Privacy Policy

​INTRODUCTION

 

Thank you for using the Unstruk Data Platform! Your trust is important to us and we’re committed to protecting the privacy and security of your personal information. The information that’s shared with us helps us to provide a great experience with Unstruk Data. 

This Privacy Policy describes how we collect, use, process, and disclose your personal information, or may do so, in conjunction with your access to and use of the Platform.

Data Controller

​When this policy mentions “Unstruk,” “we,” “us,” or “our,” it refers to Unstruk Data Inc., the company that is responsible for your information under this Privacy Policy (the “Data Controller”). 

​Applicability to Payments

This Privacy Policy also applies to any payment services provided to you by us. When using the Services in connection with any payment, you will be also providing your information, including personal information, to one or more Unstruk entities, which will also be the Data Controller of your information related to such payments, generally depending on your country of residence.

​INFORMATION WE COLLECT

​Information that is necessary for use of the Platform

​​We ask for and collect the following personal information about you when you use the Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested Services.​

  • Account Information: When you sign up for an Account, we require certain information such as your first name, last name, email address, and Payment Information.

  • Payment Information: To use certain features of the Platform we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments.

  • Communications with Unstruk: When you communicate with Unstruk, we collect information about your communication and any information you choose to provide.

 

​Information that is necessary for the payment for Services

​​We need to collect the following information necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to pay for the Services, which could restrict your access to certain features or functions of the Services:

  • ​Payment Information: When you wish to subscribe for Services, we require certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.

  • ​Identity Verification and Other Information: If you are a User, we may require identity verification information or other authentication information, your address or email address and other information in order to verify your identity, provide the Services to you, and to comply with applicable law.

 

​Information you choose to give us

You may choose to provide us with additional personal information in order to obtain a better user experience when using the Platform. This additional information will be processed based on our legitimate interest or, when applicable, your consent.

  • ​​Other Information: You may otherwise choose to provide us information when you create User Content, such as by filling in a form, updating or adding information to your Account, responding to surveys, posting to community forums, participating in promotions, communicating with our customer care team, sharing your experience with us (such as through Feedback), or using other features of the Platform.

 

Information we automatically collect from your use of the Platform

​When you use the Platform, we automatically collect personal information about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Platform. 

  • Geo-location Information: When you use certain features of Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

  • Usage Information: We collect information about your interactions with the Platform, such as the pages or content you view, your interactions with other User’s Content, and other actions on the Platform. 

  • Log Data and Device Information: We automatically collect log data and device information when you access and use the Platform, even if you have not created an Account or logged in. That information includes, among other things: details about how you’ve used the Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Platform.

  • ​Cookies and Similar Technologies: We use cookies and other similar technologies when you use our Platform or engage with our online ads or email communications. We may collect certain information by automated means using technologies such as cookies, web beacons, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to personal information. For example, we may use information we collect to better understand website traffic patterns and to optimize our Site experience. In some cases, we associate the information we collect using cookies and other technology with your personal information. Our business partners may also use these tracking technologies on the Platform or engage others to track your behavior on our behalf. Although most browsers are set by default to automatically accept cookies, you can adjust your browser settings to either stop accepting cookies or to prompt you before accepting cookies.

  • ​​Pixels and SDKs: Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our Site and elsewhere on the internet and use that information to provide measurement services and targeted ads. Third parties, including Facebook, may collect or receive information from your app and other apps and use that information to provide measurement services and targeted ads. Users can opt-out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting us with a description of your request and validation information.

  • Do Not Track Signals: While you may disable the usage of cookies through your browser settings, the Services currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.

  • Payment Transaction Information: We may collect information related to your payment transactions through the Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, email address, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and us and to allow the provision of payment services.

 

Information we collect from third parties

​​​Unstruk may collect information, including personal information, that others provide about you when they use the Platform, or obtain information from other sources and combine that with information we collect through the Platform and the Services. We do not control, supervise or respond for how the third parties providing your information process your Personal Information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

  • ​Third Party Services: If you link, connect, or login to your Account with a third party service (e.g. Google), the third party service may send us information such as your registration, and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.

  • Referrals: If you are invited to Unstruk, the person who invited you may submit personal information about you such as your email address or other contact information.

  • ​Other Sources: To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or information to help detect fraud and safety issues, from third party service providers and/or partners, and combine it with information we have about you.

 

​Children’s data

​​You must be 18 years or older to use the Platform. Our Services are not directed to, or intended for use by, anyone under 18 and we do not knowingly collect any personal information directly from anyone under 18. If you believe that we processed the personal information pertaining to a person under 18 inappropriately, we take this very seriously and urge you to contact us using the information provided under the “Contact Us” section below.

 

HOW WE USE THE INFORMATION WE COLLECT

​​We may use, store, and process personal information to: (1) provide, understand, improve, and develop the Platform, (2) create and maintain a trusted and safer environment (such as to comply with our legal obligations and ensure compliance with all Unstruk policies) and (3) provide, personalize, measure, and improve our advertising and marketing.

 

​​Provide, Improve, and Develop the Platform

​​We may use the personal information to provide, improve, and develop the Platform such as to:

  • ​enable you to access and use the Platform,

  • ​operate, protect, improve, and optimize the Platform and experience, such as by performing analytics and conducting research,

  • provide customer service,

  • send you service or support messages, updates, security alerts, and account notifications,

  • ​to operate, protect, improve, and optimize the Platform and experience, and personalize and customize your experience, and conduct profiling based on your interactions with the Platform, your profile information and preferences, and other content you submit to the Platform.

 

We process this personal information for these purposes given our legitimate interest in improving the Platform and our Users’ experience with it, and where it is necessary for the adequate performance of the contract with you.

Create and Maintain a Trusted and Safer Environment

​We may use the personal information to create and maintain a trusted and safer environment such as to:

  • ​detect and prevent fraud, spam, abuse, security incidents, and other harmful activity,

  • conduct security investigations and risk assessments,

  • verify or authenticate information or identifications provided by you,

  • comply with our legal obligations,

  • resolve any disputes with any of our Users and enforce our agreements with third parties,

  • enforce our Terms of Service and other policies, and

  • in connection with the activities above, we may conduct profiling based on your interactions with the Platform, your profile information and other content you submit to the Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Platform if such processes detect activity that we think poses a safety or other risk to the Platform, our community, or third parties. If you challenge the decisions based on the automated process, please contact us as provided in the Contact Us section below.

 

​We process this personal information for these purposes given our legitimate interest in protecting the Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.​

 

​​SHARING & DISCLOSURE

​Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights

​Unstruk may disclose your information, including personal information, to courts, law enforcement, governmental authorities, tax authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Unstruk, (iii) to respond to valid requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our Users to legal liability, (iv) to enforce and administer our Terms of Service or other agreements with Users, or (v) to protect the rights, property or personal safety of Unstruk, its employees, its Users, or the public. 

 

​These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Platform secure, preventing harm or crime, enforcing or defending legal rights, facilitating the collection of taxes and prevention of tax fraud or preventing damage.

 

​Where appropriate, we may notify Users about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Unstruk’s property, its Users and the Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that User about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

 

​Service Providers

​​Unstruk uses a variety of third-party service providers to help us provide services related to the Platform. Service providers may be located inside or outside of the European Economic Area (“EEA”). In particular, our service providers are based in North America.

 

​For example, service providers may help us: (i) perform product development, maintenance and debugging, (ii) allow the provision of the Services through third party platforms and software tools (e.g. through the integration with our APIs), (iii) provide customer service, or payments services, or (iv) process, handle or assess insurance claims or other similar claims. These providers have limited access to your personal information to perform these tasks on our behalf, and are contractually bound to protect the personal information and only use the personal information in accordance with our instructions. Unstruk will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

 

​Business Transfers

​If Unstruk undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

 

​Aggregated Data

​We may also share aggregated information (information about our Users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes.

 

​OTHER IMPORTANT INFORMATION

​​Analyzing your Communications

 

We may review, scan, or analyze your communications on the Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, analytics, and customer support purposes. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your messaging communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

 

​These activities are carried out based on Unstruk's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

 

​​Third Party Partners & Integrations

​​The Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Unstruk doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner, Unstruk, or both.

 

​These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

 

​​YOUR RIGHTS

​​You may exercise any of the rights described in this section by sending an email to the contact address provided in Section 10. Please note that we may ask you to verify your identity and request before taking further action on your request.

 

​Managing Your Information

 

​​You may access and update some of your information through your Account settings. You are responsible for keeping your personal information up-to-date.

 

Rectification of Inaccurate or Incomplete Information

​You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Account).

 

​​​Data Access and Portability

 

​In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).​

Data Retention and Erasure

 

​​We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

 

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain information from that Account to prevent that User from opening a new Account in the future.

 

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Unstruk may keep some of your information in order to comply with tax, legal reporting and auditing obligations.

 

​Some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.

 

Because we maintain the Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

 

Withdrawing Consent and Restriction of Processing

 

​​If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where: (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Unstruk override your own.

 

Objection to Processing

In some jurisdictions, applicable law may entitle you to require Unstruk not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Unstruk will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims. 

 

​Lodging Complaints

 

​You have the right to lodge complaints about our data processing activities by filing a complaint with our office, which can be reached by the “Contact Us” information in Section 10 below or with a supervisory authority.

 

​OPERATING DOMESTICALLY

 

​California & Vermont Residents

 

​Unstruk will not share information it collects about you with its affiliates or third parties (both financial and non-financial), except as required or permitted by your state’s law.

 

​California Privacy Rights

 

​California law permits Users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See Section 10 for where to send such requests. Unstruk does not share personal information with third parties for their own direct marketing purposes without your prior consent. 

 

​SECURITY

​We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us by following the instructions in the “Contact Us” section below.

​​CHANGES TO THIS PRIVACY POLICY 

 

​​We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Site and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Platform will be subject to the revised Privacy Policy.

 

​CONTACT US

​We welcome questions, comments, and concerns about our Privacy Policy and privacy practices. If you have any questions or complaints about this Privacy Policy or Unstruk’s information handling practices, you may email us at: privacy@unstruk.com.​