Privacy Policy

Consent
By using our website & mobile application, you hereby consent to our Privacy Policy and agree to its terms outlined below. Consent is required for Vaultcomms Ltd. (“we” or “us”) to process your data. However, you can exercise your right to withdraw your consent at any time. If you do not agree to the terms outlined in this Privacy Policy document, please do not continue to use our services.

Introduction
At Vaultcomms Ltd, accessible at vaultcomms.com, one of our main priorities is your privacy. This Privacy Policy document contains types of information that is collected and recorded by vaultcomms.com from your use of our mobile application, our website at www.vaultcomms.com, or your interaction with our weekly newsletters sent to the email you provided when you first signed up. This document also outlines how we use & process your information.

Personal information may refer to information about you, your devices and/or your interactions with our services. This includes but is not limited to your name, location, phone number, email, engagement with our newsletters, commodity instruments in your portfolio, simulated capital investment allocations, trading performance and engagement with what news you read on our app.

By using or interacting with our services & products (i.e. visiting our website, subscribing to our newsletter, downloading our app, communicating with other users, & providing your personal information), you agree to the terms outlined in this Privacy Policy.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at jeffery.widjaja@vaultcomms.com.

Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. The information we collect from you may include but is not limited to:

• If you contact us directly, we may receive additional information about you such as your name, email address, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.
• When you subscribe on our website, we may ask for your contact information, including items such as name and email address. Upon subscribing to our weekly newsletters, you will be sent a weekly email starting from the date of subscription. We may be able to analyse your engagement with our newsletters, including but not limited to how many times you’ve opened our articles, replies you may send in response to our articles, and which articles you have opened.
• Data regarding the devices you use when accessing or engaging with our services and/or products. This may include information about the device’s operating system, network information, browser type, & geo-location data. This is to optimise our website, newsletters and/or our app to suit the jurisdiction where you’re based in.
• Data regarding your interactions & behavioural activity upon using our services and/or products, including but not limited to our website, our app and our weekly newsletters. This may include recording which pages you’ve visited, buttons clicked, commodity pages visited, commodities you’ve traded on our app, and date & timestamps of activity.

How we use your information
We use the information we collect in various ways, including but not limited to:

• Provide, operate, and maintain our services and/or products, including but not limited to our website, our app, and our newsletters
• Improve, personalise, and expand our services and/or products.
• Understand and analyse how you use our services and/or products, including but not limited to our website, our app, and our newsletters
• Develop new products, services, features, and functionality 
• Communicate with you, including for customer service, to provide you with updates and other information relating to the website, and/or for marketing and promotional purposes
• Send you weekly emails regarding informative content surrounding commodities
• Store & retrieve your account data so that your progress, activity and/or achievements are saved
• Supplement our marketing activities
• Find and prevent fraud

Sharing your data
We may share your personal information should such action be a necessity. Conditions that may satisfy this requirement includes but is not limited to:

• Legal & regulatory obligations
• Protect Vaultcomms Ltd. against any legal liability & to defend the rights and/or property of Vaultcomms Ltd.
• Protect the safety of our users and/or the public
• Investigate any crime or any wrongdoing in relation to using our products and/or services, including but not limited to our website, our app and our newsletters

We may also share your personal information to third parties. Reasons may include but are not limited:

• We are provided with market data from data aggregators that aggregate data from financial exchanges. We may be obligated to provide them with your details so they can verify & calculate overall engagement & usage of market data supplied by them
• Should we or our assets be acquired by a third party, we may be obligated to disclose your personal information to the prospective client
• As discussed above, we may be obligated to share your personal information to comply with any legal obligation or to enforce any of our agreements in place to protect our rights, our property, the safety of our users, and/or the public.

Cookies
Like any other website, vaultcomms.com uses ‘cookies'. These cookies are used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimise the users' experience by customising our web page content based on visitors' browser type and/or other information.
 
GDPR Privacy Policy (Data Protection Rights)
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions. We may require further information to confirm that it is indeed you exercising this right.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at jeffery.widjaja@vaultcomms.com.

Amendments to this policy
We are always looking for ways to improve and add to the Vaultcomms experience. This might mean that we will need to edit this privacy policy document on occasion. We will notify you if we do make any changes. If, however, you do not agree with any of the updated amendments, please do not continue to use our services. If you do continue to use our services, we will perceive this as your acknowledgement & acceptance of the updated privacy policy.