The
Empty Vault
Privacy Policy
Effective
Date: August 1st, 2022
The Empty
Vault (“The Empty Vault”, “we”, “us” or “our”) operates the website
www.TheEmptyVault.com (“The Empty Vault Website”) and the mobile apps (“Cannon
Crisis & Move Up 2D”) (together, “The Empty Vault Family of Applications
and Websites”).
We are
committed to ensuring the privacy and protection of your personal information.
The following privacy policy describes the processing of personal information
that is collected when you access and use The Empty Vault’s Services or
otherwise interact with us. This policy should be read with any other The Empty
Vault terms and conditions or policy notified to you (including the Terms of
Use at www.TheEmptyVault.com/terms-conditions and any other applicable policies
on The Empty Vault Family of Applications and Websites).
Personal
information, or personal data, means information that identifies, relates to,
describes, is reasonably capable of being associated with, or could reasonably
be linked, directly or indirectly, with a particular consumer or household.
When you
provide information on a third-party site or platform, the personal information
you provide may be separately collected by the third-party site or platform.
The personal information we collect is covered by this privacy policy, and the
personal information the third-party site or platform collects is subject to
the third-party site or platform’s privacy practices. Privacy choices you have
made on the third-party site or platform will not apply to our use of the
personal information we have collected directly through Our applications and
websites The Empty Vault Services may contain links to other sites not owned or
controlled by us and we are not responsible for the privacy practices of those
sites. We encourage you to be aware when you leave our sites or applications
and to read the privacy policies of other sites that may collect your personal
information.
CONTENTS:
PART 1:
PERSONAL INFORMATION WE COLLECT ABOUT YOU
PART 2:
HOW YOUR PERSONAL INFORMATION IS COLLECTED
PART 3:
HOW YOUR PERSONAL INFORMATION WILL BE USED
PART 4:
SHARING YOUR PERSONAL INFORMATION
PART 5:
YOUR RIGHTS
PART 6:
RETENTION OF YOUR PERSONAL INFORMATION
PART 7:
SECURITY
PART 8:
STORAGE AND INTERNATIONAL TRANSFERS
PART 9: UNDER
18 - MINORS
PART 10:
BIOMETRIC INFORMATION
PART 11:
CHANGES TO THIS PRIVACY POLICY
PART 12:
COOKIES
PART 13:
HOW TO CONTACT US
PART 1: PERSONAL INFORMATION WE
COLLECT ABOUT YOU
We may
collect the following kinds of personal data about you:
Identity
Data - First name, last name, username, date of birth, gender, country and any other identity information you provide as
part of our shipping process which may include your mailing address.
Contact
Data - Email address and any other contact information you provide to us.
Financial
Data - Please note that for in-app shipping
purchases we do not hold your Financial Data as payment is made either through Pay-Pal.
Transaction
Data - Information about reward advertisements and Token generation Item
purchases.
Profile
Data - Your username, purchase history, the number of Tokens you earn, your
visual image if you choose upload a photo of you into
your Profile and any other personal information you include in the Bio section
of your Profile.
Device
Data - Information from and about the device you use when you use The Empty
Vault Services (whether your desktop, mobile, or other devices) including IP
address, identifiers, type, mobile carrier, browser type and language, and
operating system. This may include your general (non-precise) location which
may be understood from technical data (e.g. your IP
address, language setting of your device, or payment currency.
Usage Data
- Details of your use of The Empty Vault Family of Applications and Websites, including
the content you access, the date and time of your use and the amount of time
spent on the various sites and apps.
Marketing
and Communications Data - Your preferences in receiving marketing from us and
third parties and your communication preferences.
PART 2: HOW YOUR PERSONAL
INFORMATION IS COLLECTED
We will
collect and process the following information about you:
·
Information
you give us:
This
is information (including Identity, Contact, Financial, and Marketing and
Communications Data) you give us when you register to use the Our Services (and
update thereafter) enter a competition, promotion or
survey, and when you report a problem within the system. It also includes
information you give us when you fill in forms on the Websites or Apps, or by
corresponding with us (for example, by email or chat). If you contact us, we
will keep a record of that correspondence.
·
Information
we collect about you and your device:
Each
time you visit one of Our Websites or Apps we will automatically collect
personal data including Device and Usage Data. We collect this data using
cookies and other similar tracking technologies. Please see Part 13 (Cookies)
for further details. We also collect information about your transactions
including Item purchases.
·
Payment
service providers:
We
will receive Contact, Financial and Transaction Data from our payment partners
which allows your transactions that require shipping payments to be processed.
·
Advertising
and marketing partners:
We
may receive information about you from certain advertising or marketing
partners. This allows us to deliver more relevant ads and marketing. This
includes Device Data from analytics providers such as Google.
PART 3: HOW YOUR PERSONAL
INFORMATION WILL BE USED
We will
only use your personal data when the law allows us to do so. Most commonly we
will use your personal data in the following circumstances:
·
Where
you have consented before the processing.
·
Where
we need to perform a contract we are about to enter or
have entered with you.
·
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 or regulatory obligation.
·
To
process purchases transactions and shipping.
·
To
understand, diagnose, troubleshoot, and fix issues within the applications and
websites.
·
Services
including through communications with our customer support team.
·
To
evaluate and develop new features, technologies, and other improvements to The
Empty Vault Services.
·
To
manage our relationship with you including notifying you of changes to The
Empty Vault Services.
·
User
Communication, Marketing, Promotions and Advertising Purposes.
·
To
enable you to participate in a prize draw, competition or complete a survey.
·
To
operate effective security measures for The Empty Vault Service including
security software and processes to detect and prevent bots and other automated
threats.
·
To
operate effective security measures for your Account Identity.
·
To
carry out KYC and meet our other obligations under anti-money laundering
regulations (including transaction monitoring and reporting).
·
To
comply with legal obligations and law enforcement requests.
·
To
establish, exercise, or defend legal claims.
·
To
detect and prevent fraud, including fraudulent payments and fraudulent use of The
Empty Vault Services.
·
To
conduct business planning, reporting, and forecasting.
·
We
may enrich the personal information we hold with the personal information from
third parties where this is permitted under relevant law.
·
To
provide you with recommendations and information within The Empty Vault Family
of Applications and Websites based on the preferences you select in your
Profile and past activity.
We also
collect, use and share aggregated data such as
statistical or demographic data for any purpose ("Aggregated Data").
Biometric Data is not included in or used to generate Aggregate Data.
Aggregated
Data 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 Usage Data to calculate the percentage of
users accessing a specific feature of The Empty Vault Services. 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.
PART 4: SHARING YOUR PERSONAL
INFORMATION
Your user name may be shown on a public leaderboard.
We may
disclose your personal information to the following categories of recipients:
Third
Party Service Providers and Business Partners: We may share your personal information
with our third party service providers (such as those who provide IT (such as
data streaming and cloud services), analytics, payment processing, or customer
support), third party business partners who otherwise process personal
information for purposes that are described in this privacy policy (such as
advertising partners) or who are otherwise notified to you when we collect your
personal information. Where permitted under applicable law, our advertising
partners may combine the personal data we share with them with other data they
collect about you (e.g. your use of their services).
We and our partners may use this information to present you with offers,
promotions, or other marketing activities that we believe will be relevant to
you.
Competent
Law Enforcement Bodies, Regulators, Government Agencies, Courts or other Third
Parties: We may share your personal information with competent law enforcement
bodies, regulators, our insurers, external legal advisors, government agencies,
courts or other third parties where we believe disclosure is necessary: (i) to comply with applicable law; (ii) to exercise,
establish or defend our legal rights (including to collect amounts owed to us);
(iii) to protect your rights or vital interests or those or any other person;
or (iv) to detect, prevent or otherwise address security, fraud or technical
issues.
Potential
Buyers (and their agents and advisors): We may share your personal information
with actual or potential buyers (and their agents and advisors) in connection
with any actual or proposed purchase, merger, acquisition, financing,
reorganization, bankruptcy, receivership, sale of company assets or transition
of service to another provider, provided that we inform the buyer or transferee
that it must use your personal information only for the purposes disclosed in
this Privacy Policy.
PART 5: YOUR RIGHTS
Consent:
If we have collected and process your personal information with your consent,
then you can withdraw your consent at any time by contacting us using the
details provided under How To Contact Us. 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.
Our
communications to you: We may send marketing communications for purposes
notified to you (including as specified in Part 3 above) and, where required by
applicable law, with your consent. You can unsubscribe from electronic
marketing communications at any time by following the unsubscribe instructions
in our emails to you or by contacting us using the details provided under the
How To Contact Us. We will process your request within
a reasonable time after receipt, in accordance with applicable laws.
We may
also send you certain non-promotional communications regarding The Empty Vault Services
and, to the extent permitted by law, you will not be able to opt-out of those
communications (e.g., communications regarding updates to the Terms of Use or
this Privacy Policy).
If you
opt-in on your device, we may occasionally send you push notifications through The
Empty Vault Applications and Websites with updates, achievements and other
notices that may be of interest to you. You may at any time opt-out from
receiving these types of communications by changing the settings on your
device.
Other
rights: Depending on country you live in or where we are regulated, you may
also have other rights in relation to your personal information. For example,
under EU and UK and certain US state laws, additional rights are available as
set out below. Please contact us using the details provided under the How To Contact Us section below if you would like to know more
or with your request. To the extent that we are required to do so under
applicable law, we will process your request.
PART 6: RETENTION OF YOUR PERSONAL
INFORMATION
We will
retain your personal information for the length of time needed to fulfil the
purposes outlined in this privacy policy unless a longer retention period is
required by law. In considering what periods we retain personal data for we
consider various factor including contractual limitation periods and legal
requirements such tax and accounting rules.
PART 7: SECURITY
We take
steps to ensure that your information is treated securely and in accordance
with this privacy policy. We maintain commercially reasonable safeguards
designed to protect against unauthorized use, disclosure
or access of personal information.
PART 8: STORAGE AND INTERNATIONAL
TRANSFERS
We operate
globally and may transfer your personal information to third parties in
locations around the world for the purposes described in this privacy policy.
For example, PayPal.com (our payment provider), Amazon Web Services (our cloud
services provider) Google and Apple (our advertising distributors) are based in
the United States and therefore your personal data will be transferred to the
United States. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to
safeguard the privacy of your personal information.
PART 9: UNDER 18 - MINORS
The Empty
Vault Services are not targeted at minors and we do
not knowingly collect information from individuals under the age of 18. A minor
for this purpose is an individual under 18 years of age or the minimum age
required to use The Empty Vault Services and give valid consent to the
collection and processing of personal information in your country, if lower.
Please contact us using the details provided under the How To
Contact Us section below if you are aware that we may have inadvertently
collected personal information from a minor.
PART 10: BIOMETRIC INFORMATION
No
biometric information is collected or stored for any of The Empty Vault Family
of Applications or Websites.
PART 11: CHANGES TO THIS PRIVACY
POLICY
From time
to time, we may change this privacy policy to accommodate new technologies,
industry practices, regulatory requirements or for other purposes. The
effective date of this Policy is stated at the top of this document under
"Effective Date". Notice may be by posting the revised Policy on The
Empty Vault Website, or by other means to comply with the applicable law.
PART 12: COOKIES
We use
cookies for analytics, Service functionality, performance and for advertising.
By using the term "cookies" we also encompass any other similar
technology such as pixels and web beacons.
Please
note that opting out of personalized advertising does not mean you will no
longer be served advertising. You will continue to receive generic ads.
Other
websites may use different cookies from those we use. You acknowledge and agree
that We are not responsible for any third party
websites or applications and you access third party websites and applications
at your own risk. Please understand other websites and applications are independent
from us so you must inform yourself of their separate cookie policies.
PART 13: HOW TO CONTACT US
For
privacy queries, we can be contacted by emailing [email protected]