Privacy Policy

This Privacy Policy was last updated on February 6, 2023.

Munro Associates, LLC dba The Vault and its respective subsidiaries, parents and affiliates (collectively, “The Vault” or “Company” or “we” or “us” or “our”) provides this Privacy Policy, including, without limitation, any policies, rules and other terms that are expressly incorporated herein by reference (collectively, this “Privacy Policy”) to describe how we collect, use, and share the information of individuals who (a) visit any of our websites that link to this Privacy Policy and/or the Terms of Service of which this Privacy Policy is a part (the “Terms of Service”), including our website located http://www.thevaultma.com as well as any other media form, media channel, mobile application or mobile website related or connected thereto (collectively, the “Sites”) and (b) content, information, functionality, products or services made available on or through the Sites, including through our retail locations ((a) and (b) are referred to collectively herein as the “Services”). Please read this Privacy Policy carefully before using our Services.

By accessing, browsing, or otherwise using the Services, you agree to our collection, storage, use and disclosure of your information, as described in this Privacy Policy and the Terms of Service.

All updates to this Privacy Policy are noted at the top of this page, with time-date reference for your convenience.  The Vault reserves the right in its sole discretion to amend this Privacy Policy at any time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes so please check the policy periodically for updates.  This Privacy Policy applies to information we collect through the Sites and Services as well as any of our other websites that post this Privacy Policy.  This Privacy Policy does not apply to websites that post different privacy policies or statements.

ARBITRATION NOTICE: THESE TERMS OF SERVICE CONTAIN AN ARBITRATION CLAUSE AND CLASS ACTION WAIVER THAT REQUIRES YOU AND THE VAULT TO RESOLVE ALL DISPUTES WITH EACH OTHER ON AN INDIVIDUAL BASIS THROUGH FINAL AND BINDING ARBITRATION. PLEASE READ THESE TERMS CAREFULLY.

Privacy of Children

Our Sites and Services are not intended for persons under the age of 21. Persons under the age of 21 are not allowed to use our Sites and Services. If we learn or have reason to suspect that a user is under age 21, we will promptly deactivate that user’s personal information collected in connection therewith. If you believe we might have any information from or about a child or person under the age of 21, please contact us at info@thevaultma.com.

What is Personal Information?

For the purposes of this Privacy Policy, personal information means information that identifies, relates to, describes, is capable of being associated with, or could be linked, directly, or indirectly, with a particular individual.  Personal information does not include publicly available information.

What Information is Collected?

Information You Give Us.  When you contact us or opt in by utilizing our Services, registering to receive alerts, join our VIP Program, or provide other information via email, text, or instant message, we may collect your‎ age, date of birth, state of residence, location information, email address, phone number, as well as other information, that you directly give us. If you visit one of our retail locations or request product delivery, we may also collect personal information from your government identification card when you provide it to us, including your name, address, picture, driver license or other government identification card number, and any other information on your government identification card.

Photographic and Audiovisual Recordings

If you visit one of our retail locations or request product delivery, we may also collect personal information that we capture from our security cameras inside and around our retail locations. Photographic and audiovisual recordings of you inside and around our retail stores and delivery vehicles will be used for the purpose of maintaining physical security, identifying you, and complying with laws that require video surveillance. Audiovisual footage captured in stores, and any photo of yourself that you supply, may also be used to help identify you, and customize your experience as you use our Services. You acknowledge that audiovisual and photographic recordings of you may be stored by The Vault and accessed by and supplied to our employees, government agencies, and others at The Vault in our sole discretion at any time, for any purpose, with or without a legal order or subpoena, and without notice or financial compensation to you.

Information Automatically Collected.  We may automatically log information about you and your computer or mobile device when you access the Services.  For example, when visiting our Sites, we may log your computer operating system type, browser type, IP address, geolocation information, referring website from which you accessed the Sites, pages you viewed on the Sites, how long you spent on a page on the Sites, access times and information about your use of and actions on our Sites.  We may collect device information about your mobile device that you use to access the Mobile App. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends and to learn more about the demographics of our users. Such third-party service providers may use data collection tools to compile reports and provide us with other services in connection with the Services. We will not collect any location information that you do not volunteer or enable. We will delete any location information that you request us to delete.

In addition, we collect information relating to your interactions with us and the Services, including browser type, IP address, pages visited and other activities on the Sites and the other Services, device type, time and date of visit, and other information we collect through the use of cookies, mobile identifiers, and similar technology. We may use your IP address to derive your general location, and we may collect information about the precise location of your mobile device if you enable location services and grant permission. 

Cookies and Similar Technologies

The Sites and the other Services use cookies and similar technologies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. For the purpose of this Privacy Policy, cookies and other similar technologies (like scripts, plugins, tags, device fingerprints, Local Stored Objects, beacons and pixels) are all called “cookies.” The following cookies are used on the Sites and the other Services:

  • Strictly necessary cookies. These are cookies that are required for the operation of the Sites and the other Services. They include, for example, cookies that enable you put items in your shopping cart.

  • Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Sites and the other Services when they are using the Sites and the other Services. This helps us to improve the way the Sites and the other Services work, for example, by ensuring that users are finding what they are looking for easily.

  • Targeting and advertising cookies. These cookies record your visit to the Sites and the other Services, the pages you have visited, and the links you have followed. We will use this information to make the Sites, the other Services and any advertising which may be displayed on the Sites and the other Services more relevant to your interests. We may also share this information with third parties for this purpose.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies.  You can do this through your browser settings. Because each browser is a little different, look at your browser’s “Help Menu” to learn the correct way to modify your cookies.

If you turn cookies off, some of the features that make your Site experience more efficient may not function properly or otherwise be available to you.

Digital Advertising & Analytics

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms.  Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Sites and the other Services and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

The Vault adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity. You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.  Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, the Sites and the other Services may not function as intended.

We may also work with third parties that collect data about your use of the Sites and the other Services and other sites or apps over time for non-advertising purposes.  The Vault uses Google Analytics and other third-party services to improve the performance of the Sites and the other Services and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use the Sites, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

How Do We Use Your Information? 

We may use your information for any lawful purpose, including the following:

  • Improve our Services, functionality, and overall user experience;

  • Deliver our Services to you;

  • Better cater and market to our users, as well as learn about preferences and usage habits;

  • Respond to customer service requests, comments and questions;

  • Send periodic emails, notifications, and text messages regarding our Services;  

  • Administer promotional programs; 

  • Follow up with you after correspondence (live chat, email, or phone inquiries);

  • Communicate about our partners’ products and services; 

  • Automatically update the Mobile App on your device;  

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

  • Troubleshoot technical difficulties and errors;

  • Link or combine user information with other personal information;

  • If you apply for a job, to consider you for employment;

  • For our legal compliance and to maintain the security of the Services;

  • As permitted or required by applicable law or regulatory requirements; and

  • For any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

Who Do We Provide Your Information to? 

Except as disclosed in this Privacy Policy, we do not disclose your personal information to any companies not part of The Vault or its parent, subsidiaries, affiliates, or related entities.  In no event will we ever sell or rent any identifying personal information, except in the form of aggregate consumer information, as described below.  We may, however, share your personal information as follows:

  • With third party vendors who process data on our behalf, such as e-mail service providers, texting platforms, and e-commerce providers;

  • With our partners that we provide products and services to;

  • As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;

  • With third parties who engage in advertising, such as advertising networks, social media networks, or advertising/marketing companies;

  • Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties; 

  • With your consent or as otherwise disclosed at the time of data collection or sharing;

  • We may share information that has been de-identified or aggregated without limitation;

  • We may share personal information for any other purpose disclosed by us when you provide the personal information.

We may also share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including trusted third parties that provide services to us or on our behalf.  For example, we may share your personal information from time to time with third-party information technology, data processing, and call center service providers so that we may operate our business.  

Finally, we may also sell, rent, or share aggregate consumer information (i.e., anonymized summary data) with others for their own uses.  Specifically, if you register to use our Mobile App or join our VIP Program, we may sell, rent or share certain aggregate consumer information that we compile using personal information collected about you and other users.  This aggregate consumer information will never include your name, phone number, email address, or mailing address.  We may sell, rent or share this aggregate consumer information with our partners and other companies for their own marketing, product development, research, or other uses.  

We do not sell, trade, otherwise transfer your personal information outside of the situations detailed above, so we do not have an opt-out. If you have questions about these practices, please contact us at info@thevaultma.com.

Do Not Track Signals

We honor do not track signals and do not track, plant cookies or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Third-Party Links and Tools

The Sites and the other Services may include embedded web applications. These web applications are operated by third parties and may collect personal information about you on our behalf; however, we do not control the privacy practices of such applications and they are not covered by our Privacy Policy. In addition, the Services may provide links to third-party websites or apps. Such websites or apps are not covered by this Privacy Policy. You should review the privacy policies of other websites or apps that you use to learn about their information practices.

The Sites and the other Services may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Sites and the other Services, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.

SMS/MMS Text Messages.

Should you provide The Vault with your phone number and agree to receive SMS/MMS text messages sent by or on behalf of The Vault, including through the use of automatic dialing programs, you expressly consent to receiving such messages even in the event that your phone number is otherwise registered with a corporate, state, or national “Do Not Call” registry.  Messaging and data rates may apply if you use this service. Please consult your service agreement with your wireless carrier or contact your wireless carrier to review your phone’s pricing plan and any charges for sending or receiving text messages. You acknowledge that you are responsible for messages, data or other charges that you incur by agreeing to receive text messages from The Vault. This service may not be available on all wireless carriers. The Vault may add or remove any wireless carrier from this service at any time without notice to you. The Vault is not responsible for any delays, failure of delivery, or errors in text messages. You also understand that you do not have to agree to receive SMS/MMS text messages from The Vault in order to purchase any goods from The Vault  or its licensees or utilize the Services and that your consent to being contacted is entirely voluntary. To unsubscribe from SMS text messages, reply to said SMS text messages with the word “STOP”.

International Transfers

The Vault is based in and operates exclusively in the United States. If you are located in a jurisdiction outside the US, the data protection laws in the US may not be considered to provide an adequate level of protection under your local data protection laws.  If you are a visitor to this Services and prefer not to have your personal information transferred to the United States, do not access or use the Services.  For transfers of personal information, we may base the transfer on appropriate safeguards, such as standard data protection clauses adopted by the European Commission or by a supervisory authority, approved code of conducts together with binding and enforceable commitments of the recipient, or approved certification mechanisms together with binding and enforceable commitments of the recipient.  You can request a copy of the appropriate safeguards by contacting us as set out below.

Product Pickup and Delivery Disclaimer

Should you decide to patronize a product pickup or delivery service operated by a third party, please be aware that we are not responsible for the collection or use of any information, including personal information, collected by such third-party delivery service. We encourage you to familiarize yourself with such licensee’s privacy policy because such policy, and not this privacy policy, shall apply. 

Accessibility

Individuals who need assistance accessing this Privacy Policy in an alternative format can do so by contacting us at the email address below.

HIPAA

The Vault is not an entity that is covered by the Health Insurance Portability and Accountability Act (“HIPAA”). The HIPAA privacy rules apply generally to health plans, health care clearinghouses, and to health care providers. This means that the information that you provide to The Vault is not protected by the HIPAA privacy rules and regulations.

Rights to your Personal Information  

You have the right to “opt in” and/or “opt out” of certain uses of your personal information.  Depending on your jurisdiction, you may have additional choices about how we collect, use and share your personal information.  You may have rights to:

  • • Request that we erase or delete some (or all) of your personal information in our possession subject to limitations related to certain security measures, anti-fraud policies and procedures and other obligations set forth herein; 

  • • Edit the personal information we have on file for you through your User Account;

  • • Ask us to stop using or sharing your personal information (subject to our legal right to do so and in accordance with the terms of this Privacy Policy);

  • • Request a copy of your personal information in our possession; and

  • • You have the ability to review, change and correct the personal information you provide us. If you are a registered user, you can access, correct or update your User Account.  When you access our Sites, you may opt out of receiving future e-mail communications from us.

To exercise your rights under this Section, you can contact us by email info@thevaultma.com or by phone 774-544-1420.  We will consider your requests and our obligations to respond in accordance with applicable laws.  Please note, there may be circumstances in which we are unable to fulfill your request if it violates applicable laws or our other policies and procedures.

In the event you close your User Account, we will retain copies of your personal information if we believe it is reasonably necessary for us to do so due to our legal obligations, meet regulatory requirements, maintain security, prevent fraud and abuse, enforce our rights hereunder or the Terms of Service, or fulfill your requests related to your personal information including your requests to unsubscribe from our Services.

We will try to comply with your requests made pursuant to this Section as soon as is reasonably practicable.  It is important to note, should you exercise your right to “opt out” as described herein, we may not be able to remove your personal information from the databases of the third parties or affiliates with whom we have already shared your personal information prior to the date of your request.  

We encourage our customers who are California residents to review the “California Privacy Rights” section below which sets forth certain privacy rights specifically available to California residents.

California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.

Categories of Sources. We collect personal information from the following categories of sources:

  • Consumers;

  • Advertising networks;

  • Data analytics providers;

  • Operating systems and platforms;

  • Social networks;

  • Service providers; and

  • Affiliated entities irrespective of whatever marks they may use.

Personal Information We Collect. We collect the following categories of personal information about California consumers.

  • Personal and online identifiers (such as first and last name, email address, or unique online identifiers);

  • Categories of information described in Section 1798.80(e) of the California Civil Code (such as physical characteristics or description, credit card number, debit card number, or any other financial information, medical information, or health insurance information);

  • Characteristics of protected classifications under California or federal law (such as race or gender);

  • Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered);

  • Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);

  • Biometric information (such as call recordings);

  • Geolocation information;

  • Sensory information (such as audio, electronic, visual, thermal, olfactory, or similar information);

  • Professional or employment-related information;

  • Education information;

  • Inferences drawn from the above information about your predicted characteristics and preferences; and

  • Other information about you that is linked to the personal information above.

Why We Collect, Use, and Share California Information.

We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes include, without limitation:

Our commercial purposes, including:

    • To provide you with products and services;

    • To advertise our products and services;

    • To provide you with news and information;

Our business purposes as identified in the CCPA, which include:

    • Auditing related to our interactions with you;

    • Legal compliance;

    • Detecting and protecting against security incidents, fraud, and illegal activity;

    • Debugging;

    • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;

    • Internal research for technological improvement;

    • Internal operations;

    • Activities to maintain and improve the Services; and

    • Other one-time uses.

Your Rights Regarding Personal Information.

California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

    • The right to know the categories and specific pieces of personal information we collect, use, and disclose about you; the categories of sources from which we collected personal information about you; our purposes for collecting or sharing personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.

    • The right to request that we delete the personal information we have collected from you.

    • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA and, unless permitted by the CCPA, we will not: Deny you the ability to access the Services; charge you different prices or rates for the Services; or provide you with a different level or quality of Services.

    • To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at minimum, your full name and an email address or a mobile phone number.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by providing the authorized agent written permission to do so.  We may require you to verify your own identity directly with us for requests to access or delete personal information. 

Your Choices

To opt out of our e-mail marketing, you can use the link provided at the bottom of each marketing message. To opt out of receiving text messages from us, please reply to a text message from us and respond “STOP.”

Updating Your Information

You may request to review, change, or update your contact information by e-mailing us at info@thevaultma.com.

Consent

By using our Services, we assume that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.  You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the contact information set out below.  All communications with respect to such withdrawal or variation of consent should be addressed to our mark.sipe@thevaultma.com.  Please note that in some circumstances, withdrawing or changing your consent to certain uses of your personal information may affect: (i) our ability to provide you with the Services you request; and (ii) your ability to access the Sites and Services.  

Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time. We will text you, e-mail you and/or post a notification on the Sites and/or in the other Services in the event of any material changes to this Privacy Policy. Such changes, whether in the form of modifications, additions, or deletions, shall be effective when specified in the relevant notification and will apply to information we collect after the changes are effective. If the change is not material, the change shall be effective immediately upon appearing on the Sites and the other Services regardless of the date of notice. Please check this Privacy Policy periodically for changes.

Cannabis Acknowledgment

You acknowledge that, to the extent it pertains to cannabis, our Services are only available in the state of Massachusetts and its localities with laws authorizing and/or regulating the medical or recreational use of cannabis and only to the extent permitted by such laws.  Cannabis is a Schedule I controlled substance under the federal Controlled Substances Act and, therefore the possession, cultivation and distribution thereof, or conspiring with or assisting others to do the same, is federally illegal and can result in significant criminal and civil penalties.  You further acknowledge that medical use is not recognized as a valid defense under federal laws regulating cannabis, and that the interstate transportation of cannabis is a federal offense.  ENGAGING IN ACTIVITIES OR BUSINESS RELATED TO CANNABIS IS AT YOUR OWN RISK.

Venue; Jurisdiction; Dispute Resolution 

Venue/Jurisdiction. Our Services are owned and operated by The Vault from within the United States of America and are not meant to subject The Vault to the laws of any jurisdiction of any country other than the United States of America.  You understand we reserve the right to limit, in whole or in part, our Services to any person in any jurisdiction, subject to applicable laws.  This Privacy Policy and all other agreements referenced herein or elsewhere on our Services are subject to the laws of the state of Massachusetts without regard to its conflicts of laws principles.  By using or accessing our Services, you consent to the exclusive jurisdiction of the state courts located in Massachusetts, in connection with any action or proceeding brought to enforce our rights relating to our intellectual property or a judgment awarded pursuant to arbitration as set forth below, and waive any objection to the bringing of any such action or proceeding in such court based upon lack of personal or subject jurisdiction or improper venue.  All other actions or proceedings related to this Privacy Policy or our Services shall be resolved exclusively in accordance with the terms of the arbitration provision below.

Arbitration. Except as otherwise set herein, any dispute arising out of or relating to this Privacy Policy, or the breach thereof, shall be finally resolved by private, confidential arbitration, administered by the American Arbitration Association under its Commercial Arbitration Rules, and judgment upon the award rendered by the arbitrators may be entered in any court having jurisdiction.  There shall be a single arbitrator.  The arbitrators shall decide the dispute in accordance with the substantive law of the state of Massachusetts.  The parties will share equally the cost of the arbitration, but will separately pay their respective attorneys and other costs of the arbitration. Any arbitral award may be enforced in any jurisdiction. The parties hereby undertake to voluntarily comply with the arbitral award issued, as soon as it becomes final.

Waiver of Jury Trial.  THE PARTIES HERETO HEREBY WAIVE, TO THE EXTENT PERMITTED BY APPLICABLE LAW, TRIAL BY JURY IN ANY LITIGATION IN ANY COURT WITH RESPECT TO, IN CONNECTION WITH, OR ARISING OUT OF THIS AGREEMENT OR THE VALIDITY, INTERPRETATION OR ENFORCEMENT HEREOF.  THE PARTIES HERETO AGREE THAT THIS SECTION IS A SPECIFIC AND MATERIAL ASPECT OF THIS AGREEMENT AND WOULD NOT ENTER INTO THIS AGREEMENT IF THIS SECTION WERE NOT PART OF THIS AGREEMENT.

Miscellaneous

Entire Agreement.  This Privacy Policy constitutes the entire agreement between you and The Vault and will govern your use of the Services.

Severability.  If any provision of these Privacy Policy is held to be invalid by any applicable law, rule, order or regulation of any government or by the final nonappealable determination of any state or federal court, such invalidity shall not affect the enforceability of any other provision of this Privacy Policy.

Waiver.  The failure of The Vault to exercise or enforce any right or provision of this Privacy Policy shall not constitute a waiver of such right or provision.  

Section Headings.  The section headings set forth in this Privacy Policy are for convenience only and have no legal or contractual effect.

Terms of Service

This Privacy Policy and its terms and provisions are incorporated into, and a part of https://www.thevaultma.com/app-and-vip-terms. 

Contact

If you have questions, comments, or concerns about this Privacy Policy, please contact us at info@thevaultma.com.