Unnon - Privacy Notice
1. General
1.1 Unnon Ltd, trading as Unnon (“we” or “us”), take the privacy of your information very seriously. Our Privacy and Data Protection Policy is designed to tell you, the user of our mobile applications, website or other digital products (together referred to as the “Service”), about our practices regarding the collection, use and disclosure of personal and other information about you, your enterprise or your organisation that may be provided via our website (the “Site”), its associated mobile applications (the “Apps”) and any other digital product provided by Unnon or collected through other means such as an online form, email, or telephone communication.
1.2 This notice applies to personal data provided by our users, whether they are a user of our Service or otherwise. In this notice “you” refers to any individual whose personal data we hold or process (other than our staff).
1.3 In this notice, references to the “Site” are references to any website, app or other means by which you provide personal data to us or access our services.
1.4 This notice is governed by the EU General Data Protection Regulation (the “GDPR”).
2. Basis on which we process personal data
2.1 Personal data we hold about you will be processed either because:
2.1.1 the processing is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in processing your personal data which is not overridden by your interests in data privacy and security;
2.1.2 you have consented to the processing for the specific purposes described in this notice;
3. Personal data we collect
3.1 We may collect and process the following personal data (information that can be uniquely identified with you) about you:
- 3.1.1 information you provide to us relating to your account or profile with us such as notes, references and details of contacts (“Profile Information”);
- 3.1.2 contact information we may collect from you (for example, your name, address, telephone number, email address) (“Contact Information”);
- 3.1.3 information we collect which relates to your interaction with the Service such as posts, messages, links and comments (“Service Information”);
- 3.1.4 information provided relating to payment (“Payment Information”), but please note that credit or debit card information may be supplied directly to a third party payment processor who will process the data in accordance with their own privacy notices or policies (see below);
- 3.1.5 a record and details of any correspondence or communication between you and us or relating to any complaint submitted to us (“Communication Information”);
- 3.1.6 details of your visits to the Site, the resources and pages that you access and any searches you make (“Technical Information”).
3.2 We will not collect any sensitive personal data without your prior consent. By sensitive personal data we mean data which falls within certain ‘special categories’ which are defined in the GDPR (e.g. health data) and which require additional protection and consent measures.
3.3 You do not have to supply any personal information to us, but some of the Site’s functionality may not be operable without providing data to us.
3.4 You may withdraw our authority to process your personal data (or request that we restrict our processing – see clause 10) at any time, but we may need to withhold some personal data for legal or other reasons (see below).
4. Cookies and IP Address
4.1 A cookie is a piece of data stored locally on your computer and contains information about your activities on the Internet. The information in a cookie does not contain any personally identifiable information you submit to our Site.
4.2 On our Site, we may use cookies to track users' progress, allowing us to make improvements based on usage data. We may also use cookies if you log in to one of our online services to enable you to remain logged in to that service. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service.
4.4 We are required to obtain the consent of users from the EEA (European Economic Area) to use cookies. EEA users will be able to provide this consent when they first visit the Site.
4.5 If you choose not to accept the cookies, this will not affect your access to the majority of information available on our Site. However, you will not be able to make full use of our online services.
4.6 An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our Site, and to administer and improve the Site.
5. How we process your personal data
5.1 Please see the table below, which sets out the manner in which we will process the different types of personal data we may hold:
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| When you register with the Site | Login Information | Performance of a contract with you. Necessary for our legitimate interests (to obtain necessary information in order to provide our Service) |
| When you update or amend your profile information | Login Information, Profile Information | Performance of a contract with you |
| When you interact with the Service and other users | Login Information, Profile Information, Service Information, Payment Information | Performance of a contract with you. Necessary for our legitimate interests (for running our business and to provide you with the Service) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey (c) When you submit a complaint | Login Information, Profile Information, Service Information, Communication Information, Technical Information | Performance of a contract with you. Necessary to comply with a legal obligation.Necessary for our legitimate interests (to keep our records updated and to study how users use the Service) |
5.2 [Additional processing data omitted for brevity]
6. Data Retention
6.1 Our current data retention policy is to delete or destroy (to the extent we are able to) the personal data we hold about you in accordance with the following:
| Category of personal data | Length of retention |
|---|---|
| Records relevant for tax purposes | 8 years from the end of the tax year to which the records relate |
| Personal data processed in relation to a contract between you and us | 7 years from either the end of the contract or the date you last used our services or placed an order with us, being the length of time following a breach of contract in which a contract party is entitled to make a legal claim |
| Personal data held on marketing or business development records | 3 years from the last date on which you have interacted with us |
6.3 [Additional retention policy omitted for brevity]
7. Sharing your information
7.1 Any content posted on or appearing on the Site or any other digital product provided by Unnon is in the public domain. Users and third parties of the Site, the Apps or any other digital product provided by Unnon will be able to view most data posted on your public profile without the need for prior approval by you.
7.2 If and when we require payment for any aspect of the Service, credit and debit card information will be provided to our payment processing partner. This information will be supplied to our payment processing partner directly.
7.4 We do not disclose any personal data you provide to any third parties other than as follows:
7.4.1 We may host personal data with third party hosting partners; 7.4.2 Certain third party suppliers, including technical support providers, may have access to personal data; 7.4.3 where we carry out research to gain an insight into the use of our Service, the results of this research (but not your personal data itself) may be transferred to interested third parties; 7.4.6 we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
7.5 [Additional sharing information omitted for brevity]
8. Email and Other Communications
8.1 If you place an order for goods and services with us we may from time to time contact you about similar goods or services.
8.2 We will identify the nature of the message and the sender clearly and you will have an opportunity to opt-out of receiving further communications from us.
9. Security
9.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you.
10. Your privacy rights
10.1 The GDPR gives you the following rights in respect of personal data we hold about you:
| The right to be informed | You have a right to know about our personal data protection and data processing activities, details of which are contained in this notice. |
|---|---|
| The right of access | You can make a Subject Access Request (“SAR”) to request information about the personal data we hold about you. |
| The right to correction | Please inform us if information we hold about you is incomplete or inaccurate in any way. |
| The right to erasure | Please notify us if you no longer wish us to hold personal data about you. |
10.2 All SARs and other requests or notifications must be sent to us in writing to Unnon Ltd at contact@unnon.com
11. Data Breaches
11.1 If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO).
12. Policy towards children
12.1 The Service is not intended for individuals under 13 years of age. Our policy is not to intentionally or knowingly collect, process, maintain or use personal information from any individual under the age of 13.
13. Other websites
13.1 Our Site may contain links and references to other websites which are not covered by this notice.
14. Transferring your information outside Europe
14.1 Your information may be transferred to, processed and stored in countries or organisations outside of the EEA.
14.2 By submitting your personal information to us you agree to the transfer, storing, or processing of your information outside the EEA in the manner described above.