PRIVACY POLICY

FutureVault Privacy Policy

(Updated: June 23, 2022)

By using or accessing the Service (as defined herein), regardless of how accessed, you signify your agreement to be legally bound by this Privacy Policy and our Terms of Service (the “Policies”). The Policies apply to all Authorized Users, Designated Users and others who access or use the Service (referred to herein as “you”).

FutureVault Inc. (collectively, “FutureVault”, “we”, “us” or “our”) is committed to protecting the privacy and confidentiality of personal information in our possession. By using our website (“Site”) and mobile application (“Application”), you are accepting the practices described in this Privacy Policy. This Privacy Policy explains how we collect, use and disclose personal information that you provide to us through the FutureVault document vault platform (the “Vault”) and Application, which includes any white label or branded document vault platforms (collectively, the “Service”) we operate, manage and market for our client (“Client”).

By using this Site and Application, you consent to the use of the information that you provide to us in accordance with this Privacy Policy. We reserve the right, at our discretion, to amend this Privacy Policy at any time without prior individual notice. The date on which this Privacy Policy was last amended is shown at the top of this policy. Your continued use of the Site and Application will be deemed your agreement and consent that your information may be used in accordance with the new policy. You are responsible for verifying whether any amendments have been made and therefore we ask that you periodically check the date and review this Privacy Policy for the latest information on our privacy practices.

Website and Mobile Application Privacy Notice

Please read this Policy carefully to fully understand how we collect, share and protect information about you. This Policy is incorporated into and is a part of the Terms of Service for this Site. Unless otherwise defined herein, all defined terms have the same meaning as set out in the Terms of Service.

To access the Terms of Service, click here https://www.futurevault.com/terms-of-service/.

By accessing and using the Site and Application, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices and uses and disclosures of your information as described herein.

In order to deliver personalized and relevant information to you through our Site and Application, we collect certain information from users.

Information We Collect

While using the Service, we collect or will ask you to provide us with certain personal information.

Account Information

We collect and associate with your account the information you provide to us when you register for an account. You must provide your first and last name and email address (“Registration Information”) to create an “Account”.

As part of the Account registration process, you will be required to create a log-in, which consists of your email address and a password. You are responsible for keeping your password secret and secure. You should not disclose your password to anyone else, and you cannot share an account with others, although you may share some of Your Documents with your Contacts as further described herein. You should select a strong, secure password that is different from the password you use with other accounts or social media sites.

Your Documents

Think of the Service as a digital safety deposit box. The Service is designed to make it easy for you to deposit documents and files electronically, so that they can be accessed by you across multiple devices, and shared with others (hereinafter, the documents that you deposit will be collectively referred to as “Your Documents”).

Contacts

You may choose to share Your Documents with others. To do so, you must upload the contact information, including the name and email address, of the individuals with whom you want to share Your Documents (the “Contacts”). If you upload personal information of your Contacts, we will store that information. It is your responsibility to obtain your Contact’s consent (i) to store their contact information in the Service and (ii) for us to use it for the purpose of sending various Service-related emails (e.g., notifications that the Contact has been added to your Vault or invitations for the Contact to access Your Documents).

You can view, change and manage the permissions for each Contact at any time, including specifying which categories and sub-categories of Your Documents the Contact may access. If you grant a Contact access to Your Documents, that Contact is able to download Your Documents to their local device.

Customer Service Inquiries

To communicate with our customer service representatives, you must log-in to your Account and click the “GET HELP” button. You will be required to provide details about your question or concern.

Promotional Communications

If you wish to join our email list to receive promotional emails and our monthly newsletter, you will be required to provide your express consent.

Device Information

We collect information about the device(s) you use to access our Service, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

Usage Data

We may also collect information on how the Service is accessed and used by Authorized Users and Designated Users. These access logs include, but are not limited to, information such as the following: your machine’s TCP/IP address, your username (if applicable), files accessed, the date and time of such access, and other information pertaining to your activities on our website. These logs are used solely for performance, site administration and security reviews.

Cookies

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service provider’s systems to recognize your browser and capture and remember certain information.

We use cookies to help us remember, understand, and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Disabling cookies when you visit our Website or Application may disable some of our Services. Please consult your browser’s Help Menu for instructions.

Purposes for Collection and Use of Your Information

We may collect and use personal information for the purposes identified at the time of collection, as otherwise permitted or required by applicable law, or for any of the following purposes:

To establish, maintain and manage our relationship with you so that we can provide you with the Service;
To provide you with information related to the Service;
To fulfil or meet the reason you provided the information;
To respond to law enforcement requests and as required by applicable law, court order or governmental regulations;
To develop and manage our business and operations;
For billing, accounting and debt collection services relating to the Service;
To respond to your questions and concerns;
To detect and protect us and you from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with our third party service providers;
To monitor and conduct an analysis of our Site or Application traffic and usage patterns and;
For internal, external and regulatory audit purposes.

We will not use personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and/or updating this Privacy Policy.

How Your Information is Disclosed or Shared

How we share your information

We do not sell client lists or personal information to others.

We may disclose personal information in the following circumstances:

As described in this Privacy Policy;
To investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Service;
To meet or comply with any applicable law, regulation, legal process, audit or enforceable request from a government agency or regulatory body;
In connection with the sale, merger or change of control of FutureVault. In the event of a merger, acquisition sale or reorganization, or the potential thereof, we may disclose information about you to the extent the personal information is necessary to carry on the business or activity that was the object of the transaction. In the event of a completed transaction, notice will be given to affected users.
We may retain third party service providers, to help us provide the Service to you. We may need to transfer your personal information to them. We use contractual means to ensure these providers provide information security and privacy safeguards that are comparable to our own while your personal information is in their possession. These service providers make no independent use of your personal information.

How you may share your information

As described above, certain features of the Service allow you to make Your Documents available to your Contacts. Your Contacts may view, modify and download Your Documents. Please think carefully about what you share with others.

Links to Third Party Websites and Mobile Applications

As described in the Terms of Service, our Service may contain links to other third party sites. This Privacy Policy applies only to personal information that we collect, use and disclose. We are not responsible or liable for the privacy practices of third parties whose links you may click on within our Service, and we strongly recommend that you review any third party’s Privacy Policy before disclosing any personal information to a third party.

Retention and Destruction of Personal Information

FutureVault will store personal information collected via the Service for only as long as is necessary for the purposes for which the information was collected. Once you delete your information or Your Documents from the Service, we may retain your information to comply with our legal obligations, to resolve disputes, prevent fraud and abuse and to enforce our agreements, or as necessary for archival/audit purposes. Please note that your information and Your Documents may remain in back-up storage for some period of time after your deletion request. This may be the case even though no account information remains in our active user databases.

Safeguarding Personal Information

We employ reasonable physical, electronic and procedural safeguards that are designed to protect personal information under our control against unauthorized access and use. FutureVault employs a Chief Information Security Officer to oversee its Written Information Security Plan which details all organizational activities engaged to secure user information and privacy. FutureVault is compliant with the Processing Card Industry Data Security Standard (PCI-DSS) and has been audited by Ernest and Young (E&Y) to be SOC2 Type 2 compliant.

We may engage third party external servers as well as other external services, including cloud services and cloud compatible servers. We use contractual means to ensure that any third-party service provider provides a level of safeguards that correspond with our own.

Electronic Communications

Email is our preferred method of communicating with you, although from time to time we may use other electronic means such as text messaging or telephone. We send emails to you based on the Registration Information you provide us upon account opening. These emails, and any other electronic communications, may contain personal information. By using the service you consent to receiving such communications.

While we make every effort to secure all our electronic communications, there are inherent risks with exchanging information electronically. For example, such information may be accidentally or deliberately intercepted by third parties. We do not accept any responsibility or liability for any damages you may suffer as a result of the interception, alteration or misuse of any information during any electronic exchange.

Keeping Information Accurate

It is important that your personal information held by us is accurate and complete so that we can give you better service. We ask that you keep us informed of any changes, such as a change of address, telephone number or email address.

You have the right to access, update, and correct the information we have about you after we have received your written request and authenticated your identity. Subject to legal restrictions or specific rights of refusal, we will inform you of the existence, use and disclosure of personal information relating to you and give you access to that information.

Despite our efforts, errors sometimes do occur. If you identify any personal information that is out-of-date, incorrect, or incomplete, let us know. If we agree, we will make the corrections.

Children’s Privacy

You must be at least 18 years of age to use the Service.

If you are under the age of 18, please do not use the Service and do not submit information to our Site or Application.

We do not knowingly collect personal information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children, we will take reasonable steps to locate and remove that information from our servers and records.

Privacy Concerns

If you have any questions and concerns relating to our handling of your personal information, please direct them to our privacy officer listed below. We may need to ask you for personal information to verify your identity.

E-mail: privacy@FutureVaultInc.com

If, having shared your concerns with us, you are not satisfied with our answers, you may file a complaint with a privacy regulator, such as the Office of the Privacy Commissioner of Canada by mail at 30 Victoria Street Gatineau, Quebec K1A 1H3 or by calling 1 800 282 1376.

FOR CALIFORNIA RESIDENTS:

If you are a resident of California, you have the following rights under the California Consumer Privacy Act of 2018 (“CCPA”):

to know what categories of personal information about you we have collected and used, including how the personal information was collected;
to know that your personal information has not been sold;
to access your personal information, including the right to download or transfer personal information collected during the previous 12 months;
to request that your personal information be deleted; and
to equal service and equal price for goods or services even if you exercise your rights under the CCPA.

While California residents have the right to opt-out of the sale of their personal information under CCPA, we do not sell or share personal information to any third parties, including to third parties for their direct marketing purposes and therefore, we have not included a “Do Not Sell My Personal Information” link on our Site or Application. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law.

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us by phone at 1-844-538-2858 or by emailing us at privacy@FutureVaultInc.com. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services and;
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

FOR EU RESIDENTS:

If you are located in the European Union or other regions with laws governing data collection and use that may differ from Canadian law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to (i) the transfer of information to Canada or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities and (ii) to the use and disclosure of information about you as described in this Privacy Policy. In situations where we transfer your Personal Data (as that term is defined under the General Data Protection Regulation (“GDPR”)) outside of the European Union, we use specific contracts approved by the European Commission, in addition to other measures, to help ensure that your Personal Data receives the same protection as in the European Union.

As applicable, FutureVault has taken steps to implement adequate safeguards to protect such Personal Data. FutureVault maintains appropriate and reasonable technical and organizational measures to protect your Personal Data against unauthorized or unlawful use and against its accidental loss, damage or destruction.

Where FutureVault acts as a data controller with respect to Personal Data, we set forth below the various ways that we intend to use your Personal Data and the lawful basis for engaging in each category of processing of Personal Data. Please note that we may process Personal Data for more than one lawful basis depending on the specific purpose or activity involved.

Purpose / Activity	Type(s) of Personal Data	Lawful Basis
To establish, maintain and manage our relationship with you so that we can provide you with the Service	Identity and contact information for individual Clients and points of contact at business Clients	Necessary for our legitimate interests where you are an individual Client or point of contact for a Client for account management or billing activities For individual Clients, performance of our contract with you
To provide you with information related to the Service	Identity and contact information for individual Clients and points of contact at business Clients	Performance of our contract with you Necessary for our legitimate interests to develop our products and services and expand our business
To fulfil or meet the reason you provided the information	Usage data Technical data Support data	Performance of our contract with you
To provide third parties statistical information about the users of our Site or Mobile Application	Usage data	Necessary for our legitimate interests to develop our products and services and expand our business
To respond to law enforcement requests and as required by applicable law, court order or governmental regulations	Identity and contact information for individual Clients and points of contact at business Clients Financial data Usage data Technical data Support data	Necessary to comply with legal obligation
To develop and manage our business and operations	Usage data Technical data Support data	Necessary for our legitimate interests to develop our products and services and expand our business
For billing, accounting and debt collection services relating to the Service	Identity and contact information for individual Clients and points of contact at business Clients Financial data	Performance of our contract with you Necessary for our legitimate interests to receive compensation for services
To respond to your questions and concerns;	Identity and contact information for individual Clients and points of contact at business Clients	Performance of our contract with you
To detect and protect us and you from error, negligence, breach of contract, fraud, theft or other illegal activity, and which may include sharing personal information with our insurers	Usage data Technical data Identity and contact information for individual Clients and points of contact at business Clients	Performance of our contract with you Necessary for our legitimate interests for running and protecting our business and preventing fraud Necessary to comply with a legal obligation
To monitor and conduct an analysis of our Site traffic and usage patterns	Usage data Technical data	Necessary for our legitimate interests to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy
To correct technical problems and malfunctions related to the Services	Usage data Technical data	Performance of our contract with you Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy

We will not use personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and/or updating this Privacy Policy.

If you are a resident of the European Union, subject to applicable exemptions, here are your rights in relation to your Personal Data (as that term is defined under the GDPR):

To be informed about the Personal Data that is held about you by FutureVault;
To request access to or a copy of your Personal Data that is maintained by FutureVault and be provided information in relation to that data (including the purposes for which the data is processed and how long it will be stored for);
To request that your Personal Data be corrected or deleted;
To receive a copy of your Personal Data in a machine-readable format or to have your Personal Data sent to another entity;
To restrict the processing of your Personal Data;
To object to the processing of your Personal Data;
Not to be subject to a decision which is based solely on automated processing or profiling that could result in a significant effect on you, such as discriminatory effects; and,
To file a complaint with the relevant supervisory authority for violations of data protection laws.

You may make these requests by contacting FutureVault at:

FutureVault Inc.
154 University Ave Suite 601
Toronto, ON
M5H 3Y9
Canada
1-844-538-2858

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