Privacy Policy

Valid from June 2nd, 2018

UNLOQ Systems Ltd. (UNLOQ), is the responsible entity and has created the following Privacy Policy to describe how UNLOQ uses information it collects. This Privacy Policy applies to the UNLOQ websites and mobile applications. It explains how information is collected, used, and disclosed by UNLOQ with respect to your access and use of UNLOQ’s services, whether through our websites (https://unloq.io, https://sconfig.io, https://loglet.io, https://unloqsystems.com, https://thorinjs.com, https://thorin.io) or UNLOQ mobile applications, used as a service or in connection with sites that integrate UNLOQ.

We recommend that you read this Privacy Policy in full to ensure you are fully informed. If you have any questions about this Privacy Policy or UNLOQ’s data collection, use, and disclosure practices, please contact us at privacy@unloq.io.

1. DEFINITIONS

“Customer” means the individual accepting the terms of this Agreement or the entity such individual represents, as applicable.

“Customer Application” means a software application that interfaces with the UNLOQ Services and includes any services (web-based or other services) made available by Customer through that application.

“Customer Data” means data and other information made available to UNLOQ through the use of the UNLOQ Services under this Agreement.

“Documentation” means all of the instructions, code samples, on-line help files and technical documentation made available by UNLOQ for the UNLOQ Services.

“End User” means an end user of UNLOQ or a Customer Application

“End User Data” means all personal information of an end user including name, emails, phone numbers and other personal data related to the use of UNLOQ Services (device data, timestamps, location, etc.).

“UNLOQ Acceptable Use Policy” means certain terms and conditions relating to the use of the UNLOQ Services, available through the service setup interface, as such may be updated from time to time.

“UNLOQ API” means an application-programming interface for the UNLOQ Services (or feature of the UNLOQ Services) provided to Customer by UNLOQ.

“UNLOQ Properties” means the UNLOQ websites, UNLOQ APIs, UNLOQ mobile applications, Documentation, and technical support made available by UNLOQ to Customer in connection with the UNLOQ Services.

“UNLOQ Services” means the services provided by UNLOQ to Customer under this Agreement, including all programs, features, functions and report formats, and subsequent updates or upgrades of any of the foregoing made generally available by UNLOQ, including without limitation the UNLOQ APIs and any software provided to Customer in connection with its use of the UNLOQ Services.

2. DATA WE COLLECT

Data provided by Customers

1 Account Registration. When you register for an Account, we may ask for your contact information, including items such as name, company name, address, email address, and telephone number. If you choose to refer a friend to our Services, we may also collect your friend’s email address so that we may send them a referral or promotional code to sign up for our Services.

2 Payment Information. When you add your financial account information to your Account, that information is directed to our third-party payment processor. We do not store your financial account information on our systems; however, we have access to, and may retain, subscriber information through our third-party payment processor.

3 Communications. If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.

Data provided by End Users

1 Account Registration. When an End User register for an Account with UNLOQ Mobile App, we may ask for contact information, including items such as name, email address. In case you (the Customer) choose to integrate second factor through SMS we might also receive the End User phone number. 

2 Communications. If the End User contact us directly, we may receive additional information about you such as name, email address, phone number, the contents of the message and/or attachments he/she may send us, and any other information he/she may choose to provide.

The personal information that the End User is asked to provide, and the reasons why he/she is asked to provide it, will be made clear at the point we ask him/her to provide such personal information.

Data we collect when Customers or the End Users use of UNLOQ Services

1 Cookies. We only use essential cookies that help us provide you with the service. 

2 First-party cookies. The data we collect includes internet protocol (IP) addresses, browser type, web pages, operating system, date/time stamp. To collect this information, a cookie is set on your computer or device when you visit UNLOQ Services or, in case of an End User, when he/she visits a website that implements UNLOQ Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies. To provide our Customers with the UNLOQ Service, End Users & Customers are tracked across different websites and services. 

3 Third-party cookies. We use the services provided by Clym Ltd. (clym.io) to comply with the legal obligations brought by GDPR such as managing your consents, requests and company data (including this privacy policy). Clym sets up a cookie / cookies on your computer or device when you visit UNLOQ Services. Cookies contain a small amount of information that allows our web servers to recognize you. The data Clym collects include: internet protocol (IP) addresses, browser type, web pages, operating system, date/time stamp. Beside Clym, we might also user other third-party services in order to provide you with UNLOQ Services or to analyse our traffic. These services, might set up their own cookies to remember you. Please review the Cookie policy for a complete list of cookies we use.

4 Usage of our Services. When you use UNLOQ Services, we collect information about your engagement with and utilization of our Services, such as: sites that use UNLOQ Services; features that are used; authentication, transaction authorisations & encryption key requests the IP/location where they are made from; browser agent data. We use this data to operate the UNLOQ Services, protect the security and safety of UNLOQ Services and our customers, maintain and improve the performance and utilization of the UNLOQ Services, develop new features and provide customer support.

Data we receive from Third Parties

1 Third-Party Identity Providers. If you choose to link our UNLOQ Services to a third-party identity provider, we will receive information about the End User account, such as an authentication token, email, name from the third-party identity provider, to authorize linking. 

2 Third-Party Partners. We may receive information about you from our third-party partners such as contact data from events organisers. We may use the data to contact you and present UNLOQ Services, but only to the extent of the consent you provided and the third-party partner passed it to us. 

3. HOW WE USE THE DATA

We use the data we collect in various ways presented below grouped by the legal basis for processing:

We need the data to perform the contract with you:

1 Provide, operate and maintain UNLOQ Services

2 Process your transactions

3 Send you text messages and push notifications

4 Provide you with customer support

We have your consent:

1 To provide you with promotional materials about UNLOQ Services

2 To provide you with promotional materials about services offered by Affiliated companies

3 To analyse the traffic on our site

The processing is our legitimate interest and it is not overridden by your rights:

1 Find and prevent fraud

2 Improve, personalise and expend UNLOQ Services

3 Understand and analyse how Customers and End Users use UNLOQ Services

4 Develop new products, services, features and functionality

5 For compliance purposes, including enforcing our Terms of Service or other legal rights or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

We need to comply with a legal obligation:

1 Collect and manage your consents

2 Record your requests and the communication between you and UNLOQ regarding your data 

4. THIRD PARTY PROCESSORS

We are committed to reduce at the minimum the Third-Party Processors that we use to lower the risks of your data being exposed. We also assess and review each one of them in order to make sure they have similar and compliant privacy policies. A complete list of data processors can be found under the Third - Party Processors section. 

5. HOW WE SHARE YOUR DATA

As a rule, we do not share your data with any third-party. However, we may share your data in the following cases:

1 Business Transfers. Information may be disclosed and otherwise transferred to any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

2 As Required By Law and Similar Disclosures. We may also share information to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

3 With Your Consent. We may share information with your consent.

4 UNLOQ Service: UNLOQ enables users to provide Personally Identifiable Data directly to third party applications and services. When you register at a new site that integrates UNLOQ you agree to have part of your personal information (name, email) disclosed automatically to the third-party system, after a successful authentication event.

6. SECURITY

UNLOQ takes reasonable precautions such as policy-based access control and encryption to protect Data in our possession from loss, misuse, and unauthorized access. UNLOQ follows generally accepted industry standards to protect the Data, both during transmission and once received by UNLOQ. However, no method of transmission over the Internet or method of electronic storage is 100% secure. 

You may find more information about the protections we employ under the Security section.

7. DATA RETENTION

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. CHILDREN UNDER 16

Our service is not directed to children under sixteen and does not knowingly collect personally identifiable information from children under the age of sixteen. If you are under the age of sixteen, you must ask your parent or guardian for permission to use this website. If we learn that we have collected personal information of a child under sixteen, we will take the appropriate steps to delete such information from our files as soon as possible. If you learn that a child has provided us with personal information in violation of this Privacy Policy, you can alert us at privacy@unloq.io.

9. DEACTIVATION OF YOUR ACCOUNT

Deactivation removes information about the specific phone. The user can reactive an account on a different phone. Deactivation will not completely delete your UNLOQ account.

10. ACCESS TO YOUR DATA

If you are a registered Customer or End User, you may access certain information associated with your Account by logging into UNLOQ Services or requesting access to your data through the request form provided. If you terminate your Account, any public activity on your Account prior to deletion may remain stored on our servers and, in case of End Users may remain accessible to the Customer.

To protect your privacy and security, we also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes.

11. INTERNATIONAL DATA TRANSFERS

As a United Kingdom enterprise serving users across the world and delivering UNLOQ Services through the use of Third-Party processors, we may transfer personal information to countries other than the country in which the data was originally collected. When we transfer your personal information to other countries, we will protect that information as follows:

1 Data is kept in an EU country. Whenever is possible/feasible, we select data processors or specific options inside the data processors’ services in order to keep data inside EU.

2 Transfer data to countries with similar data privacy rules. We only select data processors that resides or store data in one of the countries from EU clear listed as it may be updated from time to time. In case of US data processors, we verified their Privacy Shield certification before engaging them. 

A full list of data processors we use, a link to their privacy policy and, where known, the country where they store the data is provided under Third-Party Processors section.

12. YOUR DATA PROTECTION RIGHTS

Please be advised that in case you allow UNLOQ to collect and process certain personal data from you, you have the following rights:

1 Right of Access. You have the right to obtain from us confirmation as to whether or not personal data concerning you are processed, and, where that is the case, you have the right to request and get access to that personal data.

2 Right to Rectification. You have the right to obtain from us the rectification of inaccurate personal data and you have the right to provide additional personal data to complete any incomplete personal data.

3 Right to Erasure (“Right to be Forgotten”). In certain cases, you have the right to obtain from us the erasure of your personal data.

4 Right to Restriction of Processing. You have the right to obtain from us restriction of processing, applicable for a certain period and/or for certain situations.

5 Right to Data Portability. You have the right to receive from us in a structured format your personal data and you have the right to (let) transmit such personal data to another controller.

6 Right to Object. In certain cases, you have the right to object to processing of your personal data, including with regards to profiling. You have the right to object at further processing of your personal data so far as such data have been collected for direct marketing purposes.

7 Right to be Not Subject to Automated Individual Decision-Making. You have the right to not be subject to a decision based solely on automated processing.

8 Right to Filing Complaints. You have the right to file complaints with the applicable data protection authority on our processing of your personal data.

9 Right to Compensation of Damages. In case we breach applicable legislation on processing of your personal data, you have the right to claim damages from us for any damages such breach may cause with you.

For further information see https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/In case you like to get in contact with us in relation to any of the above mentioned rights or any other personal data issues, please use the data privacy tool in the bottom left corner or through ourcompany public profile page.

13. CHANGES TO THIS STATEMENT

UNLOQ will occasionally update this Privacy Policy to reflect company and customer feedback. UNLOQ encourages you to periodically review it to be informed of how UNLOQ is protecting your information. For any questions please contact us at privacy@unloq.io.

14. CONTACT US

If you have any questions regarding these Privacy Policy, please contact us by email at privacy@unloq.io.

© 2018 UNLOQ Systems LTD. All rights reserved.

Last Updated 2nd of June, 2018