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Privacy Policy

This Privacy Policy sets forth VAULT’s (“we”, “our” or “us”) policies and procedures regarding the collection, use, and disclosure of your information in connection with your use of the VAULT application (the “App”) and any associated services, features, content, or applications we offer through the App (collectively, the “Services”). We receive information about you from various sources, including: (i) when  you register for the App or the Services, through your user Account (your “Account”); (ii) your use of the Services; and (iii) from third-party websites and services, such as social media companies. When you use the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.  

What Does This Privacy Policy Cover?
This Privacy Policy explains the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our Business Partners share with us or that we share with our Business Partners.  

This Privacy Policy only covers our use of Your information. It does not apply to the practices of third parties that we do not own or control, such as any third party websites, services and applications (e.g. Twitch, YouTube, Google, Twitter, Facebook, Instagram, etc.) (each a “Third Party Service”) that you you may make use of when using the Service. We cannot take responsibility for the content or privacy policies of those Third Party Services, please review those services’ policies carefully.

What Information Do We Collect and Use?
We collect information to personalize, improve, protect, and continue to operate the Services. We may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.

Account Information:If you create an Account on the Services (“Account”), you may be required to provide information that could be Personal Information, such as your name, phone number and/or email address. You may be asked to supplement this information with additional information to collect prizes or participate in certain contests. If you register for or access the Services using a Third Party Service (such as your social media account login credentials), we may receive Personal Information that you allow such Third Party Service to share with us. You acknowledge that the information we receive may be personal to you, and by creating an Account and providing Personal Information to us, you allow others, including us, to identify you. We may use your contact information to send you information about our Services. You may unsubscribe from some of these messages by emailing us at, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for Account recovery purposes.

Information Regarding Third Party Services:
You may interact with third party applications while using the Service (“Third Party Service”).  By interacting with or using these Third Party Services, your interactions with those Third Party Services, are subject to the Third Party Service’s privacy policy. Therefore, we encourage you to read the privacy policies and other policies of any Third Party Services, including any applicable social networks, you use while using our Services.Additionally, we may collect and receive your social media account login credentials to provide you with the Services, but only if you expressly provide us with such information. We will only use such login information as outlined in this Privacy Policy or as otherwise expressly authorized by you.

Personal Information Retention:
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.  Information may persist in copies made for backup and business continuity purposes for longer than we keep the original data.
Location Information:
Some of our Services may include features based on users’ actual locations and may report on users’ current locations, and may require you to use location services to access a contest or portion of the Service (“Location-Based Services”).  To the extent you opt to use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services. Additionally, we may also collect and/or receive location information from your use of the Services generally.

IP Address Information and Other Information Collected Automatically:
We automatically collect usage information, such as the number and frequency of visitors to the App and users of the Services. We may use this data in aggregate form, that is, as a statistical measure, or in other anonymous forms, but not in a manner that would identify you personally. This type of data enables us, and third parties authorized by us, to figure out how often individuals use parts of the Services.

We may collect some device-specific information if you access the Services using a mobile device.  Device information may include but is not limited to unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services.We may use this information for advertising, analytics or the other purposes described in this Privacy Policy.  If you do not want to receive behavioural in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”).  You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings pages, which will prevent continued use of existing behavioural data tied to your previous “Advertising Identifier.”  Further, you may be able to download third-party apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for behavioural advertising.

Email, Text, and Push Notification Communications:
We may communicate with you via push notification, email, SMS, MMS or other text message (“Message”) (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a Message or receive a push notification. We use this information to improve our Services, including our customer service.  

Aggregate Information:
We collect statistical information about how both unregistered and registered users, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.

Children’s Privacy:
We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information.


Public Information About Your Activity on the Services:Some of your activity on and through the Services is public. Public activity may include, content you have posted publicly on, through or in connection with the Services, including public portions of Third Party Services, such as your social media accounts. Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but we may track and store information concerning their use of the Services (such as interactions within our mobile App) anonymously. Please remember that if you provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and your knowledge, and search engines may index that information. We urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

IP Address and Device Information:
While we may collect and store IP address and device information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:
You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within our Services. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Aggregate and Non-Personally Identifiable Information:
We share Aggregate Information with our partners, service providers and other persons with whom we conduct business, such as social networks (“Business Partners”).  We may also share information with our Business Partners that is (i) not Personal Information or (ii) derived from Personal Information but has been anonymized so that it is no longer personally identifiable (collectively with Aggregate Information, “Non-Personal Information”). We use and share this type of data so that our Business Partners and we can understand how and how often people use our and their services or websites, which facilitates improving our Services, their services and how our Services interface with their services. These Business Partners may also share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.

Email and SMS Communications with Us:
As part of the Services, you may occasionally receive push notifications, email, SMS text and other communications from us, such as communications relating to your Account.

User Profile Information:
User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
Social Media Account Login Credentials:
If you share your Third Party Services account login credentials with us, we may use such information to post on your behalf.  We will never share or disclose your login credentials outside of our company.  We may share your User Content (as defined in the Terms of Service), or some derivative of it, on our company-branded social media channels, and we may tag you in such post using your name, social media name, handle or other identifier.
Information Shared with Our Agents:
We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Disclosed When Transferring the Business:In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that are transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Personal Information as outlined in this policy.

Information Handling Generally
In addition to collecting and handling Personal Information for the purposes described above, we may access, retain, use and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention, use or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Service or other contracts with you, or this Privacy Policy, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of VAULT, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.  We also use and disclose Personal Information to conduct research, improve our Services, and engage in marketing and other communications.  

Legal Basis for Processing Business Data
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal data. To the extent those laws apply, our legal grounds for processing Personal Information are as follows:

- To honor our contractual commitments to you: Much of our processing of Personal Information is to meet our contractual obligations to our users, or to take steps at users’ request in anticipation of entering into a contract with them.
- Consent: Where required by law, and in some other cases, we handle Personal Information on the basis of consent.
- Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:     

- Providing our Services      
- Marketing      
- Protecting our users, personnel and property      
- Analyzing and improving our business      
- Managing risks and legal issues
- We may also process personal data for the same legitimate interests of our Business Partners.
- Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations.

International Data Transfer
Our Services are operated primarily from the United States, and the recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the country in which you are located.  We will comply with legal requirements for cross-border data protection, including (where applicable) through the use of European Commission-approved Standard Contractual Clauses or reliance on the third-party recipient’s participation in the EU-U.S. Privacy Shield Framework.

Is Information About Me Secure?
We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. We store all of our information, including your IP address and device information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.  Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.  Additionally, you are responsible for preventing unauthorized access to your Account and Personal Information by protecting your Account credentials and limiting access to Service Device (as defined in the Terms of Service).

How Can I Exercise My Data Protection Rights?
If you are a registered user, you can access and update certain information associated with your Account by logging in and visiting the profile or settings section.  Any user can limit our use of their mobile device identifier by visiting the privacy settings of their mobile device as described further above.Residents of the European Economic Area (“EEA”) and certain other jurisdictions can contact us as described below to exercise other rights they have in relation to their Personal Information.  For example, for those in the EEA, this includes certain rights to ask us to provide access to and/or a copy of certain Personal Information we hold about them (including, in certain cases, in a portable form)update Personal Information which is out of date or incorrect delete certain Personal Information which we are holding about them restrict the ways that we process certain of their Personal Information transfer certain Personal Information to a third party revoke consent for certain processing of Personal Information (which will not affect the lawfulness of Processing prior to when the revocation takes effect) or object to our processing of their information.

For example, EEA residents have a right to opt out of our processing of their Personal Information for direct marketing purposes. We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.EEA residents and others also have a right to lodge a complaint with the relevant supervisory authority, but we invite you to raise any concerns with us first, and we will do our best to resolve them.

California Privacy Rights:  California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of personal information disclosed to those parties.

If you are a California resident and would like to request this information, please mail your request to VAULT, 100 Mamaroneck Avenue, Mamaroneck, New York 10543.

How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so through the App by deleting the App or by emailing If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.

What Choices Do I Have Regarding My Information?
You may, of course, decline to submit information through the Services, in which case we may not be able to provide certain services to you.

You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account.  You can choose to opt out of certain communications or communication methods; however, if you do so, you may not be able to take advantage of some of our Services’ best features.  

What Happens When There Are Changes to this Privacy Policy?
If we change our privacy policies and procedures, we will post those changes on this page. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will endeavor to provide you with reasonable notice of such changes.  We may do so via a prominent notice in the Service or to your email address of record, and where required by law, we will obtain your consent or give you the opportunity to opt out of such changes.

What If I Have Questions or Concerns?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to We will make every effort to resolve your concerns. We also can be reached as follows:

100 Mamaroneck Avenue
NY 10543

‍Effective Date: 1st Nov, 2021