Privacy Policy

Introduction

Last updated on 2 December 2024

Welcome to the Vaultik privacy policy.  This privacy policy gives you details on how we collect your personal data and how we will use it when you register for our services or visit the Vaultik dashboard (through a web address or mobile application) regardless of where you visit it from and tells you about your privacy rights and how the law protects you.

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Important information and who we are

This privacy policy aims to give you information on how Mintouge collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our mailing list or subscribe to our services as well as provide you with information on our Cookie Policy.

This website is not intended for children, and we do not knowingly collect data relating to children.It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Vaultik is a trading name of Mintouge Limited, and is the controller and responsible for your personal data (collectively referred to as “Vaultik”, "we", "us" or "our" in this privacy policy). If you have any questions about this privacy policy or our privacy practices, please contact us on the details below:

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Mintouge Ltd (Company Number 13988081)
Email address: support@vaultik.com
Registered office address: 86-90 Paul Street, London, England, United Kingdom, EC2A 4NE
UK’s Information Commissioner’s Office Registration Number: ZB617986

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us at the address listed above.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Where our dashboard includes any links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our dashboard, we encourage you to read the privacy policy of every website you visit.

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The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Contact Data includes first name, last name, email address and telephone number.

Transaction Data includes details about services you have subscribed to from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our dashboard together with information on how you use our dashboard.

Profile Data includes your username and password, your interests, details of products purchased and stored on our dashboard, feedback and survey responses. 

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. AggregatedData could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Technical to calculate the percentage of users accessing a specific dashboard feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not knowingly collect any data relating to children, special category data or information about criminal convictions and offences.

Your responsibilities regarding you personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by logging into your account on our dashboard and updating certain information or contacting us directly to update on your behalf.

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How is your personal data collected?

We use different methods to collect data from and about you including through:

You may give us your Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

This includes personal data you provide when you:

  • Direct interactions. We will collect some personal data from you directly when you register for our services or otherwise provide information online through our dashboard, request marketing to be sent to you, any interactions you have with us through the dashboard or any of our social media or give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our dashboard, we will automatically collectTechnical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites we operate which use our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, like any retailer you have purchased products for which are being registered with us as part of the services we offer. Additionally, Technical Data may be received from third party analytics providers or advertising networks (see our cookie policy for further details.
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How we use your personal data

We will only use your personal data when the law allows us to. This includes UK data protection rules (under the UK GDPR and Data Protection Act 2018) and other applicable laws in countries where we collect and process information. We will not collect your personal data without letting you know. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you when you register for our services through the dashboard.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us or clicking “unsubscribe” link provided in any communication.

Principles of processing

We will not process personal data in a way that is incompatible with the purposes for which it has been collected or subsequently agreed to by you. We also will not collect any personal data that is not needed for the mentioned purposes.If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rule, where it is required or otherwise permitted by law.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Contact (a) Performance of a contract with you
Providing access to our dashboard and services and provide customer support services (a) Contact
(b) Transaction
(c) Profile
(d)Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to be efficient about how we meet our obligations and to provide good service to customers)
To manage our relationship with you (a) Contact
(b) Profile
(c) Technical
(d) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services to enable use to develop our relationships and grow our business)
To administer and protect our business and our dashboard (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Contact
(b) Technical
(c) Profile		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud)
(b) Performance of a contract with you
(c) Necessary to comply with a legal obligation
To use data analytics to improve our dashboard, products/services, marketing, customer relationships and experiences (a) Technical (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our dashboard updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Contact
(b) Technical
(c) Marketing and Communications
(d) Profile		 (a) Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Contact, Profile and Technical Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or signed up to our services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of the dashboard or as a result of a service you have signed up to use from us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our dashboard may become inaccessible or not function
properly.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Third party Detail
Partners The third party retailers we partner with to provide our dashboard and services through, and the parent brand of any products which are purchased through the third party retailers.

We will share your data with these Partners to enable them to verify authenticity and ownership of products purchased. Any use of personal data by these Partners will also be subject to their specific privacy notice.
Service providers Where we appoint third parties to provide services on our behalf, like marketing, systems administration services or IT providers or third party authenticators who provide authentication services to us.

Additionally, we will share your data with a third party insurance intermediary to enable them to arrange an appropriate policy in respect of your products listed on our dashboard.
Professional advisers: including lawyers, bankers, auditors and insurers who provide banking, legal, insurance and accounting services.
Authorities: regulatory, government and industry bodies, like ICO, HM Revenue & Customs, fraud prevention organisation or law enforcement bodies who require reporting of processing activities in certain circumstances, especially in the prevention of money laundering and fraud.
Corporate partners: includes third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Except for Partners (who are data controllers of the personal data we share with them), we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

As we provide an online service through our dashboard, we may need to transfer your personal data outside the United Kingdom or European Economic Area (EEA) to enable us to provide our services.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO; or
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK (like the International Data Transfer Agreement approved by the ICO).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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Data Security

We know that it is incredibly important to protect and manage personal data appropriately, but unfortunately the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted online or through the dashboard. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, 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.

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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.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, 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.
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To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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As a general rule, we will retain your personal data as long as you are a registered user of our dashboard, and for a short period after your use of our dashboard ends. It is your responsibility to ensure all information held on our dashboard is retained by you prior to ending your use of our dashboard.

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In some circumstances we will 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.

Your legal rights

The legal rights you have will depend on the country in which you access our dashboard and receive the services. The rights detailed below apply in relation to the UK. Where you are based out with the UK, you may have different or additional rights in respect of your personal data. If this is the case, please contact us and we will confirm any additional rights which may apply.

Your UK rights

Under the UK GDPR and Data Protection Act 2018, data subjects have certain rights in relation to your personal data. We have set these out in the below:

Your Right What it means
Right to be informed
You have the right to be told how we will use your personal data		 We provide this privacy policy to explain how we use your personal data.
Right of access
You can ask us to receive a copy of your personal data, commonly known as a SAR.		 If you ask, we will confirm how we process your personal data and, in certain cases, provide you with a copy of the personal data we hold about you. There are some exemptions where we do not need to provide copies (like communications we have had with our legal advisers), and we can’t give you any personal data about other people or personal data which is linked to ongoing investigations, and we are prevented by law from sharing.
Right to rectification
You can ask us to correct your personal data if you think it is wrong or complete if it is incomplete		 You can have incomplete or inaccurate personal data corrected. Before we update your file, we may need to check the accuracy of the new personal data you have provided, and we will restrict processing while we verify the accuracy.
Right to erasure
You can ask us to delete personal data in certain circumstances		 If we do not have a reason for holding your personal data and continuing to use it, if you gave us consent and have now withdrawn that consent, you have objected to us using your personal data or we are using it unlawfully, you can ask us to delete it.
We might not be able to do this in all circumstances, and we may need to retain information for regulatory purposes. We will always confirm if we cannot delete entirely.
Right to restrict processing
In certain circumstances, you can ask us to restrict or suspect use of your personal data.		 You can ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to object
You can object to us processing your personal data for (i) direct marketing or (ii) our own legitimate interests.		 If you object to direct marketing, we must stop using your personal data for that reason.

If we are using legitimate interest, you can object to us using your personal data. But if there is an overriding reason why we need to use your personal data, we do not need to accept your request to stop and can continue to use your personal data.

If you object to us using personal data which we need in order to provide our services, we may need to close your account as we won’t be able to provide the services
Right to data portability
You can ask us to transfer your personal data to you or another company		 We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to exercise any of the rights set out above, please contact us the details at the start of this policy.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.