Privacy Policy
Last revised and effective as of April 26, 2023
Introduction
At Safe Deposit Company, Inc. (SDC), we are committed to your privacy. This Privacy Policy (this “Policy”) applies to the information supplied, collected, or shared with us through your use of our website safedeposit.company and professional services (collectively, our “Services”).
You should carefully read this Policy.
When an organization with which you are associated (an “Employer”), uses the Services, it may share information about its current relevant contacts that do business directly with SDC.
As used in this Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within SDC or among our affiliates within the United States or internationally.
Information We Collect
Depending on your use of the Services, we may collect two types of information: personal information and non-personally identifiable information.
Personal Information
Personal information is information that identifies you or can be used to identify or contact you. Such information may include:
Contact and account information, such as your name, address, email address, telephone number(s), account name and password;
Financial, tax filing and bank account information;
Government-issued identification information, such as social security, passport, permanent resident, and/or driver’s license numbers;
Audio and/or video recordings of our calls with you;
Non-Personally Identifiable Information
Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you, including non-identifiable demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Services. Certain non-personally identifiable information may be considered a part of your personal information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. However, the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your viewing preferences) in a way that would not enable you to be identified.
When and Where Information Is Collected
Registering to Use the Services and in the Course of Using the Services
We will collect information that you submit or make available to us through the Services. You may be required to establish an account in order to take advantage of certain features of the Services. If so, you will be required to provide us with information such as name, phone number, physical address, email address, and other types of information, including as set forth above under “Information We Collect”. Information may also be collected from you if you communicate with us via phone, email, survey responses or other means of communication. Audio and/or video recordings may be collected during our audio and/or video calls with you (including such calls made using the third-party business communication platform to which SDC subscribes).
If you choose to provide your cell phone number for multi-factor authentication purposes, you hereby agree that we may send you informational text (SMS) messages for such authentication purposes. In some cases, information about you may be submitted to us by third-party service providers to your Employer, which may include payroll service bureaus, insurance companies, or other third-party administrators.
Cookies
We may collect information passively using “cookies.” Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Services and other websites. Cookies can be used to personalize your experience on the Services (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Services (such as saving time by not having to reenter your name each time you use the Services), to allow us to statistically monitor how you are using the Services to help us improve our offerings or to determine the popularity of certain content.
Finally, you should be aware that third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Services. This Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services.
Log Files
We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Services. This information may be used to analyze trends, to administer the Services, to monitor the use of the Services, and to gather general demographic information. We may link this information to personal information for these and other purposes such as personalizing your experience on the Services and evaluating the Services in general.
Purposes for the Collection of Personal Information
SDC may use Personal Information to:
Provide Services to our customers;
Administer and improve our Services. We may use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Services. We may link some of this information to personal information for internal purposes or to improve your experience with the Services;
Provide customer service and support.
Respond to your questions or comments and if you identify yourself to us by sending us an e-mail with questions or comments, we may use your information (including personal information) to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference;
Unless you opt out, to the extent permitted by applicable law, contact you about products and services that may be of interest to you;
Send announcements and updates regarding the Services or, if applicable, about your billing account status. You will not be able to unsubscribe from these Services announcements and updates as they contain important information relevant to your use of the Services and are necessary for the performance of our Services; and/or
Detect fraud and monitor security of our Services, networks, and systems.
Disclosure of Personal Information
We generally disclose information we gather from you through the Services to the following types of third parties and as otherwise set forth in this Policy or as specifically authorized by you.
Laws and Legal Rights
We may disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We also may disclose your personal information to government agencies (for government and regulatory reporting and filings purposes). We may disclose personal information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Services or the general public.
Third Parties At Your Direction
We may disclose your personal information to third parties at your direction and/or to third parties that you have elected to use through our Services, such as banks and brokerage firms that process payroll and/or securities transactions.
Third Parties Generally
We may provide to third parties personal information, including where such information is combined with similar information of other users of the Services. For example, we might inform third parties regarding the number of unique users who use the Services, the demographic breakdown of our users of the Services, or the products and/or services purchased using the Services and the vendors of such products and services. In addition to the above, when users use our Services, third parties (including without limitation commercial partners) may directly collect personal information and non-personally identifiable information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect personal information and non-personally identifiable information may include vendors, affiliates and other actual or potential commercial partners, and other similar parties.
Professional Advisors
We may provide your information to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Outside Contractors
We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Services, such as hosting and maintaining the Services, providing credit card processing and fraud screening, and developing applications for the Services. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Services, including your personal information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your personal information.
Sale of Business
We reserve the right to transfer information to a third party in connection with a sale, merger or other transfer of all or substantially all of the assets of SDC or any of its Corporate Affiliates (as defined below), or that portion of SDC or any of its Corporate Affiliates to which the Services relate, or in connection with a strategic investment by a third party in SDC, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.
Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this Policy: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with SDC, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.
Information Related to Minors
SDC does not knowingly collect personal information from persons under the age of 13 and the Services are not designed for or directed to children under the age of 13. If you are under 13 years of age, you may not use our Services.
Our Commitment to Data Security
To prevent unauthorized access, maintain data security and accuracy, and ensure the proper use of information, we have put in place commercially reasonable physical, electronic, and operational procedures designed to safeguard and secure the information we collect online.
Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security and privacy of any information you transmit to us, and you provide your information to us at your own risk.
Links to Other Websites or Services
Our Services may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Services. For the avoidance of doubt, we are not responsible for the privacy practices of your Employer or third-party service providers to your Employer. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each such website and service. This Policy applies solely to information collected by us through the Services.
Transfers to Other Countries
Personal information collected on the Services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Services may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. By using the Services and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. If you are a user accessing the Services from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of the United States, please be advised that all aspects of the Services are governed by the internal laws of the United States and the state of North Carolina, USA, regardless of your location.
Updates to Personal Information
You have the right to request updates of your personal information as follows. For information that we process on behalf of your Employer, please contact that entity directly for assistance with your request. If you have an account on our Services, you may view and/or modify your personal information directly, or, you may contact us (as provided below) in order to (1) update or correct your personal information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personal information maintained about you on our systems (subject to the following paragraph). Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.
You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personal information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, all personal information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.
Do Not Track
The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.
Changes to this Privacy Policy
SDC may update this Policy from time to time. When changed, the policy revision date will be updated as well. Continued use of our Services following revisions will indicate your acceptance of those changes.
How to Contact Us
If you have any questions or comments about this Policy, please contact us using any of the following:
Safe Deposit Company, Inc.
Attn. Customer Service – Privacy Policy
210 Delburg St
Davidson, NC 28036
PHONE
980-213-0133
ELECTRONICALLY
Complete the Contact form on safedeposit.company.
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