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POLICIES

Privacy Policy

Privacy Policy

 

Version 1.1.1 – last amended on [14 May 2022]

 

 

 

General Information

The protection of Personal Data is important to Unify Platform AG (hereinafter referred to as «Unify», «we», “us” or “our”).

Therefore, we process Personal Data exclusively on the basis of the applicable data protection law. In this Privacy Policy we inform you about the types of Personal Data we collect, how this data is used, to whom it is transferred and what options and rights you have in connection with our data processing. In addition, we describe the measures we take to ensure data security and how you, as data subject, can contact us if you have any questions about our data protection practice. Together with the Terms of Use of UNIPLAT and UNIPLAT PAY [https://www.uniplat.social/terms] and/or the Terms of Use for Pre-IP Certification Services of UNIPLAT [https://www.uniplat.social/termsPreIp], this Privacy Policy governs the gathering, collection, processing, storage and use of Personal Data of Users of UNIPLAT, UNIPLAT Pay, the Services, User Content and/or visitors of our Website (hereinafter referred to as “you”, “your”, “User”, “Data Subject”). When you access UNIPLAT, UNIPLAT Pay, our Website, the Pre-IP Certification Services and/or use our Services and/or User Content you agree to have read and understood this Privacy Policy.

 

I.                   Introduction of Unify Platform AG as Data controller

We, Unify Platform AG, are Data controller within the meaning of the EU General Data Protection Regulation (“GDPR”) and the Swiss Federal Act on Data Protection (“Data Protection Act”) that determine the purposes and means of processing Personal Data. If you have any questions regarding the processing of your Personal Data, please do not hesitate to contact us:

Unify Platform AG,

Grafenauweg 7

6300 Zug

Switzerland.

 

Our data protection officer / data protection coordinator can be contacted at:

E-mail address: info@unify21.com

 

II.                 Definitions

When we use the following terms, it shall mean:

Personal Data” means any information relating to an identified or identifiable natural person (data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Data controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data; where the purposes and means of such processing are determined by Union or Member State law, the Data controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Data processor” means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data controller.

“Data Subject” / “User” / “you”: an identified or identifiable person whose Personal Data or personal information is collected, processed and used by us or on our behalf.

Other capitalized terms not defined above have the meaning as specified in the Terms of Use of UNIPLAT and UNPLAT PAY [https://www.uniplat.social/terms] and/or in the Terms of Use for Pre-IP Certification Services of UNIPLAT [https://www.uniplat.social/termsPreIp].

 

III.               Gathering and collection of Personal Data

1.                 Personal Data and information collected

We collect the following Personal Data of you, without limitation:

      First name

      Middle name

      Last name

      Full address (incl. country)

      Date of Birth

      Nationality

      Identity document, passport including photographic identification, number of document, date of issue, date of expiration, country of issue, address, etc.

      Photographic identification

      Live video interview if needed for KYC/AML purposes and a saved file of the video interview

      Information, data on sources of your wealth, sources of funds, beneficial ownership and other KYC/AML data required.

      Payment details, such as credit card details, debit card details

      Email

      Phone number

      Affiliation

      Profession (Researcher / non-researcher) and detailed subjects

      Career details, work experience, employment details

      Details on education

      Official Institute Name

      Official Website of Institute

      Registered Address

      President / Head Authority’s Name(incl. First name, Middle name, Lastname.)

      Registration Certificate

      Username and password

      User Wallet address (public key, PUK)

      Details of the transactions (purchase, redemption, donation, etc.) within UNIPLAT including funds, amount and public keys involved.

      IP address, geolocation details, browser information, information on operating system.

      Data and information related to User Content (including Personal Data of Researcher, entrepreneurs, Facilitator, research and technical data, technology information), to provide you with the Services.

      Your User Content and information, data and content you provide on UNIPLAT, to us and/or by accessing and/or using our Services and/or by using the Pre-IP Certification Services.

      If you provide us with a photo, video and/or audio (media content) as a User Content or provide a photo, video and/or audio (media content) otherwise on UNIPLAT (through live streaming, uploading a photo, video, audio on UNIPLAT or otherwise) and/or provide or make available a photo, video and/or audio (media content) by using our Services, the photo, video and/or audio (media content) containing your picture, voice, Personal Data and other data and information provided therein and related thereto.

      Your User Content and/or further content, data, Personal Data and information to provide you with our Pre-IP Certification Services. 

      Personal Data and information related to your social media accounts, social media networks, social media platforms and/or related services (e.g., Facebook, LinkedIn, Twitter) you use when entering, using or otherwise connecting to or from UNIPLAT, its Services, UNIPLAT Pay and/or our Website and/or by making use of social media plugins as set forth in this Privacy Policy.

      Your Personal Data you share with us when you contact us through our contact function on the Website or otherwise interacting with us.

      Any other information, Personal Data and data you make available to us and/or you make available on UNIPLAT.

2.                 Purpose and Use of your Personal Data

The gathering, collection of your Personal Data is normally carried out when you register as a User on UNIPLAT and/or UNIPLAT Pay (by opening a User Account and/or User Wallet), when you access your User Account, whitelist your User Wallet or when you visit our Website. We only process your Personal Data if this is necessary to provide you with a functional Website, to provide you with UNIPLAT, UNIPLAT Pay in general and all its Services and User Content as well as for marketing and research and development purposes of Unify, UNIPLAT and/or its Services. The processing of Personal Data may further be necessary to allow you to interact on UNIPLAT, to donate UNIPLAT Points and to use the Services and User Content available on UNIPLAT and UNIPLAT Pay as well as to use our Pre-IP Certification Services and/or further Services available on UNIPLAT.

We are further required to gather, collect, and process Personal Data for KYC/AML and further mandatory, regulatory purposes, such as prevention of fraud and money laundering, taxes, adherence to reporting and further obligations, etc. In the carrying out of our Services, to reduce the risk of money-laundering, fraud or abuse of our Services, we or our third-party providers/External Providers, may use automated processing and profiling. Through this automated processing, we carry out an analysis of your identification, transactional and behavioural patterns.

When you decide to contact us, submit questions, inquiries or requests to us, we collect and process your Personal Data. We will use your Personal Data to process your request, contact you, etc.

When you visit our Website [and/or UNIPLAT and/or UNIPLAT Pay], we may collect and process Personal Data and set cookies. We do this to administer or improve our Website, or our Services, for internal records (statistics, internal analysis) and ensure the functionality of our Website, as further described below.

3.                 Legal Basis for processing of your Personal Data

We process your Personal data based on the following legal basis:

      Processing for the performance of a contract to which you are party or the imple-mentation of pre-contractual measures (Art. 6 para. 1 lit. b GDPR), i.e. we process your Personal Data when you register as a member of UNIPLAT, open a User Account with us, accept the Terms of Use and/or to perform the contractual obligations and services to you.

      Processing based on your consent to the processing of your Personal Data (Art. 6 para. 1 lit. a GDPR). We may inform you and request your consent for the processing of your Personal Data.

      Processing for compliance with a legal obligation to which we are subject (Art. 6 para. 1 lit. c GDPR), i.e., to provide you with the Services. We may be obliged and entitled to request further Personal Data or information from you to comply with legal boundaries we are subject to, such as anti-money laundering and fraud prevention. You must further be aware, that we may be subject to certain reporting obligations that may oblige us to process and share your Personal Data with Reporting Offices, as further described below.

      Processing for the purpose of legitimate interests pursued by us or third parties (Art. 6 para. 1 lit. f GDPR), provided that your interests and fundamental rights and freedoms are not overriding. We may in particular process your Personal Data to ensure the security of our systems and services or for direct marketing purposes.

IV.              Website, Cookies and Tools

1.                 Creation of Log Files

Every time you visit our Website, our system automatically collects Personal Data and information from the computer system of the calling computer. The following Personal Data and information is collected:

a) Information relating to the browser type and version used

b) The User's operating system

c) The User’s Internet Service Provider

d) The User’s IP address

e) Date and time of access

f) Websites from which the User's system reaches our Website

g) Websites accessed by the User's system via our Website

 

Your IP address will be temporary stored by the system. This is necessary to enable the Website to be delivered to your computer. For this the IP address must remain stored for the duration of the session. The legal basis for the temporary storage of Personal Data is Art. 6 para 1 lit. f GDPR. The Personal Data collected for the provision of the Website will be deleted when the respective session has ended.

The data is also stored in the log files of our system but is not stored together with other Personal Data concerning you. The Personal Data is stored in log files to ensure the functionality of the Website. In addition, the data serves us to optimize the Website and to ensure the security of our information technology systems. The Personal Data is not evaluated for marketing purposes in this context. Our legitimate interest in Personal Data processing pursuant to Art. 6 para. 1 lit. f GDPR also lies in these purposes. If Personal Data is stored in log files, it will be deleted after seven days at the latest. Further storage is possible. In this case, the IP addresses are deleted or alienated so that the calling client can no longer be assigned.

The collection of Personal Data for the provision of our Website and the storage of Personal Data in log files is absolutely necessary for the operation of the Website. Consequently, there is no possibility of objection.

2.                 Cookies

Our Website uses Cookies. Cookies are text files which your web browser automatically saves on the hard disk of your computer when you visit our Websites. If you visit a Website, a Cookie may be stored on your operating system. This Cookie contains a characteristic sequence of characters that enables a unique identification of the browser when the Website is called up again. You can deactivate or restrict the transmission of Cookies by changing the settings in your Internet browser. Cookies that have already been saved can be deleted at any time. This can also be done automatically. If Cookies are deactivated for our Website, it may no longer be possible to use all functions of the Website in full. More details can be found in our Cookie Policy. [https://www.uniplat.social/cookie].

3.                 Google Analytics

Our Website uses functions of the web analytics service Google Analytics, which is offered by Google Inc. based in the USA ("Google").

The processing of your Personal Data enables us to analyse your surfing behaviour. We are in a position to compile information about the use of the individual components of our Website by evaluating the data obtained. This helps us to continuously improve our Website and its user-friendliness. For these purposes, it is also in our legitimate interest to process the Personal Data within the meaning of Art. 6 (1) (f) GDPR.

Google Analytics uses Cookies (see [https://www.uniplat.social/cookie]). The information generated by Cookies about your use of this Website is usually transferred to a Google server in the USA and stored there.

Google reserves the right to use these Cookies or the corresponding data for its own purposes, namely, to follow and investigate the use of this application, to generate reports on its activities and to pass these on to other Google services. Google may use the information collected to contextualise and personalise the ads in its own advertising network.

The use of Google Analytics is based solely on your consent. You can withdraw your consent at any time (see [https://www.uniplat.social/cookie]). The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.

The Personal Data collected by Google is:

      The IP address of your calling system

      The accessed website/Website

      The website from which the user has accessed the accessed Website (referrer)

      The sub-pages accessed from the accessed website

      The time spent on the Website

      The frequency with which the Website is accessed

The Personal Data collected by Google is usually transferred to a Google server in the USA and stored there. We have activated the "anonymizeIP" function on this Website. This means that your IP address is shortened by Google within member states of the European Union or the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. According to Google, the transmitted IP address will not be associated with any other Personal Data.

You can prevent the use of Google Analytics for this and other Websites by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en. For more information on how Google Analytics handles Personal Data, please see Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.

4.                 Social Media Plugins

So-called social media plugins ("Plugins"), in particular the LinkedIn button of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA, as well as the Like Button of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA, may be integrated on certain web pages of our Website and/or on UNIPLAT or its Services ("Social Media Platforms").

Plugins from other Social Media Platforms may be used on our Website and/or on UNIPLAT (e.g., when you use the community section on our Website).

When you call up a page of our Website and/or within UNIPLAT that contains such a Plugin, your browser establishes a direct connection to the servers of the respective Social Media Platform. The content of the Plugin is transmitted directly to your browser and integrated into the page. Through this integration, the Social Media Platform operator receives the information that your browser has called up the corresponding page of our Website and/or UNIPLAT, even if you do not have a profile on the respective Social Media Platform or are not currently logged in. This information (including your IP address) is transmitted by your browser directly to a server of the platform operator, which may be located in the USA, and stored there.

If you are logged in to the respective Social Media Platform, your visit to our Website and/or UNIPLAT or its Services can be directly assigned to your profile on the Social Media Platform. If you interact with the Plugins, for example by clicking the LinkedIn button, this information is also transmitted directly to a server of the platform operator and stored there. If you wish to prevent this, please log out of your Social Media Accounts before visiting our Website and/or UNIPLAT.

We have no influence on the data/Personal Data that LinkedIn, Facebook or Twitter and any other Social Media Platform operators collect on the basis of their Plugins. The purpose and scope of the data collection and the further processing and use of the data/Personal Data by LinkedIn, Facebook  and Twitter, as well as your rights and settings options in this regard to protect your privacy, can be found in the data protection notices of the respective providers:

      Additional information on data protection of Facebook can be found here.

      Additional information on the LinkedIn Plugin can be found here.

      Additional information on the Twitter Plugin can be found here.

In order to increase the protection of your data/Personal Data when visiting our Website, the Plugins are not integrated into the page without restriction, but only using an HTML link (so-called "Shariff solution" from c't). This integration ensures that when you call up a page of our Website or of UNIPLAT or its Services that contains such Plugins, no connection is established with the servers of the provider of the respective social network. If you click on one of the buttons, a new window of your browser opens and calls up the page of the respective service provider on which you can (if necessary after entering your login data) e.g. click on the Like or Share button. The purpose and scope of the data collection and the further processing and use of the data/Personal Data by the providers on their pages as well as your rights in this regard and setting options for protecting your privacy can be found in the data protection notices of the respective providers.

In addition, you can completely prevent the loading of the Plugins with add-ons for your browser, such as the script blocker "NoScript", which can be downloaded here.

V.                Pre-IP Certification Services and Pre-IP Certificate

1.                 Registration and Use of Pre-IP Certification Services

Upon on your request, we may provide you with our Pre-IP Certification Services and/or the Pre-IP Certificate based on our separate Terms of Use for Pre-IP Certification Services [https://www.uniplat.social/termsPreIp]

In order to provide you with our Pre-IP Certification Services and/or the Pre-IP Certificate, we process the following Personal Data and information from you:

      First name

      Middle name

      Last name

      Full address (incl. country)

      User Content incl. type of content, establishing and expiration date

      Further data, Personal Data and information you provide on UNIPLAT [and/or register as Pre-IP] that is needed to provide you with our Pre-IP Certification Services, the Pre-IP NFT and/or to issue the Pre-IP Certificate, such as the title, establishing date, type of intellectual property, register code, URL, Hash, NFT information, QR code.

 

      User Wallet address, Your public key (PuK)

      Blockchain contract

2.                 Pre-IP NFT and Use of Pre-IP Certification Services

The issuance of a Pre-IP Certificate requires you to issue an NFT/Pre-IP NFT and transfer an amount of ETH from your wallet to Unify pursuant to the Terms of Use for Pre-IP Certification Services [https://www.uniplat.social/termsPreIp]. In addition to the Personal Data and information outlined above, we process:

      User Wallet address, Your public key (PuK)

      Your contents URL

      Your IP address used by your system

3.                 Purpose and Legal Basis

We process your Personal Data, User Content, data and/or information to issue an NFT and a certificate stating Personal Data and User Content relevant data and information. The purpose and legal basis for the processing of this data is the performance of a contract according to our Terms of Use Pre-IP Certification Services [https://www.uniplat.social/terms ] and to perform our pre-contractual services and obligations towards you, i.e., Art. (1) (b) GDPR. If the User has given his consent to the processing of the Personal Data, the legal basis for the processing of your Personal Data is Art. 6 (1) (a) GDPR.

In particular, the collection and processing of your PuK is necessary in order to perform our contractual obligations under the Terms of Use for Pre-IP Certification Services [https://www.uniplat.social/terms] and is based on Art. 6 (1) (b) GDPR

4.                 Disclosure of Personal Data and/or information

To provide the Pre-IP Certification Services and/or the Pre-IP Certificate to you and/or to perform our services, we may share, disclose and/or make available your Personal Data and information to third parties necessary for the issuance of the certificate, the NFT, the performance of our Pre-IP Certification Services and related activities thereto.

The Pre-IP Certification Services, i.e., the respective Pre-IP Certificate and/or the NFT is issued by using blockchain’s smart contract technology. By using the Pre-IP Certification Services as well as by using the Pre-IP Certificate and/or the NFT/Pre-IP NFT, you acknowledge and accept that the Pre-IP Certificate, the NFT/Pre-IP NFT and your/the Personal Data and information may be publicly available, accessible for third-parties and may be seen by the public and/or disclosed to third-parties, i.e., companies, research institutions or any other third-parties located in other jurisdictions.

5.                 Data Retention and Deletion

We keep the Pre-IP NFT and the Personal Data required for the Pre-IP Certificate and/or Pre-IP Certification Services (including the NFT) as long as required to perform our contractual obligations towards you. However, in case we are permitted or required under applicable laws, for legal, tax or regulatory reasons, we may retain your Personal Data and/or information for a longer period of time. In such case, the legal basis for the processing is art. 6 (1) (c) GDPR.

The Pre-IP Certification Services uses blockchain based smart contract technology which is public. As your Personal Data (e.g., PuK) is saved on a publicly accessible blockchain, we cannot be responsible for your Personal Data and/or data nor for the retention and deletion of such data, since we do not control the Ethereum network and cannot order the deletion of your Personal Data and/or data. In so far, your right to be forgotten, as far as applicable and as defined further below in section XII. is in this regard restricted.

VI.              Contact form (UNIPLAT Support) and email contact

There is a contact form on our Website which can be used for electronic contact. If you take advantage of this possibility (e.g., by using the contact form of UNIPLAT Support), the following data entered in the contact form will be transmitted to us and will be stored:

      Your email address

      Your title

      Your membership type

      Your device (incl. OS)

      Your browser

      Your URL (optional)

      Your Personal Data you share with us through the message, inquiry, email or otherwise

      Your attachment, if any and Personal Data and information contained therein

 

At the time the message is sent, the following data is stored in addition:

      The IP address of the User

      Date and time of registration

 

Your consent is obtained for the processing of the Personal Data within the scope of the sending process and reference is made to this Privacy Policy. Alternatively, you can con-tact us via the email address provided. In this case, the User's Personal Data transmitted by email will be stored.

In this context, the Personal Data will not be transmitted to third parties. The data is used exclusively for processing the conversation.

The legal basis for the processing of data is Art. 6 (1) (a) GDPR if the User has given his consent. The legal basis for the processing of Personal Data transmitted in the course of sending an email is Art. 6 (1) (f) GDPR. If the email contact aims at the conclusion of a contract, then the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

The processing of Personal Data from the contact form serves us only for the treatment of the establishment of contact. The Personal Data collected in the course of sending an email represent also our legitimate interest in processing of Personal Data. The other Personal Data processed during the sending process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

The data will be erased as soon as it is no longer necessary to achieve the purpose for which it was collected. Consequently, the Personal Data from the contact form or the Personal Data that is sent by email will be erased as soon as the respective conversation with you is finished. The conversation is terminated when it can be inferred from the circumstances that the facts in question have been finally clarified.

The additional Personal Data collected during the sending process will be deleted after a period of seven days at the latest.

You have the possibility to withdraw your consent to the processing of Personal Data concerning you at any time. If you contact us by email, you can object to the storage of your Personal Data at any time. In this case, the conversation cannot be continued.

All Personal Data stored in the course of contacting us will be deleted in this case, provided we are not entitled or obligated to keep such Personal Data (e.g., due to regulatory and/or statutory obligations, KYC purposes, archiving purposes, etc.).

VII.            Data security

We have appropriate technological and organizational measures and operational, electronic and physical security processes designed and implemented to protect your Personal Data by taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing.

Only authorized Unify personnel, employees and/or contractors have access to your Personal Data and that access is limited by need.

Please be aware that we cannot ensure the security of your Personal Data or information you transmit to us over the Internet.

VIII.          Disclosure of Personal Data and information

We may disclose your Personal Data as follows:

      To our affiliates, associated companies;

      To our employees, directors, agents, consultants, personnel, auditors and further representatives when needed for the purpose;

      If you have given us your consent to disclose your Personal Data;

      If we are required by applicable law, regulation, court order or legal process or if we believe to do so;

      To provide you with User Content and/or share, distribute, provide your User Content and therein included Personal Data within UNIPLAT and other Users;

      To protect the rights, property and services of Unify including UNIPLAT, UNIPLAT Pay and the Services we offer and provide (e.g. defence against legal claims; allegations, infringement of Intellectual Property Rights);

      To prevent us, and our Users from fraudulent and criminal activities, illegality, etc.

      To third party service providers, External Providers (Ramp, Portis, etc.) who we use to provide UNIPLAT/UNIPLAT Pay and in delivering our Services, including financial and technology services (such as payment providers, hosting providers, identity verification provider, support, and email service providers; AML/KYC providers) as well as data storage and data hosting providers (e.g., Amazon Web Services);

      To fulfil our reporting and monitoring obligations, to comply with audits and archiving standards;

      To provide you with the Services, in particular the UNIPLAT database and to make the User Content and/or the Personal Data and information available within UNIPLAT to other Users.

      To provide you with our Pre-IP Certification Services (including the NFT) and/or to issue a Pre-IP Certificate for you;

      To External Service Providers to provide the Pre-IP Certification Services and/or the NFT/Pre-IP NFT to you and/or to issue the Pre-IP Certificate and provide the Pre-IP Certificate to you;

      To visitors of our Website, i.e., by sharing an extract and or part of your User Content and/or Personal Data (in particular your first and last name, your picture if provided, etc.) and/or further information on our Website.

      If we decide to sell, merge, transfer or reorganise part of Unify, our companies, affiliates and/or our system or business.

IX.              International Data Transfer

We are a Swiss based company, but our affiliates, personnel, contractors and third-party service providers such as consultants, auditors, KYC/AML providers, payment providers, External Providers and/or External Service Providers are located in different jurisdictions. For the purpose described above, in particular to perform our contract and to provide you with UNIPLAT, UNIPLAT Pay and all the User Content and Services therein, including the Pre-IP Certification Services, to comply with legal and regulatory obligations (identification and KYC obligations, anti-money laundering provisions, fraud prevention) and to ensure the functionality of our Website, we may be required to transfer your Personal Data to third countries outside of Switzerland and outside of EU/EEA and to countries that may not provide an equivalent level of data protection.

We transfer your Personal Data in line with Art. 44 et. seq. GDPR, based on:

      An adequacy decision by the Commission (Art. 45 GDPR);

      Standard Contractual Clauses, see: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en; to ensure your Personal Data is protected and appropriate safeguards are taken. Copies may be requested from us;

      In the absence of the safeguards above, we refer to the special conditions stated in Art. 49 GDPR and transfer your Personal Data in particular when (i) you explicitly have consented to the proposed transfer after having been informed of the possible risks of such transfer, (ii) the transfer is necessary for the performance of the contract between you and us or the implementation of pre-contractual measures at your request, (iii) the transfer is necessary for the conclusion or performance of a contract concluded in your interest between us and another natural or legal person or (iv) the transfer is necessary for the establishment, exercise or defence of legal claims.

X.                Retention and Deletion of Personal Data

We will hold and retain your Personal Data only for as long as it is necessary for the purposes described in this Privacy Policy or if we are required to do so under applicable law or regulations (e.g., to comply with record keeping requirements, KYC/AML obligations, taxes, court orders or proceedings, claims). Such Personal Data is protected from unnecessary processing and will be deleted after the fulfilment for the purposes described in this Privacy Policy (generally for a period of ten years after termination of the relationship with us and closure of your User Account) or after the fulfillment of our legal and regulatory obligations and requirements.

Where we cannot delete your Personal Data (e.g., due to automatic data archiving backups), such Personal Data will be blocked, encrypted, anonymized or its protection will be ensured otherwise by appropriate means to the extent technically possible (please refer to section V. above).

If your Personal Data is saved on the publicly accessible Ethereum blockchain, we cannot be responsible for your Personal Data and information, since we do not control the Ethereum network and cannot order deletion of your Personal Data and information. In so far, your right to be forgotten, as far as applicable and as defined further below in section XII, is restricted.

XI.              Children

UNIPLAT, UNIPLAT Pay and the Services and its content as well as the Website is not designed for and/or offered to individuals under the age of 18 years.

XII.            Rights of Data Subject

If Personal Data concerning you are processed, you are a Data Subject within the meaning of the GDPR and you have the following rights:

      Right of access: You can ask us to confirm whether Personal Data concerning you is being processed by us. Is that the case, you can request the information as defined in Art. 15 para. 1 GDPR from us. Further, you have the right to request information as to whether the Personal Data concerning you is transferred to a third country or to an international organization. In this context, you may request to be informed of the appropriate safeguards pursuant to Art. 46 GDPR relating to the transfer.

      Right to rectification: You have the right to obtain from us the rectification and/or completion of incorrect or incomplete Personal Data concerning you. Your right to rectification may be restricted to the extent that it is likely to render the performance of research or statistical purposes impossible or seriously compromises it and the restriction is necessary for the performance of research or statistical purposes.

      Right to restriction of processing: In line with the conditions stated in Art. 18 para. 1 GDPR, you have the right to request the restriction of processing of your Personal Data. Where processing of Personal Data concerning you has been restricted, such Personal Data may only be processed – with the exception of storage – with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of an-other natural or legal person or for reasons of an important public interest of the European Union or a Member State.

      Right to erasure (“right to be forgotten”): You have the right to obtain from us the erasure of your Personal Data and we are obliged to erase Personal Data without undue delay where one of the grounds pursuant to Art. 17 para. 1 GDPR apply.

Please note that your right to erasure shall not apply to the extent that a processing is necessary as stated in Art. 17 para. 3 GDPR, this includes, amongst others (i) for compliance with a legal obligation which requires processing by applicable law or for the performance of a task carried out in the public interest or in the exercise of official authority assigned to us; (ii) for the establishment, exercise or defense of legal claims.

      Right to information: If you have exercised your right of rectification, erasure or restriction of processing against us, we are obliged to notify all recipients to whom the Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. You have the right to obtain from us the information about those recipients.

      Right to data portability: You have the right to receive the Personal Data concerning you which you have provided to us in a structured, commonly used and machine-readable format. In addition, you have the right to transmit the data to another Data controller without hindrance from us to which the Personal Data have been provided in line with Art. 20 GDPR.

      Right to object: You have the right to object, on grounds relating to your particular situation, at any time to the processing of Personal Data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR, including profiling based on those provisions. We no longer process the Personal Data concerning you, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

Where Personal Data is processed for direct marketing purposes, you have the right to object at any time to processing of the Personal Data concerning you for such marketing, which includes profiling to the extent that it is related with such direct marketing. Where you object to processing for direct marketing purposes, the Personal Data concerning you will no longer be processed for such purposes.

You have the possibility to exercise your right of object in the context with the use of information society services, and notwithstanding Directive 2002/58/EC, by automated means using technical specifications.

      Right to withdraw your consent to process Personal Data: You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

      Automated individual decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision: (a) is necessary for the conclusion or performance of a contract between you and us; (b) is authorised by the European Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (c) is based on your explicit consent.

However, these decisions may not be based on special categories of Personal Data pursuant to Art. 9 para. 1 GDPR, unless Art. 9 para. 2 let. a or g GDPR applies and appropriate measures have been taken to protect your rights and freedoms and your legitimate interests.

In the cases referred to in points a) and c), we implement suitable measures to safeguard your rights and freedoms as well as your legitimate interests, including at least the right to obtain human intervention on the part of us, to express your point of view and to contest the decision.

      Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of Personal Data concerning you infringes the GDPR. The Federal Data Protection and Information Commissioner is the competent data protection authority in Switzerland. The contact details are available here: www.edoeb.admin.ch.

If you are residing in the European Union, you also have the right to complain to your local data protection supervisory authority. You can find the contact details of the respective authorities of the Member States of the European Union here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.

Kindly note that in case you refuse to share your Personal Data (or part thereof) for the purposes stated in this Privacy Policy, refuse the processing of your Personal Data through us or our third-party providers/External Providers/External Service Provider or in case you deny certain ways of processing (e.g., automated processing) we may not be able to provide UNIPLAT, UNIPLAT Pay, the Services and/or its User Content and/or the Pre-IP Certification Services and/or the Pre-IP Certificate to you. The same may apply in case you refuse the verification of your identity or certain AML, KYC, or regulatory procedures we are subject to and we are required to obtain from you. In case of any doubts or if you feel that our processing of your Personal Data is detrimental to you, please feel free to reach out to us [info@unify21.com], present your position and we will consider your request.

XIII.          Links and content of third parties

Our Website, UNIPLAT, UNIPLAT Pay and/or our Services and User Content and/or the Pre-IP Certification Services may include links to other websites or content/services of third parties whose privacy policies and practices may differ from our Privacy Policy. Please note that our Privacy Policy applies only to our Website, UNIPLAT, Pre-IP Certification Services, UNIPLAT Pay and/or our Services and its content.

We do not control those third-party websites or any of the content or services contained therein or provided by them. If you submit Personal Data or information to any of those third-party sites, use their content or services, your Personal Data or information is governed by their privacy policies and practices.

We are in no way liable or responsible for any of those third-party websites, including, without limitation, their content, services, policies, failures, promotions, products, or actions and/or any damages, losses, failures, misuse, leakage, or problems caused by, related to, arising from or are in connection with those third-party websites. We encourage you to review all policies, privacy policies, agreements, rules, terms, disclaimers, and regulations of each site that you visit and/or content, services, products etc. you use.

Please be aware that External Providers and/or External Service Providers are third parties and the processing of your Personal Data and information is subject to their policies and agreements, as stated above.

XIV.         Alterations to Privacy Policy

We reserve our right to change or adapt this Privacy Policy at any time in compliance with the applicable data protection regulations. We will tell you about any changes by posting an updated Privacy Policy on our Website and on UNIPLAT. Any change we make applies from the date we post it on the Website and on UNIPLAT. If you have any questions about our Privacy Policy, please email us: [info@unify21.com].

XV.           Inquiries and contact

In case of questions, inquiries, questions to the collection, processing, storing and further use of your Personal Data, do not hesitate to contact: [info@unify21.com]