SECURED WORLDWIDE PRIVACY POLICY

  1. Scope of This Policy

    This Privacy Policy applies only to personally identifying information (“Personal Information”) collected through the www.VULT.com website (the “Site”) of Secured Worldwide, LLC and Secured Worldwide Limited (together, “we,” “us,” “SWW” or “Secured Worldwide”) and any associated SWW websites.  Personal Information collected by Secured Worldwide through other channels is not subject to these provisions.

    Capitalized terms used in this policy that are not defined below, have the meanings ascribed to them in the Secured Worldwide Terms of Use available on the Site.

  2. What We Collect and What We Do with Your Personal Information

    When you visit the Site, use SWW Services or use third party services that use the SWW application programming interface (“API”), SWW collects information sent through your computer, mobile phone or other access device. This information may include your IP (Internet Protocol) address, device information, including but not limited to identifier, device name and type, operating system, location, mobile network information and standard Web log information, such as your browser type, traffic to and from the Site and the pages you accessed on the Site.

    The Site also allows you to provide information when you contact us.  We may use any information you provide internally for any business purpose, including to send you subsequent communications.  We will not provide your Personal Information to any non-affiliated third party for any reason, nor will we make public any comments or feedback you provide us, without your permission.

    If you create an account or use SWW Services, we, or our affiliates vendors acting on our behalf may collect the following types of information:

    Contact information: your name, address, phone, email, and other similar information.

    Financial information: the full bank account and routing numbers and/or credit card numbers that you link to your SWW Account or input when you use paid SWW Services.

    If you seek to purchase or sell VULT associated with your SWW Account, you may be required to provide additional information that may be used in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification or other Personal Information. We may also obtain information about you from third parties, such as credit bureaus and identity verification services.

    When you use SWW Services, we collect information about your transactions and/or your other activities on the Site and we may continuously collect information about your computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breach of your SWW Account and to identify any malicious software or other activity that may harm SWW or its users.

    Finally, we may collect additional information you may disclose to our customer relations team.

  3. Cookies

    “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive, including but not limited to your IP host address, internet browser type, personal computer settings, and the number, duration and character of page visits.  The Site does not use or deposit “cookies,” unless you register with the Site, in which case a cookie that will allow your device to be identified on a return visit to the Site is deposited.  We use that cookie to enhance your experience with the Site but for no other purpose, and we do not share your cookie data with any third party.  If you wish, you may configure your browser to reject cookies, in which case your experience with the Site may be less enjoyable. 

  4. Use of Personal Information

    Throughout this policy, we use the term “Personal Information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider Personal Information to include information that has been anonymized so that it does not identify a specific user. SWW takes reasonable precautions, as described herein, to protect your Personal Information from loss, misuse, unauthorized access, disclosure, alteration and destruction.

    SWW stores and processes your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, on our computers in the United States and elsewhere in the world where SWW facilities or our service providers are located, and we protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable U.S. federal and state regulations. We use computer safeguards, such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Information only to those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by a payment vendor in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to SWW staff.

    We store our customers’ Personal Information securely throughout the life of the customer’s SWW Account. SWW will retain your Personal Information for a minimum of ten years or as necessary to comply with our legal obligations or resolve disputes.

    Our primary purpose in collecting Personal Information is to provide you with a secure, smooth, efficient and customized experience. We may use your Personal Information to:

    • Provide SWW Services and customer support you request;
    • Process transactions and send notices about your transactions;
    • Resolve disputes, collect fees, and troubleshoot problems;
    • Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
    • Customize, measure, and improve SWW Services and the content and layout of our website and applications;
    • Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and
    • Compare information for accuracy and verify it with third parties.

    We will not use your Personal Information for purposes other than those purposes we have disclosed to you, without your permission. SWW may request your permission to allow us to share your Personal Information with third parties. You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your Personal Information, certain features or SWW Services may not be available to you.

    SWW will not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent. SWW may combine your information with information we collect from other companies and use it to improve and personalize SWW Services, content and advertising.

    To process your payments, SWW may share some of your Personal Information with the person or company to which you transfer or from which you receive the VULT. Your contact information, date of sign-up, the number of payments you have received from verified SWW users and whether you have verified control of a bank account are provided to other SWW users with whom you transact through SWW. In addition, this and other information you disclose to SWW may be shared with third parties who may provide, upon your authorization, ancillary services which access your SWW Account. Unless you have agreed to it, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using SWW services.

    If you use your SWW Account in connection with the purchase or sale of VULT units, SWW or you may also provide the seller with your shipping address to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it.

    In connection with a VULT sale or transfer between you and a third party, the third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer or sale has taken place between you and the third party. SWW may use this information in connection with such transfers to confirm that you are a SWW customer. If you request that we validate your status as a SWW customer with a third party, we will do so. SWW is not responsible for the operations, including, but not limited to, information practices of third parties.

    SWW may share your Personal Information with:

    • Service providers under contract who help with parts of our business operations such as fraud prevention, bill collection, marketing and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
    • Financial institutions with which we partner.
    • Companies that we plan to merge with or be acquired by. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your Personal Information. You will receive prior notice of any change in applicable policy.)
    • Law enforcement, government officials, or other third parties when:
      • we are compelled to do so by a subpoena, court order or similar legal procedure; or
      • we believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement.

    You are entitled to review, correct, or amend your Personal Information, or to delete that information where it is inaccurate, and you may do so at any time by logging in to your account and clicking the Profile or My Account tab. This right shall only be limited where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than you would be violated. If you close your SWW account, we will mark your account in our database as “Closed,” but will keep your account information in our database for a period of time described above. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

  5. Children’s Privacy

    The Site is not directed at children under the age of 13.  We do not knowingly collect or maintain information from persons under the age of 13.

  6. Online Tracking and Third Parties

    We do not change our practices in response to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer’s online activities over time and across third-party websites or online services.

    We do not knowingly permit third parties to collect Personal Information about our visitors’ online activities over time and across different websites.

  7. Contacting SWW

    SWW prefers electronic notice using our support system at support@VULT.com.

    Written notifications can also be sent to: Secured Worldwide, LLC, 50 W47th Street, Suite 910, New York, NY 10036, USA.

    Updated by Secured Worldwide, LLC and Secured Worldwide Limited on December 23, 2015.