Privacy Policy

What does this Privacy Policy Cover?

Vault respects your privacy and is committed to protecting your personal data. We want to be transparent with you about how we collect and use your personal data in making available our website(s) (including the site located at: www.vaultplatform.com and tell you about your privacy rights and how the law protects you.

This Privacy Policy does NOT cover the Vault Platform SaaS solution for misconduct reporting. With that in mind, this Privacy Policy is designed to describe:

This Privacy Policy aims to give you information on how and why Vault collects and processes your personal data through your use of this Site, including any data you may provide through this Site or other online forms we publish. We will post any modifications or changes to this Privacy Policy on this page. The effective date of the current Privacy Policy is noted at the bottom of this page.

Who we are and how to contact us

Vault Platform Ltd. is registered in England and Wales under company number 11156964.

Vault Platform Ltd. is the Controller and responsible for processing your personal data (referred to as either “Vault”, “we”, “us” or “our” in this Privacy Policy) for this Site. Our office address is: 54 Poland Street, London, W1F 7NJ, United Kingdom.

How to contact us

You can contact us by emailing: privacy@vaultplatform.com

For EU Residents: Please contact our EU Representative at EUrep@vaultplatform.com. Alternatively, they can be reached by post (The DPO Centre, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2) or +353 1 631 9460. www.dpocentre.com/

Your rights relating to your personal data

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data. This right exists where we are relying on a Legitimate Interest (or those of a third party) as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data in the following scenarios  (i) if you want us to establish its accuracy ; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your personal data (“Consent Withdrawal”). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details shown here.

Typically, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your personal data, please contact us at: privacy@vaultplatform.com

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right at any time to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

What personal data we collect

Personal data means any information about an individual from which that person can be identified. It may not include data where the identity has been removed (anonymous data).

All the personal data we may collect, use, store and transfer both from you and from third parties about you, is outlined in the table below.

Category of personal data collected What this means
Identity Data Includes first name, surname, maiden name, last name, username or similar identifier, title and gender.
Contact Data Includes work address, billing address, email address and telephone numbers.
Marketing and Communications Data Includes your preferences in receiving marketing from us and our third parties and your communication preferences, including any information you provide in any online form through this Site or other online forms we publish.
Profile Data Includes your interests, preferences and feedback.
Usage Data Includes information relating to how you use our Site
Technical Data Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site or use our services.

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data, but once in aggregated form it will not constitute considered personal data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

No Special Categories of personal data

We do not collect any “Special Categories of personal data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we collect your personal data

Different methods are used to collect data from and about you including:

Direct interactions. You may give us your Identity and Contact Data by filling in forms or providing other information via our Site or other online forms we publish. This includes personal data you provide when you request our services; subscribe to our email newsletters or publications; request marketing to be sent to you; or give us some feedback.

Third parties or publicly available sources. We may receive personal data about you from third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google based outside the UK and the European Economic Area (“Europe”).
  • Identity and Profile Data from sales providers such as Hubspot, Appollo and Zoominfo based outside the UK and Europe.
  • Our social media pages on LinkedIn, Twitter and Facebook.

Automated technologies or interactions. As you interact with our Site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

Generally, we do not rely on your Consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by
contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format a description of the purposes and ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose and usage Type of data  Lawful basis
Account creation which include registering you as a new customer.
  • Identity Data
  • Contact Data 
 Contractual Necessity.
Administer and protect our business and Site (such as testing and troubleshooting, data analysis, system maintenance and support, data reporting and hosting
  • Identity Data
  • Contact Data 
  • Technical Data
 Legitimate Interests for running our business and systems and fraud prevention.
Deliver relevant Site content and advertisements, measure and assessing their effectiveness
  • Identity Data
  • Contact Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Technical Data
 Legitimate Interests to study how our Site is used, to develop and grow our business and to inform our marketing strategy.
Use data analytics to improve our Site, products/services, marketing, client relationships and experiences
  • Usage Data
  • Technical Data
 Legitimate Interests to define types of usage for our products/services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy.
To assess what we think you may want, need, or be interested in, to decide which services and offers may be relevant for you.
  • Identity Data
  • Contact Data
  • Usage Data
  • Technical Data
  • Marketing and Communications Data
 Legitimate Interests to develop our products/services and grow our business by providing updates on our Site and related offers.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising

We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products/services and offers may be relevant for you (marketing).

You will receive marketing communications from us if you have requested information from us or received services from us and, in each case, you have not opted out of receiving that marketing.

We may share information with third-party partners for the purposes of hosting events.  Outside of hosting events, we will get your express opt-in consent before we share your personal data with any company outside Vault for marketing purposes.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at marketing@vaultplatform.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the services provided to you.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

What happens when you do not provide necessary personal data?

Where we need to collect your personal data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you from using our Site but we will notify you if this is the case at the time.

To learn about how we use cookies, please see our Cookies Policy.

Who we share your personal data with

In this section, we describe who we may share your personal data with, what we share and why we share it.

  • We share your personal data internally within the Vault Platform group of companies acting as processors and who are based in the United States and Israel and help us provide our services and manage our customer relationships, including providing customer support, customer liaison, sales administration etc. This will involve transferring your data outside of Europe. This may include third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
  • We may share your personal data with third-party partners for the purposes of hosting events. 
  • Some of our external third parties acting as processors for IT service, system admin and support as well as sales administration service and advisors or investors are based outside Europe, so their processing of your personal data will involve a transfer of data outside of Europe.

We require third parties to whom we provide your personal data to hold it subject to appropriate safeguards and controls and to treat it in accordance with the law. We do not allow those third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Whenever we transfer your personal data out of UK and Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use service providers outside Europe, we may use specific contracts approved by the UK Government or the European Commission, which give personal data the same protection it has in the UK and Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and Europe.

How we keep your personal data secure

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your personal data to those employees and contractors and other third parties who have a business need to know. All such people will only process your personal data on our instructions and are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify any applicable regulators and you of a breach where we are legally required to do so.

How long we store your personal data

We will only retain your personal data for so long as necessary to fulfil the purposes set out above , unless a longer retention period is required by law (for example for regulatory purposes).

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure of your personal data above for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Our policy on children

This Site is not intended or structured to attract anyone below 16 and we do not knowingly collect data relating to such children. Parents and guardians should supervise their children’s activities at all times.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

Vault Platform Ltd., December 2022