Last Update: March 10, 2014
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.
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 European Union - 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 http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list. For more information about the Privacy Shield and Safe Harbor Principles, please visit the U.S. Department of Commerce's Website at http://export.gov/safeharbor.
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 U.S.-EU 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:
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.
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 firstname.lastname@example.org Under the Privacy Shield and Safe Harbor programs, any unresolved privacy complaints can be referred to an independent recourse mechanism. We use the Whistic.com. If you feel that we have not satisfactorily addressed your complaint, you can go to https://www.whistic.com/privacyshield/complaints#/intro in order to file a complaint. In some cases, you may be able to invoke binding arbitration.
"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.
We will use the information described above that you submit:
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.
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.
Subject to applicable law, we and our various Service Providers (defined below) may disclose and share your Personal Information:
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.
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.
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.
Under laws that may apply to you, you are entitled to request that TRUEVAULT:
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 email@example.com. 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.
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.