Vanta Privacy Policy

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Effective date: December 19, 2022

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This Privacy Policy describes how Vanta Inc. (“Vanta”) collects, uses and discloses information, and what choices you have with respect to the information.

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1. Scope of this Privacy Policy

This Privacy Policy applies to Vanta’s products and services, including applicable mobile and desktop applications (collectively, the “Services”), Vanta.com and other Vanta websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Vanta. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of Vanta’s business.

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This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Vanta platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “MSA”), including the processing of any data submitted through the Services (“Service Data”). The organization (e.g., your employer or another entity or person) that agreed to the MSA (“Customer”) controls its instance of the Services and any associated Service Data (the “Customer Instance”).

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2. Information Vanta Collects and Receives

Vanta may collect, generate, and receive Service Data and other information and data (“Other Information”; Service Data and Other Information collectively “Information”)) in a variety of ways:

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• Service data. Customers and individuals granted access to a Customer Instance by a Customer (“Authorized Users”) may submit Service Data to Vanta when using the Services.
  

• Other information.
• ~Account information. To create or update a Vanta account, you or a Customer (e.g., your employer) supply Vanta with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Vanta (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
  
• ~Usage information.
• ~~Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users interact with the Services. For example, Vanta logs what Third Party Services are connected with the Services (if any).‍
• ~~Log data. As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.‍
• ~~Device information. Vanta collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether Vanta collects some or all of this information often depends on the type of device used and its settings.‍
• ~~Location information. Vanta receives information from you, your Customer and other third parties that may help Vanta approximate your location. Vanta may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Vanta may also collect location information from devices in accordance with the consent process provided by your device.
  

• ~Cookie information. Vanta uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how Vanta uses these technologies, and your opt-out opportunities and other options, please see Vanta’s Cookie Policy.

• Third-Party Services. A Customer can connect Third-Party Services to its Customer Instance. Typically, Third-Party Services are software services that integrate with Vanta Services, and a Customer can permit its Authorized Users to enable and disable these integrations for its Customer Instance. Vanta may also develop and offer Vanta applications that connect the Services with a Third-Party Service. Once enabled, the provider of a Third-Party Service may share certain information with Vanta. For example, if a single sign-on service is connected with Vanta, Vanta may receive the username and email address of Authorized Users, along with additional information that the application has elected to make available to Vanta to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third-Party Services to understand what data may be disclosed to Vanta. When a Third-Party Service is enabled, Vanta is authorized to connect and access Other Information made available to Vanta in accordance with any permission(s) granted by Customer (including, by its Authorized User(s)). Vanta does not, however, receive or store passwords for any of these Third-Party Services when connecting them to the Services.

• Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.

• Third-party data. Vanta may receive data about organizations, industries, lists of companies that are customers, Website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners, or others that Vanta engages with to make Vanta’s own information better or more useful. This data may be combined with Other Information Vanta collects and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
• ‍Additional information provided to Vanta. Vanta receives Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in an educational program hosted by Vanta or a vendor, request support, interact with our social media accounts or otherwise communicate with Vanta.

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3. How Vanta Uses Information

Service Data will be used by Vanta in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law. Vanta is a processor of Service Data and Customer is the controller.

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In addition, Vanta uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Vanta uses Information:

• To provide, update, maintain and protect our Services, Websites, and business. This includes use of Service Data and Other Information to support delivery of the Services under an MSA, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.

• As required by applicable law, legal process, or regulation.
• To communicate with you by responding to your requests, comments, and questions. If you contact us, Vanta may use Information to respond.

• To develop and provide additional features. Vanta tries to make the Services as useful as possible for Customers and Authorized Users, and Vanta may use aggregated and anonymized Services Data and Other Information to develop new Services or improve existing Services.

• To send emails and other communications. Vanta may send you service, technical and other administrative emails, messages, and other types of communications. Vanta may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, Vanta sometimes sends emails about new product features, promotional communications, or other news about Vanta. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Vanta please reach out through the contact mechanisms described below.

• For billing, account management, and other administrative matters. Vanta may need to contact you for invoicing, account management, and similar reasons and Vanta uses account data to administer accounts and keep track of billing and payments.
• To investigate and help prevent security issues and abuse.

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If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Vanta may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

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4. Data Retention

Vanta will retain Service Data in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law.

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Vanta may retain Other Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Other Information for the period of time needed for Vanta to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

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5. How Vanta Shares and Discloses Information

This section describes how Vanta may share and disclose Information.

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• Displaying and operating the Services. Because of the nature and functionality of the Services, Information will be displayed as part of the Services to Authorized Users in a Customer Instance. For example, information about which of Customer’s employees may have two-factor authentication enabled may be displayed as part of the Services.
• Third-party service providers and partners. Vanta may engage third parties as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services. To the extent necessary and applicable, these third-party service providers and partners will be bound by appropriate and commercially reasonable confidentiality obligations. Additional information about the subprocessors Vanta uses to support delivery of our Services is set forth in our list of Vanta Subprocessors.
• Third-Party Services. Customer may enable or permit Authorized Users to enable Third- Party Services. Vanta requires each Third-Party Service to disclose all permissions for information access in the Services, but Vanta does not guarantee that they do so. When enabled and as requested by Customer, Vanta may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Vanta and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the service provider for any questions.
• Corporate affiliates. Vanta may share Information with its corporate affiliates, parents, and/or subsidiaries.
• During a change to Vanta’s business. If Vanta engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Vanta’s assets or stock, financing, public offering of securities, acquisition of all or a portion of Vanta’s business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to appropriate and commercially reasonable confidentiality arrangements.
• Aggregated or de-identified data. Vanta may disclose or use aggregated or de-identified Information for any purpose. For example, Vanta may share aggregated or de-identified Information with prospects or partners for business or research purposes.
• To Comply with Laws. If a law enforcement or government agency sends Vanta a demand for Information about a Customer, Vanta shall attempt to redirect the agency to request that data directly from the Customer. As part of this effort, Vanta may provide the Customer’s basic contact information to the law enforcement or government agency. If compelled to disclose Information to a law enforcement or government agency, then Vanta will give the Customer reasonable notice of the demand and cooperation to allow the Customer to seek a protective order or other appropriate remedy unless Vanta is legally prohibited from doing so. Vanta will not voluntarily disclose Information related to a Customer to any law enforcement or government agency.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Vanta or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.‍
• With consent. Vanta may share Information with third parties when Vanta has consent to do so.

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6. Security

Security is critical to Vanta’s mission, and Vanta takes security of data seriously. Vanta uses industry-standard technical and organizational measures to protect Information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information Vanta collects, processes, and stores, and the current state of technology. Given the nature of communications and information processing technology, Vanta cannot guarantee that Information in our care will be absolutely safe from intrusion by others during transmission through the Internet or while stored on our systems or otherwise. When you click a link to a third-party site, you will be leaving our site and Vanta doesn’t control or endorse what is on third-party sites.

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7. Age Limitations

To the extent prohibited by applicable law, Vanta does not allow use of our Services and Websites by anyone younger than 16 years old. If Vanta learns that anyone younger than 16 has unlawfully provided Personal Data, Vanta will take steps to delete such information.

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8. Changes to This Privacy Policy

Vanta may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or Vanta may make changes to our services or business. Vanta will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If Vanta makes changes that materially alter your privacy rights, Vanta will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should cease interacting with the Services. Contact the applicable Customer if you wish to request the removal of Personal Data under their control.

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9. International Data Transfers

Vanta may transfer your Personal Data to countries other than the one in which you live - generally, from locations outside the United States to the United States. Vanta deploys the following safeguards if Vanta transfers Personal Data from jurisdictions with differing data protection laws:

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• European Union Model Clauses. Vanta offers European Union Model Clauses (“Model Clauses”) also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the EEA, Switzerland, and the UK and for other international transfers of Customer Data as relevant. A copy of our standard data processing addendum, incorporating Model Clauses, is available here.

E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. While Vanta is self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, it is not currently relying on those frameworks for the transfer of personal data. For more information, see the Privacy Shield section below.

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10. Data Protection Officer

To contact Vantas DPO please contact:
GDPR Local Ltd‍
contact@gdpr.com

Tel + 441 772 217 800

GDPR Local Ltd

1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB

‍Our appointed EU Representative is:
Instant EU GDPR Representative Ltd

Adam Brogden

contact@gdprlocal.com

Tel + 353 15 549 700

INSTANT EU GDPR REPRESENTATIVE LTD

Office 2,

12A Lower Main Street,  Lucan Co.  Dublin

K78 X5P8

Ireland

Our nominated UK Representative is:
GDPR Local Ltd

Adam Brogden

contact@gdpr.com

Tel + 441 772 217 800

GDPR Local Ltd

1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB

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11. Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Service Data. In general, Vanta is the processor of Service Data and the controller of Other Information.

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12. Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. Contact the Customer who controls your Vanta instance for additional access and assistance. That Customer can work with Vanta’s Legal and Customer Success teams to address your concerns.

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To the extent that Vanta’s processing of your Personal Data is subject to the General Data Protection Regulation or applicable laws covering the processing of Personal Data such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), Vanta relies on its legitimate interests, described above, to process your data. Vanta may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Vanta’s use of your Personal Data for this purpose at any time.

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13. Your California Privacy Rights

This section provides additional details about the personal information Vanta collects about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

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For more details about the personal information Vanta has collected over the last 12 months, including the categories of sources, please see the Information Vanta Collects and Receives section above. Vanta collects this information for the business and commercial purposes described in the How Vanta Uses Information section above. Vanta shares this information with the categories of third parties described in the How Vanta Shares and Disclose Information section above. Vanta does not sell (as such term is defined in the CCPA) the personal information Vanta collects. Please note that Vanta may use third-party cookies for our advertising purposes as further described in our Cookie Policy.

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Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information Vanta collects (including how Vanta uses and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

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California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@vanta.com. Vanta will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

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14. Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Vanta’s use of Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority or the Irish Data Protection Commissioner, which is Vanta’s lead supervisory authority in the European Union. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to privacy@vanta.com or to our lead supervisory authority:

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Irish Data Protection Commissioner

Office of the Data Protection Commissioner

Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland

Phone +353 57 868 4757

Fax: +353 57 868 4757

Email: info@dataprotection.ie

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If you are a resident of the United Kingdom and believe we maintain your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.

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15. Privacy Shield

‍Vanta complies with the EU-U.S. Privacy Shield Framework and/or the Swiss-U.S. Privacy Shield  Framework(s) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland, to the United States.  Vanta has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Vanta commits to resolve complaints about our collection or use of your personal information. European Union and/or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Vanta at privacy@vanta.com.

Vanta has further committed to refer unresolved Privacy Shield complaints to JAMS ADR, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit 

https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information or to file a complaint.  The services of JAMS ADR are provided at no cost to you.

An individual who decides to invoke this arbitration option must take the following steps prior to initiating an arbitration claim: (1) raise the claimed violation directly with Vanta and afford us an opportunity to resolve the issue within the timeframe set forth in Section III.11(d)(i) of the Principles; (2) make use of the independent recourse mechanism under the Principles, which is at no cost to the individual; and (3) raise the issue through their Data Protection Authority to the Department of Commerce and afford the Department of Commerce an opportunity to use best efforts to resolve the issue within the timeframes set forth in the Letter from the International Trade Administration of the Department of Commerce, at no cost to the individual. This arbitration option may not be invoked if the individual’s same claimed violation of the Principles (1) has previously been subject to binding arbitration; (2) was the subject of a final judgment entered in a court action to which the individual was a party; or (3) was previously settled by the parties.

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In addition, this option may not be invoked if an EU Data Protection Authority or the Commissioner (1) has authority under Sections III.5 or III.9 of the Principles; or (2) has the authority to resolve the claimed violation directly with Vanta. A DPA’s, or the Commissioner's authority to resolve the same claim against an EU or a Swiss data controller does not alone preclude invocation of this arbitration option against a different legal entity not bound by the DPA or Commissioner's authority.

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The Federal Trade Commission has jurisdiction over Vanta’s compliance with the Privacy Shield.

In the context of an onward transfer, Vanta has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Vanta shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

While Vanta is a Privacy Shield participant, Vanta does not rely on Privacy Shield in order to lawfully transfer data from non-US locations into the US.

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16. Contacting Vanta

Please also feel free to contact Vanta if you have any questions about this Privacy Policy or Vanta’s practices, or if you are seeking to exercise any of your statutory rights. Vanta will respond within a timeframe that is compliant with all applicable regulations

You may contact us at privacy@vanta.com or at our mailing address below:

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Vanta Inc.

‍Attn: Data Privacy Officer

369 Hayes

San Francisco, CA 94102