Last updated: 24th October 2023

Privacy Policy

Welcome to Privacy Policy (the “Policy”).
This Policy informs you how we collect, use, share, retain and dispose personal data
received through the website https://vault.ist/ (“Website”) and our branded social media pages(such as our LinkedIn) (“Social media”). Our Website and Social media are hereinafter jointly
referred to as “Platform”.
We may collect and receive personal data through our online platform. Personal datameans any information relating to an identified or identifiable natural person.
We collect personal data that you choose to voluntarily provide to us for your use of ouronline platform.
Accordingly, the purpose of this Policy is to set out the basis on which we will process
your Personal data when you:1.

visit and use the Website, regardless of where you visit or use them from;2.

apply for and fill customer form with us;

This also includes any data which you may provide to us for our events, newsletters, andother marketing items.
This Policy informs you about the items of Personal data that we may collect about you
and how we will handle it, and in turn, also tells you about(i)our obligations to process your Personal data responsibly,(ii)
your data protection rights as a data subject, and (iii) how the law protects you.
It should be read in conjunction with our Cookie Policy.

Please read the following information carefully to understand our practices regarding
your Personal data.
1.

Important information and who we areThis Policy aims to ensure that you are fully informed on how we will collect and process
your Personal data in the circumstances and scenarios outlined in the Policy.
This Website are owned by the company and VAULT IST DMCC, a company duly
existing and organized under the laws of United Arabic Emirates, company registration number
DMCC198149 with a registered office at Unit No: AG-13-H-F168, AG Tower, Plot No:
JLT-PH1-I1A, Jumeirah Lakes Towers, Dubai, which is regulated by the laws of that country(the “Vault”).
a. Controllers
Vault (as defined) above is the controller and is responsible for your Personal data.
There may be other controllers of your Personal data, such as, for example, electronic
identification verification service providers, or associated companies or other service providers
engaged by us for purposes of processing and storing your Personal data. They will be
so-called “joint controllers” of your Personal data and as such, will share responsibility forsuch control with us.
Presently, we use the services of the following service providers:Sum&Substance: https://sumsub.com for KYC/AML verification;
Safened: https://www.safened.com for KYC/AML verification;
Ondato: https://www.ondato.com for KYC/AML verification;
Connectum: https://www.connectum.com for credit and debit card processing andacquiring;
EmailOctopus: https://emailoctopus.com for handling e-mail lists and campaigns; andHasOffers: https://www.hasoffers.com for performance marketing.
Please familiarize yourself with these providers and their privacy and liability policies. If
you find any of these may not work for you, please do not access any of the Websites.
As a general rule, we always seek to minimize the amount of your Personal data that
we ourselves collect and store.
b. Changes to the Policy and your duty to inform us of changes
We may occasionally update this Policy.
It is imperative that the Personal data we hold about you is accurate and current at all
times. Please keep us informed if any of your Personal data changes during your relationshipwith us.
c. Third-party links
Our Website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect orshare data about you. We do not control these third-party websites and are not responsible for
their privacy notice or policies. We strongly encourage you to read the privacy notice of every
website you visit, particularly when leaving our Website.
d. General Data Protection Regulation
General Data Protection Regulation. (Regulation (EU) 2016/679) (GDPR) regulations shall be
implemented for EU users (the “Regulation” or the “GDPR”).
2.

Glossary

Set out below are key definitions of certain data protection terms which appear in thisPolicy.
“Consent Form” refers to separate documents which we might from time to time provide
you where we ask for your explicit consent for any processing which is not for purposes set out
in this Policy.
“Data subjects” means living individuals (i.e. natural persons) about whom we collectand process Personal data.
“Data controller” or “controller” means any entity or individual who determines the
purposes for which, and the manner in which, any Personal data is processed.
“Data processor” or “processor” means any entity or individual that processes data on
our behalf and on our instructions (we being the data controller).
“Personal data” means data relating to a living individual (i.e. natural person) who canbe identified from the data (information) we hold or possess. This includes, but is not limited
to, your name and surname (including maiden name where applicable), address, date of birth,nationality, gender, civil status, tax status, identity card number & passport number, contact
details (including mobile and home phone number and personal email address), photographic
image, bank account details, emergency contact information as well as online identifiers. The
term “personal information”, where and when used in this Policy, shall have taken the same
meaning as Personal data.
“Processing” means any activity that involves use of Personal data. It includes
obtaining, recording or holding the data, or carrying out any operation or set of operations on
the data including, organizing, amending, retrieving, using, disclosing, erasing or destroying it.
Processing also includes transferring Personal data to third parties.
“Sensitive Personal data”, “sensitive data” or “special categories of Personal data”
includes information about a person's racial or ethnic origin, political opinions, religious orsimilar beliefs, trade union membership, physical or mental health or condition or sexual life,
or about the commission of, or proceedings for, any offence committed or alleged to havebeen committed by that person, the disposal of such proceedings or the sentence of any courtin such proceedings. This type of sensitive data can only be processed under strict conditions.
Note that Personal data does not include information relating to a legal person(such as, for example, a company). Therefore, information such as a company name,its company number, registered address and VAT number, does not amount to Personal
data in terms of both the Act and the GDPR. Naturally, we will still treat any and all suchinformation in a confidential and secure manner.
3.

The data we collect about you

Personal data, or personal information, means any information about an individual fromwhich that person can be identified. It does not include data where the identity has been
removed (anonymous data).
We may collect, use, store, share and disclose different kinds of Personal data about
you which (for purely indicative purposes) we have grouped together as follows. For the
avoidance of doubt, categories marked in blue are not applicable to non-customers (i.e.
individuals who do not hold a registered customer account with us).
●
Identity Data includes your first name, maiden name (where applicable), last
name, username or similar identifier, marital status, title, nationality, date of birth, gender,
identity card and/or passport number.
●Contact Data includes address, billing address, email address and contact
number (telephone and/or mobile).
●

Usage Data includes details about how you use our Platform and the Websites.

●
Data includes internet protocol (IP) address, your login data, browser type andversion, time zone setting and location, browser plug-in types and versions, operating systemand platform, and other technology on the devices which you (whether a client or otherwise)
use to access and browse the Websites.
●
Website Visit Data includes the full Uniform Resource Locators (URL),
clickstream to, through and from the Website (including date and time), products you viewed
or searched for, page response times, download errors, length of visits to certain pages, pageinteraction information (such as scrolling, clicks, and mouse-overs), methods used to browseaway from the page●
Marketing and Communications Data includes your preferences in receiving
marketing from us or our third parties and your communication preferences. This may include
information whether you have subscribed or unsubscribed from any of our mailing lists,
attended any of our events, or accepted any of our invitations.

We will also collect, use and process any other information that you voluntarily choose
to provide or disclose to us where relevant for processing your token requests and/or
providing you with your requested Services. Any such information that we receive from you
would fall under the ‘Transaction Data’ category.
We also collect, use and share Aggregated Data such as statistical or demographic
data for any purpose. Aggregated Data may be derived from your Personal data but is notconsidered Personal data in law as this data does not directly or indirectly reveal your identity.
For example, we may aggregate your Website Visit Data to calculate the percentage of users
accessing a specific feature of the Website. However, if we combine or connect Aggregated
Data with your Personal data so that it can directly or indirectly identify you, we treat the
combined data as Personal data which will be used in accordance with this Policy.
If you fail to provide Personal data
Where we need to collect Personal data about you:●by law, or●as part of our legitimate (business) interests to verify the identity of ourapplicants and customers, mitigate against risks (such as potential or suspected fraud) and, inparticular, to assess and take a decision on whether we want to enter into a customer
relationship with you (as subject to our customer acceptance criteria and policies),and you either fail to provide that data when requested, or else provide
incomplete or insufficient data, we may not be able to perform or conclude the contract
which we have or are otherwise trying to enter into with you. We will however notify you if thisis the case at the time.
4.

Special categories of Personal data

We do not knowingly collect Special Categories of Personal data (or Sensitive
Personal data) about you. Should we receive sensitive Personal data about you, we will only
process that data when there is a legitimate basis to do so and, in all circumstances, inaccordance with our obligations at law and under the appropriate safeguards.
5.

How is your Personal data collected?

We generally use different methods to collect data from and about you including through:a. Direct Interactions. You may give us your Identity, Marketing and Communications
Data by filling on our forms (such as our ‘Contact Form’ or by corresponding with us
by post, phone, email or otherwise. This includes Personal data you provide when
you:
●
●
●
●
●
●
●
●
●
●

discuss with us the particular Services that you require;
request and receive our Services;
contact us with complaints or queries;
complete an enquiry form;
contact us for further information about our products and services;
request marketing to be sent to you;express interest and/or attend any of our seminars or other hosted events;
participate in a survey;
subscribe to our newsletters;
give us some feedback.

b. Automated technologies or interactions. When you interact with our Website, we
may automatically collect Technical and Usage Data about your equipment,
browsing actions and patterns. We may collect this Personal data by using cookies,
server logs and other similar technologies. Please see our Cookie Policy for further

details.
c. Third parties or publicly available sources. We may receive Personal data about
you from various third parties and public sources as set out below:
Technical Data from the following parties:(a)analytics providers;(b)advertising networks; and(c)search information providers.

We may also receive customer due diligence reports about our applicants from ouroutsourced third-party KYC provider. These reports may encompass identity checks, document
integrity checks, checks against global sanctions lists and related screening and monitoringmeasures. In such cases, this third-party provider will conduct the requested customer due
diligence checks in an autonomous manner and will generally amount to a controller of the
Personal data which it collects in connection with those checks. It also has its own data policies
and practices, which will be duly notified and communicated to the applicant.
6.

How we use your Personal data

We will only use your Personal data when the law allows us to. Most commonly, we will
use your Personal data in the following circumstances:●

Where you wish to enter into a customer relationship with us.

●

Where we need to perform the agreement we have or which are about to enter
into with you as a customer (including in respect of your token purchases andsubscriptions, and use of the Services).

●

Where it is necessary for our legitimate interests (or those of a third party) andyour interests and fundamental rights do not override those interests.

●

Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to such marketing at any time by contacting us,
as indicated above under ‘Contact Details’.
7.

Purposes for which we will use your Personal data

We have set out below, in a table format, a description of all the ways we plan to use
your Personal data, and which of the legal bases we rely on to do so. We have also identified
what our legitimate interests are where appropriate.
Note that we may process your Personal data pursuant to more than one lawful groundor basis, depending on the specific purpose for which we are using your data. Please contact
us at support@vault.ist if you need details about the specific lawful basis we are relying on toprocess your Personal data where more than one lawful basis has been set out in the tablebelow.
Purpose/Activity

Type of data

Lawful basis for processing
including basis of legitimate
interest(a)To conduct customer
due diligence measures on you(following your application to enter
into a customer relationship with us).

(a)

Identity;(b)

Contact;(c)

AML and KYC.

(b)
To determine whether
we want to enter into a customer
relationship with you and, if positive,
to register your customer accountand on-board you as a customer.

(a)Performanceofacontract with you or in order to takesteps at your request prior toentering into such a contract.
(b)
Necessaryfor ourlegitimate interests (to verify youridentity, conduct initial screening andmonitoring (sanctions lists, fraud
databases and other KYC checks),
determine whether you present any
risks as a prospective customer, andultimately to enable us to take an
informed decision on whether wewant to enter into a customer
relationship with you).

(a)
To establish and verify
your identity.

(a)
(b)

(b)
To fulfill our otherinternal KYC policies andrequirements.

(c)

KYC
over
and

(a) To enable your use of the
Platform, process your token
subscriptions,purchases
andtrading activity, and provide you with
the Services that you haverequested from us.
(b)
To keep your account andportfolio accurate and updated.

Identity;

Necessary for our legitimate
interests (for risk assessment
Contact;
purposes, to prevent and mitigate
against fraud, to safeguard the
AML and KYC; reputation of our business).

(d)Enhanced
Data (for paymentsa certain threshold);(e)Transaction.

(a)Identity;(b)

Contact;(c)Financial;(d)Transaction;(e)Portfolio.

(a)Identity;(b)

Contact;(c)Financial; and(d)Transaction.

(a)Performance of acontract with you.
(b)
Necessary to comply
with our contractual obligations.
(c)
Necessary to comply
with a legal obligation.

(c)Manage transactions
and generate transaction reports
and records.

For tax and accounting
purposes (e.g. reporting to tax
authorities, and accounting
andreporting requirements).

Necessary to comply with alegal obligation.

(a)Identity;(b)

Contact;(c)Financial;(d)Transaction;(e)Portfolio.

To manage our customer
relationship with you, which may
include to:(a)

Identity;(b)

Contact;(a)notify you aboutchanges to our terms of service or
privacy notices;(c)

Financial;(d)Transaction;(b)
set up, manage andadminister your customer accounton the Website;(e)Usage;(f)

Portfolio; and(a)purposes;

For billing and invoice(b)
To collect and recovermoney which is owed to us (debt
recovery);(c)Internal record
keeping (including files).

(c)your funds;(g)Marketing anddistribute and account Communications.

(d)
deal
with
your
enquiries, requests,
complaints or reported issues;(e)contact you in thecourse of providing the requested
services;(f)in a survey;
(g)

and

ask you to participate
request feedback from

you;
(h)
advise you of industry
and legislative updates,(i)
inform you about our
events and seminars (including
webinars);(j)provide you withinformation about our products andservices;(k)provide you with anyother information or materials which(a)Performance
contract with you.

of

a

(b)
Necessary to comply
with a legal obligation.
(c)
Necessary for ourlegitimate interests (to recover debts
due to us, to keep track of yourtoken subscriptions and purchases
and the provision of the Services toyou (including any developmentsthat took place), and to then be able
to review such information should anissue arise).

(a)Performance
contract with you.

of

a

(b)
Necessary for ourlegitimate interests (for customer
relationshiphandling
andmanagement, to study businessgrowthandpossibletrendsregarding our products and service
areas, to enable a review andassessment of our products andservice provision, to develop andgrow our business).

you have requested from us.

(a)
To detect, prevent
and/or report fraud or any otherpotentially illegal or prohibited
activity that comes to our attention.

(a)Identity;(b)

Contact;

(c)

AML

(b)
To
assistand KYC;
cooperate in any criminal or(d)regulatory investigations against
KYC;
you, as may be required of us.

andEnhanced

(e)

Data;

terms.

(f)Financial;(d)
To protect the rights
and property of ourselves and andothers.

(g)Transaction;(h)Payment.

(a)

Identity;(b)

Contact;(c)Usage;(d)Technical; and(e)Website Visit.

(c)

To enforce our service

To administer and protect ourbusiness, the Website and our
Platform (including troubleshooting,data analysis, testing, system
maintenance, support, reporting andhosting of data).

(a)
Necessary to comply
with a legal obligation.
(b)
Necessary for ourlegitimate interests (including, toprotect the reputation of ourbusiness).

(a)
Necessary for ourlegitimate interests (for running andadministering
ourbusiness(including IT support), systems
administration, network security, toprevent fraud and to maintain theconfidentiality of communications,and in the context of a businessreorganization or group restructuring
exercise).
(b)
Necessary to comply
with a legal obligation.

(a)
To carry out market
research campaigns;(b)To
marketour
products and services to you byemail or other means if you havesubscribed to one of our mailing lists(where you are not a customer);relevant and(a)

Identity;(b)

Contact;(c)Technical;(d)Usage;(e)Website Visit;(c)
To deliver
Website content and advertisements(f)Marketing andto you, and measure or understand Communications.
the effectiveness of the advertisingthat we serve to you.

(a)
Necessaryfor
ourlegitimate interests (to develop our
products and services and grow ourbusiness, to define our customers,
to keep our products, services andthe Website updated and relevant,and to inform our marketingstrategy).
(b) On the basis of yourconsent, in the absence of acustomer relationship.

To permit us to pursue
available remedies or limit any
damages which we may sustain.

(a)

Identity;(b)

Contact;

(c)

AML

(d)

Enhanced KYC;

(e)

Data;

(f)

Financial;(g)Transaction;(h)Portfolio; and

and

KYC;

(a)
Performance of acontract with you.
(b)
Necessary for ourlegitimate interests.

(i)Marketing andCommunications.

“Legitimate Interest” means our interest to conduct and manage our business affairs
appropriately and responsibly, to protect the reputation of our business, and to provide ourcustomers with the best possible service and the users of the Websites with a secure
experience. We make sure we consider and balance any potential impact on you (bothpositive and negative) and your rights before your Personal data is processed for ourlegitimate interests. We do not use your Personal data for activities where our interests areoverridden by the impact on you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities by contacting us
at the following email address: support@vault.ist“Performance of Contract” means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before
entering into such a contract. This includes our Terms of Service or other applicable terms ofbusiness.
“Comply with a legal obligation” means processing your Personal data where it isnecessary for compliance with a legal or regulatory obligation to which we are subject.
8.

Marketing

We strive to provide you with choices regarding certain Personal data uses, particularlyaround advertising and marketing. Through your Contact, Usage, Technical and Website Visit
Data, we are able to form a view on what we think you may want or need. This is how we thendecide which of our products and/or services may be relevant or of interest to you (ourmarketing communications).
You may receive marketing communications from us (which may consist of
newsletters, industry and legislative updates, mailshots, publications and/or information about
our events, seminars and webinars) where:●●

you have entered into an ongoing commercial or contractual relationship with us;
andprovided you have not opted out of receiving marketing from us (see Your rightto object below).

Where the above does not apply to you, we will only send you our marketing
communications if you have expressly consented to receive them from us.
a. Third-Party Marketing
We will get your express opt-in consent before we share your Personal data with any
third parties (including our affiliated entities) for marketing purposes.
b. Opting out
You can ask us to stop sending you marketing communications (unsubscribe) at any
time by following the opt-out (unsubscribe) links on any marketing communication sent to you.
c. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when
the Website sets or accesses cookies. If you disable or refuse cookies, please note that someparts of the Website may become inaccessible or not function properly.
9.

Change of purpose

We will only use your Personal data for the purposes for which we collected it, unless
we reasonably consider that we need to use it for another reason and that reason iscompatible with the original purpose, or we are obliged to process your data by applicablelaws or court / enforceable orders.
If you wish to get an explanation as to how the processing for the new purpose iscompatible with the original purpose, please contact us at support@vault.ist
If we need to use your Personal data for an unrelated purpose, we will notify you andwe will explain the legal basis which allows us to do so. Please note that we may process your
Personal data without the need to obtain your consent, in compliance with the above rules,
where this is required or permitted by law.
10.

Disclosures of your Personal data

We may have to grant access to, disclose or share your Personal data with the parties
set out below (which may be in or outside your jurisdiction) for the purposes set out in thetable above:●
Third party service providers, including platform integration and infrastructure
hosting providers (in order to store data), KYC providers and identity and customer verification
service providers (to facilitate the set-up and opening of your account and from whom we may
receive customer due diligence reports on you), payment services and payment gateways (inorder to process payments), and token accounting services (in order to verify, monitor andsecure token subscriptions, purchases and trading activity).
●
Services.

Our affiliated entity, such as partner firms involved in the provision of certain●

Affiliated group entities. We share information with these entities in order to:a)help, detect and prevent potentially illegal acts and violations of our policies;b)allow you to use the products and services they provide that are supplied inconnection with, or using, our products and services; andc)guide decisions about our products, services and communications.

●
Suppliers and external agencies that we engage to process information on
our or your behalf, including to provide you with the information and/or materials which youmay have requested.
●
Professional advisers such as consultants, bankers, professional indemnity
insurers, brokers and auditors.
●
overseas).

Law enforcement agencies, public authorities and judicial bodies (local and●Other organizations where exchange of information is for the purpose of fraud
protection or credit risk reduction.
●

Debt recovery agencies who assist us with the recovery of debts owed to us.

●
Third parties to whom we may choose to sell, transfer, or merge parts of ourbusiness or our assets (successors in title). Alternatively, we may seek to acquire otherbusinesses or merge with them. If a change happens to our business, then the new owners
may use your Personal data in the same way as set out in this Policy.
We require all affiliated entities and third-party service providers to respect the securityof your Personal data and to treat it in accordance with the law. We do not allow them to use
your Personal data for their own purposes and only permit them to process your Personal
data for specified purposes and in accordance with our documented instructions. Our service
providers currently store your Personal data in Germany. We will update this Privacy Policy if
their data storage location changes.
11.

International transfers

We do not generally transfer your Personal data to outside the European Economic Area(“EEA”) except
as may be necessary to: (i) process your transactions, subscriptions, purchases, and/or
trading activity, (ii) provide the requested services, (iii) fulfill our contractual obligations to you,(iv) exercise and enforce our contractual rights and terms of services, (v) comply with our legal
and/or regulatory obligations or (vi) assert, file or exercise a legal claim.
Where we do need to transfer your Personal data to outside the EEA, we will ensure asimilar degree of protection is afforded to that Personal data by ensuring at least one of thefollowing safeguards applies or is otherwise implemented:●
We will only transfer your Personal data to countries that have been deemed toprovide an adequate level of protection for Personal data by the European Commission.
●
In the absence of an adequacy decision, we will use specific contracts approvedby the European Commission which give Personal data the same protection it has in Europe.
●
Where we use providers based in the U.S., we may transfer data to them if they
are part of the Privacy Shield which requires them to provide similar protection to Personal
data shared between Europe and the US.
Please contact us at support@vault.ist if you want further information on the specificmechanism used by us when transferring your Personal data out of the EEA.
12.

Data security

We have put in place appropriate security measures to prevent your Personal data frombeing accidentally lost, used or accessed in an unauthorized way, altered or disclosed (i.e. tosafeguard its integrity and confidentiality). We also regularly review and, where practicable,
improve upon these security measures.
We also limit access to your Personal data to strictly those employees, agents,
contractors, and third parties that have a professional ‘need-to-know’. They will only process

your Personal data on our instructions and they are subject to a duty of confidentiality. All our
employees and agents have received appropriate training on data protection.
We have put in place procedures to deal with any suspected Personal data breach andwill notify you and any applicable regulator of a breach where we are legally required to do so.
13.

Data retention

Please note that we consider our relationship with customers to be an ongoingand continuous customer relationship, until such time that either we or the customer
terminates it.
We will only retain your Personal data for as long as necessary to fulfill the purposes forwhich we collected it and, thereafter:●
for the purpose of satisfying any legal, accounting, tax, anti-money laundering,and regulatory obligations or reporting requirements to which we may be subject (including as
an issuer of a virtual financial asset in terms of applicable Lithuanian law); and/or●
to the extent that we may also need to retain your Personal data to be able toassert, exercise or defend possible future legal claims against you or that otherwise involveyou.
By and large, our retention of your Personal data shall not exceed the period of six (6)years from the termination of your customer relationship with us (which would typically arise
from the closure or termination of your customer account). This retention period enables us tomake use of your Personal data for any applicable AML retention and reporting obligations
and for the filing, exercise or defense of possible future legal claims (taking into accountapplicable prescriptive periods and statutes of limitation). In certain cases, we may need toretain your Personal data for a period of up to ten (10) years in order to comply withapplicable accounting and tax laws (this will primarily consist of your Transaction Data). There
may also be instances where the need to retain Personal Data for longer periods, as dictatedby the nature of the products and services provided.
In some circumstances, you can ask us to delete your data. Kindly contact us at
support@vault.ist for further details about the retention periods that we apply.
14.

Data Minimization

To the extent possible, we may anonymize the data which we hold about you when it is
no longer necessary to identify you from the data which we hold about you. In somecircumstances, we may even pseudonymize your Personal data (so that it can no longer be
associated with you) for research or statistical purposes, in which case we may use thisinformation indefinitely without further notice to you.
15.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to
your Personal data. Please click on the links below to find out more about these rights:●

Request access to your Personal data.

●

Request correction (rectification) of your Personal data.

●

Request erasure of your Personal data.

●

Object to processing of your Personal data.

●

Request restriction of processing your Personal data.

●

Request transfer of your Personal data.

●Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at
support@vault.ist
a. No fee is usually charged
You will not have to pay a fee to access your Personal data (or to exercise any of theother rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may simply refuse to comply with your request insuch circumstances.
b. What we may need from you
We may need to request specific information from you to help us confirm your identityand ensure your right to access your Personal data (or to exercise any of your other rights).
This is a security measure to ensure that Personal data is not disclosed to any person who
has no right to receive it. We may also contact you to ask you for further information in relation
to your request to speed up our response.
c. Time limit to respond
We try to respond to all legitimate requests within a period of one month from the dateof receiving your request. Occasionally it may take us longer than a month if your request isparticularly complex or you have made a number of requests. In this case, we will notify you
and keep you updated.
d. You have the right to:i.

Request access to your Personal data (commonly known as a “data subject
access request”). This enables you to receive a copy of the Personal data we holdabout you and to check that we are lawfully processing it
You may send an email to support@vault.ist requesting information as the Personal
data which we process. You shall receive one copy free of charge via email of the
Personal data which is undergoing processing.

ii.

Right to information when collecting and processing Personal data about you
from publicly accessible or third party sources. When this take places, we will
inform you, within a reasonable and practicable timeframe, about the third party or
publicly accessible source from whom we have collected your Personal data.

iii. Request correction or rectification of the Personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you
corrected and/or updated, though we may need to verify the accuracy of the newdata you provide to us. As mentioned, it is in your interest to keep us informed ofany changes or updates to your Personal data which may occur during the courseof your relationship with us.
iv.

Request erasure of your Personal data. This enables you to ask us to delete or
remove Personal data where:• there is no good reason for us continuing to process it;• you have successfully exercised your right to object to processing (see below);• we may have processed your information unlawfully; or• we are required to erase your Personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasurefor specific legal reasons which will be notified to you, if applicable, at the time of yourrequest. These may include instances where the retention of your Personal data is necessary
to:• comply with a legal or regulatory obligation to which we are subject; or• establish, exercise or defend a legal claim.
v.

Object to processing of your Personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your particularsituation which makes you want to object to processing on this ground as you feel it
impacts on your fundamental rights and freedoms. You also have the right to object
where we are processing your Personal data for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds toprocess your personal information that override your rights and freedoms.
vi.
Request restriction of processing of your Personal data. This enables you to
ask us to suspend the processing of your Personal data in the following scenarios:a.

if you want us to establish the data's accuracy;b.

where our use of the data is unlawful but you do not want us to erase it;c.
where you need us to hold onto the data even if we no longer require it, as youneed it to establish, exercise or defend legal claims; ord.
where you have objected to our use of your Personal data, but we need to verify
whether we have overriding legitimate grounds to use it.
vii.
Request the transfer (data portability) of your Personal data to you or to athird party. We will provide to you, or a third party you have chosen, your Personal data in a
structured, commonly used, machine-readable format. Note that this right only applies toautomated information which you initially provided consent for us to use or where we used theinformation to perform a contract with you.
viii.
Withdraw your consent at any time where we are relying on consent toprocess your Personal data (which will generally not be the case). This will not however affectthe lawfulness of any processing which we carried out before you withdraw your consent. Anyprocessing activities that are not based on your consent will remain unaffected.

Kindly note that none of these data subject rights are absolute, and must
generally be weighed against our own legal obligations and legitimate interests. If adecision is taken to override your data subject request, you will be informed of this by
our data protection team along with the reasons for our decision.
16.

Complaints

You have the right to lodge a complaint at any time to a competent supervisory
authority on data protection matters, such as (in particular) the supervisory authority in theplace of your habitual residence or your place of work.
We would, however, appreciate the opportunity to deal with your concerns before you
approach the supervisory authority, so please contact us in the first instance at
support@vault.ist
17.

Conclusion

We reserve the right to make changes to this Policy in the future, which will be duly
notified to you. If you have any questions regarding this Policy, or if you would like to send us
your comments, please contact us today or alternatively write to our data protection teamusing the details indicated in this Policy.