Vault Investments Inc.
Privacy Policy
Last Updated: May 19, 2017

The following privacy policy outlines the types of personal information that Vault Investments Inc. (“Vault”) collects, including that which is collected through Vault’s website (www.getvault.com) and our mobile applications for iOS and Android devices.

Our Commitment to You
Vault Investments Inc. (“Vault” or the “Advisor”) is committed to safeguarding the personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”).

Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Vault (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implement controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.

Vault does not sell or rent your personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as outlined further below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.

Applicability
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.

Information Collected
Vault collects various types of information when you visit the website, mobile application, sign-up as a customer, or otherwise, engage with Vault. Vault collects various types of anonymous information about visitors to the Vault site, including but not limited to:

This information is used to better understand our visitors, facilitate site navigation, provide the services or information you request, and enhance Vault’s services.

Work Savings Plans
When a company leverages Vault as a retirement plan facilitator, Vault collects information regarding both the company and the plan participants (the employees). This information may include but is not limited to, the company’s name, the email address of the company’s contact person and other relevant plan information. We will also collect plan participants’ relevant personal and financial information, such as participants’ legal names, social security numbers, date of births, annual income, addresses, length of service with the company, email addresses, and other contact information. Information regarding one’s occupation, contribution rates, and tax bracket may also be collected.

Additional Information Collection
In addition to the account opening process and those visiting the Vault site, Vault may collect your information or that of someone you know in the following circumstances:


Cookies

Similar to most online services and mobile applications, we use cookies and other technologies, such as web beacons, pixels and web storage to collect information about your activity, browser, and device. Most web browsers are set to accept cookies by default. If preferred, you may remove or reject browser cookies through the settings on your browser or device. However, removing or rejecting cookies may affect the availability and functionality of our services.

Analytics Services
Vault utilizes third-party analytics tools, such as “Google Analytics” in order to collect information about site traffic, overall use of the site, and previous sites visited before coming to the Vault site. Vault uses the information we receive from third-party analytic tools to improve our site, the user experience, and marketing efforts.

Among information collected, analytics service providers collect the IP address assigned to you on the date you visit this site, along with other information (e.g., browser type and type of device used to visit the site). Analytics services’ ability to use and share information about customer visits to the Vault site is restricted by their terms of use and privacy policies.

How Vault Uses Personal Information
Vault utilizes personal information in order to enhance the customer experience. Here are some examples of ways that Vault may leverage customer data:

As part of this process, we may from time to time aggregate some of your personal information in certain data analysis, reports, or other interpretations of investment trends for both internal and external purposes. When aggregating account data, Vault ensures that aggregated information is not identifiable to any one customer.

Sharing of Information
Vault does not sell, rent, or trade your personal information with any third parties, without your consent, unless required by law. In line with the services and products Vault offers, Vault may share customer information with third parties such as consumer identification verification services, public accounting firms and other service providers (including companies that perform marketing and analytical services). We require third parties that assist in providing our services to you to protect the personal information they receive from us. Vault may also disclose your information to other third-party financial firms, for example, if the customer asks to transfer assets to Vault from their previous financial institution.

Below are some scenarios through which personal information may be shared:

Servicing our Clients
We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting.

Marketing Purposes
Vault does not disclose and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Vault or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes.

Authorized Users
Your non-public personal information may be disclosed to you and persons that are your authorized agent(s) or representative(s).

Information About Former Clients
Vault does not disclose and does not intend to disclose, nonpublic personal information to non-affiliated third parties with respect to persons who are no longer our Clients.

State-Specific Regulations

California
In-line with California laws, we assume that accounts with California addresses do not want us to disclose personal information about them to non-affiliated third parties, except as permitted by California law. Vault also limits the sharing of personal information about customers with our affiliates to ensure compliance with California privacy laws.

Massachusetts
In response to a Massachusetts law, clients must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. We may disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account.

Protection of Customer Information
The Vault team works to safeguard your personal information from unauthorized use. In order to do this, we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage, and a secure office environment. Vault utilizes the strongest available browser encryption, store all of our data on servers in secure facilities, and implement systematic processes and procedures for securing and storing data. Access to customers’ financial data is limited to those employees who need to know customer information in order to perform their jobs. Moreover, Vault associates are trained on their responsibilities to protect client’s personal information. It is your responsibility to protect and maintain the confidentiality of your account, password and for restricting access to your computer.

How to Access & Change Personal Information Stored with Vault
Once a client registers with Vault, they may access, review, and revise their information stored with Vault. In accordance with U.S. regulatory requirements, Vault preserves all customer data for a minimum of three years.

By agreeing to the Vault Program Agreement during the initial application process and by continuing to use the Vault website, mobile application and/ or services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. 

Changes to our Privacy Policy
Vault may periodically revise this policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. In the case of a material change, Vault will do its best to notify you via email or through a site or mobile app notification. Vault will not revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personally identifiable information we collect.

Any Questions?
Contact us at 1 (866) 846-8874 or by email at support@getvault.com.

Vault
1455 N.W. Irving St, Suite 200
Portland, OR 97209

SIPC Disclosure
Please note that you can obtain information about SIPC, including the SIPC brochure, by visiting the website www.sipc.org or by calling (202) 371-8300.