MOBILE APPLICATION PRIVACY POLICY
VAULTD
Effective as of April 2, 2026
This privacy policy (the “Privacy Policy”) applies to the Vaultd mobile application (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”).
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.
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, date of birth, phone number and email address or Apple ID (collectively, the “Personal Information”). In certain situations (such as the exercise of any of your rights over your Personal Information as provided herein), we may as you to verify your identity by providing proof of government issued identification such as your driver’s license or passport. Additionally, if another Vaultd User invites you to download the Application and create an Account via SMS message (text) or email, your phone number or email (as applicable) was provided to us by the User who generated the invitation. 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 (whether directly or through use of the Application’s Interactive Features).
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.
User Contributions and Use of Interactive Services. As more particularly described in our Terms of Service, the Application permits Users to post, upload, submit, display and transmit (hereinafter “post”) User-generated and User-owned content or materials (“User Contributions”) onto the Application and to other Users. The Application may contain memory vaults (which may include photos, videos, voice/audio files and written notes and captions), comment functions, personal and/or profile pages, group pages, communities, and other interactive features (collectively, the “Interactive Features”). We 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. User Contributions will be permanently deleted only when the posting User voluntarily deletes the User Contributions from the Application. If you delete your Account, please be aware that your User Contributions will NOT be permanently deleted from the Application. User Contributions will be permanently deleted only when the posting User voluntarily deletes their User Contributions from the Application.
Usage Information. We may automatically collect, receive and/or process 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:
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; (3) your browser type; (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.
How We Use and Share Data.
You authorize us to use the Personal Information, Interaction Information, Usage Information and any other information described in Section 1 above (collectively, the “Data”) to:
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”);
provide Accounts and Subscriptions, and related Content and Services, to our Users;
analyze the Application’s use and to help us enhance and improve the Application and its Content and Services;
identify you when you use or access the Application;
provide direct marketing and administer our promotional programs;
carry out our obligations and enforce our rights arising from any contracts you enter with Vaultd;
notify you about changes to the Application or any of the Application’s Content and Services;
solicit your feedback; and
inform you about our products and services, including the Content and Services.
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.
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.
Subscription Management. As more particularly detailed below, we use RevenueCat, Inc. (“RevenueCat”) as our Subscription manager (the “Subscription Manager”). The Subscription Manager automatically receives certain Subscription Information (as hereinafter defined) from the applicable Payment Processor (as hereinafter defined) for the purpose of validating Users’ Subscriptions. No Payment Information (as hereinafter defined) is shared with the Subscription Manager by either Payment Processor. RevenueCat’s privacy practices are governed by their own privacy policy, which can be found at revenuecat.com/privacy.
Third-Party Analytics. We work with Amplitude, Inc. (“Amplitude”) as our third-party analytics partner to help us to 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 Personal Information or User Contributions 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.
Bug Reporting. We work with Functional Software, Inc. d/b/a Sentry (“Sentry”) to diagnose and report bugs in the Application’s code. Sentry automatically receives information on bugs and other issues in the Application’s code to diagnose any bugs and report relevant details to Vaultd so we can maintain and improve the Application. Sentry’s privacy practices are governed by their own privacy policy, which can be found at sentry.io/privacy.
SMS Messaging. We work with Twilio, Inc. (“Twilio”) as our SMS messaging partner. We may use your name, phone number, Account-related information and Subscription Information to contact you by SMS (text). Unless you have opted out of receiving 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. Your phone number may be shared with 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. Except as expressly stated in this Privacy Policy, Vaultd does not sell, rent, disclose or otherwise share your phone number with third-party marketers or advertisers.
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.
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.
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.
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 this anonymized and aggregated Data to our affiliates, agents and business partners, and other third parties solely for the purpose of receiving the services mentioned in Section 2(c) from our service providers. 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.
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.
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.
To the extent permitted by law, we may also disclose the Data:
when required by law, court order, or other government or law enforcement authority or regulatory agency;
to enforce or apply our Terms of Use, EULA, and other User agreements (as applicable), including for billing purposes; or
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.
Information Collected and Maintained by Third Parties. Unless otherwise specified in this Privacy Policy, we do not collect the following types of information; however, our business partners may collect the following information to provide services to us:
Payment Information. If you choose to enroll in a Subscription with Vaultd, you will be required to provide your payment information, which may include, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, billing information, billing address and similar data (collectively, “Payment Information”) to either (a) Apple’s App Store (the “App Store”) or (b) Google’s Google Play store (“Google Play” – together with the App Store, the “Payment Processors”) depending on the your mobile device and operating system. Such Payment Information will be collected and processed by the applicable Payment Processor as our third-party payment vendor pursuant to the terms and conditions of the applicable Payment Processor’s privacy policy and terms of use. Vaultd does not collect or receive any Payment Information, whether in connection with your purchase of a Subscription or otherwise.
Subscription Information. We use RevenueCat as our third-party Subscription Manager. The Subscription Manager automatically receives from the applicable Payment Processor and processes information relating to the status of your Subscription, including User IDs, product identifiers that denote the types of Subscription (e.g., monthly or annual), Subscription status (e.g., active or expired), as well as Subscription renewal and expiration dates and transaction data to validate Subscription purchases and status (collectively, the “Subscription Information”). The Subscription Manager collects and processes the Subscription Information to validate your Subscription and provide us with up-to-date information on the status of your Subscription so we may provide you with access to the Application and its Content and Services (as hereinafter defined). The Subscription Manager collects and processes Subscription Information in accordance with its own privacy policy and terms of use.
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.
App Stores. Both Apple (via the App Store) and Google (via Google Play) may collect certain information in connection with your use of the Application, such as Personal Information, Payment Information, and other Usage Information. We have no control over the collection of such information by such third-party app stores, and any such collection or use will be subject to that third party app store’s applicable privacy policies.
External Websites. 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.
Children. The Application is not directed to children under the age of 18 and we do not knowingly permit children under the age of 18 to create an Account, enroll in a Subscription or otherwise use the Application. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 18. If a child under the age of 18 has provided us with any Personal Information, a parent or guardian of that child may contact us by email to support@myvaultd.app 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 or other Data in accordance with the timeframe set forth in Section 13 below.
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 (as provided herein), 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.
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 by email to support@myvaultd.app with your request. You may also request access to or the removal of any User Contributions you post to the Application by contacting by email to support@myvaultd.app. 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.
California Privacy Rights. This Section provides additional information on how we collect, use and share the Personal Information of California residents.
California Consumer Privacy Act.
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):
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
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.
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.
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.
Nondiscrimination: you have the right to exercise your rights under the CCPA without discrimination from us.
To exercise any of your rights under the CCPA, please contact us via email to support@myvaultd.app.
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@myvaultd.app.
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 not monitor, recognize and honor any opt-out or do not track mechanisms, including a general “Do Not Track” setting established on your mobile device.
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.
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”).
Data Subject Rights. Under the GDPR, if you are a resident of the European Union, you have the right to:
Access and receive a copy the Personal Information Vaultd has collected from you;
Have your Personal Information corrected, restricted or deleted;
Withdraw any consent that you have granted to Vaultd with respect to the processing of your Personal Information; and
Object to Vaultd’s processing of your Personal Information.
Exercising Your Rights. To exercise any of your rights under the GDPR, please contact us via email to support@myvaultd.app.
Data Processing Bases. In processing your Data, including your Personal Information, we rely on the following bases:
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@myvaultd.app.
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.
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.
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.
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.
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 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.
Data Retention Practices. We will retain your Personal Information while you have an Account with Vaultd (regardless of Subscription status) and thereafter, upon the deletion of your Account, we will retain your Personal Information for up to one (1) year unless you request that we permanently delete your Personal Information prior to such time. Following the deletion of your Account, unless you request otherwise, we may archive your Personal Information for up to one (1) year before its final, permanent deletion as part of our ordinary business procedures. Except for such archival as part of our ordinary business procedures, 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).
Please be advised that upon the cancellation of or lapse of your Subscription, so long as you have an active Account, your Personal Information and User Contributions will remain securely stored in case of the subsequent renewal of your Subscription. Your User Contributions will only be removed from the Application if you voluntarily delete your User Contributions from the Application.
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.
How to Contact Us. If you have questions about this Privacy Policy, please send us an email to support@myvaultd.app with “Privacy Policy” in the subject line or write to us by mail us at the following address:
Vaultd Inc.
11987 Southern Boulevard #1093
Royal Palm Beach, Florida 33411