Effective: January 09, 2017
1. Information Collected
We collect both Personal Information and Other Information about users in connection with the Services. For purposes of this Policy, “Personal Information” is information that we can directly associate with a specific person without additional information. “Other Information” is any information that is not Personal Information. We may combine Personal Information with Other Information, in which case we will treat the combined information as Personal Information.
We may collect and process the following types of Personal Information from or about you in connection with the Services, including: your name, address, email address, phone number, username, password, financial account information, pictures, videos, and recordings, and the contact information of your friends and family whom you wish to send messages through the Services.
We may also collect Other Information automatically through the Services. This may include information such as your IP address and domain name, your Internet service provider, the date and time of your visit, your use of the Services during your current session and over time (including the pages you view and the files you download), the URLs from the websites you visit before and after navigating to the Services, your computer’s operating system and browser type, your software and hardware attributes (including device IDs), and your general geographic location (e.g., your city, state, or metropolitan region).
We also may combine Personal Information or Other Information that we have about you with additional information that we or third parties collect in other contexts—such as our communications with you via email or phone, or your customer service records. In those circumstances, we will treat the combined information in accordance with this Policy.
2. Cookies and Similar Technologies
We may collect information using the following technologies:
Server Logs. When you use the Services, we may automatically receive and record certain information from your computer (or other device) and your browser. To obtain such information, we may use server logs or applications that recognize your computer or other devices and gather information about its online activity.
Pixel tags. The Services or the emails that you receive from us may use an application known as a “pixel tag” (also known as a “clear gif” or “web beacon”). A pixel tag is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include Personal Information. For example, it allows an email sender to determine whether a user has opened a particular email.
We may partner with certain third parties to collect, analyze, and use some of the Personal and Other Information described above. For example, we may allow third parties to set cookies or use pixel tags on the Services or in email communications from GV. This information may be used for a variety of purposes, including analytics and targeted advertising, as described in the “Third-Party Analytics and Targeted Advertising” section below.
3. Use of Information
We may use Personal and Other Information for a variety of purposes. If we have personal information about you, we may use it, for example: to respond to your questions or requests concerning the Services offered by us or our partners; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.
We may use the Other information that we collect for such purposes as: counting and recognizing visitors to the website; analyzing how visitors use the Services and various features of the Services; improving the Services and enhancing users’ experiences with the Services; creating new products and services or improving our existing products and services; enabling additional website analytics and research concerning the Services; and managing our business. GV may link Other information gathered using cookies and web beacons with Personal information. But in that event, we will treat the combined information as Personal information.
Please be assured that we do not use the contact information of your friends and family that you enter through our Services to send any type of direct marketing to your friends and family. We may, however, use your contact information to contact you about the Services or, if you opt in, other things we think may interest you. You can opt-out of receiving direct marketing communications by following the steps described in the “Your Choices” section below.
4. Information Sharing with Third Parties
GV may share Personal and Other Information with third parties for a variety of purposes, as described below.
Affiliates. We may share Personal and Other Information with our corporate affiliates for the purposes described in this Policy.
Third-party service providers and business partners. We sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, and processing payments. When we employ another company to perform a function of this nature, we may need to provide them with access to certain Personal Data or Other Information. These third-party service providers may use information received in the course of providing services to us only for the specific purposes for which such information was disclosed.
Your Direct sharing of personal information. The Services may contain links to third-party websites that incorporate comment and social media features, including the Facebook “like” button and the Twitter “follow” button. If you choose to use these features, you may disclose your Personal Information not just to those third-party websites and services, but also to their users and the public more generally. Because these third-party websites and services are not operated by GV, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your Personal and Other Information will be subject to the privacy policies of the third-party websites or services, and not this Policy.
Legal purposes. We also may use or share your Personal or Other Information with third parties when we believe, in our sole discretion, that doing so is necessary:
- To comply with applicable law or a court order, subpoena, request from government or law enforcement, or other legal process;
- To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms of service, or situations involving threats to our property or the property or physical safety of any person or third party;
- To establish, protect, or exercise our legal rights or defend against legal claims; or
- To facilitate the financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
De-identified or aggregated information. GV also may share de-identified and aggregated information about users with third parties.
5. Third-Party Analytics and Targeted Advertising
Targeted Advertising. The Services also may enable third-party tracking mechanisms to collect Other Information over time and across unaffiliated websites for use in online behavioral advertising. For example, third parties may use the fact that you visited the Services to target online ads for GV Services to you on non-GV websites. In addition, our third-party advertising partners might use information about your use of the Services to help target non-GV advertisements based on your online behavior in general. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.
The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here. Please note that the opt-out will apply only to the specific browser or device from which you opt out, and therefore you will need to opt out separately on all of your browsers and devices. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.
Like many other online services, the Services do not respond to “do not track” browser headers.
6. Children’s Privacy.
Our Services are available only to, and may only be used by, individuals who are 18 years and older and who can form legally binding contracts under applicable law. If you are a parent or guardian and you discover that your child has created an unauthorized account on our Services, please contact us at firstname.lastname@example.org and we will remove the account.
7. Your Choices.
If you no longer wish to receive marketing communications from GV, please email us at email@example.com or follow the “unsubscribe” instructions that are included at the bottom of each message. We do reserve the right to send you certain communications relating to the services we provide, such as service announcements and administrative messages.
8. Reviewing, Updating, and Deleting Your Personal Information
You have the right and ability to edit your GV account information on our Services at any time by logging into your account and accessing your GV Dashboard, clicking your name in top right corner and selecting “Account & Billing” from the dropdown menu, and subsequently updating your Profile. You may access, amend, and/or request deletion of certain information to the extent permitted under applicable law. To make such requests and/or inquire about such rights, please send us an email at firstname.lastname@example.org. For your protection, we may only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will attempt to comply with any reasonable requests for accessing, amending, or deleting your information.
9. Security and Data Retention
GV uses commercially reasonable physical, electronic, and procedural safeguards to protect your information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal or Other Information.
We will retain your Personal Information for as long as reasonably necessary to accomplish the purposes in this Policy or as required by law. If you delete your account, we will not retain the pictures, videos, recordings, or other materials that you have sent or intended to send to friends and family through the vault Services.
10. Third Party Sites.
11. Users Outside the United States
The Personal and Other information that we collect about you is controlled by GabrielsVault, LLC, which is headquartered in the United States at GabrielsVault, LLC P.O. Box 22452, Portsmouth, NH 03802-2452. The Personal and Other Information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. GV also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this Policy, using the Services, or providing information to us, you expressly consent to such transfer and processing.
12. California Privacy Rights
If you are a California resident, you have a right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be sent to email@example.com. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your information shared rather than providing the above described information. To that end, you may request that we do not disclose your personal information to unaffiliated third parties for their own direct marketing purposes by contacting us by email at firstname.lastname@example.org.
13. Changes to this Policy
P.O. Box 22452
Portsmouth, NH 03802-2452