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Privacy Policy

Privacy Policy for Vault Pay

Effective Date: 02/10/2024

1. Introduction

This Privacy Policy explains how VENMOB LLC ("we", "our", or "us") collects, uses, and shares information about you when you use our mobile application Vault Pay (the "App") available on the Google Play Store and through our website.

By using the App, you agree to the collection and use of your information in accordance with this policy.

2. Privacy Policy Availability

This Privacy Policy is available on our Vault Pay Google Play Store listing page and within the App itself under the [Settings/Info] section.

3. Entity Reference

This policy applies to VENMOB LLC, as listed on the Google Play Store under the developer ZAKARIA DERICHE for the app Vault Pay.

4. Information We Collect

We collect the following types of personal and sensitive data when you use the Vault Pay app:

1. App Info and Performance

  • Crash logs, Diagnostics, and Other app performance data: We collect information about how the app performs on your device to improve the user experience. This may include crash reports, diagnostics, and other app-related data.
2. Personal Information
  • Name, Email Address, Address, and Phone Number: We collect this information when you sign up for our services or interact with the app in ways that require you to provide personal details. This data may be used for account creation, communication, and customer support.
3. Device or Other IDs
  • Device or Other IDs: We collect unique device identifiers to ensure a secure user experience, track app usage, and monitor app performance.
4. App Activity
  • We collect information on your in-app activity, which may include interactions with features and other usage data, to provide and improve the app's functionality.
5. How We Use Your Data
We use the collected data for the following purposes:
  • App functionality: To ensure proper operation of the app and its features.
  • Performance optimization: To monitor and improve app performance, including crash reporting and diagnostics.
  • Customer support: To assist you with any issues you may experience while using the app.
  • Communication: To contact you regarding your account, app updates, or other important notifications.

6. Data Sharing

We may share your data with third-party service providers who assist us with:

  • Data storage and security.
  • Analytics services for monitoring app performance and usage patterns.

We do not sell your personal information to third parties.

7. Data Security

We take reasonable measures to protect the personal data we collect from unauthorized access, use, or disclosure. These measures include encryption, access control, and secure data storage.

8. Data Retention and Deletion Policy

We retain personal data for as long as necessary to provide the services and fulfill the purposes described in this policy. Users may request data deletion by contacting us through the methods listed below.

9. Contact Information

If you have any questions or concerns about our privacy practices, or if you wish to submit an inquiry regarding your personal information, please contact us at:

Email: law@venmob.com
Mail: VENMOB LLC, 3790 EL CAMINO REAL PALO ALTO CA 94306

General Provisions

  1. According to the Joint Controller Agreement No. 20180919 from April 19, 2023, your personal data controller is the Vault Pay network. Contact details for Vault Pay are available on the Vault Pay website. Contact details for the data protection officer authorized by Vault Pay: law@vaultpay.com.

  2. Personal data collected by Vault Pay is processed in accordance with applicable legal protections for personal data. All employees, agents, and contractors of Vault Pay who know the secret of personal data must keep it secure even after termination of employment or contractual relationships.

  3. Vault Pay, in accordance with applicable legal requirements, shall ensure the confidentiality of personal data and the implementation of appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, accidental loss, alteration, destruction, or other unlawful processing.

  4. This Privacy Policy sets out the basic rules for the collection, storage, processing, and retention of your personal data, other information relating to you, the scope, purpose, sources, recipients, and other important aspects of your personal data when you use Vault Pay as a payment service provider.

  5. By accessing and/or using the information on this website and/or our services, you acknowledge and confirm that you have read, understood, and agree to this Privacy Policy. Also, after you register with the system and start using our services, this Privacy Policy becomes a Supplement to the General Payment Services Agreement.

  6. Vault Pay reserves the right, at its sole discretion, to modify this Privacy Policy at any time by publishing an updated version of the Privacy Policy on the website and, if the changes are substantial, notifying registered users by email. An amended or updated version of this Privacy Policy shall take effect upon its publishing on the website.

  7. If the user of the services is a legal entity, this Privacy Policy applies to natural persons whose data is transmitted to us by the legal entity. The user shall inform the data subjects (managers, recipients, agents, etc.) of the transfer of their data to Vault Pay in accordance with applicable legal requirements.

Data Processing Purposes. Data Providers, Deadlines, Recipients

  1. The main purpose for which Vault Pay collects your personal data is to provide payment services to clients who send and receive payments. As a payment service provider, Vault Pay is bound by law to establish and verify your identity prior to entering into financial services transactions with you. At the time of providing services, Vault Pay may also request further information, as well as assess and store this information for the retention period set out by legislation. Taking this into account, you must provide correct and complete information.

  2. PURPOSE: Client identification, provision of payment services (account opening, fund transfers, payment collection, and other services), and implementation of other legal obligations of the payment service provider.

    9.1. Personal data is processed for this purpose in compliance with legal requirements related to:

    9.1.1. Establishment and verification of the client’s identity;

    9.1.2. Conclusion and execution of agreements with the client or in order to take steps at the request of the client;

    9.1.3. Execution of fund transfers and transmission of the necessary information together with a transfer in accordance with legislation;

    9.1.4. Implementation of "Know Your Client" requirements;

    9.1.5. Continuous and periodic monitoring of the client’s activity;

    9.1.6. Risk assessment;

    9.1.7. Updating client data in order to ensure its accuracy;

    9.1.8. Prevention of possible money laundering and terrorist financing, prevention of fraud, detection, investigation, and informing of such activity;

    9.1.9. Ensuring proper risk and organization management.

    9.2. For this purpose, the following personal data may be processed: name, surname, national identification number, address, date of birth, a face photo, citizenship, data from an identity document and a copy of the document, direct video transmission recording, email address, phone number, current account number, IP address, current professional or work activity, current public function, and other data required by applicable legal acts.

    9.3. This personal data is collected and processed on the basis of a legal obligation imposed on the payment service provider and is required in order to open an account and/or provide a payment service.

    9.4. Data retention period: 10 (ten) years after the termination of the business relationship with the client. This personal data must be retained for 8 (eight) years according to applicable laws on the prevention of money laundering and terrorist financing. This data is retained for another 2 (two) years based on the legal interests of Vault Pay according to the ordinary limitation period of the lawsuit.

    9.5. Data providers and sources: the data subject directly, credit and other financial institutions and their branches, state and non-state registers, databases for checking the data of identity documents (databases of expired documents and other international databases), authority check registers, the Register of Incapacitated and Disabled Persons, the Population Register, other databases, companies processing consolidated debtor files, law enforcement agencies, legal entities (provided you are a representative, employee, founder, shareholder, contractor, or the real beneficiary of these legal entities), partners or other legal entities that engage us or are engaged by us in the provision of services, and other persons.

    9.6. Groups of data recipients: supervisory authorities, credit, financial, payment and/or electronic money institutions, pre-trial investigation institutions, state tax agencies, payment service representatives or partners of Vault Pay (if the transaction is carried out using their services), recipients of transaction funds receiving the information in payment statements, the recipient’s payment service providers and correspondents, participants, and/or parties related to national, European, African, and international payment systems, debt collection and recovery agencies, and other entities having a legitimate interest, under an agreement with Vault Pay or on other lawful bases.

10. PURPOSE: Debt management.

10.1. Personal data is processed to manage and collect debts, submit claims, and pursue legal action.

10.2. Data processed: name, surname, ID number, address, date of birth, ID document, email, phone, account number, IP, account statements, and other debt-related data.

10.3. Data retention: 10 years from the debt date, extended until repayment and for 24 months afterward, based on civil code limitations.

10.4. Data providers: subject directly, credit institutions, registers, debtor files (e.g., U.S. “Equifax”), other entities.

10.5. Data recipients: debtor file processors, financial institutions, lawyers, bailiffs, courts, tax agencies, and debt recovery agencies.

10.6. If debt is overdue for 30+ days, Vault Pay can share identity, contact, and credit history with debt databases and collection companies. Access your credit history through credit bureaus.


11. PURPOSE: Client relations and dispute prevention.

11.1. Personal data is processed to maintain business relationships, protect interests, prevent disputes, and assess service quality.

11.2. Data processed: name, surname, address, date of birth, email, phone, IP, account statements, call recordings, and correspondence.

11.3. Data retention: 5 years after the business relationship ends, extendable by 2 years upon request from authorities.

11.4. Data providers: subject directly.

11.5. Data recipients: supervisory authorities, debtor file processors, courts, tax agencies, debt recovery agencies, and others under agreement with Vault Pay.

  1. PURPOSE: Credit rating assessment, credit risk management, and automated decision making.

12.1. The personal data for this purpose is processed to assess the creditworthiness of clients, to manage the credit risk, and to meet the requirements related to operational risk management and capital adequacy, so that Vault Pay can offer to provide funding.

12.2. The following personal data may be processed for this purpose: name, surname, address, date of birth, email address, telephone number, payment account number, IP address, payment account statements, client's balance on the account, financial liabilities, credit and payment history, income, education, workplace, current work position, work experience, available assets, and data on relatives, and other information.

12.3. Data retention period: 10 (ten) years after the termination of the business relationship with the client.

12.4. Data recipients: credit, financial, payment and/or electronic money institutions or service providers assisting in the assessment of creditworthiness, and companies processing consolidated debtor files.

12.6. In order to conclude or offer to enter into a funding agreement with you and to provide you with services, Vault Pay will, in certain cases, apply decision-making based on the automated processing of your personal data. In this case, the system checks your creditworthiness with a set algorithm and assesses whether the service can be provided. If the automated decision is negative, it may be changed by the client providing more data. Vault Pay takes all the necessary measures to protect your rights, freedoms, and legitimate interests. You have the right to demand human intervention, express your opinion, and challenge an automated decision. You have the right to oppose an automated decision by contacting Vault Pay directly.

  1. PURPOSE: Protection of interests of Vault Pay and the client (video surveillance on the premises of Vault Pay).

13.1. Personal data for this purpose is processed in order to ensure the security of Vault Pay and/or the client, to protect the life and health of the client and/or their representative, and other rights of Vault Pay and the client (video surveillance and recording in the premises of Vault Pay) in pursuit of the legitimate interest to protect clients, employees, and visitors of Vault Pay and their property, as well as the property of Vault Pay.

13.2. For this purpose, the following personal data may be processed: video recordings on the premises managed by Vault Pay.

13.3. Before entering the premises of Vault Pay where video surveillance is conducted, you are informed about the surveillance by special markings.

13.4. Data retention period: 1 (one) year.

13.5. Data providers: the data subject directly who visits the premises of Vault Pay where video surveillance is conducted and is captured by the surveillance camera.

13.6. Data recipients: courts, pre-trial investigation institutions, lawyers (only in case of an attempt to attack).

  1. PURPOSE: Informing the client about services.

14.1. Personal data for this purpose is processed in order to inform the client about the services provided by Vault Pay, their prices, specifics, changes in the terms of the agreements concluded with the client, and for sending system and other messages relating to the provided Vault Pay services.

14.2. The following personal data may be processed for this purpose: email address, phone number.

14.3. The data subject confirms that they are aware that such messages are necessary for the execution of the General Payment Services Agreement and/or its supplements concluded with the client, and they are not considered to be direct marketing messages.

14.4. Data retention period: 24 (twenty-four) months after the termination of the business relationship with the client.

14.5. Data providers: the data subject directly.

14.6. Data recipients: the data for this purpose is not provided to other persons.

  1. PURPOSE: Direct marketing.

15.1. For this purpose, personal data is processed in order to provide clients with offers on the services provided by Vault Pay and find out the clients' opinions on the above-mentioned services.

15.2. The following personal data may be processed for this purpose: name, surname, email address, and phone number.

15.3. For this purpose, Vault Pay sends newsletters and direct marketing messages after obtaining the client's consent. Vault Pay may use a newsletter service provider while ensuring that said provider complies with the personal data protection requirements set out in the Joint Controller Agreement. The client may revoke their consent upon receiving newsletters or direct marketing messages by clicking on the Revoke your consent link as well as informing Vault Pay at any time about their refusal to process personal data for direct marketing purposes by e-mail support@VaultPay.com.

15.4. Data retention period: until the termination of the business relationship with the client or until the day the client objects to the data processing for this purpose.

15.5. Data providers: the data subject directly.

15.6. Data recipients: The data for this purpose may be transmitted to search or social networking systems (the possibility to object data processing is ensured by the websites of these systems), newsletter service providers.

  1. PURPOSE: Statistical analysis. Your personal data collected for the aforementioned purposes, except for the national identification number, identity documents and their details, also the exact place of residence, may be processed for the purpose of statistical analysis. For this purpose, personal data shall be processed in such a way that, by including it in the scope of statistical analysis, it is not possible to identify the data subjects concerned. The collection of your personal data for the purpose of statistical analysis is based on the legitimate interest to analyse, improve, and develop the conducted activity. You have the right to disagree and object to your personal data processing for such purpose at any time and in any form by informing Vault Pay thereof. However, Vault Pay may continue to process the data for statistical purposes if it proves that the data is processed for compelling legitimate reasons beyond the interests, rights, and freedoms of the data subject or for the establishment, exercise, or defence of legal claims.

  2. PURPOSE: Service improvement. The data collected for all of the above purposes can be used to improve technical and organisational tools, IT infrastructure, adapt services to the devices used, develop new Vault Pay services, enhance satisfaction with existing services, as well as test and improve technical tools and IT infrastructure.

  3. PURPOSE: Service misuse prevention and proper service delivery. The data collected for all of the above purposes may be used to prevent unauthorised access and use, i.e. to ensure privacy and information security.

  4. For the processing of personal data, Vault Pay may engage data processors and/or, at its own discretion, hire other persons to perform certain ancillary functions on behalf of Vault Pay (e.g. data centres, hosting, cloud hosting, system administration, system development, software development, provision, support services such as improvement and development; services of customer service centres; marketing, communication, consulting, temporary staffing, or similar services). In such cases, Vault Pay shall take the necessary measures to ensure that such data processors process personal data in accordance with Vault Pay's instructions and applicable laws, and shall require compliance with the appropriate personal data security measures. Vault Pay shall also ensure that such persons are bound by confidentiality obligations and cannot use such information for any purpose other than the performance of their functions.

  5. Personal data collected for the purposes specified in this Privacy Policy shall not be processed in any ways incompatible with these legitimate purposes or legal requirements.

  6. The data referred to above will be provided and received through a software tool used by Vault Pay or its authorised agent, also by other means and third persons with whom Vault Pay has entered into personal data processing agreements in accordance with laws and regulations.

Geographical area of processing

  1. Generally, personal data is processed within the African continents/ European Union/European Economic Area (EU/EEA) but may in certain cases be transmitted and processed outside the EU/EEA.

  2. Personal data may be transferred and processed outside the EU/EEA where the transfer is necessary for the conclusion or execution of a contract (for example, when a payment is carried out to a third party or through a third party partner (correspondent)) or for example, when the client carries out commerce activities using an online platform (is a registered user) where payment service providers of registered users are subject to specific customer information requirements when law provisions stipulate the need for the transfer, or when the client gave their consent. We seek to ensure that appropriate technical and organisational measures are in place in all of these cases as indicated in the Joint Controller Agreement.

Profiling

  1. Profiling carried out by Vault Pay involves the processing of personal data by automated means for the purposes of legislation relating to risk management and continuous and periodic monitoring of transactions in order to prevent fraud; such ongoing profiling is based on the legal obligations of Vault Pay.

  2. For the purpose of direct marketing and statistical analysis, profiling may be carried out using Matomo, Google, Facebook, and other analytics tools.

Processing the personal data of minors

  1. A minor under 14 (fourteen) years of age, seeking to use the payment services of Vault Pay, shall provide written consent from their representative (parent or legal guardian) with regard to their personal data processing.

Cookie policy

  1. Vault Pay may use cookies on this website. Cookies are small files sent to a person's Internet browser and stored on their device. Cookies are transferred to a personal computer upon first visiting the website.

  2. Usually, Vault Pay uses only the necessary cookies on the person's device for identification, enhancement of the website functionality and use, and facilitating a person's access to the website and the information it contains. Vault Pay may use other cookies upon receiving the client's consent. You will find a brief description of different types of cookies here:

  • Strictly necessary cookies. These cookies are essential for the website to function and cannot be turned off in the Vault Pay system. They are usually set in response to actions taken by you, like setting your privacy preferences, logging in, or filling in forms.

  • Performance cookies. These cookies allow the website to count visits and traffic sources so that Vault Pay can measure and improve the performance of the website. They help Vault Pay to know which pages are the most and least popular and see how visitors move around the site.

  • Functional cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by Vault Pay or by third-party providers whose services have been added to the pages of Vault Pay. If you do not allow these cookies, some or all of these services may not function properly.

  • Targeting cookies. These cookies may be set through Vault Pay's site by its advertising partners. They may be used by those companies to build a profile of your interests and show you relevant ads on other sites. They do not store directly personal information, but they are based on uniquely identifying your browser and device.

  • Social media cookies. These cookies are set by a range of social media services that are added to the site to enable you to share our content with your friends and networks. They can track your browser across other sites and build a profile of your interests. This can impact the content and messages you see on other sites you visit.

  1. You can set your browser to refuse cookies or to alert you when cookies are being sent. However, if you do not accept cookies, you may not be able to use some features of the Vault Pay service.

  2. Your browser may also allow you to delete cookies. If you want to delete cookies, you will need to do this separately for each browser and device you use.