Effective date: 14th December 2021
Welcome to UNBLOK!
The UNBLOK (“Company,” “us,” “we,” or “our”) owns and operates www.unblokapp.com and UNBLOK mobile application (hereinafter referred to as “Service”).
SERVICE means the www.unblokapp.com website and UNBLOK mobile application.
PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
COOKIES are small files stored on your device (computer or mobile device).
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of Personal Data.
THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
3. INFORMATION COLLECTION AND USE
3.1. We collect Personal Information directly from you, from others, and automatically from your use of the Services. We will only collect your Personal Information (a) when applicable, with your consent, (b) if we have a legitimate interest in doing so, or (c) as authorized or required by law. The types of Personal Information we collect about you and the manner of collection depends on how you interact with UNBLOK. We only collect Personal Information as reasonable and necessary. If you do not provide the relevant information, we may not be able to provide you with certain Services or features.
3.2. Sources. We collect Personal Information from these sources:
3.2.1. Directly from you, with your consent. When you register for an UNBLOK account, we collect your username, gender, phone number, email, mailing address, zip code, consignee information, method of payment and bank account information, etc. If you participate in one of UNBLOK’s offline product experience events, we will also ask for your name, gender, email address, and phone number and will collect any other Personal Information you choose to provide. When you contact us for customer service or to make inquiries via our forms, surveys, or other means, we ask for your name, phone number, and transaction information, and we record the date, frequency, and other details about your inquiry. We collect this information with your consent, and we use it to provide you with UNBLOK, respond to your inquiries, and communicate with you, including sending you direct marketing materials.
3.2.2. Automatically from your use of UNBLOK, with your consent. If you opt-in to UNBLOK, you consent to UNBLOK sharing your geolocation and other Personal Information from your account. You can opt-out of UNBLOK at any using the deactivate button on your UNBLOK dashboard. We collect this information with your consent, and we use it to provide you with UNBLOK and for other purposes that you consent to or are permitted by law.
3.4.3. Automatically from your use of UNBLOK or the Site, with a legitimate interest of providing and improving our Services. When you navigate to and through UNBLOK or the Site, we collect information about your device, software, and network, including IP address, browser type, device name and model, device ID, operating system version number, language selected for the device, time zone, telecom operator information, error logs, certain user behavior, and other information collected through cookies and other similar technologies. We collect this information to achieve our legitimate interest in monitoring and improving our Services.
3.5.4. From third parties with a legitimate interest, such as other websites and social networks that you may link to your UNBLOK account, marketing companies, and other third parties that may lawfully provide us with Personal Information. When you link from another website or social network, we may obtain information from your account, such as account ID, email address, and profile picture. We reserve the right to collect information about you from our Service Providers and third-party sources. We may combine this data with information we already have about you. This helps us update, expand and analyze our records, identify new users, and improve and expand our Services.
3.3. Other Ways UNBLOK Uses Personal Information. In addition to the uses specified above, UNBLOK may use your Personal Information:
3.3.1. To provide our Services that you request, such as order processing, maintenance, electronic security implementation, push system upgrades, and other similar purposes for the legal basis of fulfilling our contractual obligations to UNBLOK users and other parties.
3.3.2. For authentication, security, fraud monitoring, archiving, and backup purposes to ensure the security of products and services provided to you by UNBLOK to achieve our legitimate interest of ensuring security for the processing of your Personal Information.
3.3.3. For performance analytics to make user-friendly adjustments to our operations, track regional use of Services to ensure our personnel, language, and after-sales resources are distributed appropriately and for other purposes related to our legitimate interest in improving our Services.
3.3.5. To respond to legal requests and prevent harm, such as if we receive a subpoena or other legal request.
3.3.6. If we believe it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to UNBLOK, or others.
3.3.7. Comply with a law, regulation, legal process, or court order.
3.3.8. For any other purpose with your consent.
4. SHARING YOUR PERSONAL INFORMATION
4.1. Categories. In the preceding 12 months, UNBLOK has disclosed the following categories of Personal Information for business purposes:
4.2.2. Sensitive personal information
4.2.3. Internet or similar activity
4.3.4. Employment-related information
4.4.5. Commercial information
4.2. Recipients. UNBLOK may disclose Personal Information for a business purpose to the following recipients:
4.2.1. Service Providers. Vendors that provide us with services (collectively, “Service Providers”) may access your Personal Information while performing their contractual obligations. These Service Providers include but are not limited to payment processors, marketing companies, IT service providers, and email and data hosting providers. We prohibit our Service Providers from selling or disclosing the Personal Information we provide, and we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. UNBLOK requires our Service Providers to comply with relevant cybersecurity laws and regulations. The type of information that we provide to a Service Provider will depend on the purpose of the service they provide to us.
4.2.3. Law enforcement, and other governmental agencies, as permitted or required by law.
4.3.4. Cookie information recipients, subject to their respective privacy policies.
4.2.5. Other third parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
4.2.6. Aggregated and Deidentified Information. We reserve the right to share aggregated, anonymized, or de-identified information about any individuals with nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction.
5. RETENTION OF DATA
5.2. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
5.3. We will also retain Usage Data for internal analysis purposes.
5.4. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
6. TRANSFER OF DATA
6.1. Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
6.2. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
7. DISCLOSURE OF DATA
7.1. We may disclose personal information that we collect, or you provide:
7.1.1. Disclosure for Law Enforcement.
18.104.22.168. Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
7.1.2. Business Transaction.
22.214.171.124. If our subsidiaries or we are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.
7.1.3. Other cases. We may disclose your information also:
126.96.36.199. to our subsidiaries and affiliates;
188.8.131.52. to contractors, service providers, and other third parties we use to support our business;
184.108.40.206. to fulfill the purpose for which you provide it;
220.127.116.11. for the purpose of including your company’s logo on our website;
18.104.22.168. for any other purpose disclosed by us when you provide the information;
22.214.171.124. with your consent in any other cases;
126.96.36.199. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the company, our customers, or others.
8. PERSONAL INFORMATION ACCESS AND CONTROL
8.1. Depending on where you reside, your options to control your Personal Information may include some or all of the following:
8.1.1. Changing your UNBLOK account and preferences.
8.1.2. Changing your preferences for how and about what we communicate with you.
8.1.3. Correcting, updating, and deleting the Personal Information in your account. Please note that certain legal obligations may limit or prevent our ability to fulfill these requests and that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Site or Software for a period of time.
8.1.4. Requesting access to the Personal Information we hold about you.
8.1.5. Choosing whether to receive marketing communications from us, including promotions, surveys, and information about products and services that may be of interest to you.
8.1.6. Controlling how the cookies we use interact with your browser.
8.2. Do Not Sell My Personal Information. UNBLOK does not share your Personal Information in direct exchange for cryptocurrency, so we don’t sell your Personal Information in the literal sense. We do share your Personal Information with Businesses, Brand & Influencers with your consent as part of the UNBLOK program. In exchange for your participation in UNBLOK, you receive UNBLOK tokens reflecting the value of your participation in UNBLOK for use with our Businesses, Brand & Influencers. Privacy laws define “sell” very broadly, and, in some cases, sharing data for these purposes may be viewed as a “sale” under applicable laws. You can opt-out of these “sales” of your Personal Information anytime by deactivating your participation in UNBLOK on your UNBLOK account dashboard. If you deactivate UNBLOK, you will no longer be eligible to receive UNBLOK tokens in exchange for your data sharing, but you may still use other features available through the UNBLOK platform.
8.3. Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed below.
9. SECURITY OF DATA
9.1. The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure.
9.2. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
10. YOUR RIGHTS
10.1. You have the following rights in relation to your Data:
10.1.1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is "manifestly unfounded or excessive." We may refuse your request where we are legally permitted to do so. If we refuse your request, we will tell you the reasons why.
10.1.2. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
10.1.3. Right to erase - the right to request that we delete or remove your Data from our systems.
10.1.4. Right to restrict our use of your Data- the right to "block" us from using your Data or limit the way in which we can use it.
10.1.5. Right to data portability- the right to request that we move, copy or transfer your Data.
10.1.6. Right to object - the right to object to our use of your Data, including where we use it for our legitimate interests.
10.2. To make inquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this email address: email@example.com
10.3. If you are not satisfied with the way we handle a complaint you make in relation to your Data, you may be able to refer your complaint to the relevant data protection authority.
10.4. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
11. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
11.1. If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj
11.2. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
11.3. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at firstname.lastname@example.org
11.4. In certain circumstances, you have the following data protection rights:
11.4.1. the right to access, update, or to delete the information we have on you;
11.4.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
11.4.3. the right to object. You have the right to object to our processing of your Personal Data;
11.4.4. the right of restriction. You have the right to request that we restrict the processing of your personal information;
11.4.5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable, and commonly used format;
11.4.6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
11.5. Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.
11.6. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. Please contact your local data protection authority in the European Economic Area (EEA) for more information.
12. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)
12.2. According to CalOPPA, we agree to the following:
12.2.1. users can visit our site anonymously;
12.2.4. users are able to change their personal information by emailing us at email@example.com
12.2.5. Our Policy on “Do Not Track” Signals:
12.3. We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
12.4. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
13. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)
13.1. If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data, and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:
13.2. What personal information we have about you. If you make this request, we will return to you:
13.2.1. The categories of personal information we have collected about you.
13.2.2. The categories of sources from which we collect your personal information.
13.2.3. The business or commercial purpose for collecting or selling your personal information.
13.2.4. The categories of third parties with whom we share personal information.
13.2.5. The specific pieces of personal information we have collected about you.
13.2.6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
13.2.7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
13.3. Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.
13.4. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
13.5. To stop selling your personal information. We don't sell or rent your personal information to any third parties for any purpose. You are the only owner of your Personal Data and can request disclosure or deletion at any time.
13.6. Please note, if you ask us to delete or stop selling your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services that require the usage of your personal information to function. But in no circumstances will we discriminate against you for exercising your rights.
13.7. To exercise your California data protection rights described above, please send your request(s) by one of the following means:
13.7.1. By email: firstname.lastname@example.org
13.8. Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.
14. CONSUMER PRIVACY REQUESTS
14.1. Through the Services, UNBLOK provides methods for you to directly access, edit, delete or export certain Personal Information UNBLOK processes in your use of the Services.
14.2. If you wish to exercise your rights under applicable privacy laws beyond these methods, please submit a verifiable Consumer Privacy Request: by email at email@example.com
14.3. UNBLOK may only legally fulfill a Consumer Privacy Request when we have sufficient information to verify that the requester is the person or an authorized representative of the person about whom we have collected Personal Information and to understand, evaluate, and respond to the request properly.
14.4. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
15. UNBLOK PROTECTS YOUR PERSONAL INFORMATION
15.2. Data Security. UNBLOK implements technical, organizational and physical safeguards in place to help protect your information from unauthorized access, processing, or disclosure. We adopt and adhere to various policies, such as information security systems, confidentiality agreements with information management employees, and limiting information access to employees only as necessary. We use technical safeguards to protect information online and stored on our systems, such as password protection, access control isolation, and monitoring computer use to prevent the loss of information, improper use, and unauthorized reading or disclosure. For some services, UNBLOK uses encryption technology (such as TLS) to protect Personal Information. Please note, however, that no transmission of data over the Internet or mobile platforms is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes. Systems and communication networks you use to access UNBLOK services may be subject to problems and vulnerabilities that are beyond UNBLOK’s control. We are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks or the data that is stored on your device. You should only access the Site and Services within a secure environment.
15.3. Your Account. When you sign up or create an account with us, you will have a login and password. We encourage you to take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized activity.
15.4. Consent to Cross-Border Data Transfer. UNBLOK is headquartered and operated in the United States. If you visit the Site or use our other Services, know that your Personal Information may be transmitted and transferred across national and regional borders and stored and processed in a different country from where you reside and remain there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than the law of the receiving country or may result in governments, courts, law enforcement, or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.
16. SERVICE PROVIDERS
16.1. We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.
16.2. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
17.1. We may use third-party Service Providers to monitor and analyze the use of our Service.
17.1.1. Google Analytics.
188.8.131.52. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
184.108.40.206. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.
220.127.116.11. We also encourage you to review Google's policy for safeguarding your data:
18. BEHAVIORAL REMARKETING
18.2. Google Ads (AdWords)
18.2.1. Google Ads (AdWords) remarketing service is provided by Google Inc.
18.2.2. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page.
18.2.3. Google also recommends installing the Google Analytics Opt-out Browser Add-on – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
18.2.4. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page.
18.3.1. Facebook remarketing service is provided by Facebook Inc.
18.4. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
18.4.1. To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
18.4.2. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
18.4.3. For more information on the privacy practices of Facebook, please visit Facebook's Data Policy
18.5.1. Instagram remarketing service is provided by Facebook Inc. For more information on the privacy practices of Instagram, please visit the Instagram Privacy Terms web page.
18.6.1. LinkedIn remarketing service is provided by Microsoft Corporation.
18.6.2. You can learn more about interest-based advertising from LinkedIn:
18.6.3. For more information on the privacy practices of LinkedIn, please visit LinkedIn's Data Policy:
18.7.1. Twitter remarketing service is provided by Twitter Inc.
18.8. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
19. LINKS TO OTHER SITES
19.1. Our Service may contain links to other sites that are not operated by us.
19.2. If you click a third-party link, you will be directed to that third party's site.
19.4. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
20. CHILDREN’S PRIVACY
20.1. Our Services are not intended for use by children under the age of 18 (“children”).
20.2. We do not knowingly collect personally identifiable information from children under 18.
20.3. If you become aware that a child has provided us with Personal Data, please contact us.
20.4. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
20.5. UNBLOK and our other Services are designed for users 18 and older, and we require verified parent or guardian consent for children age 12 to 18 to use UNBLOK; we do not knowingly collect Personal Information from children under 18 or minors subject to heightened privacy protections according to the laws of their jurisdiction (in each case, a “Minor”) without first obtaining the applicable required parent or guardian consent. If we discover that a Minor has provided us with Personal Information through an unauthorized submission, we will delete that information from our systems. If you believe we might have any information from or about a Minor, or if you become aware of an unauthorized submission of information to UNBLOK, please contact us at firstname.lastname@example.org
22. CONTACT US
22.2. By email: email@example.com