Effective date: December 19, 2022
This Privacy Policy describes how Vanta Inc. (“Vanta”) collects, uses and discloses information, and what choices you have with respect to the information.
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.
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”).
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:
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.
In addition, Vanta uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Vanta uses Information:
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.”
Vanta will retain Service Data in accordance with the applicable MSA, Customer’s use of Services functionality, and as required by applicable law.
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.
This section describes how Vanta may share and disclose Information.
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.
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.
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.
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:
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.
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
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.
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.
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.
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.”
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.
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.
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.
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:
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
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.
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.
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.
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.
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:
Vanta Inc.
Attn: Data Privacy Officer
369 Hayes
San Francisco, CA 94102