This Privacy Notice (the “Notice”) applies to personal information collected by, or provided to, Unit21, Inc., and/or its affiliates and subsidiaries (collectively "Unit21”, "we", “us", “our") via the websites, applications, and other platforms from which this Notice is linked. This Notice describes how Unit21 uses the personal information that it collects, receives, maintains, and stores about you. This Notice does not apply to personal information processed, stored, or hosted by or on behalf of our customers. Our customers are responsible for deciding how their data is used, so please see their applicable privacy notice for more information.
1. Types of Personal Information Collected
We may collect personal information from or about you in order to provide, enhance, market, and offer the Services, and to otherwise communicate with you. This section describes the categories of personal information we may collect, including personal information we have collected in the past twelve (12) months. You are not required to give us all the personal information identified in this Notice; however, if you do not provide requested personal information, we may not be able to provide you with some or all of the Services.
Contact and Demographic Information – first and last name; address (including billing and shipping address); telephone number; affiliated organization and industry; job title; and email address.
Payment Information – If you make a purchase, our payment processor will collect your payment information including your name, credit card information, and billing address, together with your purchase details.
Account Information – We may also collect login credentials, such as your user ID and password.
Location Data – While navigating the Services, your mobile device or browser may share your location data, both through WiFi and GPS, and IP address or MAC address. We will collect this information based on the settings of your phone and browser.
Usage Information – We may also collect usage and device information when you use the Services. This may include information relating to your Internet activity or other electronic network activity, which includes device information; web server type and version; PHP version; database type and version; cookie information; device information; browsing activities on our website and related domains, and platform or mobile application use data; referring domain; destination domain and destination path; performance, security, software configuration and availability of our software on your servers and network; website user statistics and website and portal use and viewing activity records; and communication preferences.
Education and Employment Information – If you apply for employment with Unit21, we may collect your employment and work history, as well as personal information related to your potential employment. This may include, but is not limited to, your education and employment history, address and contact information, demographic information, and the contents of your resume.
Communication Information - We may collect audio, electronic, or visual information, which includes screen sharing views; any data in any files uploaded, emailed or otherwise provided by customers; the contents of your communications with Unit21, whether via e-mail, social media, Slack, telephone or otherwise; and inferences we may make from other personal information we collect.
2. Method of Information Collection
We collect personal information in a variety of ways. We may collect personal information directly from you; for example, when you visit our websites, respond to a survey, participate in a telephone interaction, fill out a registration form or otherwise use the Services.
We may also collect personal information from third parties. For example, we may collect personal information from service providers that help us to build and maintain our contact lists, that integrate their services into ours, or in other ways work with us for our mutual benefit.
We may also collect personal information from you passively. For example, the Services use tracking tools like cookies, pixels, and web beacons to collect usage and browser information. For more information about the trackers that we use, please see Section 6 of this Notice. Additionally, if you enable location data on your device, this data will be collected based on the location settings on your device.
3. Combining Personal Information
We may combine personal information we obtain. For example, we may combine personal information that we have collected online with personal information that we have collected offline, for instance during calls between you and our support team. We may also combine personal information that we have collected across other third-party sites or from other third parties with personal information we already have.
4. How We Use Personal Information
To the extent permitted by applicable law, we may use personal information for a variety of purposes including to:
- operate the Services and provide support to our business functions;
- fulfill customer requests, such as to create a Unit21 account or complete customer purchases;
- protect against criminal activity, claims and other liabilities;
- send customers information regarding Unit21 and our Services;
- respond to reviews, comments, or other feedback provided to us;
- support and personalize the Services and our advertising efforts;
- protect the security and integrity of the Services;
- provide customer support;
- the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Services, facilitating product, software and applications development, improving the Services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
- meet our contractual requirements;
- comply with applicable legal or regulatory requirements and our policies;
- communicate with our customers, including to provide them with information about our products, programs, services and promotions;
- respond to inquiries related to employment opportunities;
- market, advertise, and provide the Services; and
- the extent necessary for any other lawful purpose for which the personal information is collected.
5. Sharing Personal Information
We may share your personal information in the following circumstances:
- Within Unit21 – We may share your personal information with our affiliates, subsidiaries, and employees.
- Service Providers – When we hire a service provider to help operate the Services or our business, we may allow access to personal information as necessary to perform the service for us. This may include service providers that operate the Services, collect payment, send our communications, or run our promotions.
- Business Partners – We may share personal information with our trusted business partners. For example, we may share your personal information with a company when we co-sponsor a promotion or service. These partners may use your personal information to, among other things, send you information or contact you about their services and products.
- Third Parties for Marketing Purposes – To the extent permitted by applicable law, we may share personal information with third parties for purposes of our marketing, advertising, promotions, contests, or other similar purposes.
- Mergers, Acquisitions, Divestitures – If we are involved in a merger, acquisition, or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, personal information may be transferred along with the business. Where legally required we will give you prior notice and, if you have a legal right to do so, an opportunity to object to this transfer.
- Purposes described to you – We may share your personal information for other purposes, as we describe to you and as permitted by applicable law.
6. Cookies and Other Technologies
We collect information about users over time through the Services by using several common types of cookies and other tracking technologies including log files, pixel tags, web bugs, web beacons, clear GIFs, Local Storage Objects (LSOs) such as HTML5 and Flash or other similar technologies to collect information about the ways you interact with and use the Services, to support and enhance features and functionality, to monitor performance, to personalize content and experiences, for marketing and analytics, and for other lawful purposes. We may also permit third parties that collect information in this way on our behalf and for their own purposes. Cookies are small files that download when you access certain websites. For more information about cookies visit: http://www.allaboutcookies.org/.
To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services such as Google Analytics. For more information on Google Analytics’ processing of your information, please see “How Google uses information from sites or apps that use our services.” You can opt-out of Google Analytics by installing Google’s opt-out browser add-on.
Type of Cookies
Required cookies are essential for the operation of the Services. They include, for example, cookies that allow you to access and use secure areas of the Services.
Functionality cookies allow the Services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
These cookies collect information about how you use the Services, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Services function and perform.
Targeting or Advertising
Most internet browsers accept cookies by default. During your first visit to our website, you can change your cookie preferences through our cookie management tool. You can also accept, or block cookies by activating the setting on your browser that allows you to reject all or some cookies, or by changing your cookie preferences via the Services. The help and support area on your internet browser should have instructions on how to block or delete cookies. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you to when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all of the features available through the Services.
- Cookie settings in Internet Explorer
- Cookie settings in Firefox
- Cookie settings in Chrome
- Cookie settings in Safari web and iOS.
To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:
On a mobile device, you may also adjust your settings to permit or limit ad tracking.
7. Children Under the Age of 13
The Services are meant for adults, and we will not knowingly collect personal information from any person under the age of 13 without permission from a parent or guardian. The Services is not designed to attract the attention of persons under the age of 13. If you are a parent or legal guardian and think your child has given us information, you can email us at email@example.com. You can also write to us at the address listed in the “Contacting Unit21” section of this Notice. Please mark your inquiries “COPPA Inquiry.”
8. Your Choices
Depending on where you are located, you may have certain choices about how we use your personal information. To opt-out of marketing communications please email us at firstname.lastname@example.org or by following the instructions included in the email or text correspondence. To exercise other rights with respect to your personal information, please contact us using the information in the “Contacting Unit21” section below.
Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain personal information, we may be unable to provide some or all of the Services to you.
9. California Privacy Rights
Pursuant to California’s Shine the Light statute (Cal. Civ. Code Sec. 1798.83), you can control if we share personal information with third parties for their marketing purposes. To opt-out of us sharing your personal information with third parties for such purposes, email us at email@example.com or write to us in the “Contacting Unit21” section of this Notice and include “Marketing Opt-Out” in your request.
In addition, pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents may have certain other rights concerning their personal information. This section describes (i) the categories of personal information collected and disclosed by Unit21, subject to CCPA, (ii) your privacy rights under CCPA, and (iii) how to exercise those rights.
When we use the term “personal information” in this section, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
a. Personal Information We Collect.
During the past twelve (12) months we and our service providers have collected the categories of personal information set forth below. We may disclose each of these categories of personal information to our service providers for our business purposes (to enable the service providers to provide their services) and as otherwise described in the “Sharing Personal Information” section above. We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you notice.
- Identifiers (for example, name, date of birth, email address, IP address, and online identifiers);
- Categories of personal information as defined by Cal. Civ. Code § 1798.80 (for example, name, signature, telephone number);
- Commercial information (for example, transaction history);
- Internet or other electronic network activity information, including information on your usage of the Services;
- Geolocation data;
- Sensory data (for example, audio from call recordings);
- Professional or employment related information; and
- Inferences drawn from any information identified above to create a profile.
b. Your Privacy Rights.
In accordance with the CCPA, California residents may exercise, under certain conditions, the following privacy rights with respect to their personal information. Please note: you will not be discriminated against in any way if you exercise the rights listed below, which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.
You may have the right to be notified, at or before the point of collection, of the categories of personal information we collect and the purposes for which they will be used and shared.
You may have the right to request the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You may also have the right to request the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information.
You may have the right to receive the personal information you have previously provided to us.
You may have the right to ask us to delete (and have us direct our service providers to delete) your personal information. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your personal information for one or more of the following categories of purposes: (1) to complete a transaction for which the personal information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
To Opt Out
You may have the right to opt out of us selling personal information.
c. How to Exercise Your Rights.
If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to firstname.lastname@example.org or email@example.com. You can also contact us using the other methods listed in the “Contacting Unit21” section below.
d. How We Respond to Your Requests.
In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
10. EU-US Privacy Shield For EU and UK Individuals Whose Data is Transferred into the United States
Pursuant to the EU-US Privacy Shield Framework we attest to the following principles in relation to the transfer of EU and/or UK data into the United States:
- We are subject to the oversight and jurisdiction of the United States Fair Trade Commission (US FTC)
- We acknowledge the right of individuals to access their personal data and to update or correct inaccurate information or request erasure of data that has been processed in violation of the Privacy Shield Principles. EU and/or UK individuals wishing to exercise this right may do so by emailing us at firstname.lastname@example.org or write to us in the “Contacting Unit21” section of this Notice and include “Marketing Opt-Out” in your request
- Individuals wishing to limit the sharing of their data with non-agent third parties may exercise this right by emailing us at email@example.com or write to us in the “Contacting Unit21” section of this Notice and include “Marketing Opt-Out” in your request
- We may be compelled to share personal data in response to lawful requests by governing authorities including to meet law enforcement and national security requirements.
- We remain liable for the onward transfer of personal data to agent third parties unless we can prove we were not a party giving rise to the damages.
In compliance with the Privacy Shield Principles, Unit21 commits to resolve complaints about our collection or use of your personal information. European Union, United Kingdom, or Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Unit21 at:
343 Sansome St
San Francisco, CA 94104
Attn: Unit21, Ballindamm 39, 20095
DP Data Protection Services UK Ltd.,
Attn: Unit21, 16 Great Queen Street,
Covent Garden, London,
WC2B 5AH, United Kingdom
Unit21 has further committed to refer unresolved Privacy Shield complaints to BBB EU Privacy Shield, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free or charge to you.
Unit21 also committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-1-introduction
11. Information for Individuals in the EU and UK -- GDPR
In accordance with European and UK law (collectively, the “GDPR”), individuals in the EU and UK may have additional rights relating to the collection and processing of personal information.
a. Basis for Processing
Our legal basis for processing the personal information described in this Notice will depend on the personal information concerned and the context in which we process it. We process personal information from you:
- where we need it to perform a contract with you;
- where the processing is in our legitimate interests (including the purposes described, above, in How We Use Personal Information);
- where the processing is necessary for us to meet our applicable legal obligations; or
- if we otherwise have your consent.
b. Your Privacy Rights
Depending on applicable law, you may have the right to:
- Request access to your personal information.
- Request correction of your personal information.
- Request erasure of your personal information. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information.
- Request restriction of processing of your personal information.
- Request the transfer of your personal information to you or to a third party.
- Withdraw consent at any time where we are relying on consent to process your personal information.
If you wish to exercise any of these rights or would like further information, please contact us at firstname.lastname@example.org or write to us using the address in the “Contacting Unit21” section below. Depending on the nature of your request, we may need to verify your identity.
Depending on where you are located, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning personal information. We encourage you to first reach out to us at email@example.com or using the address in the “Contacting Unit21” section below, so we have an opportunity to address your concerns directly before you do so.
12. Storage, Security and Retention of Information
We take reasonable steps to protect the personal information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting personal information. We will retain your personal information in compliance with the uses described in this Notice, as well as to comply with our legal, financial reporting, or compliance obligations.
13. Transfers of Personal Information
We process and store personal information both inside the United States and overseas. If you live outside of the United States, be advised that we may transfer your personal information to the United States and other countries, whose laws may not provide the same protections as the laws in your country. Personal information transferred outside of the European Economic Area will be subject to the appropriate safeguards pursuant to GDPR and other applicable law, including without limitation, standard contractual clauses approved by the European Commission.
14. Links to Third Parties and their Sites
The Services may include third-party content and links to third-party websites and services that collect personal information. We do not control these third parties and this Notice does not apply to their privacy practices. We are not responsible for the practices of these third parties or how they use information you provide to them. Please read the third parties’ privacy policies carefully.
15. Contacting Unit21
If you have any questions about this Notice, or the privacy practices of Unit21 please email us at firstname.lastname@example.org or write to us at:
343 Sansome St
San Francisco, CA 94104
Individuals and data protection supervisory authorities in the EU and UK may contact our data protection representatives according to Article 27 GDPR:
Attn: Unit21, Ballindamm 39, 20095
DP Data Protection Services UK Ltd.,
Attn: Unit21, 16 Great Queen Street,
Covent Garden, London,
WC2B 5AH, United Kingdom
If you are contacting us to exercise your rights with respect to your personal information as detailed in this Notice, we ask you to please adhere to the following guidelines:
- Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the personal information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
- Help Us Verify Your Identity: Provide us enough information to verify your identity. For example, provide us (at a minimum) your full name, address, and phone number. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process. Any personal information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
- Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).
Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.
This Notice may be amended from time to time. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to the Services, so please check our website periodically for updates. You can see when this Notice was last updated by reviewing the “Last Updated” legend at the top of this page. We will provide notice of material changes by updating the Notice here and communicating with you in the manner and format in which we typically communicate with you in our regular course of business, as required by applicable law.