UNIGINE respects your concerns about privacy. We want you to understand the kinds of information we may collect, how we intend to use that information, with whom your information may be shared, and how you can opt-out of such uses or correct or change such information. When you use our websites, services, products, and content (“Services”) you agree to our collection, use, disclosure, and transfer of information as described in this policy, so please review it carefully.
These definitions should help you understand this policy. When we say “we,” “us,” “our,” and “UNIGINE,” we are referring to UNIGINE HOLDING S.À.R.L. When we say “you,” we are referring to a person who visits any of our websites or uses our products, services. “Personal data” means any information relating to an identified or identifiable natural person, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. If we are not (or at least not without a disproportionate amount of time and effort) able to relate a direct link to you personally, this information is not personal data.
Information We Collect and Receive
We generally collect or receive information in three ways: (1) you voluntarily provide information to us, such as by creating an account, making purchases, or signing up for email alerts, (2) we collect information automatically, such as through cookies or through use of our services, and (3) other parties, such as social networks, may provide information to us. Each of these methods is described in more detail below.
(1) Information You Voluntarily Choose to Provide
You may provide your personal information to us when you choose to use our websites, products and services. Because we change our offerings and features from time to time, the options you have to provide us with information also may change. The following are some examples of situations in which you may provide information to us:
- Creating an account to use our websites, services or products;
- Purchasing something from us or otherwise engage in a transaction with us;
- Registering for or participate in special events;
- Participating in any of our promotions;
- Signing up for email alerts or subscribing to receive other information from us;
- Complete a survey;
- Contacting us for any reason, such as by email, including for technical support or customer service.
The personal information we collect from you will vary depending on the services you are using, the websites you are visiting, and how you access those services and websites. The information you provide to us may include your name and your email address(es). If you choose to make a purchase, we will collect payment card information such as your card’s payment account number and expiration date. Sometimes we ask for your phone number, your postal address, your billing address.
(2) Information Collected Automatically When You Use Our Websites, Products and Services
We collect some information automatically when you visit our websites or use our services and products. If a combination of information that we collect does identify you as an individual, we will treat the combined information as personal information. We typically aggregate the data that we collect automatically and use it in statistical form to determine trends among groups of users, rather than using it to identify individuals. We collect information automatically through technologies such as web browsers, cookies, log files, and our back-end servers collect usage data transmitted from our services and products. We may also utilize Google Analytics and Yandex Metrics in the collection, compilation and analysis of information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content.
This analytics data is not tied to any Personal Information. We use the information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud, and conducting data analytics. The type of information that we automatically collect may vary, but generally includes:
- Technical information about your computer, device, hardware, or software you use to access the Internet or our services, such as IP address or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system related specifications);
- Usage information and statistics about your interaction with our websites, services and products, which may include the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, platform type and other usage statistics;
- Information that facilitates a safer and more personalized experience;
- The location of your device, such as may be derived from your device’s IP address.
Please note that if certain features on our websites are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of our websites or others’ websites over time. These features are subject to those third parties’ privacy notices and policies.
You may, at any time, prevent the setting of cookies through our websites by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If you deactivate the setting of cookies in the Internet browser used, not all functions of our websites may be entirely usable.
Application and Use of Google Analytics (With Anonymisation Function)
On our websites we have integrated the component of Google Analytics (with the anonymizer function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behavior of visitors to websites. A web analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of the Google Analytics component is to analyse the traffic on our websites. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our websites for us.
During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of an individual, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements. With each visit to our websites, personal data, including the IP address of the Internet access used by an individual, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America.
(3) Information We Receive from Other Sources
From time to time we may obtain information about you from third party sources, such as public databases, social media platforms, third party data providers. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide you with more relevant products features, and services.
Although we cannot control your privacy settings at those websites or how those other parties protect your privacy, once we receive information about you through those websites, we will treat it in accordance with this policy.
How We Use This Information
We are able to deliver, personalize, and improve our websites, services and products by combining and using the information we have about you (including information we receive on and off our websites, services and products) to understand how you use and interact with our websites, services and products and the people or things you’re connected to and interested in.
We also may use the information we have about you for the following purposes:
- Provide, maintain, improve, and develop relevant features, content, and services;
- Analyze use of the relevant site, product, or service; test changes and improvements; to personalize your experiences;
- Perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of products and services that Unigine provides;
- Сreate and share statistics and reports;
- Credit or accept payments;
- Fulfill your requests and when authorized by you;
- Provide technical support and respond to inquiries;
- Combine information we have about you with information we obtain from business partners or other companies, such as your activities on other sites;
- Detect and defend against abusive or unlawful activity;
- Prevent fraud, enforce the relevant terms of service or licenses, and protect users;
- Inform users of new products and services, including promotional offers;
- Contact you with information that we believe will be of interest to you.
How We Share the Information We Collect
We also can share the information we collect and receive in some cases:
- Third party service providers: We provide User information to other companies who perform services on Unigine’s behalf. For example, we may employ service providers to process payments; host or store our data; deliver email messages or analyze data.
- Safety, security, and legal compliance: We may share your information:
- when we have a good faith belief that we are required to disclose the information in response to legal process (for example, if we receive a court order, search warrant, subpoena, or similar legal process);
- to satisfy any applicable laws or regulations;
- if we believe that our services and products are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
- when we have a good faith belief that there is a meaningful risk that poses a threat to the safety of you, another person or the public generally; and
- in order to protect the rights or property of Unigine, including to enforce the terms and licenses that govern the use of our services and products.
- Sale or merger: In the event that Unigine explores or undergoes a business transition, such as a merger, acquisition by another company, transfer of control, or sale of all or a portion of its assets, we may share or transfer all of your information, including personal information.
- Advertising: We also may share certain limited information, such as device identifiers, with advertisers and other marketing partners for purposes of gauging the effectiveness of advertising and other marketing strategies.
- With your consent: We may share your information for other purposes if you direct us to do so or you consent to such sharing.
- De-identified and/or aggregated information: Some of the information we collect does not directly identify you or your device. We may modify other information that can identify you or your device to limit or prevent such identification by de-identifying it or aggregating it. We can share de-identified and/or aggregated information to any third party without restriction and use it for any purpose.
Protecting Children’s Privacy
Our websites, services and products are restricted to individuals over the age of 18. We do not knowingly collect, maintain, or use Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age, and no part of our websites, services and products are directed to children under the age of 13 (and in certain jurisdictions under the age of 16). If you are the parent or guardian of a child and you believe that we have inadvertently received personal information about that child, please contact us as described in the Questions and Concerns section of this policy and we will delete the information from our records.
Your Rights and Choices Regarding Your Personal Data
(1) Right of Confirmation
You have the right to obtain the confirmation whether or not personal data concerning you are being processed. If you want to avail yourself of this right of confirmation, you may, at any time, contact us firstname.lastname@example.org.
(2) Right of Access
You have the right to obtain free information about your personal data stored at any time and a copy of this information. Furthermore, you are granted to access to the following information:
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- The existence of the right to request rectification or erasure of personal data, or restriction of processing of personal data concerning you, or to object to such processing;
- The existence of the right to lodge a complaint with a supervisory authority;
- Where the personal data are not collected from you, any available information as to the source;
- The existence of automated decision-making, including profiling, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for you.
Furthermore, you have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, you have the right to be informed of the appropriate safeguards relating to the transfer.
If you want to avail yourself of this right of access, you may at any time contact us email@example.com.
Although Unigine makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Unigine is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
(3) Right to Rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
If you want to exercise this right to rectification, you may, at any time, contact us firstname.lastname@example.org.
(4) Right to Erasure (Right to Be Forgotten)
You have the right to obtain the erasure of personal data concerning you without undue delay, and we have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- You withdraw consent to which the processing is based according to, and where there is no other legal ground for the processing;
- You object to the processing and there are no overriding legitimate grounds for the processing;
- The personal data have been unlawfully processed.
If one of the aforementioned reasons applies, and you want to request the erasure of personal data stored by Unigine, you may at any time contact us email@example.com. We shall promptly ensure that the erasure request is complied with immediately.
(5) Right of Restriction of Processing
You have the right to obtain restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
- The processing is unlawful and you oppose the erasure of the personal data and request instead the restriction of their use instead;
- We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
If one of the aforementioned conditions is met, and you want to request the restriction of the processing of personal data stored by us, you may at any time contact us firstname.lastname@example.org. We will arrange the restriction of the processing.
(6) Right to Data Portability
You have the right to receive the personal data concerning you, which was provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit those data to another company without hindrance, as long as the processing is based on consent, or on a contract, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in our company.
Furthermore, in exercising your right to data portability, you have the right to have personal data transmitted directly from one company to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
In order to assert the right to data portability, you may at any time contact us email@example.com.
(7) Right to Object
You have the right to object, on grounds relating to your particular situation, at any time, to processing of personal data concerning you.
Unigine shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
If Unigine processes personal data for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing. This applies to profiling to the extent that it is related to Unigine will no longer process the personal data for these purposes.
In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data concerning you by Unigine for scientific or historical research purposes, or for statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, you may directly contact us firstname.lastname@example.org.
(8) Right to Withdraw Consent
You have the right to withdraw your consent to processing of your personal data at any time.
If you want to exercise the right to withdraw the consent, you may at any time directly contact us email@example.com.
(9) Right to Unsubscribe
If you receive an unwanted email from us, you can unsubscribe of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested.
We provide you with choices about whether to provide us with personal information and whether it is shared. For example, we have to ask you before we can use your personal information for any purpose incompatible with the purposes identified in this policy. Other examples of your choices include:
- You can browse our website without providing any personal information. We may collect some limited information automatically, as described above;
- You may opt-out of receiving our messages at any time by using the opt-out mechanism.
- You can choose not to give us all the information we request. In some cases, if you decide not to provide the information we request, we will not be able to provide the product or services you requested;
- You can change your privacy settings on other parties’ websites, such as social networks, which will stop or limit our receipt of information from those other websites.
- You may change your browser settings or take other steps to block, manage, or delete cookies. In some cases, blocking or disabling cookies may cause our websites not to work as intended and some features may not be available.
You may also exercise and amend your choices by sending an email to us firstname.lastname@example.org.
How We Protect Your Personal Data
Personal data we received are stored on specially protected servers. Access is restricted to a limited number of authorized persons who need the access in order to administer our websites or ensure their proper functionality, especially with regard to technical support. We employ industry-standard administrative, physical and electronic measures to safeguard personal information submitted to us from unauthorized access. We encrypt the transmission of all personal information using Secure Sockets Layer (SSL) technology and only store that information in secured data centers.
Please note that no system can be guaranteed to be 100% secure. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee or warrant the security of the information you share with us and we cannot be responsible for the theft, destruction, loss or inadvertent disclosure of your information.
Transfers of Information
As part of our international operations, we may transfer information about you to any jurisdiction where we do business. If you are an EU resident, we will transfer your personal information for the above purposes to our service providers that may be located outside of the EU. The laws in those jurisdictions may not necessarily provide the same level of data protection compared to the laws in your country. However, we will treat your personal information as subject to the protections described in this policy. When you use our websites, products and services, you acknowledge that we may transfer information about you as described in this policy.
Period for Which the Personal Data Will Be Stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you, then Unigine will notify you as soon as possible and later report the action we took in response.
Links to Other Websites
This policy does not apply to websites not owned or controlled by Unigine, even if we link to them or they link to us. Because Unigine does not operate those other sites and services, we can’t take responsibility for the privacy practices of the entities that operate them. We recommend that you consistently check privacy policies to understand an operator’s practices.
Questions & Concerns
If you have any questions or comments about this policy, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please email to us email@example.com or contact us at:
UNIGINE Holding S.à.r.l
Registration №. B211502
9bis rue basse, 4963 Clemency
Unigine will address your concerns and attempt to resolve any privacy issues in a timely manner.
Last Updated: May 24, 2018