manner adapt, alter, copy, reproduce, recompile, decompile, disassemble, reverse engineer or create a derivative work from any of the material contained in the Website or use it for any other purpose, than was intended.
8 INDEMNITY
You agree to indemnify, defend and hold harmless Us, as well as Our employees, representatives and agents from and against any claims, actions demands or other proceedings brought against Us and/or against any of Our employees, Our representatives or Our agents, by a third party, to the extent that such claim, suit action, or other proceeding brought against Us and/or against any of Our employees, Our representatives or Our agents is based on or arises in connections with any of the following:
- your use or visitation of the Website;
- any breach by you of these Terms;
- a claim that any use or visitation of the Website by you: infringes any intellectual property rights of any third party; or infringes any right of personality or publicity; or is false or defamatory, or otherwise results in injury or damage to any third party;
- any deletions, additions, insertions, or alterations to, or any unauthorised use of the Website by you; or
- any misrepresentation or breach of representation or warranty made by you contained under these Terms.
References in this section of the Terms to your use of the Website shall be deemed to include any use by a third party where such third party accesses the Website using your computer.
9 WAIVER
No waiver by Us of any breach of any obligation arising under these Terms shall constitute a waiver of any other breach and no failure to exercise or to partially exercise by Us of any remedy shall constitute a waiver of the right subsequently to exercise that or any other remedy.
10 LOCAL LAWS AND REGULATIONS
The Website is not for use by any person in any jurisdiction where for any reason the publication or availability of the Website or its content is prohibited. You hereby acknowledge that We do not represent that either the Website or its content are appropriate for use or permitted by all local laws in all jurisdictions. Those who access the Website do so on their own initiative and are responsible for compliance with applicable local laws or regulations. In the event of any doubt the user should seek suitable legal advice.
11 NO CONFLICT
If there is a conflict between these Terms and any other rules and/or specific terms and conditions appearing on this Website relating to specific material, products and/or services, then the latter shall prevail. In the event where any of these Terms should be determined to be illegal, invalid or otherwise unenforceable by reason of the laws of any state or country in which these Terms are intended to apply, then to the extent and within the jurisdiction which such term or condition of these Terms is illegal, invalid or unenforceable, it shall be severed and deleted from these Terms and the remaining terms and conditions under these Terms shall survive, remain in full force and effect and continue to be binding and enforceable.
12 GOVERNING LAW AND JURISDICTION
Unless expressly provided otherwise pursuant to any other agreement that you may conclude with any entity representing the ‘ vaultavo ’ brand in relation to any part of the services made available on the Website, these Terms: shall be governed by and construed in accordance with the laws of the Republic of Singapore (hereinafter referred to a “ Singapore ”); and the courts of Singapore are to have exclusive jurisdiction to settle any disputes arising out of or in connection with the use or visitation of Website.