Privacy policy Privacy policy Privacy policy Virtual Vaults is dedicated to protecting the privacy of its users. Virtual Vaults complies with the rules and regulations of the European Union. 1. Personal Information For registration purposes, users are asked to provide Virtual Vaults with certain information. This may include a company name and your personal name, position with the company, mobile phone number and email address. If you do not provide this information to us, we cannot register you as a user. Once registered, the personal information we collect will include information relating to your use of the vault. Virtual Vaults will maintain this information in strict confidence. It will only use this information in connection with the operation of the vault service or to comply with rules and regulations of the European Union. Some sections of this website may also allow you to contact us by email or otherwise volunteer information about yourself, such as your name, email address and preferred means of communication. In addition to the above purposes, this information may be used and disclosed for the purpose of carrying out or responding to your requests and for other purposes outlined at the time that you provide the information. We may not be able to respond to an enquiry or to carry out other things without your personal information . Virtual Vaults blocks access to https://secure.virtualvaults.com by means of third party search engine “crawlers” (e.g. Google, Yahoo, etc.). Should the ownership of all or substantially all of the Virtual Vaults business change, your user information may then be transferred to the new owner so that the service can continue operations. In any such transfer of information, your user information will remain subject to the promises made in any pre-existing privacy policy. You can use the publicly accessible parts of the Virtual Vaults website (https://www. virtualvaults.com) without identifying yourself (see the section below on cookies for further information about the data that we collect in relation to website usage). However, where we collect personal information as described above, it is not practicable to transact with you on an anonymous basis or by means of a pseudonym. 2/4 Privacy policy 2. Use and Disclosure Virtual Vaults uses the personal information that you provide only for purposes that are consistent with the above reason for which you provided it (primary purpose) or for a related purpose (secondary purpose). In particular, registration information that you provide in connection with your application to be a vault participant will be disclosed to the registered administrator of the vault and other vault participants, and our vault provides the ability for registered users to communicate with each other, which may involve the disclosure of personal information to each other. We do not otherwise share your personal information with other organisations unless you give us your express consent, or where sharing is otherwise required or permitted by law. If we do disclose personal information to third parties, we will do so in accordance with the primary or secondary purpose. We do not disclose personal information to third parties for the purpose of allowing them to send marketing material to you. We generally hold your personal information in Europe. However, where the personal information relates to a vault, such personal information may be stored in the country where the administrator of your vault chooses to have the vault hosted. Some of the recipients to whom we disclose personal information may thus be located outside Europe, and users and administrators may be located in many different countries. It is therefore not practicable for us to identify the specific countries in which persons to whom we disclose your personal information may be located. 3. Security Virtual Vaults takes extensive security measures and uses a host of security technologies to protect personal information from loss and misuse and from unauthorised access, modification or disclosure. While we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us online, and individuals do so at their own risk. Virtual Vaults uses 256-bit SSL encryption on data transfer. Virtual Vaults takes all reasonable steps to ensure that sensitive information that it collects is only accessible by authorised persons. 3/4 Privacy policy 4. Changing your Information Virtual Vaults will not amend your personal information except at your direction or the direction of the registered administrator of the vault that you participate in. 5. Cookies Cookies are small data files that a website can place on a user’s hard drive to record aspects of that user’s experience of the website. These files allow the user to move quickly and easily around our site. They are used to identify a user’s session, providing information that the system uses to efficiently manage your use of the site. As a general rule, we do not link this information to a user’s personal details. However, we may link this information to personal details where a user has requested or downloaded content generated by Virtual Vaults. We do not pass this information on. 6. Updates and changes to this online Privacy Statement Your use of the Virtual Vaults website and of Virtual Vaults online vaults, and any disputes arising from it, are subject to this Privacy Policy as well as to our terms of use and all of our dispute resolution provisions including arbitration, limitation on damages and choice of law. Non-material changes and clarifications will take effect immediately, and material changes will take effect within 30 days of their posting on this site. We reserve the right to change our Privacy Policy and our terms of use at any time. We therefore recommend that you return to the website on a regular basis and read the information provided. 7. Accessing and correcting your information If you wish: • further information regarding this Online Privacy Statement, • to request access to or correction of any personal information we hold about you, or • to make a complaint about our handling of any personal information that we hold about you, then please contact us on [email protected] 4/4
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