Privacy Policy


Introduction:
Effective: February 20, 2019

Your privacy is important to us. This Privacy Policy sets out the foundation on which SecurelyShare Software Private Limited built its platform Vault.Direct. This sets forth SecurelyShare Software Private Limited (“SecurelyShare”, “Vault.Direct”, “we”, “us”, or “our”) privacy practices in connection with SecurelyShare’s websites located at securelyshare.com(“Site” or “Sites”), the Vault.Direct mobile applications, the Vault.Direct web browser extensions, and the Vault.Direct plugins (collectively, the “Services”). This Privacy Policy applies only to information collected by SecurelyShare from users of our Services and visitors of our websites. This Privacy Policy does not apply to information collected by SecurelyShare in other ways, including offline. Access to the Services is provided pursuant to the Terms of Service accessible on our Sites and Services. Capitalized terms used but not defined in this Privacy Policy, shall have the meaning set forth in the Terms of Service.

Summary

Because SecurelyShare integrates with a variety of content imported, with your authorization, from your email, contacts and other services, we take precautions to ensure that your personal information is protected.

Rather than a dense legalistic Privacy Policy, we have tried to write a clear, open and transparent Privacy Policy that an average human can understand without retaining a lawyer. Here are a few highlights about the Personal Information1 and/or Sensitive Personal Information2 we collect through our Services, how we use it, and your choices about its use:

  • We won’t sell your data.
  • We won’t spam your email or social networks.
  • We’ll be open and transparent as to how we will use your information within SecurelyShare.

You must be 18 years old or the age of majority in your jurisdiction in order to use our website. Otherwise, it is advised to have parental consent to proceed to use the Services.

Information About You

We use your Personal Information to communicate with you, provide you with our Services, and to help us improve our Services. We collect your name and contact information as well as your Third Party Login Credentials for each Third Party Platform (as defined below), and if you purchase our Premium Services, we also collect your payment information through third-party online payment services.

We use cookies and other technologies to keep track of your use of our Services and to provide a personalized experience. Cookies are described and discussed below. We also use cookies to help us measure usage and improve the quality of our Services.

By using our Services, you indicate your consent for SecurelyShare/Vault.Direct/Us to send cookies to your computer or other devices in order to uniquely identify your browser and improve the quality of our Services. You may turn off cookies in your browser however, in doing so, some or all of our Services may not work.

Your Privacy Choices

You may review and correct your Personal Information and preferences.

You may opt-out of marketing and promotional emails from us.

You may execute your right to forget.

Important Information

We will update the “last updated” date to indicate the effective date of any changes to our Privacy Policy.

How to Reach Us if You Have a Question

By email to privacy@securelyshare.com.

Protecting Your Data and Ensuring Your Privacy at SecurelyShare

The SecurelyShare Services

Vault.Direct is an intelligent inbox in the hand of end users to receive store and share files, messages, notifications, etc. designed specifically to enable secure and trusted communication with enterprises.

Third Party Platforms

“Third Party Platforms” are software that integrate with our Services and that you have authorized to connect with us. This may include email, calendar, messaging, file storage, phone services, note taking, reminders, social networking, and other cloud services such as Office 365, Gmail, Slack, Facebook, Dropbox, Digilocker, Evernote and other similar platforms from which you authorize us to import, search, and access, content.

What Is Personal Information?

“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, address, telephone number, mobile number or e-mail address, an identification number, location information, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. “Sensitive Personal Information” means racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union members, the processing of genetic, biometric data for purposes of uniquely identifying a natural person, and information concerning an individual’s health, sex life, or sexual orientation. We treat your Personal and Sensitive Personal Information as confidential.

“Other Information” is any information that is not Personal Information or Sensitive Personal Information. Personal Information does not include anonymized or “aggregate” information, or publicly available information that has not been combined with Personal Information or Sensitive Personal Information.

What Information Do We Collect And When Do We Collect It?

We may collect your Personal Information in the following circumstances:

  • When you voluntarily provide it to us, such as when you register for an account by creating a username and password (“Vault.Direct Login Credentials”), send us an email or post information or other content to our Site or Service;.
  • When you choose to sign in to, or create a Vault.Direct account, using a Third Party Platform login (for example, by choosing the “Sign in with Google” option on the Vault.Direct Services);
  • When you connect a Third Party Platform with your Vault.Direct account we may collect your credentials to that Third Party Platform if this is required in order to connect;
  • If you apply for or purchase a Premium Service requiring billing or payment information on our Websites, we require that you provide certain additional Personal Information, including your address, phone number, and credit card number (“Payment Information”). This information is necessary to process your requests and to contact you.
  • We may also collect Personal Information about you from your employer when your employer engages us to provide the Services to you. For example, we may obtain your name and email address from your employer.
  • When you utilize the Services, we also receive certain Other Information about you or your use of the Services. Such Other Information may be collected using various technologies, including:

Logs

We track the data you see in SecurelyShare and how you interact with it by automatically collecting certain information such as, the pages you visit or features you use within the Services, the date and time of your activities on the Services, the URLs from the websites you visit before and after navigating to the Services, your software and hardware attributes (including operating system type and version, App version, device type, and device identifiers, including IDFA and/or Advertising IDs), your browser type and version, and your general geographic location derived through your IP address (e.g., your city, state, or metropolitan region). To obtain such information, we may use web logs or applications that recognize your device and gather information about its online activity. We treat this information as Private Data if we combine it with or link it to any of the your Personal Information. Otherwise, it is used in aggregate form only. We use tracking data about individuals in an aggregated form to inform us about how Vault.Direct is being used to help us provide a better user experience.

Cookies

Like almost all websites today, SecurelyShare uses cookies to determine whether you are logged in on your computer and to recognize repeat visitors. We send cookies to your computer in order to uniquely identify your browser and improve the quality of our Services. Cookies are small pieces of information that a website sends to your computer's hard drive while you are viewing a site. We may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them). If you wish to restrict or block the cookies which are set by SecurelyShare, or by any other website, you can do this through your browser settings. Please note, if you choose to disable cookies, some of our Services may not work properly or at all.

Web beacons

The Services or the emails that you receive from us may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email.

Local storage

We may collect and store information (including Personal Information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

SecurelyShare keeps Personal Information contained in your cookies and obtained through the other tracking technologies confidential. We do not set any cookies outside of the Sites.

We also may partner with certain third parties to collect, analyze, and use some of the Personal and Other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from SecurelyShare. This information may be used for a variety of purposes, including analytics and online behavioral advertising.

Your Content

When you authorize us to access Third Party Platforms, we collect, store, and process “Content” on your behalf. Content are all communication records and documents (including your contacts, messages, files, call records, notes, meetings, email and other similar information) from Third Party Platforms that you have authorized us to access, similar information you directly enter in Vault.Direct (for example, when sending emails, creating new contacts, adding notes, setting reminders, etc.), as well as information Vault.Direct discovers and provides to you (for example, public information about your contacts, when contacts of yours open files you sent from Vault.Direct, etc.). By its nature, Content will often contain Personal Information (for example, an email will contain the sender and recipient’s email addresses).

We have no direct relationship with the individuals whose Personal Information is contained in your Content. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to you. We provide tools to allow you to export, delete, or update Content so you can comply with these requests.

How Do We Use the Information We Collect?

We use your Personal Information and Other Information collected through our Services for the following purposes:

  • to provide you an encrypted single vault to store and manage your secure information;
  • to enable you to share Content and communicate with other users;
  • to provide our Services or information you request, and to process and complete any transactions;
  • to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
  • to monitor and analyze usage of the Services and trends, and to personalize and improve our Services and our users’ experiences on our Services, such as content, or features that match their profiles or interests, and to increase the functionality and user friendliness of our Services;
  • to send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, our Services;
  • to contact you about the Services in which you have expressed interest or that might be of interest to you; and
  • for any other purpose for which the information was collected.

User Communications

You may choose to provide us with another person's e-mail address so that person may be invited to create an account on our Service. By providing us with another person's e-mail address, you represent to us that you have obtained the consent of the person concerned as regards such disclosure to us of that e-mail address. We may disclose such information if required to do so in order to comply with legal process, as described above.

Links to Other Sites

Our Services may contain links to other sites. Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from our Services.

What Steps Do We Take To Protect Your Information Online?

Securelyshare uses our patented and high standard Military grade 256 bit encryption that safeguards to help protect against loss, unauthorized access, destruction, and disclosure of your personal information. While we take reasonable steps to protect your personal information as outlined in this Privacy Policy, we cannot ensure or warrant our ability to do so because unfortunately no internet transmission is 100% secure and any transmission of your personal information via our website is at your own risk. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

What Choices Do You Have Regarding the Use of Your Information?

You may withdraw your consent to process your Personal Information at any time. If you do so, you will be unable to use the Services.

You may “opt out” of receiving marketing or promotional communications from us by following the instructions in those communications or by emailing us at unsubscribe@securelyshare.com. If you opt out, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.

Your Rights: Reviewing, Changing or Deleting Your Information

You may review, update, correct or delete the Personal Information in your account from within the Service itself or by contacting us at support@securelyshare.com. By deleting your data in your account, we may deactivate your account. You may request deletion of your data at any time. Your account will be closed after a period of inactivity of six months or such other period of time as we may choose from time to time. You also authorize us, on your behalf, and in accordance with your account preferences to delete information when not reasonably needed for the Services. If you have shared your Content with others and they have not deleted it, or it was copied or stored by other users, SecurelyShare will not be obligated to delete such information.

If you are an EU or Swiss individual, you have the right to object to processing and to data portability, in some circumstances, as well as the right to lodge a complaint with a supervisory authority.

Retention of Your Information

We retain information for as long as reasonably necessary to deliver our Services to you or to fulfill the purposes described in this Policy. You may delete the Personal Information in your account as described above. Please note that, in limited circumstances, we may retain information for a longer period of time as required by law.

Right to Forget

Securelyshare is committed to protect user information and will strive to address any need to delete or erase data, if the end user has a genuine request. However, this may not be possible to erase data completely based on Securelyshare business Continuity or further dependencies. We ensure the data is not used further from the time of approval of our Data Protection Officer or Privacy office has approved the request. You may contact privacy@securelyshare.com for more clarifications

Minors

Our Services are not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, he or she should contact us at support@securelyshare.com. If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information from our files.

Dispute Resolution

In compliance with the EU-US and Swiss-US Privacy Shield Principles, SecurelyShare commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact SecurelyShare at privacy@securelyshare.com.

International Transfer

The Services are operated from and hosted on servers located in the United States. Your information may be transferred around the world to countries in which we do business, including to affiliates, service providers or third parties, which may be located in jurisdictions that may not have the same level of data protection laws as those in your home country. By using the Services or by providing any personal information to us, you expressly consent to such transfer and processing.
With regards to any personal information transferred to other locations, SecurelyShare is committed to complying with the local frameworks/guidelines like and not limited to U.S.-E.U. Safe Harbor Framework and U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding its handling of personal information from European Union member states and Switzerland.

Lawful Bases for Processing

We will only collect and process Personal Information about you where we have lawful bases. Our lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, such as when you purchase a Premium Service) and our legitimate interests (such as to comply with applicable laws and enable or administer our business).

Information for California Residents

If you are a California resident under 18 years of age and a registered user of our Services, you may request that we remove content and information that you publicly post on our Services. To obtain removal of such content and information, please send us an email at privacy@securelyshare.com with a short description of the content or information you would like to have removed. Please note that such a request does not necessarily ensure complete or comprehensive removal of content posted by you, since the content and information may remain in our databases, may remain visible in a manner that does not identify you, or may have been re-posted by another user.

Changes to our Privacy Policy

We may update this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes on this page with an “effective date” indicating when the changes will take effect. We encourage you to review this Privacy Policy periodically. If you have questions or concerns regarding our Privacy Policy, please contact us at: privacy@securelyshare.com.

Questions

If you have any questions relating to this Privacy Policy, you may contact us at privacy@securelyshare.com or at:

Data Protection Officer
No. 1133, First Floor,
Anand Embassy,
100 Ft Road, HAL 2nd Stage,
Indira Nagar, Bengaluru – 560038
India

Appendix

  1. “Personal Information” identifies a person, whether by itself, or together with other information in the organisation's possession, or is likely to come into its possession; and is a living person and affects that person's privacy (whether in his/her personal or family life, business or professional capacity) in the sense that the information has the person as the focus or is otherwise biographical.
  2. “Sensitive Personal Information" is information about an individual's: racial or ethnic origin;
    political opinions;
    sex life;
    biometric;
    generic;
    trade union membership;
    physical or mental health or condition;
    religious beliefs or other beliefs of a similar nature;
    commission or alleged commission of any criminal offence; and
    proceedings for any offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings.