Revised: December 10, 2019
What Information Do We Collect About You and Why Do We Collect It?
You can visit some of our online products on our website without giving us any personal information. However, for many of our products, such as our surveys, we request and collect information about you in certain circumstances so that we can provide our users and customers with the most efficient, enhanced, and personalized service. The options you have to provide us with personal information may change, but here are some examples of situations in which you will have the opportunity to provide personal information to us:
Users Accounts and Profiles. When you create a user account through our online products, we need to collect your name, mailing addresses, and/or email addresses. When you set up an individual user account in Vault or Vault Jobs, you may create a profile (“Profile”) that will include the personal information you provide. Your Profile can be viewed by prospective employers and recruiters if that option is selected for your account. If you upload a resume in Vault or Vault Jobs, we may extract information from the resume, and the extracted information may be viewed by prospective employers and recruiters. Generally, this information includes your name and personal contact details, (current and former) employment, education, awards and recognitions, memberships and associations, references, publications, and volunteer work. If you apply to a job advertisement (“Job Ad”), your email address, name, resume/CV and cover letter are sent to the employer (specifically to the email address designated by the employer as the “Apply via Email” address when the employer posted the Job Ad). An employer with appropriate permissions may view the job seeker’s Profile data.
Registration Forms and E-Mail Alerts. Our registration forms will indicate what information is required and what information (if any) is optional. Users may opt to receive email updates, newsletters, and job alerts, as well as emails from selected Vault partners. In these circumstances, we need to collect and use your email address and may request other optional information, such as information on your preferences.
Information Collected from Social Media and Other Websites. If you connect to Vault’s website or online services using third-party websites, including Facebook, Google, Instagram, LinkedIn, or another social media platform or network (each a “Social Networking Site”), we will receive information that you authorize the Social Networking Site to share with us, which may include public profile information, email address, and locale. When we receive this information, it becomes Vault account information for purposes of your use of Vault’s website or online services. We may also be able to authenticate your account via your use of a third-party website. Any information that we collect from your Social Networking Site account may depend on the privacy settings you have set with the Social Networking Site, so please consult the Social Networking Site’s privacy and data practices. You have the ability to disconnect your Social Networking Site account from your Vault account by adapting the privacy settings in your Social Networking Site account. If you come to Vault’s website or online services through a Social Networking Site, from other websites, or with devices that enable third parties to collect information from or about you, such third parties receive information about you subject to their privacy policies.
Demographic and Sensitive Information. Vault’s surveys may also collect demographic details, which may include special categories of data, such as data related to gender and race. Vault uses this demographic information to analyze the survey participants and, at times, to compare results among different groups of participants. All demographic questions are purely voluntary, and participants will not be penalized for not answering such questions.
Consumer Inquiries & Communications. There may be other times that you provide Vault with information about yourself or others. For example, if you communicate with Vault’s helpline or a sales representative, you may provide your personal information, such as contact data (e.g., name, address, telephone, or email) and other personal information related to your communication (e.g., employer, consumer preferences, and interests). We will collect the personal information that we think is reasonably necessary to your inquiry or that is otherwise related to your communication. We will collect and retain such information in accordance with the purposes you provided it, and with our legitimate business interests.
Purchase and Transactional Data. In addition, we may collect and process the following categories of personal information concerning our customers, vendors, suppliers, and similar business contacts: name, contact details, job title, bank account details and financial information (including credit/income history), transaction history, and business correspondence and communications. We process this information to facilitate routine and common business practices, such as those related to sales orders and management, membership services, promotion and quotation submitting, warranty management, credit collection, compliance with legal requirements, tax and accounting purposes, and defense or promotion of our interests and claims.
Who Provides Us With Data and Other Information?
What Do We Do With Collected Information and Survey Data?
Generally, Vault uses the information you provide to us to fulfill your requests and improve our products. We use personal information so that we may register accounts, display or send custom, personalized content to our website visitors and send newsletters, mail, emails, features, surveys, or other updates to our users. A user may, at any time, opt out of receiving such information. We also use collected information to evaluate and administer our products and services, fulfill customer requests, respond to any problems that may arise (such as delivery issues or difficulties in navigating our sites or accessing certain features), as well as to gauge user trends to determine what products and services are most popular with users. Vault may also use your personal information provided in the surveys in the following manner:
Employer Profiles. With regard to Vault surveys, Vault editors review the feedback provided by surveyed respondents to write a summary of employees’ views about their workplaces. Vault editors may also select representative quotes to include as part of an employer profile. Here, although Vault may seek to minimize the personal information associated with these quotes, respondents should be aware that their comments may be published and avoid including in their comments any personally identifying data or other details that might compromise either their own anonymity or that of any other individual.
Employee/Intern Reviews. For some of Vault’s surveys, comments from survey participants may be published on the website without prior editorial review. In other circumstances, individuals may register with Vault in order to submit reviews, insights, and opinions about their current or former employers or schools. In either case, while an individual’s name is not associated with a quotation or review, the review may be accompanied by general identifiers, where provided, such as office location, position/level, department, or year in which the sur-vey was conducted. The review also identifies whether the survey respondent is a “verified employee” or “verified intern” to indicate that the comment was collected through Vault’s survey process and distinguish it from other user-generated reviews.
Blog Posts, Career Advice, and Other Forums. Vault may use anonymous comments and/or aggregated scores provided to the surveys for the purposes of publishing blog posts or articles; making presentations; or participating in public or private forums or other discussions on employee satisfaction, perceptions of employers, and industry trends.
Research Reports. Vault may use aggregated and de-identified data from our surveys for the purposes of client research, to help employers benchmark themselves against the industry and their peers and/or to gauge relative levels of satisfaction among their own employees. In the event these research reports include the survey’s text feedback, Vault reviews and edits, as necessary, such feedback to seek to minimize the personal information associated with individual respondents’ comments. However, respondents should be aware that their comments may be published or used for research and avoid including details that might compromise their anonymity.
What About De-Identified and Aggregated Data?
How Do We Share Personal Information?
Any personal information that is provided to Vault is made available to its technical agents, service providers, and consultants who make our websites and our products and services available to you. We use affiliated and unaffiliated service providers all over the world (including web servers, cloud storage systems, CRM providers, email services, content support teams, marketing partners, advertising partners, and others) to help us deliver our service and run our business. These companies are authorized to use your personal information only as necessary to provide these services to us and we do not sell or rent your personal information to another business or a third party. Notwithstanding, we may disclose information to third parties in the following circumstances:
Software Provider. Vault uses a third-party software provider to assist with the administration and maintenance of our online surveys. Vault and the software provider have executed a written agreement that creates confidentiality obligations that limits the software provider’s ability to access, collect, and use any data, including personal information, transmitted as part of the services.
Required Disclosures: We may be required to disclose personal information with courts, tribunals, and opposing or other related parties to such proceedings and their professional advisors, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law.
Legal Compliance and Protecting Vault’s Interests: We may disclose your personal information with any third party when we believe disclosure is necessary to comply with the law or to protect the rights, interests, property, or safety of Vault. We reserve the right to investigate any fraudulent or other activities involving Vault’s property or interests and to disclose any information reasonably necessary for any of these purposes, including to law enforcement or regulatory authorities and with any other organization.
Corporate Restructuring. We may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vault’s business or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which your personal information held by Vault is among the assets transferred.
Your Web browser offers so-called “cookies” which, if you allow their use, store small amounts of data on your computer when you visit a website. Cookies assist us in tracking which of our features you like best. Cookies also enable us to customize our content according to your preferences. You have the ability to accept or decline cookies by modifying your browser and our websites are viewable even if you disable the cookie function on your browser. However, if you disable cookies, some features or offerings will not be available to you.
Vault works with third parties, such as Google Ad Manager, to provide you with personalized, interest-based advertising. Vault also works with Google Analytics, to provide analytics services that use the cookies set on your device to measure the performance of advertising and track traffic to Vault generally. We have also implemented Google Analytics Demographics and Interest Reporting, which categorizes cookie information so that we and third-party service providers can better deliver advertisements that are relevant and useful to you on the platform and various websites across the internet. For more information about how Google uses data from sites that use their services, see https://policies.google.com/technologies/partner-sites. To learn about Google Analytics' opt-out services, see https://tools.google.com/dlpage/gaoptout/.
You are also able to opt out of other third-party advertiser and ad network placement of cookies or targeted advertising generally by visiting the following links: Network Advertising Initiative; Digital Advertising Alliance; European Interactive Digital Advertising Alliance (for users in the EU); or The Digital Advertising Alliance of Canada (for users in Canada).
What Is Our Data Retention Policy and Criteria?
Vault retains your personal information for the time period reasonably necessary to satisfy the purpose for which it was collected or as long as necessary to comply with legal obligations or for the establishment, exercise or defense of a legal claim. For our customers, vendors, suppliers, and other business contacts, we retain your personal information for the duration needed to complete or facilitate our contract, agreement or engagement, and for a reasonable amount of time thereafter in accordance with our legitimate business needs and functions. We will retain survey results for the length of time needed to validate its conclusions, or to the extent relevant to future surveys, studies, or research. Vault does not have any retention control with regard to reports that have been made publicly available or provided to other third-parties.
Where Is Your Personal Information Transferred and Stored?
The information (including personal information) that Vault collects, uses, and retains may be stored in multiple countries, including the United States. If you are located outside of the United States, please be aware that information you submit will be transferred to the United States, and that the United States may not provide the same level of protections as the laws in your country. In addition, Vault does *not* participate in the U.S. Privacy Shield program. By continuing to provide us such information you hereby consent to the transfer of your information to the United States, or other Vault locations.
How Do We Protect Your Personal Information?
Vault has implemented commercially reasonable steps to protect the personal information it collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please note that despite our reasonable efforts, no security measure is ever perfect or impenetrable, so we cannot guarantee the full security of your personal information. In other words, you provide us with your personal information at your own risk. We disclaim any liability, and you agree to not hold us responsible, for the loss, misuse, or compromise of your personal information.
Your Responsibilities and Representations
Your Rights and Privileges
Depending on the jurisdiction in which you reside, you may have the following rights with respect to the personal information we hold about you. If you wish to exercise any of these rights, please contact us in accordance with the instructions provided below in the “Contact Information” section. We may need to collect and process information about you solely for the purpose of responding to, and satisfying, any such data request.
Updating Personal Information and Marketing. We offer several ways for you to update your contact information or change your preferences. If you are a registered user at our websites, you will be able to log in and update or change your contact or account information. You may unsubscribe to any of our online email updates by following the unsubscribe instructions in the body of any message.
Parental Rights. Our website and our services are not directed to children under sixteen (16) years of age. By using this website, or otherwise engaging with Vault, you represent and warrant to Vault that you are over the age of sixteen (16). If we learn we have collected or received personal information from a child under sixteen (16) without parental consent or a lawful basis, we will delete that information immediately upon notice. If you believe we may have erroneously collected information from or about a child under sixteen (16), please contact us in accordance with the instructions provided below in the “Contact Information” section.
California Data Privacy Disclaimer. Pursuant to California’s “Shine the Light” law, California residents who provide personal information to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. Vault does not, at any time, share your personal information with a third party with whom we know or have reason to believe uses the personal information to undertake independent direct marketing. Vault is not a “business” or “service provider” within the meaning of the California Consumer Privacy Act of 2018, as amended (“CCPA”) and is not subject to, and will not process, data rights requests made pursuant to the CCPA.
Nevada Privacy Rights. Pursuant to Nevada law, a “consumer” (as the term is defined therein) may, at any time, submit a verified request through a designated request address to an “operator” directing the “operator” not to make any sale of any of his or her personal data that the “operator” has collected or will collect about the consumer. For clarity purposes, Vault does not sell your personal information.
Do Not Track Responses. Some browsers have a “Do Not Track” feature, which permits you inform websites you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Therefore, Vault’s website is not able to respond to “Do Not Track” browser requests.
European Economic Area Privacy Rights. If your personal information is subject to, or otherwise afforded protection under, the European Union (EU) General Data Protection Regulation (GDPR), you may have additional rights or privileges. For example, to the extent permitted by the GDPR or EU Member State law, you may access the personal information we hold about you; request that inaccurate, outdated, or no longer necessary information be corrected, erased, or restricted; and request that we provide your personal information in a format that allows you to transfer it to another service provider. You also may withdraw your consent at any time where we are relying on your consent for the processing of your personal information. If you wish to exercise these rights, you can do so at any time by contacting us at support@Vault.com. However, please note that these rights are not absolute, and, for example, withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Vault processes personal information in accordance with the legal bases set forth in the GDPR. For example, our processing of personal information (as described herein) is justified based on the following GDPR statutory provisions: (1) processing is based on the consent; (2) processing is necessary for Vault’s legitimate interests as set out herein; (3) processing is necessary for the performance of a contract to which you are a party; and (4) Vault is required to comply with a legal or statutory obligation in the EU or a Member State. However, you have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes and enforce our agreements.