The Vault’s Privacy Policy

Effective Date: May 30, 2018

Vault Management Inc. and its affiliates (collectively, “The Vault,” “we,” “us,” or “our)” care about your privacy. This Privacy Policy (“Policy”) describes how The Vault collects, uses, and discloses your Personal Information in connection with the use of our websites (“Website Services”), applications (“apps”), or other service that refers to or links to the Policy, as well as any offline products, programs, courses, events and other services (collectively our “Services”).  Before you use our Services, please read this Policy in its entirety.

By accessing or using our Services, you agree to this Privacy Policy. The provisions contained in this Privacy Policy supersede previous notices regarding our privacy practices with respect to our Services.


We may collect various types of information in connection with Services, including information you provide directly to us; Information we collect about your device(s) and your use of our Services (including through cookies, web beacons and other Internet technologies); and information we obtain from third-party sources (collectively, “Personal Information”).


We collect various types of information and content that you provide us directly. For example, in order to enroll as a member of The Vault or to access some of our Services, we may request information such as your name, phone number, email address, mailing address and, where applicable, your company or organization name. We also collect other content and information that you provide us directly or that your company provides us about you and we collect billing and payment information you provide when you access some of our Services or purchase our products or services.


We collect information about how you use our Services and, depending on the permissions you have granted, other information from and about the computers, phones and other devices where you install or through which you access our Services. We use standard Internet technologies, such as cookies and web beacons, to collect information about your computer or device and your online activity, as explained in more detail here.

The information about your device(s) and your use of Services that we collect is:

  • Your browser type and operating system;
  • IP address and device identifiers;
  • Your browsing behavior when using any of our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services;
  • Websites you visit before or after visitng our websites;
  • Whether you have opened or forwarded our e-mails or connected to offers or links that we send you; and
  • Your general or specific geographic location, such as through GPS, Bluetooth or WiFi signals to the extent permitted by the settings of your devices.


We may receive information about you from publicly and commercially available sources (as permitted by law), other third parties and third-party social networking services when you choose to connect with those services. We may combine this information with other information we receive from or about you.


We do not share your Personal Information with: (1) financial companies for joint marketing purposes, (2) affiliated companies for their everyday business purposes or (3) any third parties so they can market to you.

We use your Personal Information that we collect as necessary and appropriate for the following purposes:

  • To provide and improve our products and Services. For example, we may use your information as necessary or appropriate to respond to inquiries we receive from you or your company or organization or in connection with a transaction that you or your company or organization has initiated; to deliver notifications and other communications; to improve user experiences; or to recognize and analyze how users navigate and use Services and for related analysis, auditing, research, reporting and troubleshooting.
  • To deliver advertising and promotional communications. For example, we may contact you with offers and information about our products and Services; send you newsletters or other information about topics that we believe may be of interest to you; conduct online surveys; or contact you to promote our products and Services. We also may deliver targeted advertisements to you.
  • We may use your information as we believe is necessary or appropriate to protect, enforce or defend legal rights, privacy, safety or property, whether our own or that of our employees or agents or others, and to comply with applicable law.

We may disclose your Personal Information in the following circumstances:

  • Our Community. Our Services may include member communities and other online forums and networks that allow you to share and connect with others. We may make this possible for The Vault members by creating a profile for new members that contains your name and the name of your company or other organization. This profile is created automatically and is accessible to other members of the forum or network, some of which may include all members of The Vault, and you may be able to supplement your profile by adding additional information about yourself and your company or organization and by posting content and comments and sharing your profile with a broader audience. By enrolling as a member of The Vault, you consent to the automatic creation of your profile as described above and the sharing of your profile information with other users of Services.
  • Service Providers. We rely on third-party service providers to perform a variety of services on our behalf. To do so, we may need to share your information with them. For example, we may rely on service providers to host data and platforms, fulfill product and service requests and answer your questions, send e-mails on our behalf, process payment card or other transactions and analyze data to improve our products and Services.
  • Other Parties When Required by Law and as Necessary to Provide and Protect Our Services. There may be instances when we disclose your information to other parties. For example, we may do so to provide you Services that you or your company or organization request; to comply with applicable law or to respond to legal process or a request for cooperation by a government entity or law enforcement; to prevent fraud or verify and enforce compliance with policies governing Services; or to protect the rights, property, or safety of us or any of our affiliates, business partners, customers or employees
  • Other Parties in Connection with a Corporate Transaction. We may disclose your information to a third party in the event we sell or transfer all or a portion of a business or assets to a third party, such as in connection with a merger.
  • Other Parties with Consent or at Your Direction. In addition to the disclosures described in this Policy, we may share information about you with third parties when you or your company or organization consent to or request such sharing. For example, we may partner with third parties to make products or Services available to individual members or participating companies and organizations. If you or your company or organization requests to participate, we may share your information with the relevant third party in connection with the requested product or Service.
  • Aggregated and Non-Personal Information. We may also share with third parties information in a manner that does not identify particular individuals: for example, information that has been aggregated with other records.

Our Services may contain links to other sites that we do not own or operate. We provide links to third-party sites as a convenience to our users. They are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms, which we recommend you read carefully. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party and not this Policy.


We may also partner with the following categories of third parties to collect, analyze, and use some of the Personal Information described in this Policy:

  • Third-parties that provide features and functionality of Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they may collect information about you, such as your IP address and the pages that you view.
  • Advertising providers may help us and our advertisers provide ads on Services or elsewhere, including ads that are targeted based on your online behavior, and analytics companies help us measure and evaluate the usage of our services.
  • Other content providers may offer products and services on our Services.

These third parties may collect or receive certain information about your use of Services, including through the use of cookies, web beacons and Internet technologies and this information may be collected over time and combined with information collected across different websites and online services.


Although we take steps to protect your information, no security program is foolproof and we cannot guarantee the absolute security of your personal or other information.


In accordance with applicable law, you may have the right to access, update, or correct inaccuracies in your Personal Information in our custody and control, subject to certain exceptions prescribed by law. If you would like to access, review, or update your information, please e-mail


The Services are headquartered in the United States. Please be aware that information you provide to us or that we obtain as a result of your use of the Services may be collected in your country and subsequently transferred to another country in accordance with applicable law. By using the Services, you consent to the collection, international transfer, storage and processing of your information.


If you do not wish to receive offers or other notices from us in the future, you can “opt out” by contacting us at

Some web browsers may transmit “do-not-track” signals to the websites and other online services with which a user communicates. There is no industry standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established and accepted, we may revisit our policy on responding to these signals.


Services are not directed to children under the age of 18 and we do not knowingly collect personal information from anyone under the age of 18. If you are under the age of 18, we request that you not use our Services or submit any information to us.


Privacy laws and guidelines are part of a constantly changing environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. We encourage you to review this Privacy Policy periodically to ensure that you are aware of our current privacy practices, although we may also elect to notify you by e-mail or by posting something on some or all of our online Services. Your continued use of our Services following any changes signifies your acceptance of these changes.


If you have any questions or comments regarding our Privacy Policy, please contact us at:  The Vault, 415 Jackson Street, San Francisco, CA 94111, Attention: Legal. Email: