PRIVACY POLICY

• Details about your device, browser, or operating system; time zone setting;
• Your IP address, anonymized to protect your privacy;
• Information about interactions you have with the Website (such as scrolling and clicks);
• Referral Source: How you arrived at our website (e.g., via a search engine or direct link).
• Demographic Information: Such as age, gender, and interests (this is anonymized and based on Google's demographic reports)

• Communication with you
• Provision, execution and administration (including support) of Services
• Marketing, improvement and maintenance of Services as well as services and product development
• Security and prevention
• Compliance with statutory and regulatory requirements
• Protection of rights

• 6.1 Lawful basis for processing 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 have asked us to do so, or consented to us doing so;
  • Where it is necessary for the performance of a Service or in order to take steps at your request prior to providing the Services;
  • Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests;
  • Where we need to comply with a legal or regulatory obligation.
  
  You will receive marketing messages from us by email if you have given us your consent to do so. To unsubscribe from marketing emails at any time and without cost, please click on the unsubscribe link at the bottom of any marketing email. You may also contact us (info@vultisig.com) to inform us if you do not wish to receive any marketing materials from us.
  
  
• 6.2 Sharing your personal information

  If we collect personal data in the future, we may share it in the following ways:

  • with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
  • with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them (see “Service Providers” below); or
  • with analytics that assist us in the improvement and optimisation of the Services.
  
  

  We may also disclose your personal data to third parties in the following events: if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets;

  If Vultisig or substantially all of its assets are acquired by a third party, in which case personal data held by us about our users will be one of the transferred assets; or

  if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging personal data with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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  6.3 Service Providers

  Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.

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  6.4 Other Disclosures

  During your use of the App, your app store provider and mobile network operator may also collect personal data about you regarding your use of the App such as your identity, your usage and location.

  These third parties shall act as separate and independent controllers of that personal data and shall process it in accordance with their own privacy policy.

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  6.5 Links to third party sites

  The Website and App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We may also provide links to third party websites that are not affiliated with the Website and App. All third-party websites are out of our control and are not covered by this Privacy Policy. If you access third party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

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  6.6 How long we keep your personal data

  We will hold your personal data on our systems only for as long as required for the purposes of processing and compatible purposes, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

  In some circumstances you can ask us to delete your personal data: see ‘Your Rights’ below for further information.

  In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Vultisig takes the protection of your personal data very seriously. We have put in place appropriate technical, organizational, physical, electronic and managerial security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers, passwords and industry standard encryption for data both in transit and at rest.

Where we have given you a password or PIN code that enables you to access certain parts of our App, you are responsible for keeping this password or PIN code confidential. We ask you not to share a password or PIN code with anyone.

When first launching the App, it creates an individual encrypted digital wallet, i.e. a private key, for every user to store his/her crypto assets. Vultisig does not have, at any point in time, access to the user’s private keys and funds. You are responsible for keeping your private key confidential. We ask you not to share your private key with anyone. If you lose or give away your private key, you lose or give away your crypto assets.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business, need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We may disclose your personal information to service providers and other recipients located outside of Australia. These entities may assist us with various services, including fulfilling your requests for information, products, and services, and providing support services.

When we disclose your personal information to an overseas recipient, we take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to your information. This may include:

• Ensuring the recipient is located in a country that has laws substantially similar to the APPs, providing an adequate level of protection for your personal information.
• Entering into a contract with the recipient that requires them to handle your personal information in a manner consistent with the APPs.
• Obtaining your consent to the disclosure, after informing you that the overseas recipient may not be required to comply with the APPs and you may not be able to seek redress under the Privacy Act.

In some cases, we may be required to disclose your personal information to overseas recipients by law, or where it is necessary for the performance of a contract with you or in other legally permitted situations.

By providing us with your personal information, you consent to the disclosure of your information to overseas recipients on these terms.

If you have any questions or would like more information about how your personal information is handled, please contact us at info@vultisig.com.

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have as well as how you can exercise them (provided that the applicable conditions are met and subject applicable statutory exceptions).

• 9.1 Right of Access

  You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

  Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

  You can exercise this right at any time by writing to us (info@vultisig.com) and telling us that you are making a “subject access request”. You do not have to fill in a specific form to make this kind of request.

• 9.2 Your Right to Rectification and Erasure

  You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. Please note that we may ask you to verify any new personal data that you provide to us and may take our own steps to check that the new data you have supplied us with is right.

  You may also ask us to erase personal data that we control if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). Although we will do everything to respect your request and personal data, it may not always be possible to erase all of your personal data as there may be legal requirements to keep certain personal data or technical limitations to the data we can delete.

  There may also be legitimate interests in keeping certain personal data including, amongst others, if the personal data is required for the App to function. If this is the case, we will continue to process this personal data.

  If erasure is not technically possible or we believe that we have a good legal reason to continue processing personal data that you ask us to erase, we will tell you this and our reasoning at the time we respond to your request.

  You can exercise this right at any time by writing to us (info@vultisig.com) and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

• 9.3 Your Right to Restrict Processing

  Where we process your personal data on the basis of a legitimate interest, you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

  You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

  Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

  You can exercise this right at any time by writing to us (info@vultisig.com) and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

• 9.4 Your Right to Portability

  Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party, you may write to us and ask us to provide it to you in a commonly used machine-readable format.

  Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

• 9.5 Your Right to object to processing

  You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

• 9.6 Your Right to stop receiving marketing communications

  To unsubscribe from receiving marketing messages at any time, please click on the unsubscribe link at the bottom of any marketing email and update your notification preferences in the App. For details on your rights to ask us to stop sending you various kinds of communications, please contact us (info@vultisig.com).

  9.6.1 8.7 Your Right to object to automated Decision Making and Profiling You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

• 9.7 Withdrawal of Consent

  Where we are relying on consent to process your personal data, you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• 9.8 Exercising your rights

  When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

  It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case, we will tell you).

  For contact information to make a request or exercise your right, see also below under section 11.

We use various techniques on our Website that allow us and third parties engaged by us to recognize you during your use of our Website and possibly to track you across several visits. This Section informs you about this.

In essence, we wish to distinguish access by you (through your system) from access by other users, so that we can ensure the functionality of the website and carry out analysis and personalization. We do not intend to determine your identity, even if that is possible where we or third parties engaged by us can identify you by combination with other data. However, even without registration data, the technologies we use are designed in such a way that you are recognized as an individual visitor each time you access the website, for example by our server (or third-party servers) that assign a specific identification number to you or your browser (so-called «cookie»).

Cookies are individual codes (for example a serial number) that our server or a server of our service providers or advertising partners transmits to your system when you connect to our website, and that your system (browser, cell phone) accepts and stores until the set expiration time. Your system transmits these codes to our server or the third-party server with each additional access. That way, you are recognized even if your identity is unknown.

Whenever you access a server (for example when you use the Website , or because an e-mail includes a visible or invisible image), your visits can therefore be «tracked». If we integrate offers from an advertising partners or a provider of an analysis tool on our Website they may track you in the same way, even if you cannot be identified in a particular case.

We use these technologies on our Webite and may allow certain third parties to do so as well. However, depending on the purpose of these technologies, we may ask for consent before they are used. You can access and change your current settings here[link]. You can also set your browser to block or deceive certain types of cookies or alternative technologies, or to delete existing cookies. You can also add software to your browser that blocks certain third-party tracking. You can find more information on the help pages of your browser (usually with the keyword «Privacy») or on the websites of the third parties set out below.

Currently we only use the following cookies:

• Analytical Cookies: Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.

We currently use offers from the following service providers and advertising partners (where they use data from you or cookies set on your computer for advertising purposes):

• Google Analytics: Google LLC is the provider of the service «Google Analytics». For the purposes of the GDPR and the Australian Data Protection Act (DPA), Google Ireland Ltd. is the controller (both «Google»). Google tracks the behavior of visitors to our Website (duration, page views, geographic region of access etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our Website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. Google provides us with reports and may therefore be considered our processor, but it also processes data for its own purposes. Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals. You should assume that this processing takes place if you consent to the use of performance cookies. Information about data protection with Google Analytics can be found here and if you have a Google account, you can find more details about Google's processing here.

If you have any questions or concerns relating to this Privacy Policy or the processing of your personal data, please contact us as follows: