INFORMATION COLLECTION BY UNBXD
Data Controller and Data Processor:
SAN MATEO, CA 94404; by phone at +1 312-934-0010 or by e-mail at GDPR@unbxd.com.
Legal basis for collection and processing of Personal/Usage Information:
The legal basis for collection and processing of any information collected and processed by Unbxd including the Personal Information is (i) your consent at the time of providing the Personal Information; (ii) where it is in our legitimate interests to do so and not overridden by your rights (for example, in some cases for direct marketing, fraud prevention, network and information systems security, responding to your communications, the operation of networks of groups by the network administrators, and improving our Website). In some cases, we may also have a legal obligation to collect information about you, or may otherwise need the information to protect your vital interests or those of another person. We may also process information to comply with a legal requirement or to perform a contract.
Unbxd may ask you to provide certain categories of information such as personal information, which is information that could reasonably be used to identify you personally, such as your name, company address, e-mail address, date of Birth and mobile number (“Personal Information”), when you access the Website, in order to provide you with the relevant information requested.
Additionally, we may collect this information through various forms and in various places through the Website, including when you first register with us, when you create a transaction, when you contact us, when you update your information or from time to time or when you otherwise interact with us. Unbxd may include registration, surveys, and other online forms where users will need to provide Personal Information.
Cookies: Unbxd may use standard “cookie” browser application feature to collect and understand website usability trends. Cookies are text files that we may place in your computer browser to store your preferences. Cookies are used to record various aspects of your visit and assist us in providing you with uninterrupted service. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalized content. [However, no personal information identifying the user is collected nor any data capture mechanisms is employed.] The user may change browser settings to accept or reject cookies on personal preference. You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify the browser setting to decline cookies if you so prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Website that may depend on cookies. If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated. We process and keep all data for our own use and, if you wish to opt-out from tracking by Unbxd you can do so by sending an email to GDPR@unbxd.com.
Processing of Data:
Unbxd may also process any Personal Information or Usage Information collected from you for legitimate commercial purposes including to provide you with the requisite information requested. A list of uses of the Personal Information and Usage Information collected is provided at Section 3 of this Policy (Use of Information Collected).
Unbxd implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals such as (i) only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible; (ii) using secure servers to store your information; (iii) verifying the identity of any individual who requests access to information prior to granting them access to information; and (iv) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.
Right of a user in relation to data submitted:
Any user who has submitted Personal Information on the Website has the right to (i) access, correct, delete such Personal Information subject to us successfully verifying your identity; (ii) object to us processing your Personal Information on legitimate grounds; (iii) to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information; (iv) opting out of receiving any promotional or marketing material by clicking on the “Unsubscribe” button or by sending an email to GDPR@unbxd.com. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent; (v) right to have the Personal Information transferred to another data controller; and (vi) lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. Any request received by us by the user in relation to the aforesaid shall be acknowledged by us within seventy-two (72) business hours.
USE OF INFORMATION COLLECTED
Unbxd does not share any Personal Information with any third party without your consent, except when directed by the law. Unbxd can use this data to verify user identity in line with engagement initiated by the user. [We will communicate with you using the contact information provided by you in order to respond to any queries that you may have and to provide any information that you may request regarding the Services. We may communicate with you either by written, physical communication, email, telephone, SMS or via notifications on your mobile device]. We may also send strictly service-related announcements to you periodically and when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email, text message, flash notification or telephone call. If you do not wish to receive such alerts, you have the option to unsubscribe from such emails or opt out by sending an email to GDPR@unbxd.com.
We may use Personal Information or Usage Information collected through the Website in the following ways:
• To operate and improve our Website and tools associated with the Website;
• To create aggregated and anonymized information to determine which Website features are most popular and useful to users, and for other statistical analyses;
•To customize the content or the Services on the Website for you, or the communications sent to you through the Website.
•To help provide you the Services;
•To observe, improve and administer the quality of Service;
•To analyze how the Website is used, diagnose technical problems;
•Remember the basic information provided by you for effective access;
•To confirm your identity in order to determine your eligibility to use the Website and avail the Services;
•To notify you about any changes to the Website;
•To enable Unbxd to comply with its legal and regulatory obligations;
•For the purpose of sending administrative notices, Service related alerts and other similar communication with a view to optimizing the efficiency of the Website;
•Doing market research, troubleshooting, protection against error, project planning, fraud and other criminal activity; and
Administrative and Legal Reasons:
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of Unbxd, our Services, the Website or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to you.
THIRD PARTY CONTENT AND LINKS TO THIRD PARTY SERVICES
We do not include or offer third party products or services on our website.
Your information will be retained with Unbxd as long as it is needed by Unbxd to provide Services to you. If you wish to cancel your account or request that Unbxd no longer uses your information to provide Services, you may contact Unbxd at GDPR@unbxd.com Unbxd will promptly delete the information as requested. Unbxd will retain and use your information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements or for other business purposes. When Unbxd has no ongoing legitimate business need to process your information, we will either delete or anonymize it.
This website, in compliance with PCI – DSS norms, has a number of security measures to ensure there is no loss, misuse or illegal alteration of information collected from its users. Personal Information and Usage Information we collect is securely stored within our databases, and we use standard, industry-wide, commercially reasonable security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won't be intercepted while being transmitted to us over the Internet or wireless communication and any information you transmit to Unbxd you do at your own risk. If, despite our best efforts, an unauthorised breach of our security measures occurs, resulting in the unauthorised access, duplication, removal or alteration of any Personal Information, Third Party Information, or Usage Information, Unbxd, its directors, officers, employees, promoters, or affiliates will not be held responsible for any loss resulting from such breach.
COMPROMISE OF PERSONAL INFORMATION
In the event that personal information is compromised as a breach of security, Unbxd will notify the supervisory authority in compliance with applicable law, within 72 hours of the breach coming to its notice.
CONTACT & POLICY UPDATES
CHANGE OF INFORMATION AND CANCELLATION OF ACCOUNT
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer desire to access the Website, you may correct, delete inaccuracies, or amend information by contacting us through GDPR@unbxd.com and we will respond within 72 hours of receipt of communication.
You have the right to request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority.
If you wish to opt for receiving non-essential communications such as promotional and marketing-related information regarding the Website and the Services, please send Unbxd an email at firstname.lastname@example.org.
CALIFORNIA ONLINE PRIVACY PROTECTION ACT
According to CalOPPA we agree to the following:
• Users can visit our site anonymously.
•Users are able to change their personal information:
•By emailing us
•By logging in to their account
How does our site handle 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.
Does our site allow third party behavioral tracking?
It's also important to note that we allow third party behavioral tracking
COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)
When it comes to the collection of personal information from children under 13, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation's consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
Protecting the privacy of young children is especially important. For that reason, Unbxd does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at GDPR@unbxd.com.
CAN SPAM ACT
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
• Send information, respond to inquiries, and/or other requests or questions; and
•Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM we agree to the following:
• NOT use false, or misleading subjects or email addresses;
•Identify the message as an advertisement in some reasonable way;
•Include the physical address of our business or site headquarters;
•Monitor third party email marketing services for compliance, if one is used;
•Honor opt-out/unsubscribe requests quickly; and
•Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can
•Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.
FAIR INFORMATION PRACTICES
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email
•Within 7 business days
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
951 MARINERS ISLAND BLVD,
SUITE 200 SAN MATEO,