Privacy Policy and Cookies

UNLOCTEAM respects your privacy and wants to make you comfortable with our privacy policy and the security measures that we take to protect your personal data.

If you provide UNLOCTEAM with personal data, or we collect personal data about you from other sources, UNLOCTEAM will treat it in accordance with this policy. UNLOCTEAM encourages you to read this privacy policy in full.

1. General principles for processing of personal data

To ensure that your personal data is processed correctly and with a suitable level of data protection, UNLOCTEAM has adopted the following processing principles:

  • Personal data is processed lawfully, fairly and in a transparent manner;
  • Personal data is collected only for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
  • Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  • Personal Data shall be accurate and, where necessary kept up to date and inaccurate or incomplete personal data will be rectified or erased or further processing suspended.
  • Personal data shall not be kept in a form which permits identification of the Data Subjects for longer time than necessary for the purposes for which the data was collected or for which it is further processed.
  • Personal data shall be processed in a manner that ensures appropriate security of the personal data.

UNLOCTEAM will always inform you of the collection and processing of your personal data unless we have a legitimate reason not to do so.

2. Types of personal data

We will collect and process your personal data in a number of ways when you engage with us via the various existing channels.

Some of the personal data is necessary to process in order for us to provide you with the services you have requested and some personal data you can choose to provide voluntarily. We will always let you know which personal data is necessary (e.g. via the use of an asterisk (*)) and the consequences of not providing such data to us, for instance that we will not be able to (fully) satisfy your request.

The personal data that we collect and process can generally be divided into the following categories:

  • Contact information such as name, address, phone number, email address, title, place of work, etc.
  • Information that you provide when contacting us via online contact forms, emails or phone
  • User information such as technical data regarding usage and viewing, including IP addresses when you visit our websites or applications, including on third-party sites

As a general rule we will not process any special categories of personal data (special personal data) about you unless you have provided your explicit consent thereto, or we are required to do to comply with applicable regulation.

3. Our purposes for processing your personal data

We only process your personal in order to pursue a legitimate purpose and generally we will only process your personal data if:

  • You have provided your consent to such processing; or
  • The processing is necessary for the performance of a contract; or
  • The processing is necessary for compliance with a legal obligation that we are subject to; or
  • The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party and such processing is not considered to be harmful towards you.

We process your personal data for the following purposes:

  • To administer our business relations and negotiate and execute agreements; or
  • To provide general customer service and support; or
  • To communicate with you regarding various matters; or

4. Cookies

We may use cookies on our websites or our applications.

The purposes of processing of data collected using cookies, are the following:

  • to operate, improve and optimize the performance and user experience of the website and its services,
  • perform customer and user analysis and segmentation in order to improve our understanding of our users, and provide better and tailored services to users, including you,
  • statistical purposes.

5. Disclosure, transfer and making available personal data to recipients

Our disclosure and transfer of your personal data to recipients (natural or legal persons, public authorities, agencies or another body, to which the personal data is disclosed) is kept to a minimum and is subject to the existence of an adequate level of data protection.

We may disclose or make personal data available to recipients under the following circumstances:

  • Recipients who carry out services on our behalf, such as e.g. hosting, cloud computing, IT-support, marketing services, administrative services or other data processing. Such recipients are only allowed to process the personal data in accordance with our instructions and the relationship will be governed by a written data processor agreement; or
  • To establish, exercise or defend our legal rights; or
  • If you have provided your prior consent to the disclosure of personal data to a recipient or
  • As set out in our cookie-policy, cf. section 4 above.

If the recipient of the personal data is located in a country outside the EU/EEA not ensuring an adequate level of data protection, we will only transfer your personal data to such recipient following execution of a written transfer agreement based on the EU Commissions Standard Contractual Clauses.

6. Your consent

As stated above some of our processing activities will be based on your consent. In such case, you will have the right to withdraw your consent at any time.

If you withdraw your consent, we will cease to process your personal data, unless and to the extent the continued processing or storage is permitted or required according to the applicable personal data legislation or other applicable laws and regulations.

Please note that the withdrawal of your consent will not affect the lawfulness of processing conducted prior to the withdrawal. Further, as a consequence of your withdrawal of your consent, we may not be able to satisfy your requests or provide you with our services.

7. Data Security

In order to safeguard your personal data, UNLOCTEAM has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risks represented by the processing and the nature of the personal data to be protected, having regard to the state of the art and the costs of their implementation.

Following the evaluation of the risk, UNLOCTEAM has taken measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, in particular where the processing involves the transmission of personal data over a network, and against all other unlawful forms of processing.

8. Your rights

You have the right to access to the data processed about you, subject to certain statutory exceptions. Furthermore, you can object to the collection and further processing of your personal data. In addition, you have the right to correct your personal data, if necessary. You may also choose to request us to restrict the processing.

We will delete or correct any information, which is inaccurate or out of date by reason of the time elapsed since it was collected or by reason of any other information in our possession.

If you provide us with a written request, we will also delete your personal data without undue delay, unless we have a legal basis to continue the processing, e.g. if the processing is necessary to establish, exercise or defeat a legal claim or necessary to the performance of a contract with you.

With regard to such requests, kindly provide us with relevant information to take care of your request, including your full name and email address so that we can identify you. We will respond to your request as soon as possible and within one month.

If you disagree with our processing of your personal data please be informed that you can lodge a complaint with your local data protection agency.

9. Links to other websites, etc.

Our website may contain links to other websites or to integrated sites. We are not responsible for the contents of the websites of other companies (third-party websites) or for the practices of such companies regarding the collection of personal data. When you visit third-party websites, you should read the owners’ policies on the protection of personal data and other relevant policies.

10. Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy in the future due to changes in applicable legislation. We will inform you of any such amendments.

11. Contact information

If you have a request or a question regarding your processing of personal data or this privacy policy in general, please email us: [email protected].

Version 1.0, March 13, 2020

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