Privacy Policy

Last edit: December 22 2022

1. GENERAL PROVISIONS

1.1 Vaultody LTD, a company, registered and existing under the laws of Bulgaria, EU, having its registered company number having its UIC 207186381, having its registered seat and address at 101 Blvd. Tsarigradsko shose, 1113, Sofia, Bulgaria (hereinafter referred to as “Vaultody”) that maintains and operates the website https://vaultody.com/ and provides the Vaultody Service, as described in detail on the cited website (hereinafter referred to as the Service). This Privacy policy explains practices regarding collection, use and disclosure of certain information, including Your personal data when You use the corporate website and Vaultody provides the Service to You. It serves to inform You about our processing of Your personal data and to ensure You that Your personal data is treated with respect and in accordance with the applicable data protection legislation when using the Service.

1.2 You should always feel safe when sharing Your personal data with Vaultody. Vaultody has taken the technical and organizational security measures that are required to ensure that Your personal data is protected from unauthorized access, use, modification and deletion.

2. PERSONAL DATA CONTROLLER

2.1 Vaultody is the data controller for the processing of Your personal data handled by Vaultody. Information on how to contact us can be found in section 11.

3. WHEN DOES Vaultody COLLECT PERSONAL DATA?

Vaultody collects personal data about You when:

You request a demo version of the Service through the form, available on our website;

You enter into contractual relation with Vaultody in order to use the Service;

When You apply for job at Vaultody and You provide us with you CV, as well as with other information/documentation on your professional experience, educational status, heath condition;

You voluntarily fill in any information and test forms, provided by us;

You answer a survey, including but not limited to questionnaires or marketing surveys or reply to communication from Vaultody, or

It is otherwise necessary to legally manage the relationship between You and Vaultody.

4. WHAT PERSONAL DATA DOES Vaultody COLLECT?

4.1 In the cases, listed in pt. 3 above, Vaultody collects personal data about You. Basic data that Vaultody collects includes Your full name, address, e-mail address, phone number, employer company, position in the employer company, as well as other personal data, that You would voluntarily provide to us. When using the Service and when visiting Vaultody website, we may also collect data concerning usage, viewing and technical data, including Your IP address.

4.2 Further Vaultody may also collect and process data that You provide in public forums on Vaultody website or to Vaultody when You use Vaultody website, Vaultody sites on third-party platforms such as social networking sites.

5. HOW LONG IS THE DATA KEPT?

Vaultody will keep personal information regarding You only as long as it is necessary, having regard to the purpose of the processing. This means that personal information collected and processed for marketing purposes will be stored for as long as You have an account and deleted immediately after Your contract is terminated, unless You have given Vaultody Your voluntary consent to continue to process such data. Vaultody may store data for longer if required by law or if required in order to monitor Vaultody legal interests, for example if there are ongoing legal proceedings.

6. WHY DOES Vaultody PROCESS INFORMATION ABOUT YOU?

6.1 Vaultody processes Your personal data for various purposes. Primarily, Vaultody processes Your personal information in order to provide, manage, develop and customize the Service and its features, to manage the licensing relationship with You and to meet security and other statutory regulatory requirements. Your personal information may also provide the basis for market and customer analyses, market research, statistics, business monitoring and business and methodological development for Vaultody.

6.2 Vaultody also processes Your personal data to provide better and more personalized offers and services. Personal data may, for example, be processed, linked, segmented and analyzed in order, by means of targeted marketing, to provide information, offers or recommendations on Vaultody advisory services, which are tailored to Your preferences, behaviors, needs or lifestyle.

6.3 In addition to the above, Vaultody processes Your personal data to prevent, detect and investigate potential prohibited or illegal activities, including fraud.

7. WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

7.1 A majority of the personal data that Vaultody processes about You is processed in order for Vaultody to be able to provide and administer the Service and its features. Such is the case when Vaultody processes, inter alia, Your contact information such as Your e-mail address or Your phone number.

7.2 Some of the personal data which Vaultody processes is processed based on a balance of interest, i.e. Vaultody interest of processing the data outweighs the impact and risk the processing may have on Your integrity.

7.3 To the extent that processing is carried out on the basis of a consent, it is voluntarily for You to give such a consent and You may at any time, wholly or partly, withdraw Your consent. If You choose to withdraw Your consent, and Vaultody processing is such that it requires Your consent, the processing will be carried out in accordance with Your most recently given consent.

8. DATA SECURITY AND INTEGRITY

The security, integrity and confidentiality of Your personal data and information is all important to us. We have implemented technical, administrative and physical security measures that are designed to protect Your personal data from unauthorized disclosure, use and modification. From time to time, we review our security procedures in order to assess the need to implement additional measures or to make technical upgrades to existing procedures. Please be aware that, despite our best efforts, few security measures are impenetrable, and we therefore kindly ask that You inform us immediately of any suspicious activities that You notice when using the Service.

9. WHO DOES Vaultody GIVE THE DATA TO?

9.1 Depending on the service that you entered a contractual relation for, Vaultody may disclose Your personal data and information to our employees, our external consultants, business partners and other third parties in order to fulfil the agreement with You or to fulfill agreements with Vaultody suppliers and partners.

9.2 Vaultody may also disclose personal information to companies that process personal information on our behalf, such as our IT system providers, customer service companies and affiliates. If personal information is disclosed to such companies that process data on Vaultody behalf, Vaultody enters into data processing agreements with such parties in order to ensure that a high level of security for Your personal data is maintained.

9.3 Personal data may also be disclosed, if needed, to comply with statutory legal requirements or requirements from regulatory authorities, to safeguard Vaultody legal interests or to detect, prevent, or pay attention to fraud and other security or technical issues.

9.4 Your personal data may be transferred to or stored in a country outside the EU/EEA. If Your personal information is transferred or stored outside the EU/ EEA, special safety measures will be taken, we will e.g. ensure that such transfer is carried out in accordance with this privacy policy and as permitted by the applicable laws on data protection, for example through the use of data transfer agreements that includes the standardized EU-model clauses for transfer of data adopted by the EU Commission and that are available on the EU Commission’s website.

10. CHANGES TO THE PRIVACY POLICY

This privacy policy may be revised from time to time. If Vaultody makes any significant changes to the privacy policy, Vaultody will inform You in an appropriate way before the changes take effect. The privacy policy will also be published on Vaultody website. If any change requires Your consent, Vaultody will obtain a new consent from You.

11. RIGHT TO REQUEST INFORMATION AND CORRECTIONS ETC.

11.1 You have the right to be given free information about, inter alia, the personal data that Vaultody processes on You and for what purpose Vaultody is processing Your personal data (so-called record extract). Any such request for a record extract must be made in writing and be signed by You.

11.2 You are also entitled to have inaccurate, misleading or incomplete data corrected, anonymized or deleted. You are also entitled to request Vaultody to restrict the processing of Your personal data and to object to the processing. Furthermore, You may exercise Your right to data portability, which means that You have the right to receive the personal data processed about You in a structured, commonly used and machine-readable format.

11.3 Please note that some of the rights above only may be exercised in certain situations, e.g. the right to data portability, which only applies when the processing is carried out on the basis of an agreement or a consent and if the processing is carried out by automated means. In case You have any questions regarding how Vaultody processes Your personal data, want to exercise any of Your rights or want to know more about the rights, You may contact us as indicated below.

E-mail address: [email protected]

Address: ul. "Nikolay Haytov" 12, 1113 g.k. Iztok, Sofia, Bulgaria

Contact person: Nashwan Khatib, CEO

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