Privacy Policy

This Privacy Policy describes the terms and conditions under which Vault Studio, acting as the Data Controller (hereinafter referred to as “the Data Controller”, “we”, “our” or “us”), collects, uses, stores and protects the personal information of users (hereinafter referred to as “the User” or “you”) of the “Vault” iOS application (hereinafter referred to as “the Application”).

We are committed to respecting and protecting the privacy of our Users, in accordance with the laws and regulations in force regarding data protection, in particular the General Data Protection Regulation (GDPR).

1. Identity and Contact Information of the Data Controller

The Data Controller of the data collected through the Application is:

Vault Studio

SIRET: 83213367200028

For any question relating to this Privacy Policy, or to exercise your rights regarding the protection of personal data, you may contact us at the following email address: support@vault-application.com or through the contact form available on our website: https://vault-application.com/

2. Your Vault Content: What We Never Collect

The Data Controller does not collect, access or store the content that you keep in the Application: photos, videos, notes, albums, intrusion reports, and the open tabs and favourites of the built-in browser. This content is never sent to us.

Where it is stored depends on the storage mode you choose in the Application:

On this device (default mode): your content stays in the Application’s storage on your iPhone or iPad and is not sent to iCloud. Deleting the Application permanently deletes it.
iCloud synchronisation (optional, Premium feature): your content is stored in your personal iCloud account, managed by Apple Inc., so that you can find it on your other Apple devices. Its level of protection depends on the type of data:
- your notes, browser favourites and open tabs, intrusion reports and photo thumbnails are end-to-end encrypted by iCloud: only your devices can decrypt them;
- your full-resolution photos and videos are stored in iCloud Drive with Apple’s standard data protection: they are encrypted, but with keys held by Apple. They are end-to-end encrypted only if you turn on Advanced Data Protection for iCloud in your device settings;
- the information used to organise your vault (album names, dates, the profile to which an item belongs, preview images of open browser tabs) benefits from Apple’s standard data protection.

Settings: whatever the storage mode, and if you are signed in to iCloud on your device, the Application saves most of its settings, including your access codes, your chosen options and your subscription status, in the iCloud key-value storage of your Apple account, so that they follow you to your other devices. This storage benefits from Apple’s standard data protection.

The security of the data stored in iCloud is ensured by Apple, in accordance with Apple’s terms and the iCloud settings you choose.

3. Data Processed by the Data Controller and Purposes of Processing

The Data Controller processes only the data described below. None of it contains the content of your vault.

3.1. Usage Measurement (Firebase Analytics)

Types of data collected: the Application uses Google Analytics for Firebase to measure how it is used. It sends:

events describing your use of the Application, for example: opening of the Application and screens viewed, unlocking of a profile (main or secondary), onboarding steps, display and closing of the subscription screens, subscription started, cancelled or failed (with the identifiers of the product and of the offer, and the error code), features used (note created, browser opened, emergency shortcut triggered, icon changed, media saved from a website), your answer to the rating request, the number of items imported and synchronisation incidents (number of files concerned, error codes);
properties describing the state of the Application, for example: number of items in the vault and in the bin, lock method and protection method chosen, storage mode (device or iCloud), subscription and free trial status, synchronisation consistency counters;
your answers to the optional feedback forms (reasons for cancelling a purchase or for not liking the Application), including the free comment if you choose to write one; the second form also sends the language and region of your device, the number of days since installation and the version of the Application;
technical data collected automatically by Firebase: a pseudonymous identifier of your installation of the Application, device model, iOS version, Application version, country, session information, Application and iOS updates, and in-app purchase events.

The Application does not ask for permission to track you (App Tracking Transparency) and therefore has no access to your device’s advertising identifier (IDFA). These data never contain your photos, videos, notes, album names, codes or the addresses of the websites you visit.

Purpose of processing: to understand how the Application is used, measure the use of its features and the subscription journey, detect synchronisation problems, and improve the Application and its offers. These data are not used for advertising, are not sold and are not used to profile you.

Legal basis for processing: the legitimate interest of the Data Controller in measuring the use of its Application in order to improve it. You may object to this processing at any time (see section 7).

Recipients and copies: these data are processed by Google (Firebase). We export them to Google BigQuery, in a data centre located in the European Union (Belgium), and then into our own statistics database, which we use to produce aggregated statistics.

3.2. Remote Configuration (Firebase Remote Config)

Types of data collected: to receive its configuration, the Application sends Google a Firebase installation identifier, the country and language of the device, its time zone, the iOS version, the version of the Application and the properties described in section 3.1.

Purpose of processing: to adjust certain settings of the Application without an update, for example the limits of the free version, the offers presented, variants of certain screens (A/B tests) or the activation of certain features.

Legal basis for processing: the legitimate interest of the Data Controller in operating and improving the Application.

3.3. Crash Diagnostics (Firebase Crashlytics)

Types of data collected: in the event of a crash of the Application, technical data is collected through Firebase Crashlytics: device model, iOS version, Application version, installation identifiers (Crashlytics identifier and Firebase installation identifier), the state of the Application at the time of the crash (crash information, stack traces) and the last screens viewed before the crash. This data is copied to Google BigQuery (European Union, Belgium) for analysis.

Purpose of processing: the sole purpose is to diagnose, analyse and resolve bugs and technical issues of the Application, in order to improve its stability and performance.

Legal basis for processing: the legitimate interest of the Data Controller in ensuring the proper functioning, security and continuous improvement of the Application. This data is pseudonymised and is not used to identify you.

No data linking: the diagnostic data is not combined with any other information in our possession that would allow a direct link to be established with your identity.

3.4. Subscriptions and Purchase Verification

Payments are processed by Apple via the App Store (StoreKit 2). Your payment details (credit card number, etc.) are managed exclusively by Apple and are never transmitted to the Data Controller.

When you subscribe, and when a new transaction (renewal, restoration) reaches the Application, the Application sends our server the transaction signed by Apple (transaction identifiers, product, dates) so that it can be verified. To apply a promotional offer, the Application asks our server for the signature required by Apple, by sending it the identifiers of the product and of the offer. Our server, hosted by Amazon Web Services in the Paris region (France), does not store these transactions. Like any internet service, it receives the IP address of your connection; its technical logs do not contain the content of the transactions and are deleted after 90 days.

The result of the verification (your subscription status) is saved in the iCloud key-value storage of your Apple account (see section 2).

Legal basis for processing: the performance of the contract (providing the service you have subscribed to).

3.5. Built-in Browser

The pages you open in the built-in browser are loaded directly from the websites concerned, which receive the IP address of your connection and may place cookies under their own policies. The searches you submit are carried out on Google Search. The Data Controller receives none of this information.

Two features of the browser also send data to Google:

Search suggestions: while you type in the address bar, the text typed is sent to Google, with the language and region of your device, in order to display suggestions. This request is sent without any cookie, so it is not linked to a Google account, and its result is kept only in memory, never saved on your device. Google receives the IP address of your connection.
Website icons: when you add a favourite, the Application fetches the website’s icon from the website itself; if none is found, it sends the address of the page to Google’s icon service.

Purpose and legal basis: to provide the features you use (performance of the contract). These requests are governed by Google’s privacy policy.

Some features need access to resources of your device. The data concerned remain on your device or in your vault (see section 2) and are never sent to us.

Camera and microphone: to take photos and record videos directly from the Application and add them to your vault. If you activate the corresponding option (disabled by default), the front camera also takes a photo when a wrong code is entered; this photo is saved in the intrusion report, in your vault.
Photo library: to import photos and videos into your vault. After an import, the Application offers to delete the originals from the Photos app; it only does so with your agreement (for this import only, or always), and iOS asks you to confirm the deletion.
Face ID: to unlock your main profile, if you activate this option. Recognition is performed by iOS: the Application only receives the result (success or failure) and never any biometric data.
Motion sensors: to detect the gestures of the emergency shortcuts (for example, device turned face down or shaken), only if you have activated them. This data is processed on the device only.

Legal basis for processing: your consent. iOS asks for it before the first access to the camera, the microphone, the photo library and Face ID; motion sensors are only used once you have activated the emergency shortcuts. You can withdraw your consent at any time in your device’s settings or by deactivating the option in the Application.

4. Data Retention Period

Usage measurement (Firebase Analytics): in Google Analytics, 14 months for event-level data, and 14 months after your last use of the Application for user-level data; 60 days in Google BigQuery; up to 25 months in our statistics database.
Remote configuration (Remote Config): Google keeps Firebase installation identifiers until we request their deletion; they are then deleted within 180 days.
Crash diagnostics (Crashlytics): 90 days at Google; 60 days in Google BigQuery.
Purchase verification: transactions are not stored by our server; its technical logs are deleted after 90 days.
Requests sent to Google by the built-in browser: we do not receive them; their retention is governed by Google’s privacy policy.
Your vault content and settings: we do not store them. They remain on your device until you delete them or delete the Application, and in your iCloud account according to your iCloud settings.

The Data Controller does not sell your data and does not share it with third parties for commercial, advertising or profiling purposes. The Application does not display any advertising.

The only recipients of the data described in section 3 are:

Google, for Firebase Analytics, Remote Config, Crashlytics and BigQuery, as well as for the search suggestions and icon requests of the built-in browser (section 3.5). For Firebase services, Google generally acts as a data processor under the Firebase Data Processing and Security Terms; Google Analytics is subject to its own terms.
Amazon Web Services, which hosts our purchase verification server in the Paris region (France).
Apple, which processes payments and, if you activate synchronisation, stores your iCloud data, under the terms you have accepted with Apple.

International transfers: Google may process data outside the European Union, in particular in the United States. Google LLC is certified under the EU-U.S. Data Privacy Framework.

6. Security Measures

The Data Controller implements appropriate technical and organisational measures to ensure a level of security adapted to the risk, in order to protect the data we process against any destruction, loss, alteration, unauthorised disclosure or unauthorised access.

These measures include in particular:

Protection of your vault: access to the Application is protected by your code and, if you activate it, by Face ID. In iCloud, your content benefits from the protection described in section 2.
Data minimisation: the usage and diagnostic data we receive are limited to counters, technical states and pseudonymous identifiers; they never contain the content of your vault.
Access control: access to relevant systems and data is strictly limited to authorised personnel necessary for the performance of their duties. We have no access to the content you store on your device or in iCloud.
Infrastructure security: usage and diagnostic data are processed on Google’s infrastructure. Our purchase verification server does not keep transactions.
Maintenance and updates: the “Vault” Application and all its software dependencies are subject to regular updates in order to incorporate the latest security advances and correct any vulnerabilities.
Privacy by design: the Application is designed to minimise the collection of personal data, with an architecture where you keep control over your content.

7. User Rights

In accordance with the applicable regulations regarding data protection (in particular the GDPR), the User has several rights concerning their personal data:

Right of access: To obtain confirmation that data concerning you is being processed and, where applicable, to request a copy.
Right of rectification: To request the correction of inaccurate or incomplete information concerning you.
Right to erasure: To request the deletion of your data under certain conditions defined by law.
Right to restriction of processing: To request the restriction of the processing of your data under certain conditions.
Right to object: To object to the processing of your data, in particular processing based on our legitimate interest, such as usage measurement.
Right to data portability: To receive the data you have provided to us, in a structured, commonly used and machine-readable format.
Right to withdraw your consent: For processing based on your consent (such as access to the camera, photo library, Face ID or motion sensors), you have the right to withdraw this consent at any time.

How to Exercise Your Rights

For your vault content and settings: since the Data Controller has no access to them, you exercise your rights directly in the Application (deleting items or the Application) and in the settings of your iCloud account, managed by Apple Inc.
For usage, configuration and diagnostic data (Firebase): you may contact us by email at support@vault-application.com or through the contact form on https://vault-application.com/. This data is pseudonymous and the Application does not display your installation identifier: we will respond to your request to the extent that we are able to identify the data concerning you. The Application does not include a setting to turn off usage measurement: to object to it, you can delete the Application, which stops all collection.
For device permissions (camera, microphone, photo library, Face ID): you may manage and revoke your consent at any time in your device’s settings, under the “Vault” Application. The emergency shortcuts, and therefore the use of motion sensors, can be deactivated in the Application.

In the event of questions or complaints not resolved directly with us, you retain the right to lodge a complaint with the competent supervisory authority for data protection (for example, the Commission Nationale de l’Informatique et des Libertés — CNIL — in France).

8. Changes to This Privacy Policy

The Data Controller reserves the right to modify this Privacy Policy at any time. Any modification will be published on this page with the updated “Effective Date”. We invite Users to consult this page regularly to take note of any changes.