Last Update: August 10, 2017

This Privacy Policy by TrueVault, Inc., and affiliates and other entities (each, an Affiliate, with TrueVault and its affiliates collectively called here "TRUEVAULT" or "We") explains what type of information may be gathered or tracked on our Site or Services (as defined in our Terms of Service, "TOS", available at, how such information may be used and with what other parties the information is or may be shared.

YOUR PRIVACY IS IMPORTANT TO US. We understand your and share your concerns about the privacy of information and Content you may provide to us or store through our Services and in this Privacy Policy attempt to explain as clearly as possible what we do with your information and, if applicable, how we collect it. Please read this policy carefully as it also explains how you may verify the accuracy of any Personal Information we have concerning you and how you may request TRUEVAULT delete or update your Personal Information. By using our Site ( and any other URLs that we may operate or make available from time to time) and/or Services you consent to this Privacy Policy.

Please also review carefully our Terms of Service that provides the terms, conditions, disclaimers, and limitations of liability governing the use of our Services and if you are or intend to become a subscriber to our Services, your use and access to the Site and Services will be further conditioned upon your agreement to the Terms of Service.

EU-U.S. Privacy Shield & Safe Harbor Privacy Statement

TrueVault has established a comprehensive privacy program, including a global privacy office and a chief privacy officer, designed to help us respect and protect your data privacy rights. This statement includes both TrueVault's EU-U.S. Privacy Shield and Safe Harbor Privacy Statement and the Website Privacy Statement.

For personal information of employees, consumers, healthcare professionals, medical research subjects and investigators, customers, investors, and government officials that TrueVault receives from the European Economic Area, TrueVault has committed to handling such personal information in accordance with the Safe Harbor Principles. TrueVault's Safe Harbor certification can be found at For more information about the Privacy Shield and Safe Harbor Principles, please visit the U.S. Department of Commerce's Website at

For more information about the EU-U.S. Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website.

For more information about U.S.-Swiss Safe Harbor and to view our certification, visit the U.S. Department of Commerce’s Safe Harbor website.

TrueVault believes in protecting your privacy. When we collect personal information from you on our website, we follow the privacy principles of (an independent resource mechanism) and comply with the EU-U.S. Privacy Shield and Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union. These are our promises to you:

  • Notice. When we collect your personal information, we'll give you timely and appropriate notice describing what personal information we're collecting, how we'll use it, and the types of third parties with whom we may share it.
  • Choice. We'll give you choices about the ways we use and share your personal information, and we'll respect the choices you make.
  • Relevance. We'll collect only as much personal information as we need for specific, identified purposes, and we won't use it for other purposes without obtaining your consent.
  • Retention. We'll keep your personal information only as long as we need it for the purposes for which we collected it, or as permitted by law.
  • Accuracy. We'll take appropriate steps to make sure the personal information in our records is accurate.
  • Access. We'll provide ways for you to access your personal information, as required by law, so you can correct inaccuracies.
  • Security. We'll take appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction.
  • Sharing. Except as described in this policy, we won't share your personal information with third parties without your consent.
  • International Transfer. If we transfer your personal information to another country, we'll take appropriate measures to protect your privacy and the personal information we transfer.
  • Enforcement. We'll regularly review how we're meeting these privacy promises, and we'll provide an independent way to resolve complaints about our privacy practices.

EU-U.S. Privacy Shield Onward Transfers

For personal data transferred from the EU, if we transfer your personal data to a third party, we will ensure that the third party is contractually obligated to process your data only for limited, specific purposes consistent with this policy. We will also ensure that the third party will apply the same level of protection to that data as the EU-U.S. Privacy Shield Principles and will notify us if it makes a determination that it can no longer meet this obligation. Truevault may be potentially liable if these requirements are not met.

Complaints, Questions, and Arbitration

In compliance with the EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Principles, we strive to resolve all complaints about privacy and the collection or use of customer information. If you have questions about our participation in the Privacy Shield or Safe Harbor programs or have a complaint, please send an e-mail to Under the Privacy Shield and Safe Harbor programs, any unresolved privacy complaints can be referred to an independent recourse mechanism. We use the If you feel that we have not satisfactorily addressed your complaint, you can go to in order to file a complaint. In some cases, you may be able to invoke binding arbitration.

What information do we collect?

"Personal Information" (including, but not limited to, your name, company, address, telephone number, payment account information and e-mail address) may be collected when you order Services, register with our site for other information or contact us with a specific concern, information request or question. We may also collect any relevant comments provided with any question or inquiry and information, if requested, about your company, industry, number of employees and such other related information.

We may also collect non-personally identifiable and anonymous "Aggregate Information" (for example, tracking the number of visitors to our Site, where visitors enter our site, how long they remain, etc.) in connection with the operation of our Site and Services. Other than Personal Information you supply to us voluntarily or the Aggregate Information that may be gathered via cookies, as described in this policy, TRUEVAULT does not at this time collect Personal Information in connection with your use of this Site.

If you are a subscriber or user of TrueVault's Services, you provide us, through your acceptance of the TOS, with your Content (as further defined in the TOS), which may contain your personal information or other personal or sensitive information (i.e., Protected Health Information) of your clients and other third parties.

How and what do we use your information for?

We will use the information described above that you submit:

  • To answer your specific inquiry;
  • To personalize your experience with the Site and/or Services;
  • To improve customer service, using your information to help us more efficiently respond to service requests and support needs;
  • At your option, to send additional materials relating to TrueVault and Services that may be of interest to you or to send you periodic emails using the email address you provided for Services – such emails may provide information and updates pertaining to your services, additional services being introduced, as occasional news, updates, service information and status, etc.;
  • To aid in the administration of the Site and Services;
  • To process transactions, in which case your information, whether public or private will not be sold, exchanged, transferred or given to any other company ("Information Sharing") other than as provided herein, without your consent - excluding Information Sharing conducted for the express purpose of delivering the purchased Services or in the case of an acquisition, merger, sale or change in control of TRUEVAULT in which case no consent by you is required; or
  • As otherwise described in this policy.

TRUEVAULT may, from time to time, share your Personal Information with trusted third party consultants, in which case, the consultants shall use your Personal Information solely to assist TRUEVAULT, at its request, with its Services, Site and operations, and any such consultants shall be required to comply with the terms of this policy and obligations of confidentiality and data security. We may also release your information when we believe release is appropriate to comply with the law, enforce our Site and Services' policies, or protect our or others' rights, property or safety.

We do not, at this time, share any Aggregate Information that we may collect with other parties for marketing, advertising or other such uses.

How we use cookies and other technologies.

As noted above, when you visit the Site or utilize Services various general information regarding your browser, operating system, IP address, domain name and the like that you use to access the Site and Services from is automatically collected as part of Site and Services' normal operations.

As part of such Aggregate Information we may collect details about your browsing behavior, such as, but not limited to, the number of times and dates you have visited the Site or Services, and the amount of time you spend viewing the Site or using the Services, if applicable. In addition, TRUEVAULT may track your response to our e-mails, including, for example, learning how many users open an e-mail and compiling aggregated statistics about e-mail and other activities conducted for TRUEVAULT. Such information is used solely for our internal purposes and in assisting us in enhancing customer experiences, support and the usability and efficiency of our Site and Services.

Although we do not do at this time, in addition to our own cookies for the above purposes, we reserve the right to use "transparent GIFs," on our sites to help manage any online advertising or e-mail marketing we may conduct in the future. These GIF files are commonly used and provided by one or more third-party service providers, and enable service providers to recognize a unique cookie in your web browser to learn which advertisements or e-mails brought you to our website and how you use the site. To conduct these or other activities, we or our service providers sometimes may link Personal Information you previously provided us (such as, for example, your name and e-mail address) to the information the GIF files provide about how you arrive at, navigate through and leave our sites.

You may choose not to accept any such cookies and our Site will still work if you choose to do so, by adjusting the privacy and cookie settings available in your web browser. You should refer to your browser's help file and other directions to learn how to do this. Note, that under certain circumstances blocking all cookies may restrict the sites you can visits and may affect your use of our Services.

What Personal Information may we disclose to outside parties?

Subject to applicable law, we and our various Service Providers (defined below) may disclose and share your Personal Information:

  • Within TRUEVAULT;
  • To unaffiliated third parties under contract to perform services for or on behalf of TRUEVAULT ("Service Providers"), who are required to uphold and maintain privacy and security policies with respect to privacy and the treatment of your Personal Information;
  • To a third party in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or division of TRUEVAULT; and
  • To other such persons or agencies as permitted or required by applicable law or regulations.

For debit, credit card and ACH payments, we of necessity employ third parties to process payments on our behalf. These third-party processing parties will only have access to the information you provide that allows them to fulfill your payment. They are required under agreements with TRUEVAULT to process this information securely and in accordance with the relevant privacy or data protection laws, standards, regulations and best practices.

How we protect and store your information.

TRUEVAULT takes the security of the information it collects through its Site and Services seriously and in response implements a variety of security measures designed to reduce the risk of unauthorized disclosures and accidental destruction or loss of your Content and to maintain the safety of your personal information using methods appropriate to the nature of the data and information provided to us by you.

Personal Information collected via this Site and Services is stored on servers located in the United States, and these servers are subject to TRUEVAULT's IT security policies and procedures. To discuss the security programs, procedures and policies that we have selected and utilize to reasonably secure your personal information and Content, please contact your TRUEVAULT representative or contact us through our Site. We will be happy to discuss our security program with you.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. As part of the California Online Privacy Protection Act, subscriber to our Services who have submitted Personal Information may make any changes to their information at any time by logging into their account. In addition, given that there are no current defined widely accepted standards, as of the date of this Privacy Policy, regarding responding to and handling "Do Not Track" mechanisms we do not recognize any web browser Do Not Track settings. If this changes in the future we will modify this policy and provide an applicable notice.

Children's Online Privacy Protection Act ("COPPA") Compliance

TRUEVAULT is concerned about the safety of children when they use the internet, and will never knowingly collect Personal Information from minors (children under 13 years of age, or any other age defined under applicable law) without prior verifiable parental consent that complies with those recommended practices and applicable rules put forth by the Federal Trade Commission. Our Site and Services are all expressly directed to people who are at least 13 years old or older. If we become aware that a minor is attempting to or has submitted Personal Information, we will not accept such Personal Information and will then take prompt steps to remove any such Personal Information from our records, Site and Services.

Links and third-party websites.

This policy applies only to our Site and Services. Occasionally, at our discretion, we may include or offer links to Affiliate or third party products or services on our Site. These third party sites have separate and independent privacy policies and we therefore have no responsibility or liability for the content and activities of these linked sites. You should read and understand the applicable Terms of Use and Privacy Policy that such third party sites may offer and require you to conform with. We welcome any feedback about these sites.

How to opt out or request changes.

Under laws that may apply to you, you are entitled to request that TRUEVAULT:

  • Provide you with a copy of your Personal Information that we hold;
  • Cease processing your Personal Information, in whole or in part, as you direct us, for the purposes of direct marketing;
  • Correct any errors in that Personal Information; and
  • Update Personal Information as required.

If you would like to receive a copy of the Personal Information we have about you as submitted to us via this Site, or if you wish to opt out of receiving marketing related communications from us, please send a request to TRUEVAULT at If your Personal Information is incorrect or incomplete, and you wish us to correct or delete it, please contact us. We will then make reasonable efforts to timely correct or update your Personal Information (unless we require further information from you to complete your request).

You may also ask us to remove your name and other Personal Information from our databases. For each such request, we will make all reasonable efforts to do so promptly, subject to legal requirements and other considerations, which may require that we maintain your information for a specified length of time.

Questions regarding this policy.

If you have questions concerning this Privacy Policy, please contact us at: 415.214.9795 or

Modification to this Privacy Policy.

TRUEVAULT may, in its sole discretion, update this policy from time to time by posting a new or amended policy on this Site. If we make material changes to this policy affecting handling of your Personal Information we will provide you an opportunity to opt in under the terms of the revised policy through an email notice, or conspicuous notice on the Site or Services' home page, if applicable. After any such changes take effect, any newly collected Personal Information will be subject to the terms of the revised policy and all previously collected Personal Information will be handled in accordance with your response to our opt-in notice (per the revised policy if you opt in and under the previous policy if you do not opt in, which may, however, limit or prevent your further use of the Site and Services).

If no material changes are made to this policy affecting treatment of your Personal Information, the amended policy shall be effective upon posting and your access to or use of the site following an update shall be deemed consent to the revised policy.

We recommend you visit this page regularly and in particular before supplying any Personal Information to us via this Site or Services.

This policy may not be otherwise amended by you without the written consent of TRUEVAULT.