1. INTRODUCTION

This privacy policy provides you with details of how we collect and process your personal data through your use of our site - https://www.unsaid.com/.

By providing us with your data, you warrant to us that you are over 13 years of age.

Walking Tree EU BV (hereinafter "UNSAID") acts as the Data Controller for the processing of  your personal data (hereafter referred to as “we”, “us” or “our”) as described in this Privacy Statement.

If you have any questions or concerns regarding this Privacy Statement, please contact our Data Protection Officer.  The details are provided below or, alternatively, you may contact us via the contact form provided on this website.

Contact Details

Walking Tree EU BVBA

Attn: Data Protection Lead

Hoveniersstraat 30

Box 122

2018 Antwerp

Belgium

Email address: hello@unsaid.com

It is very important that the information we hold about you is accurate and up to date.  You will have reasonable access to information you have provided which can be updated, modified or deleted by you. We encourage you to keep your personal settings complete and current. By accessing your personal profile, you may also change your preferences on how we communicate with you.

If you would like to update your personal information, simply send a request to us at hello@unsaid.com or by editing  your profile page.

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

• Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
• Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.  In case you opt to save your card details with us, please note that no information regarding your CVV/ passwords / PINs or any such private information/personal data is stored or collected by us.  We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
• Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
• Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. (This data is only collected if you provide us with implicit consent to do so.) We process this data to enable you to partake in our promotions, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
• We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you, unless you specifically sign up for one of our services that requires it for delivery of the service. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at hello@unsaid.com. In case we need to use your details for any new purpose, except as provided herein, we will let you know and explain the legal grounds for processing.

We consider your data strictly confidential and will never forward, loan or sell to any third party unless required by law and shall intimate you the same.

We do not carry out automated decision making or any type of automated profiling.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our Cookie Policy for more details about this.

We may receive data from third parties such as analytics providers such as Google based outside of the EU, advertising networks such as Facebook based outside of the EU, such as search information providers such as Google based outside of the EU and providers of technical, payment and delivery services.

We may also receive data from publicly available sources based inside or outside of the EU.

4. MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at hello@unsaid.com at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We do not sell trade, rent, license or otherwise send your personally identified information to any third party(s). This does not include trusted third parties who assist us in operating www.unsaid.com, conducting our business, or servicing you. Such third party(s) users are not allowed to use your personal data for any other commercial or personal purposes which are not authorized by us. We may release your information when we believe release is appropriate to comply with the law, enforce our Website policies, or protect ours or other rights, property, or safety. Except as set forth in this Privacy Statement, you will be notified when your personal data may be shared with third parties and will be able to prevent the sharing of this information.

We may have to share your personal data with the parties set out below:

• Other companies in our group who provide services to us.
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers.
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

As we work with "processors" outside the European Economic Area, like India, your personal data may be transferred to so-called "third countries". We will always make sure that appropriate or suitable safeguards are in place when transferring your personal data to such "third countries" .

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

• We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

• If we use US-based providers that are part of a privacy framework (such as the successor to the EU-US Privacy Shield), we may transfer data to them, as they have equivalent safeguards in place; or

• Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.  Financial Transaction information is protected by the high security measures adopted by our payment gateway provider.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. DATA RETENTION

We will only retain your personal data for as long as your account is active or as needed to provide you services,, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure and the processing purposes - and if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years following the taxable period to which the documents correspond.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you wish to exercise any of the rights set out above, please email us at hello@unsaid.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

12. CONTACT US

Should you have a problem with our use of your personal data, please let us know and we will make all reasonable efforts to meet your concerns.

In case you have any questions or comments regarding this Privacy Statement, please contact us at hello@unsaid.com.