Mobile Application Privacy Policy

VAULTD

Effective as of [3/24/2026]

This privacy policy (the “Privacy Policy”) applies to the Vaultd mobile application[1] (the “Application”), owned and operated by Vaultd Inc. (“Vaultd,” the “Company,” “we,” “us,” or “our”). This Privacy Policy describes what information the Application collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. We encourage you to read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.

By accessing or using the Application, you agree to this Privacy Policy and the accompanying Terms of Use. If you do not agree with our Privacy Policy and related practices, you are not permitted to use or access the Application and must discontinue use of the Application and delete it from your mobile device immediately.

Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use (the “Terms of Use”) or End User License Agreement (“EULA” – together with this Privacy Policy and the Terms of Use, the “Legal Terms”).

1.     Information We Collect or Receive. In the course of operating the Application, we will collect and/or receive the following types of information about you as a user of the Application (a “User”). You authorize us to collect and/or receive such information by using or accessing the Application.

(a)        Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email or other means. When you create an account with Vaultd (an “Account”), enroll in a subscription with Vaultd (a “Subscription”) or contact us directly, you will be required to provide us with personal information about yourself, which may include, without limitation, your name, email address, phone number and mailing address[2] (collectively, the “Personal Information”). You may also be asked to verify your identity by providing proof of government issued identification, which may include your driver’s license or passport.[3] Additionally, if a Vaultd User invites you to join the Application and create an Account and join the Application via SMS message (text), your phone number was provided to us by the inviting User. Except as otherwise set forth herein, we do not collect any Personal Information from you when you use the Application unless you voluntarily provide us with your Personal Information.[4]

(b)        Third-party Log In. If you sign in through your email provider or Apple ID, you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that such third-party email provider or Apple, as applicable, would provide to us through their respective Application Programming Interface (“API”). Such information may include, without limitation, your full name, email address, Apple ID, profile picture, unique identifier and access token, as may be the case depending on the third-party API.

(c)        Payment Information. If you choose to enroll in a Subscription with Vaultd, you will be required to provide us with your payment information, which may include, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, billing information and similar data (collectively, “Payment Information”).[5] Such Payment Information will be collected and processed by (i) Apple’s App Store (the “App Store”) as our third-party payment vendor (“Payment Processor”) pursuant to the terms and conditions of the App Store’s privacy policy and terms of use and (ii) RevenueCat as our third-party subscription manager (the “Subscription Manager”) pursuant to the terms and conditions of RevenueCat’s privacy policy and terms of use.[6] [We do not obtain access to any of your Payment Information in connection with such your purchase of a Subscription.]

(d)        User Contributions and Use of Interactive Services[7].  As more particularly described in our Terms of Service, the Application permits Users to post, upload, submit, display and transmit (hereinafter “post”) User-generated or User-owned content or materials (“User Contributions”) onto the Application and to other Users. The Application also may contain message boards, chat areas, personal and/or profile pages, forums, bulletin boards, communities and other interactive features (collectively, the “Interactive Features”). We may collect certain information when you post User Contributions and utilize the Application’s Interactive Features (collectively, the “Interaction Information”). Please note that your User Contributions are posted on the Application and transmitted to other Users with your consent and at your own risk.

(e)        Geolocational Information.[8] Certain features and functionalities of the Application are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent[9], automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers[10] (collectively, “Geolocational Information”). Vaultd’s collection of Geolocational Information occurs only when the Application is running (open) on your device.[11] You may decline to allow us to collect such Geolocational Information by [process- is there a setting in the App? Or is this done by changing settings on the mobile device or contacting Vaultd?][12], in which case we may not be able to provide certain features or functionalities to you.

(f)         Usage Information.[13] We may automatically collect or receive additional information about you, your use of and interactions with the Application, your mobile device and your connection to the Application (collectively, the “Usage Information”). The Usage Information we collect may include, without limitation:

(i)       Information about Your Activity and Mobile Device. We may collect or receive information regarding: (1) your activity on the Application, including search queries and other performance and usage data; (2) your IP address (which may consist of a static or dynamic IP address and will sometimes direct to a specific mobile device[ or computer]; (3) your browser type[14]; (4) your language preferences; (5) your date and time (and consequently your time zone); (6) referring and exit pages and URLs; (7) your mobile device; (8) your device’s name; (9) your operating system and version (e.g., iOS, Android, etc.); (10) your network connection; and (11) other technical information collected and used for analytics purposes.

(ii)      Information from Cookies[15].  Cookies are small text files that an application or website can utilize to recognize a repeat visitor to the application or website. We may utilize session cookies (which expire when the Application is closed), persistent cookies (which remain on your mobile device[ or computer] until you delete them), and other tracking technologies to help us collect data and to enhance your experience with the Application. We may also utilize cookies to personalize your experience on the Application, analyze which portions of the Application are visited and used most frequently, and measure and optimize advertising and promotional effectiveness.[16] If you do not want us to utilize cookies in the Application, you can opt out by rejecting cookies [in your mobile device settings OR in the Application’s settings].[17] You may opt to disable cookies on the Application, however doing so may restrict your ability to use and access certain features of the Application.[18]

(g)        Additional Information You Provide. In addition to the foregoing categories of information, you may, but are not required to, provide additional information about yourself to us, such as [your gender, age, and product and service preferences].[19]

2.     [Information Collected by or Through Third-Party Advertising Companies. We may share Other Information about your activity on the Application with third parties for ad distribution and ad optimization (defined as the tailoring, targeting (i.e., behavioral, contextual, retargeting, analyzing, managing, reporting, and optimizing of ads). These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect Other Information for such purposes. Pixel tags enable us and these third-party advertising companies to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. In addition, we may receive Other Information from advertisers and/or their service providers such as advertising identifiers, IP addresses, and post-conversion data.][20]

3.     [How to Opt Out of Third-Party Interest-Based Advertising. If you wish to opt out of third-party interest-based advertising, please contact us via email to [support email] or visit http://www.networkadvertising.org and http://www.aboutads.info/choices for details on how to do so. Additionally, users of mobile devices can follow instructions for their applicable mobile device(s).][21]

4.     How We Use and Share Data.

(a)        You authorize us to use the Personal Information, Payment Information, Interaction Information, Geolocational Information, Usage Information and any other information described in Section 1 above (collectively, the “Data”) to:

(i)       provide the Application, the Application’s content (including but not limited to all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof – collectively, the “Application Content”) and the Application’s services products, features and functionality (collectively, the “Services,” and together with the Application Content, the “Content and Services”);

(ii)      enhance and improve the Application and its Content and Services;

(iii)    analyze the Application’s use and to help us improve the Application and its Content and Services;

(iv)    to identify you when you use or access the Application;[22]

(v)      provide direct marketing and administer our promotional programs;

(vi)    carry out our obligations and enforce our rights arising from any contracts you enter with Vaultd, including for Subscription and billing purposes;[23]

(vii)   to notify you about changes to the Application or any of the Application’s Content and Services

(viii) solicit your feedback; and

(ix)    inform you about our products and services, including the Content and Services.

(b)        [In order to provide the Application and its Content and Services and to administer our promotional programs, we may share certain Data with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.][24]

(c)        We engage third-party vendors and service providers to perform functions on our behalf. Examples may include providing technical assistance, payment processing, subscription management, communications, customer service, and marketing assistance. These vendors and service providers will have access to certain Data only as necessary to perform their respective functions pursuant to the written contract between the relevant vendor/service provider and Vaultd and to the extent permitted by applicable law.

(i)       We will use your Payment Information to process your authorized Subscription-related payments through the [App Store/Application].[25] We will share your Payment Information with the Payment Processor as a third-party service provider only to the extent necessary to process your Susbcription payment. The Payment Processor stores your Payment Information; we do not store this information. Storage by the Payment Processor of your Payment Information is subject to the privacy policies and practices of the App Store as our Payment Processor and is not subject to the terms of this Privacy Policy. By providing your Payment Information, you acknowledge and agree to the App Store’s use of such information for the purpose of processing your Subscription-related payment(s).

(ii)      As mentioned above, we use RevenueCat as our Subscription Manager. We provide the Subscription Manager with information relating to the status of your Subscription and any payments you make in connection with your Subscription[26]. RevenueCat’s privacy practices are governed by their own privacy policy, which can be found at revenuecat.com/privacy.

(iii)    Third-Party Analytics. We work with Amplitude, Inc. (“Amplitude”) as our third-party analytics partner to help us to [collect and][27] evaluate your use of the Application, compile reports on activity, analyze performance metrics, and evaluate Usage Information and other information relating to the Application’s use. By using the Application, you consent to the processing of your Usage Information by Amplitude in the manner and for the purposes set out in this Privacy Policy. We do not share any User Contributions or Personal Information with Amplitude. For more information on Amplitude, including how to opt out from certain Data collection, please contact us via email to [support@myvaultd.app]. Please be advised that if you opt out of any such service or Data collection, you may not be able to use some or all of the Application’s Content and Services.

(iv)    We may use your name, phone number and Account-related information and Subscription-related information to contact you by SMS (text). If you have opted in[28] to receive SMS messages from Vaultd, we may send you the following types of SMS messages: (i) account notifications, including memory reminders, activity alerts, and re-engagement messages encouraging you to add memories to your vaults; (ii) transactional messages related to your account, such as account confirmation or password resets; and (iii) peer-to-peer invitation messages, sent when an existing Vaultd User invites you to join the Application. Vaultd does not sell, rent, disclose or otherwise share your phone number with third-party marketers. Your phone number may be shared with our Twilio, Inc., our SMS messaging service provider (“Twilio”), solely for the purpose of delivering messages on Vaultd’s behalf. Twilio’s privacy practices are governed by their own privacy policy, which can be found at twilio.com/legal/privacy. 

(A)     By using the Application and agreeing to our Legal Terms, you consent to receive SMS messages from Vaultd. You may opt-out of receiving SMS messages from Vaultd at any time by replying “STOP” to any message you receive from us. Once you opt out, you will receive a single confirmation message and thereafter we will not send any further SMS messages to your number. To re-enable SMS messages, reply “START” at any time. You may also opt-out of receiving SMS messages from Vaultd or request that we delete your phone number at any time by sending us an email to support@myvaultd.app.

(B)     Message frequency may vary based on your activity on the Application and your specific notification settings. You can manage your notification preferences at any time within the Application’s settings.

(C)     Standard message and data rates may apply depending on your mobile carrier and plan. You acknowledge and agree that Vaultd is not responsible for any charges incurred from your mobile carrier.

(d)        In an ongoing effort to better understand our users, the Application, and our products and services, we may analyze certain Data in anonymized and aggregate form to operate, maintain, manage, and improve the Application and/or such products and services. This anonymized and aggregated Data does not identify you personally, nor can such anonymized and aggregated Data be attributed to you personally. We may share [and/or license][29] this anonymized and aggregated Data to our affiliates, agents, business and promotional partners, and other third parties.[30] We may also disclose anonymized and aggregated User statistics to describe the Application and the Content and Services to current and prospective business partners and investors and to other third parties for other lawful purposes.

(e)        We may share some or all of your Data with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

(f)         As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Data may be part of the transferred assets. In such a case, we will notify you of the event and how your Data will be impacted.

(g)        To the extent permitted by law, we may also disclose the Data:

(i)       when required by law, court order, or other government or law enforcement authority or regulatory agency;

(ii)      to enforce or apply our Terms of Use, EULA, and other User agreements (as applicable), including for billing purposes; or

(iii)    whenever we believe that disclosing such Data is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

5.     Your Communication Preferences.  You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing or promotional emails. We will use commercially reasonable efforts to process such requests in a timely manner in accordance with requirements established by applicable law. You should be aware, however, that it is not always possible to completely remove or modify information in our Subscription databases. You cannot opt out of receiving transactional emails related to the Application or your Subscription (e.g., requests for support or purchase confirmations). We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by changing the settings on your mobile device[ or in the settings page of the Application][31].

6.     Data Retention Practices.  We will retain your Personal Information while you have an active Subscription with Vaultd and thereafter, upon the lapse or termination of your Subscription or the deletion of your Account, we will retain your Personal Information for [to be provided period]. We will not retain your Personal Information for longer than necessary for the purposes for which we collected your Personal Information (as described more particularly in this Privacy Policy). [We may archive your Personal Information for a certain period prior to its final, permanent deletion as part of our ordinary business procedures.][32] [We will [delete/anonymize and aggregate] your Personal Information when it is no longer necessary or to retain your Personal Information.][33]

7.     App Stores; External Websites. The App Store[and Android Store, Google Play, etc.][34] may collect certain information in connection with your use of the Application, such as Personal Information, Payment Information, Geolocational Information, and other Usage Information. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.[35]

[The Application may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.] [36]

8.     Children. The Application is not directed to children under the age of [13/16/18]. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information or Geolocation Information from any child under the age of [13/16/18][37]. We ask that children under the age of [13/16/18] not use the Application. If a child under the age of [13/16/18] has provided us with Personal Information, Geolocation Information or other Data, a parent or guardian of that child may contact us (as set forth below in Section 14) and request that such information be deleted from our records and not used for any further uses and/or processing. We will evaluate and respond to any requests regarding a child’s Personal Information, Geolocation Information or other Data in accordance with the timeframe set forth in Section 6 above.

9.     How We Protect Your Data. We have implemented appropriate and reasonable security measures and take commercially reasonable steps to protect our User’s Data from loss, misuse, corruption, unauthorized access and disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Data, nor can we guarantee that the Data you supply will not be intercepted while being transmitted over the Internet. As such, you acknowledge and agree that transmission of your Personal Information through the Application is at your own risk. When we contract with third party vendors to provide services related to the Application and any Data, such contracts require the relevant vendor to treat your Data in a manner no less protective than and consistent with this Privacy Policy.[38]

10.  Accessing and Modifying Your Personal Information. We strive to provide you with choices regarding the Personal Information you provide to us. If you have provided us any Personal Information, you may access, review, correct, and/or request we delete your Personal Information by contacting us as set forth below in Section 14 of this Privacy Policy. You may also request access to or the removal of any User Contributions you post to the Application by contacting us as set forth below in Section 14. In certain cases, we may not be able to delete your Personal Information except by also deleting your Account and terminating your Subscription. We may, in our sole discretion, refuse to accommodate a request to change your Personal Information if we believe the change would violate any law or legal requirement or cause your Personal Information to be incorrect.

11.  California Privacy Rights.  This Section provides additional information on how we collect, use and share the Personal Information of California residents.

(a)        California Consumer Privacy Act. 

(i)       Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), California residents have the following rights with respect to their Personal Information (as defined in the CCPA):

(A)     Right to Know and Access; Data Portability: you have the right to obtain a copy of the Personal Information we have collected about you in the past twelve (12) months. You also have the right to know, in the last twelve (12) months: what categories of Personal Information we have collected from you; the sources from which we collected your Personal Information; our commercial purpose for collecting and/or sharing your Personal Information; the categories of Personal Information we have shared and/or sold to third parties; and the categories of third parties to whom we have shared and/or sold your Personal Information

(B)     Right to Delete: you have the right to request that we delete any Personal Information we have collected about you in the past twelve (12) months. Please note that depending on the specifics of your deletion request, we may be required to delete your Account and Subscription.

(C)     Right to Correct: you have the right to correct any inaccurate Personal Information that we have collected about you in the past twelve (12) months.

(D)     Right to Opt Out of Sharing or Selling: you have the right to opt out of the sharing, disclosure or sale of your Personal Information.

(E)     Nondiscrimination: you have the right to exercise your rights under the CCPA without discrimination from us.

(ii)      To exercise any of your rights under the CCPA, please contact us via email to [support email].

(b)        Shine The Light Law.  Under California Civil Code § 1798.83, California residents who have an established business relationship with Vaultd may request a list of the categories of Personal Information that we have disclosed to third parties in the past twelve (12) months and the third party business partners to whom we have disclosed your Personal Information in the past twelve (12) months. Additionally, California residents who have an established business relationship with Vaultd may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to request such information or opt out, please send an email to [support email].

(c)        Do Not Track Law.  Your mobile device may be configured to deliver “Do Not Track” signals to websites and applications that you access. As of the date of this Privacy Policy, we [do/do not][39] monitor, recognize and honor any opt-out or do not track mechanisms, including a general “Do Not Track” setting established on your mobile device.

12.  Important Notices to Non-U.S. Residents. The Application and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Data, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Application, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

13.  GDPR Privacy Rights.  This Section provides additional information on how we collect, use and share the Data (including Personal Information) of European Union residents in accordance with the General Data Protection Regulation (“GDPR”).

(a)        Data Subject Rights.  Under the GDPR, if you are a resident of the European Union, you have the right to:

(i)       Access and receive a copy the Personal Information Vaultd has collected from you;

(ii)      Have your Personal Information corrected, restricted or deleted;

(iii)    Withdraw any consent that you have granted to Vaultd with respect to the processing of your Personal Information; and

(iv)    Object to Vaultd’s processing of your Personal Information.

(b)        Exercising Your Rights.  To exercise any of your rights under the GDPR, please contact us via email to [support email].

(c)        Data Processing Bases.  In processing your Data, including your Personal Information, we rely on the following bases:

(i)       Consent.  We may process your Data, including your Personal Information, if you have given us permission to use your Data for a specific purpose. You may withdraw your consent to processing your Data at any time by contacting us via email to [support email].

(ii)      Performance of a Contract.  We may process your Data, including your Personal Information, when we reasonably believe that it is necessary to fulfill our contractual obligations to you, including for purposes of providing you with an Account and/or Subscription with Vaultd or providing you with the Content and Services.

(iii)    Legitimate Business Interests.  We may process your Data, including your Personal Information, when we reasonably believe that it is necessary to achieve our legitimate business interests, provided that such business interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your Data, including your Personal Information, to understand how our Users access and use the Application and its Content and Services so we can improve the Application’s experience and offerings.

(iv)    Legal Obligations.  We may process your Data, including your Personal Information, where we believe it to be necessary to comply with our legal obligations. For example,, we may process your Data, including your Personal Information, when it is necessary to cooperate with law enforcement and/or government agencies or to exercise or defend our legal rights.

(v)      Vital Interests.  We may process your Data, including your Personal Information, when we reasonably believe it to be necessary to protect the vital interests of you or a third party, such as situations involving potential threats to the health or safety of any person.

14.  Requests Related to Your Data.  If you have submitted any request(s) related to your Data (such as, for example, to access or correct the Personal Information we have collected about you) in accordance with the procedures set forth in this Privacy Policy, we reserve the right to request additional information in order to verify your identity and confirm the legitimacy of your request. Upon receiving your request, we will verify your identity and respond to your request within forty-five (45) days[40] of your request. If we need more time to process your request or verify your identity, we will notify you of the extension, explain why it is necessary and fulfill your request as soon as possible.

15.  Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and in our sole discretion. Any such changes will be posted on the Application. By accessing the Application after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of Users’ Data is governed by the Privacy Policy in effect at the time we collect the Data. Please refer back to this Privacy Policy on a regular basis.

16.  How to Contact Us. If you have questions about this Privacy Policy, please send us an email to [support email] with “Privacy Policy” in the subject line or write to us by mail us at the following address:

Vaultd Inc.