PRIVACY POLICY
We, 15486963 Canada Inc. based out of Unit #400, 111 2 Ave S, Saskatoon, SK S7K 1K6, Canada.(“Unlockd” / “Unlockd PR”) understand your concerns over the privacy of Personal Data you may submit through the use of this website or through any other form of contact with our organisation.
This Privacy Policy applies to Personal Data about you that we collect, use and otherwise process.
It provides you with information about what types of information is collected, what tracking takes place, how we use the collected information and with whom we share the information.
The information we collect:
Personal Data is anything which identifies you as an individual, either on its own or by reference to other information. We may collect the following Personal Data from you when you use our website or contact us or engage our services:
Information such as name, address, email address, contact number and payment details which are collected to support the transactions carried out between you and us on or in relation to this website;
Information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation); and
Any other information that you choose to provide to us.
Cookies:
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser, and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We use “session” cookies on the website. Session cookies will be deleted from your computer when you close your browser.
We will use the session cookies to: keep track of you whilst you navigate the website; prevent fraud and increase website security.
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: https://www.google.com/privacypolicy.html.
Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites.
Legal Basis for using Personal Data:
Unlockd will only process Personal Data where we have a legal basis to do so. The legal basis will depend upon the reason we collected and the needs to use the Personal Data. Under UK and EU data protection legislation in almost all cases the legal basis will be because:
Processing of the Personal Data is necessary to perform the contract to fulfil your request for services;
Processing of the Personal Data is necessary to support the creation of a contract with you as a customer of Unlockd;
It is in Unlockd’s legitimate interests as a provider of marketing support services to process the Personal Data to operate and improve our IT and associated services;
Unlockd processes the Personal Data to comply with a legal obligation;
You have consented to Unlockd using the Personal Data for a particular purpose
If processing of your Personal Data is subject to any other laws then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.
How we use the Personal Data we collect:
Personal Data submitted to us will be used for the purposes specified in this privacy policy.
Unlockd will use Personal Data to fulfil our contractual obligations under any IT Service Agreement and associated Service Specific Terms (SSTs). For example, we will process Personal Data such as, name, address, email address, payment details for the purpose of:
answering any enquiry you raise;
enabling you to register to use our services;
billing you for the services you consume;
delivering and supporting the services for which you have engaged Unlockd, including notification of service status updates;
storing historical data of the faults you raise to enable us to provide technical support services;
administering your customer account, and to support other general business activities;
validating our licence returns to 3rd party vendors;
As a provider of IT services, we have a legitimate interest to process Personal Data to improve the services we offer and carry out our business. For example, we will process Personal Data such as, name, address, email address, IP address, browsing history, page visits, length of visit for the purpose of:
answering any enquiry you raise;
sending you marketing communications;
administering and enhancing our website;
improving your browsing experience by personalising the website;
There are instances where Unlockd is subject to a legal obligation and processes Personal Data to comply with those obligations. For example, we will process Personal Data such as, name, address, for the purpose of:
satisfying legal or regulatory requirements, e.g. periodic returns to HMRC;
Alternatively, Unlockd may collect and use Personal Data that you have consented to be processed for a specific purpose. For example, we will process Personal Data such as, name, address, for the purpose of:
registering you as a potential candidate for employment with Unlockd;
providing your personal testimony regarding your experiences of dealing with Unlockd
If you opted to receive any communications from us, but subsequently change your mind, you may opt-out at any time by emailing the Head of Compliance (hello@unlockdpr.com) or by writing to the Head of Compliance, Unlockd PR 86-90 Paul Street, Old Street, London EC2A 4NE
While we will restrict the processing of your Personal Data in line with your request, we may add your Personal Data (name and address) to a ‘suppression list’ to ensure we do not send any communications in the future.
How long will we keep the Personal Data:
Unlockd will keep your Personal Data only for a long as we need it for the purpose it is being processed for. For example, if we provide IT services for you we will keep your Personal Data as long as you are an active user of our services, and after that for a period which enables us to handle or respond to any complaints, queries or concerns relating to the service. We will also keep Personal Data as required to comply with any legal obligation.
We will actively review the Personal Data we hold and delete it securely, or in some cases anonymise it, when there is no legal, business, or customer need to retain it.
Disclosures:
We may disclose information about you to other organisations who provide specific business services to us.
Such organisations (listed below) are required to handle your Personal Data in accordance with applicable laws related to privacy and data protection.
The processing of any Personal Data by the organisations will be explicitly defined within contractual terms.
Cloud Service providers – organisations who require your Personal Data in order to deliver the business services to which you subscribe.
Financial Services organisations – used to support the financial processes that we perform. For example, these include credit checks against prospective customers, to ensure we are not exposed to unnecessary financial risk, and BACS to facilitate those customers paying via Direct Debit.
Payment Gateways – used to facilitate the payment for services. The organisation will only have access to the Personal Data you provide directly to them when you make a card payment. We will not collect or store payment card details.
Business Bureaus – used to check the accuracy of the Personal Data (name, address and contact details) for potential customers who have consented to us holding their Personal Data.
Recruitment Websites – used to facilitate the recruitment of new employees. The organisation will only have access to the Personal Data you provide directly to them when you complete their on-line forms. The organisation is a data controller for this Personal Data.
General Service providers – who provide specific, ad-hoc services to us. For example, Courier services, Hospitality services to help promote Unlockd events.
Cloud Service Providers – who host bespoke business applications that allow us to improve the efficiency and effectiveness of our general business activities.
Auditors – used to validate our compliance with the Vendor’s contractual Terms and Conditions. For example, Personal Data (email address) may be used to confirm our licence management procedures are correct.
Other persons or organisations permitted or required by applicable law or regulation.
Except as provided in this privacy policy, we will not disclose Personal Data to any other category of organisation.
We also utilise Co-locators – who host components of our physical infrastructure within their own datacentre, but who do not have any access to the Personal Data held by Unlockd.
International data transfer:
Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this privacy policy.
Information which you provide may be transferred to countries which do not have data protection laws equivalent to those in force in the European Economic Area.
We will only transfer Personal Data when satisfactory safeguards are in place.
Your rights:
You have the right to:
request confirmation whether we hold your Personal Data and, if so, to access that Personal Data.
We will inform you of: the purposes for which the Personal Data is processed; the categories of the Personal Data processed; whether your Personal Data has been disclosed and the categories of recipient of the disclosure; whether your Personal Data has been transferred to another country or international organisation; the expected period for which the Personal Data will be stored. If we did not obtain the Personal Data directly from you, we will also inform you of the source.
We may withhold such Personal Data to the extent permitted by law.
request correction of the Personal Data we hold.
request erasure of your Personal Data, subject to any legal obligation to which we are subject or where the processing of the Personal Data is for the establishment, exercise or defence of legal claims. We will accept your request for erasure where we have a legal obligation so to do, acceptance of such a request is otherwise at our discretion. Please be aware that the erasure of your Personal Data may affect our ability to provide services to you and in some cases our acceptance of an erasure request may require your account to be closed.
restrict processing of your Personal Data where you contest the accuracy of the Personal Data we hold, consider our processing to be unlawful, consider that we no longer need the Personal Data but it is required by you in relation to a legal claim or where you have objected to our processing in accordance with your legal rights, provided in each case that we shall only be required to apply such restriction where we have a legal obligation to do so and until the issue giving rise to the restriction is resolved.
withdraw any consent that you have previously given to our processing of your Personal Data.
receive the Personal Data you have provided to us in a structured, commonly used and readable format, where the processing is carried out by automated means.
We may withhold such Personal Data if it adversely affects the rights and freedoms of others.
object to the processing of your Personal Data, for example the use of your Personal Data for direct marketing purposes.
Children:
We will never knowingly collect Personal Information from minors (children under 16 years of age, or any other age defined under applicable law). If we become aware that a minor is attempting to or has submitted Personal Information, we will notify the user that we will not accept his or her Personal Information. We will then remove any such Personal Information from our records.
Updating information:
Please let us know if the Personal Data which we hold about you needs to be corrected or updated. Failure to inform us of a change to your Personal Data may result in the suspension, or withdrawal, of your services.
Third party websites:
Our website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites. We recommend that you make yourself familiar with the privacy policy for any third-party website you visit.
Questions about this Privacy Policy:
If you have any questions about this Privacy Policy or our treatment of your Personal Data, please contact us by emailing the Head of Compliance (Hello@unlockdpr.com) or by writing to the Head of Compliance, Unlockd PR, 86-90 Paul Street, Old Street, London EC2A 4NE
In the unlikely event that you have a complaint about our treatment of your Personal Data, it will be dealt with in accordance with our complaints handling procedure. You should contact the Head of Compliance, who will respond to you within 28 days.
If you are dissatisfied with this response you may request that your complaint be escalated, in which case it will be escalated to a member of the Unlockd PR Executive Team who will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.
You may also raise a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/for-the-public/raising-concerns for more information.
Whilst this privacy policy sets out a general summary of your legal rights in respect of your Personal Data, this is a complex area of law and this privacy policy is not intended to represent legal advice. More information about your rights in respect of your Personal Data can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public
Policy amendments:
We may update this privacy policy from time-to-time by posting a new version on our website. We recommend that you check this page regularly. Continued use of this website will indicate your acceptance of any changes.
Additions:
If you sign up for (any) call with us via our Calendly links, we’ll:
Send a reminder email to you 24 hours before the call (via Calendly).
Send a reminder email to you 2 hours before the call (via Calendly).
If it’s a discovery call, we’ll also subscribe you to our ‘General’ Active Campaign audience and we might email you from time to time. You can unsubscribe at any time (using the unsubscribe button) or by contacting Hello@unlockdpr.com with your email address.
If you sign up to a call via one of our Facebook or Instagram lead ads, we’ll:
Subscribe you to our ‘General’ Active Campaign audience. You can unsubscribe at any time (using the unsubscribe button) or by contacting Hello@unlockdpr.com with your email address.
Send you a text message (via FireText).
Send you periodic emails from us (via Active Campaign, as part of our ‘General’ Audience). Once you sign up with us, you’ll be unsubscribed from this audience automatically and/or you can manually unsubscribe at any time.
Periodically we may contact you via our ‘General’ Active Campaign audience, email (via Outlook), text message (via FireText) or phone call. By unsubscribing to the Active Campaign audience we won’t contact you again.
If you sign up with us, we’ll:
Subscribe you to our ‘Key holders’ Active Campaign audience and send you a welcome email and periodically send you emails (via Active Campaign). You can unsubscribe at any time (using the unsubscribe button) or by contacting hello@unlockdpr.com with your email address. However, this is a key method of how we talk to you and we highly recommend you don’t unsubscribe.
You’ll get emails (with invoices attached) from Recurrly.
All Zoom calls are recorded and transcribed for training and monitoring purposes.