Privacy Policy of the iVAULT^TM App

This Privacy Policy regulates what data Vault Security Systems AG (hereinafter “iVAULT”) of Rüschlikon, Switzerland, collects, uses, stores or otherwise processes when you use the iVAULT App.

Your privacy is important to us. Please read this Privacy Policy together with our Terms of Use, which includes further guidance on the use of the iVAULT App.

This Privacy Policy applies to the use of the iVAULT App. If you access or are directed to other websites, apps or other services through our app, it is also possible that these other tools may  collect your data. This is beyond iVAULT’s control and separate privacy policies apply to these other tools. iVAULT is not responsible for the data use by other companies, website, apps or other tools.

If you do not agree with this Privacy Policy, you should not use our iVAULT App.

Data Protection Officer

iVAULT designates the following company (hereinafter also referred to as “we” or “us”), which is responsible for the use of your data (“the Officer”):

Vault Security Systrems AG Zürcherstrasse 66 8800 Thalwi Switzerland

The party responsible for using your data differs depending on where you live:

For users from the United States, iVAULT Corp is responsible.

For iVAULT users outside the United States and in particular in connection with the assertion of rights under the EU General Data Protection Regulation, Vault Security Systems AG is responsible:

Vault Security Systems AG
Zürcherstrasse 66
8800 Thalwi
Switzerland

As data protection representative and additional point of contact for iVAULT users in the European Union according to Art. 27 DSGVO applies:

VGS Datenschutzpartner UG
Am Kaiserkai 69
20457 Hamburg
Germany

We are available to all iVAULT users via the App or by email at support@ivault.app.

Principles

For iVAULT, users are our top priority. It is our concern for iVAULT users to know what data is collected from them and how it is used.

Collection of User Data

When using the iVAULT app, personal data is requested and collected. The purpose of data collection is iVAULT’s interest in being able to continuously improve our services and to enable users to make the best possible use of the iVAULT app. In addition, we collect data when we are required to do so for the fulfillment of our Terms of Use. Without this data, we cannot guarantee that all offered services will be available to you.

The iVAULT™ App uses the app performance and analysis technology “adjust”, a service provided by adjust GmbH (“Adjust”). When you launch the iVAULT™ App, Adjust collects install and event data from the iOS and the iVAULT™ app in order to help us understand how our users are interacting with the iVAULT™ app and to optimize and analyze mobile ad campaigns. For such analysis, adjust uses your IDFA or Google Play Services ID, and your anonymized (hashed) IP- and MAC address. The hashes used are one-way hashes and it is not possible to identify you or your mobile device individually.  Your data will be transferred transnationally. The legal basis for the processing is based on Art. 6 para. 1 f) GDPR. The legitimate interest lies in the analysis and improvement of our mobile advertising campaigns.

If you refuse to be tracked by adjust, please contact support@ivault.app or our data protection officer.

When opening an iVAULT account (registration), you agree to register with true information about yourself. Therefore, your true personal data is collected. During the registration process, depending on the type of registration, we generally collect the following data: Your e-mail address as well as your name. In addition, you may be asked to choose a password to protect your account.

If you wish, you can also provide the following additional information: profile pictures, phone number and / or home address.

If you store items in your vault, you can specify associated data, such as a description of the item, its location or specific identifiers (e.g. serial number).

When you communicate with iVAULT or other iVAULT users, comment on or share their posts, we generally collect anonymous data on user behavior as well as on the functionality of the app. Should it be necessary for authorities, law or enforcement measures (e.g. verification of rules to be followed), the anonymity can be lifted.

Automatic Data Collection

The following data is collected automatically when you use the iVAULT App. Basically, this data collection can also take place via automated services:

Usage:

How you use the iVAULT App (including duration and frequency), how you log in, which posts you share or comment on, are collected.

Registration:

Data collected includes your login (which may include third-party links), Internet Protocol addresses, time of login and usage, and device characteristics.

Cookies:

The iVAULT app does not use cookies. However, it is possible that you will be redirected via our apps to other websites that use cookies. The data collected via such cookies is not stored by iVAULT.

Location data:

If you want to be informed about certain circumstances in your environment, you give us access to your location data. You can revoke access to location data at any time in the settings of your personal electronic device.

Device used:

We collect certain data about your personal electronic device, such as the device data, the IP address used and device IDs.

Software development kits:

Software development kits can be used to optimize the app. These are not managed by third parties and there is no exchange of user information with third parties.

Collection of Data from Other Sources

When logging in to iVAULT via third-party providers, Facebook, Apple or Google, you allow us to verify your identity. In doing so, you allow us to receive your data in accordance with the privacy policies of these companies. For this purpose, you allow us to exchange data with the third-party provider.

In this case, the third-party provider asks you to pass on the following data, if it is stored: Your name, your e-mail address and your profile picture. If you have registered via the third-party provider by mistake, you can delete your account at any time. To do so, please contact iVAULT directly.

Data Use for the Optimization of iVAULT Services

We use the collected data – according to your settings – to improve and optimize our services. In this way, we want to be able to offer you an optimal use of our services, further develop our offer and implement any new services.

• Your login information is collected and verified to identify you and to determine whether or not your account is being used by a third party.
• When you share posts, comment, or otherwise interact on our app, your legitimacy is verified.
• During the use of the app, we collect data about the functioning of the app in order to be able to check whether the operation is working properly and, if necessary, to evaluate error messages or crashes and to further develop the app.
• For in-app purchases via Apple Pay or Google Pay, a data exchange between iVAULT and Apple Pay or Google Pay takes place so that the payment can be processed. Thereby it may be necessary that iVAULT transmits your personal data. For in-app purchases via Google Pay or Apple Pay, these companies have access to your login data if it is required for payment processing. IVAULT does not receive access to your bank data. In this context, please also note the privacy policy and terms of use of Apple Pay or Google Pay.
• If you have provided your email address as a means of communication with iVAULT, your email address will be used to send you current information, including updates to our terms and policies. Also, in this case, we will correspond with you via your provided email address.

Data Use for the Protection of iVAULT Users

We verify your login information to ensure that no third parties have unwanted access to your account.

With the collected data, we control that no suspicious activities are made in order to prevent fraud, spam and other unwanted actions.

We further verify that there are no violations of applicable laws, our terms and policies, or other regulations that must be followed.

Which Data is Passed On and to Whom

It is important to us that we do not sell or share your information with third parties without informing users and obtaining your consent.

If you register with iVAULT using your Facebook, Google or Apple account, iVAULT will get access to the data stored there as part of your registration. No further data exchange takes place.

When you post, comment or correspond with other iVAULT users, you share your account information with those iVAULT users on a limited basis. As a result, those users with whom you interact will learn about your account name. Your email address will not be disclosed. What other data is disclosed through your activity depends on your settings. For example, if you have stored a profile picture and marked it as public, your profile picture will be displayed in comments or your posts.

In connection with in-app purchases, a limited exchange of data with Apple or Google Pay takes place in order to complete your transaction. This exchange is limited to the processing of the transaction.

It is possible that we are obliged or required to hand over your data to the authorities or responsible persons as part of legal or official proceedings or based on other legal situations. Such a release of data is possible, for example, if we are called upon to do so in the context of criminal proceedings or if we have to defend claims asserted against us in judicial or official proceedings. We may also be required to disclose your information to enforce our terms or policies or to protect IVAULT or our employees.

If we conclude that our rights or the rights of our employees, other iVAULT users or the public are affected and defense or protective measures need to be taken, we may also disclose your information.

Within the iVAULTTM Group, an exchange of your data takes place, which also affects personal data. Due to the international nature of iVAULTTM, your data may also be exchanged worldwide within iVAULT. Basically, data is processed and exchanged anonymously. Personal data is only shared anonymously. Related data, such as location, device data or usage time, are generally collected and processed and shared without reference to personal data.

The internal data exchange takes place on an anonymous basis. This exchange is intended to serve an optimization and improvement of the app, its functions and offers. If required by authorities, law or enforcement measures, personal data may also be exchanged, for example to ensure the complete deletion of your data.

iVAULT uses external contractual partners for certain tasks. Such contractors are generally not granted access to personal data without the consent of the authorized person. They may have access to anonymized information, such as general user behavior or reports on app error messages.

If iVAULT decides to discontinue its services, you will be informed and your data will be deleted. In this case, your data will not be passed on. A transfer of your data is possible in case iVAULT makes a change in its corporate structures, such as mergers or acquisitions. In this context, your data deposited with iVAULT would be passed on or exchanged.

Your Options for Selection and Control

It is our desire that iVAULT users are able to decide as individually as possible which data they want to share with us.

When you post or comment on a post, certain data is disclosed, namely your name. What other data is disclosed by your activity depends on your settings. For example, if you have stored a profile picture and marked it as public, your profile picture will be displayed in comments or your posts.

In your personal iVAULT account, you can delete your profile picture, your location data as well as your shared posts at any time.

You can delete your iVAULT account at any time. To ensure complete deletion of all data deposited with iVAULT, contact iVault via the app.

Notifications are possible via email or through the message center of your personal electronic device, and email notification can be disabled at any time. We reserve the right to notify you about important updates as well as urgent information about your account or activity if it is essential.

You can restrict data collection via your personal electronic device, for example by not granting iVAULT access to your location data.

Security

iVAULT takes all reasonable security measures to prevent unauthorized intrusion into the data deposited with iVAULT. For this purpose, internal and also external audits are carried out in particular. Identified security gaps are closed as quickly as possible.

iVAULT users know that communication over an internet connection is not absolutely secure. Data reaching the iVAULT servers is protected on these servers.

Children

Use of the iVAULT App is not intended for children. Use of the App is not permitted for persons in the United States under the age of thirteen (13), persons to whom the EU General Data Protection Regulation applies under the age of sixteen (16), and they may not legitimately register for an iVAULT account. iVAULT does not knowingly collect data from individuals in the United States who are not at least thirteen (13) years of age. iVAULT does not knowingly collect data from individuals to whom the EU General Data Protection Regulation applies who are not at least sixteen (16) years of age.

If children register with iVAULT without the consent of their parents or legal guardians and registration is not permitted under applicable regulations, the parents or legal guardians should contact us.

If we learn that children are using our services without permission, we will delete their account with all data. In this case, we may be forced, in accordance with applicable regulations, to contact other persons or authorities (e.g. parents or guardians) and pass on your data.

Please note that your country may have different regulations regarding the use of our app. It is your responsibility to comply with any applicable regulations or policies.

EU Data Protection Rights

iVAULT users who invoke the EU General Data Protection Regulation can exercise rights either by contacting iVAULT via the iVAULT App or via support@ivault.app. If you wish to exercise your rights, we may require you to prove your identity before we can process your request or take further action.

Information and disclosure:

If you wish to exercise your right to information and access to the data being processed, contact iVAULT directly.

Right of rectification:

You can check the accuracy of saved data yourself in your account settings and adjust it if necessary. If the adjustment is not possible, contact us directly.

Right to deletion (“being forgotten”):

The EU General Data Protection Regulation gives you the right to have your stored data deleted under certain circumstances. iVAULT supports by the fact that you can request that your account including your data be deleted at any time and without giving reasons. Should you wish to delete your account, please contact iVAULT directly.

iVAULT generally stores your data during the time you have an iVAULT account. However, iVAULT may store your data longer if we are required to do so by law or due to legitimate interests. A legitimate interest on our part is, for example, to protect our services from fraud or abuse.

Right to restriction of processing:

You may have the right to prohibit the processing of your data. If you wish to exercise such a right, notify us directly. In this case, iVAULT will refrain from processing your data.

Notification requirements:

iVAULT may be obliged to notify you of the correction or deletion of your data as well as the restriction of its processing. iVAULT will comply with this request. You can also track and make changes to your data yourself in your iVAULT account.

Right to data portability:

If necessary, iVAULT users have the right to request copies of the data stored about them. You generally have the possibility to view stored data in your account and your account settings. If you would like to receive copies in machine-readable format of the stored data, please contact us directly.

Right to object:

You can revoke your consent to data processing at any time. To do so, change your settings in the iVAULT account or contact us directly.

Notification of personal data breaches:

We may be required to notify the relevant supervisory authority in the event of a personal data breach. This does not apply to situations where the breach is unlikely to result in a risk to the rights or freedoms of users.

California Users

Individuals who rely on the California Consumer Privacy Act of 2018 (“CCPA”) may exercise their right either by contacting iVAULT via the iVAULT App or via support@ivault.app. If you wish to exercise your rights, we may require you to provide proof of your identity before we can process your request or take further action.

You have the right not to be discriminated against in the exercise of these rights. We assure you that we will comply with this and will not discriminate against you on the basis of the exercise of these rights or otherwise.

Right to Information:

You have the right to know what personal data we have processed about you in the last twelve (12) months. If you wish to exercise this right, please contact iVAULT directly.

We collect the following personal data (please see above for details):

• Identification information, such as name, e-mail address or username, if provided during registration
• Pictures of your saved items as well as any profile pictures
• IP address, information about your network as well as your device data
• Type, duration and frequency of use of the iVAULT app and interaction with other iVAULT users.

In the course of our business activities, the companies of the iVAULT Group have access to this data. Companies contracted by iVAULT may also have access to this data in certain cases. External companies, which are not directly affiliated with iVAULT, do not have access to collected data.

If you register via Google, Apple or Facebook, these companies have access to your login data.

Right of deletion:

You may have the right to request the deletion of the data processed about you. iVAULT stands by the fact that you can request that your account, including your data, be deleted at any time and without giving any reason. Should you wish to delete your account, contact iVAULT directly.

Right to Opt-Out:

iVAULT does not sell data.

You have the right under the CCPA to object to the disclosure of your data. If you wish to exercise this right, please contact iVAULT directly.

Contact details

iVAULT users can reach us via app, via email or by mail:

Via the App, use the possibility to contact us in your account under “Contact iVAULT Team”.

Via mail, we can be reached at the following address:

Vault Security Systems AG
Zürcherstrasse 66
8800 Thalwi
Switzerland

Please note that if you contact us, we may be required to ask you to identify yourself.

Changes to this Privacy Policy

We will keep this privacy policy up to date and make adjustments as necessary. If this privacy policy is adjusted, iVAULT users will receive a corresponding notification. This does not include urgent changes, for example to address security vulnerabilities or abusive practices. iVAULT users who do not agree with the privacy policy should delete their iVAULT account and not use our services.

Final Remarks

In the event of any disagreement or difference, the English version of this Privacy Policy shall be binding. Translation into other languages is for informational purposes only.

Before you open an iVAULT account, you will be asked to read and accept the applicability of our Terms of Use and Privacy Policy and to confirm that you meet the age requirements of your country of residence to use this app. By using the iVAULT App, you expressly and unconditionally agree to this Privacy Policy. Please also consult our Terms of Use.

For interpretation and enforcement of these Privacy terms, Swiss law without application of conflicts of laws provisions, applies, with a forum in Zurich, Switzerland.

Version 1.2 / October 2021