Our goal is to keep the personal information we receive completely confidential at all times. And even though we would never forward or distribute your personal information outside of our organization, we still have to tell you what we collect from you and how we use it. We may update this policy from time to time. Your continued use of this site indicates your agreement to the updated terms.

1. What Personal Information do we collect and how do we collect it?

We collect specific types of personal information directly from you. Depending on how you interact with our website and platforms, we may collect the following personal information about you:

Identity Data, which may include first name, last name, title.

Contact Data, which may include location address, email address, and phone numbers.

Profile Data, which may include username and password, purchases or buy/trade orders made by you, customer service requests, your photo, bio, interests, preferences, feedback and survey responses; and preferences in receiving marketing and non-marketing communications from us.

Information and content, which includes content, communications and other information you provide when you use our platforms, including when you sign up for an account, create or share content, and message or communicate with others.

Transaction Data, which includes deposit snapshots, account balances, trade history, withdrawals, order activity and distribution history. This transaction data is monitored for suspicious trading activity for user fraud protection, and legal case resolution.

Website Technical Data, which includes the following information if you use our online platform and services: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and the ways in which you use or interact with our online platform and services.

Data from Device Settings, which includes information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.

2. How and for what purpose do we use Personal Information?

We only use your personal information for specific business purposes related to the goods and services we provide, e.g.:

To process and deliver customer orders

To manage payments, fees and charges

To manage our relationship with customers, such as communicating with them about our goods and services, providing customer service, and notifying them of changes to our terms or privacy policy

To administer and protect our business and services, including troubleshooting, and performing data analysis, testing, system maintenance, support, reporting and hosting of data

To detect, prevent, or otherwise address fraud, security or technical issues, including by monitoring and enforcing compliance with our terms of use, appropriate use policies, and privacy policies

To defend our interests in the event of a dispute To comply in good faith with applicable laws, legal processes, and lawful government requests

To understand what may be of interest to a customer

To deliver relevant news, offers and other content to a customer and measure and understand the effectiveness of the content

To ask and enable a customer to take a survey

To use data analytics to debug, optimize, and improve our products and services, marketing, customer relationships and experiences

3. What happens with your Personal Information?

For the purposes mentioned above, we may share your personal information with the following categories of business partners:

Our Service Providers: We may share your personal information with our service providers for the purposes we outline above. For example, we may rely on service providers to host and maintain our online services, perform backup and storage services, process payments, transmit communications, and perform analytics services.

Government Agencies, Regulators and Professional Advisors: Where required by applicable law, we may also need to transfer your personal information to government agencies and regulators (e.g., tax authorities, courts, and government authorities).

We would like to specify that both we and our service providers currently process personal information on servers located in the Republic of Ireland and thus in the EU. We therefore abide by the rules and regulations established by the European Union, specifically, the GDPR. In connection hereto, you as a subject of data processing are entitled to the rights that the GDPR grants every individual located in the EU.

If you are a resident of California, our CCPA Privacy Policy applies to you. If you are located in the European Economic Area, the United Kingdom, or Switzerland (collectively “EEA+”), our EEA+ Privacy Policy may apply.

You specifically have legal rights to access, update, review or demand deletion of certain personal information as well as restrict or object to the use thereof. For your security, we may need to request specific information from you to verify your identity.

To review your personal information and/or to exercise your rights in accordance with the GDPR as well as in case of further questions, we encourage you to reach out to our Data Protection Officer, Alexander Berstein, per email at [email protected]

As mentioned in our other privacy disclosures, we don’t sell your personal information, but the privacy laws of California, including the California Consumer Protection Act of 2018 (“CCPA”), require us to provide some information about our data processing practices to California residents.

If you are a resident of California and not part of our workforce, this Supplemental CCPA Privacy Policy applies to you. However, this Privacy Policy does not reflect our collection, use or disclosure of California residents’ personal information where an exception under the CCPA applies.

1. Your Personal Information: Right to Know, Request Deletion, and Opt-Out

As a California resident, you have the right to request that we disclose what personal information we collect, use, and disclose about you specifically (“right to know”), and the right to ask that it be deleted. To submit a request to exercise the right to know or to delete, please submit a request, with the details you would like to know or delete, by email to [email protected] and include “California Request to Know or Delete” in the subject line.

We may need to verify your identity, and/or ask you to confirm your request. If we deny your request, we will explain why.

You also have the right to opt-out of the sale of your personal information by a business. We do not sell personal information, so there is no need to opt-out. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

2. Right to non-discrimination for the exercise of Consumer’s Privacy Rights

You have a right not to receive discriminatory treatment based on the exercise of your privacy rights under the CCPA.

3. Right to be Informed of financial incentives

We do not currently offer any financial incentives in exchange for the retention or sale of California residents’ personal information.

4. Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if your authorized agent is a natural person or a business entity registered with the Secretary of State of California, and you sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request under the CCPA, please have the authorized agent take the following steps in addition to the steps described in Section 1 above: (1) Email a notarized copy of your written declaration authorizing the agent to act on your behalf to the address listed below and (2) Provide any information we request from you to verify your identity and that you provided the authorized agent permission to submit a request under the CCPA on your behalf.

5. What We Collect

We have set out in the Privacy Policy the categories of personal information we have collected about California residents in the past 12 months as well as the sources, business or commercial purposes, and categories of third parties with whom we shared the personal information. We collect this information directly from California residents who use our website or subscribe for our services. We may also collect some information about a California resident’s interests and preferences from a third-party source where they or their organization make such information publicly available, such as on their organization’s public website.

If you are located in the European Economic Area, the United Kingdom, or Switzerland (EEA+), and access our website, subscribe for Unit.Ventures services in your personal capacity, or use Unit.Ventures services as an authorized user of an organization that subscribes for Unit.Ventures services, this Supplemental EEA+ Privacy Notice applies to you.

As mentioned in our other privacy disclosures, we don’t sell your personal information, but the data protection laws of the EEA+, including the General Data Protection Regulation (“GDPR”), require us to provide information about our data processing practices to certain people in the EEA+.

1. Who Is the Data Controller?

The controller of data responsible for collection, processing and storage of your personal data is Unit.Ventures.

2. Why and how do we process Personal Data?

We minimize the amount of data collected from you to the minimum extent required by the business reasons and rely on the following legally defined goals for processing:

collection of data necessary to perform a contract with you or take steps at your request prior to entering into a contract (“Contract Performance”), to comply with an applicable legal obligation or to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests (“Legitimate Interests”);

acquisition of your consent (“Consent”); and

protection of your vital interests or those of another person (“Vital Interests”).

More information is provided below. Please contact us if you need details.

3. How do we protect Personal Data?

We may transfer your personal data to service providers and business partners outside of the EEA. Some of these recipients are located in countries, for which the European Commission has issued adequacy decisions, in which case, the transfer is recognized as providing an adequate level of data protection under European data protection laws (GDPR Art. 45).

Some recipients of your personal data may be located in countries outside of the EEA for which the European Commission has not issued an adequacy decision in respect of the level of data protection there, e.g. the United States. In such cases, we will enter into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in GDPR Art. 46(5) or other adequate means, and establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. You may ask for a copy of such appropriate data transfer agreements by contacting us using the contact details below.

4. How long do we store Personal Data?

We will only store personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may keep your personal data for a longer period of time in the event of a complaint or litigation.

5. How do we use Cookies?

We use small files known as cookies to collect information about how individuals interact with our online services.

Required Cookies: We use cookies that are strictly necessary to enable users to navigate around our online services and use their features, otherwise known as Required Cookies. Without these cookies, we would not be able to provide a secure log-in, or provide certain other core features of our online services.

Functional Cookies: We use “functional cookies” to enhance users’ experience on our online services and for internal operational purposes, including to collect aggregated information about how users of our website interact with it, and remember choices they make while using our website.

You can delete, restrict and block cookies from being set on your device via the settings of your browser. To do so, please refer to the Help function within your browser or visit www.allaboutcookies.org, a website that contains a large amount of comprehensive information on how to disable cookies on a wide variety of desktop browsers.

6. Your Rights

Regarding your personal data, you have the right to:

Request access (commonly known as a "data subject access request") - enables you to receive a copy of the personal data we hold about you and information about how it is processed.

Request correction - enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure - enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

Object to processing - where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

Request restriction of processing - enables you to ask us to suspend the processing of your personal data if, (i) you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

To exercise these rights, please contact us using the details below.

7. Your Choices

You are not required to provide personal data to us but if you do not provide any personal data to us, you may not be able to use our website or we may not be able to authenticate and assist you with your orders, inquiries or requests, and we generally will not be able to provide you with our products and services.

8. Contact Us

You may contact us using the following details:
Data Protection Officer Unit.Ventures: Alexander Berstein, email address: [email protected]