Privacy Policy

UniKey Technologies, Inc.

Privacy Policy for Website and Mobile Applications

 

Scope and Consent

Scope: Your privacy is important to UniKey Technologies, Inc. (hereinafter: "UniKey", "we", "us" or "our"). This Privacy Policy describes our collection, use, disclosure, retention and protection of your Personal Information [1] and governs your use of our mobile applications as well as online websites, including: UniKeyMyKey, and  Kevo.UniKey and successor sites (the "Sites"). Our applications include mobile applications, services, platforms, products or tools (collectively "Products" or “Platform”) accessed through UniKey whether via personal computers, mobile devices, or otherwise. The Privacy Policy applies to your use of the Sites as well as any interactive features, widgets, plug-ins, applications, content, downloads and/or other Products and/or Platform that we own and control and make available through the mobile or online version of the Sites., regardless of how you access or use them.

By using our Products, Platform and/or registering for an account with us, you are accepting the terms of this Privacy Policy and our Universal General License Agreement (“UGL”), and you are consenting to our collection, use, disclosure, retention, and protection of your personal information as described in this Privacy Policy. If you do not provide the information we require, we may not be able to provide You all of our Products and/or access to the Platform.

This Privacy Policy does not govern the data practices of third parties that may interact with our Sites. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Sites (unless otherwise stated), and does not govern the data practices of third parties that may interact with our Sites.

You must read and understand the entire Privacy Policy before using any of the Sites. If you are unwilling to consent to Our collection and use of your Personal Information as described in this Privacy Policy, and to accept the terms in the UGL, you should not access or use the Sites.

 

Collection and Purpose

From time to time we collect, retain and utilize Your Personal Information to operate our business and to make services and other opportunities available. We recognize and respect your privacy concerns about Your Personal Information. We obtain Personal Information in a variety of ways (for example, when you contact us directly by email, from your other transactions or experiences with us, or from other third parties). Also, when you visit the Sites, we collect information that might or might not identify you for purposes of measuring the use of the Sites and improving its content, as described below.

 We collect, process, and retain personal information from you and any devices (including mobile devices) you may use when you: use UniKey Products and/or Platform, register for an account on UniKey’s website or through its mobile app, provide us information in your account or when you otherwise correspond with us regarding our Products and Platform.

In addition to any Personal Information or other information that you choose to submit to us via our Sites, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Sites ("Usage Information"). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, laptop, tablet or mobile phone (a "Device") whenever you visit or interact with our Sites. Usage Information may be non-identifying or may be associated with you. To the extent that we associate Usage Information with your Personal Information, we will treat it as Personal Information. Notwithstanding anything to the contrary herein, We are not responsible for Usage or treatment of Personal Information to the extent the same is in the control of businesses with whom we contract to provide Products and/or access to the Platform, or related services, products or platforms.

  • Personal information you give us when you use our Products and/or Platform or register for an account with us may include:
  • Identifying information such as your name, addresses, telephone numbers or email addresses
  • Content that you generate, or that is connected to your account (such as adding items to a basket)
  • Financial information (such as credit card numbers) in connection with a transaction
  • Information supplied through a web form, by updating or adding information to your account or when you otherwise correspond with us regarding our Products and/or Platform
  • Additional information that is required or authorized by applicable national laws to collect and process for purpose of authenticating or identifying you or to verify as correct the information we receive

Personal information we may automatically collect may include usage information such as:

  • Information about your interaction with our Products and/or Platform, such as your advertising preferences and your communications with us
  • Your IP address or other unique identifier ("Device Identifier"). A Device Identifier is a number that is automatically assigned to your Device used to access the Sites, and our computers identify your Device by its Device Identifier or a unique device token
  • Your Device functionality (including browser, operating system, hardware, and mobile network information)
  •  The URL that referred you to our Sites
  • Your Device characteristics
  • Certain other Device data, including the time of day, among other information
  • Information at registration for an account and submitted on a web form, or when You update or add information to your account or when you otherwise correspond with us regarding our Products and/or Platform
  • Geo-location information, including location information from your mobile device. Keep in mind that most mobile devices allow you to control or disable the use of location Products and/or Platform by any application on your mobile device in the device's settings' menu
  • Computer and connection information such as statistics on your page views, traffic to and from the Sites, ad data, your browsing history, preferences and your web log information

Personal information collected from “Tracking Technologies,” including cookies[2], web beacons[3], unique identifiers or similar technologies,[4] including

  • Information we consider are strictly necessary to allow you to use and access our Sites, including cookies required to prevent fraudulent activity, improve security, or allow you to make use of shopping cart functionality
  • Information we consider useful in order to assess the performance of the Sites, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Sites
  •  Information that is necessary in order to offer you enhanced functionality when accessing the Sites, including identifying you when you sign in to our Sites or keeping track of our specified preferences, including in terms of the presentation of content on our Sites, including pages you view, links you click or other actions you take on our Products and/or Platform, on the website, from advertising or e-mail content
  • So as to deliver content relevant to your interests on our Sites and third party sites based on how you interact with our content such as to understand the usefulness to you of the content that have been delivered to you.

There may be other Tracking Technologies now and later devised and used by us in connection with the Sites. In addition, third parties may use Tracking Technologies with our Sites. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Sites and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.

Personal information from other sources

  • We may supplement the personal information we collect with information from third parties and add it to your account information. For example, we may collect and use demographic information that is publicly available as permitted by applicable national laws

In the event you give us personal information about someone else, you must do so only with their explicit and prior consent. You shall further inform them how we collect, use, disclose, and retain their personal information according to our Privacy Policy.

 

Use and Retention

We may share Personal Information that you provide to us through this Site or through this Site’s customer service department with our affiliates, service providers and strategic partners. In turn, our service providers may share this Personal Information with their affiliates and with service providers whom they engage to perform services related to this Site or the operation of our business. Examples of these services include Sites’ operation, hosting, designing and/or operating features, as well as tracking the Sites activities and analytics, order fulfillment and shipping, customer service, marketing and promotional material distribution, data analysis and, where applicable, data cleansing. We may provide these vendors with access to user information such as and including Device Identifiers and Personal Information, to carry out the services they are performing for you or on our behalf. These service providers are authorized to use this personal information only in connection with the services they are engaged to perform. Nonetheless, We have no control over the activities of service providers beyond contractual obligations they undertake on Our behalf and have no liability for non-compliance by virtue of this Privacy Policy.

We may further use the Personal Information we collect to provide and improve our Products and/or Platform. We may retain your personal information as long as it is necessary and relevant for such improvement. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our UGL and/or take other actions permitted or required by applicable national laws.

We may also Contact you about your account and provide you customer service, including to:

  • notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, or as otherwise necessary to provide you customer service
  • reach out to as may be necessary to enforce our UGL, applicable national laws, and any agreement we may have with you
  • provide you with information or services or process transactions that you have requested or agreed to receive, such as password resets and granting permissions to others
  • process your registration with the Sites, including verifying your information is active and valid
  • improve the Sites or our services, to customize your experience on the Sites, or to serve you specific content that is relevant to you
  • contact you with regard to your use of the Sites and, in our discretion, changes to the Sites and/or Sites policies
  • facilitate internal business purposes and for research purposes
  • to allow for purposes disclosed at the time you provide your information

We may also compile and provide to third parties aggregated de-identified information, i.e., compiled information that does not in itself identify you. We, and third parties may use the same for internal research, quality assurance, product development and benchmarking purposes.

We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information), including disclosure to third parties: (a) to satisfy any applicable law, regulation, subpoenas, governmental requests, or legal process if in our good faith opinion such is required or permitted by law; (b) to protect and/or defend the Sites Terms of Use or other policies applicable to the Sites, including investigation of potential violations thereof; (c) to protect the safety, rights, property or security of the Sites or any third party; and/or (d) to detect, prevent or otherwise address fraud, security or technical issues.

We are not responsible for any information, including Personal Information that you might disclose in the course of using our services. For example, after you have created an account you might elect to grant permissions to third parties. The information you disclose in your invitation message via our services is not within our control.

 

Consent and Opt Outs

You have a choice about how we use your personal information to communicate with you, send you marketing information, and provide you with personalized advertising, and whether you want to stay signed into your account.

If you do not wish to receive marketing communications from us, you can unsubscribe in a link which shall be provided in the email you receive. If you do not wish to participate in advertising personalization programs, if any, you can opt-out by following the directions provided within the applicable advertisement. The effect of an opt-out will be to stop personalized advertising, but it will still allow the collection of information for certain purposes such as usage, research, internal use, quality assurance, analytics and to monitor Products and/or Platform operations). We do not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We do not allow third parties to track you.

If you withdraw your consent for the use or disclosure of your Personal Information for purposes set out in this Privacy Policy you may not have access to all our Products and/or Platform and we might not be able to provide you all of the Products and/or Platform and customer support offered to our users and authorized under this Privacy Policy and our UGL.

 

Access

We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access it and make corrections to it. We will honor any statutory right you might have to access, modify or erase your personal information and have established procedures to correct inaccurate information in a timely manner. Upon your request, we will close your account and remove from view as soon as reasonably possible, your Personal Information in accordance with applicable national laws. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws, but will give you reasons if we do so. If you have any reason to believe that Personal Information about you that is stored and maintained by us is incorrect, please contact us by email at: privacy@unikey.com.

 

Disclosure

We may disclose your personal information to third parties. This disclosure may be required for us to provide and to provide you access to our Products and/or Platform, to comply with our legal obligations, to enforce our UGL or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Products and/or Platform.

Regarding an investigation: if necessary to disclose information we deem relevant to an investigation or inquiry, (such as name, city, state, postcode, telephone number, email address, User ID history, IP address, fraud complaints to third parties involved in a legal proceeding,) we will do so under a subpoena, court order or substantially similar legal procedure, or if we otherwise believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

We may use third-party vendors to perform certain services on behalf of us or the Sites, such as hosting the Sites, designing and/or operating the Sites features, tracking the Sites activities and analytics, and enabling us to send you special offers about our products or services and our partners products or services, or enabling us to perform other administrative services. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. We do not disclose your Personal Information to third parties for their marketing and advertising purposes without your explicit consent.

We may share or transfer your Personal Information as directed to do so by you. We may otherwise transfer Personal Information or Usage Information to third-party vendors who act for us in accordance with the purposes for which the information was originally collected, or for purposes to which you have consented. For example, sometimes a third-party vendor may have access to your Personal Information or Usage Information in order to support our information technology or help obtain, compile and manage the information for us. Additionally, we may share Personal Information with existing or future third-party partners, who manufacture products with which UniKey’s services are utilized, for product support or marketing reasons.

Except as indicated within this Policy, we will not sell, rent or transfer your Personal Information to or otherwise share your Personal Information with third parties. We do not control, and are not responsible for, the privacy and data security practices of these third parties.

 

Child Privacy

The Sites are a general audience website and we do not knowingly collect any personal information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any personal information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personal information to us, please contact us at privacy@unikey.com.

 

Safeguards

We protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We strive to maintain the reliability, accuracy, completeness and currency of your Personal Information in our databases and to protect the privacy and security of our databases and the information we collect. Any Personal Information that you provide to us will be stored on our or our third-party provider’s computer network servers. We and our vendors maintain reasonable physical, electronic and procedural safeguards to protect the confidentiality of your Personal Information. The security measures in place for the Sites and its servers aim to protect the loss, misuse or alteration of the information you provide to us. If you have any questions or concerns regarding the security of your information, please email us at privacy@unikey.com.

If you attempt to change your password, User ID, update any other account information or attempt other account activity beyond those listed above, you will be asked to enter your password.       

You can typically end your signed in session by either signing out and/or clearing your cookies. If you have certain browser privacy settings enabled, simply closing your browser may also end your signed in session. If you are using a public or shared computer you should sign out and/or clear your cookies when you are done using our Products and/or Platform in order to protect your account and your personal information.

You should know that while visiting the Sites, you can be directed, through links, to other websites that are beyond our control. UniKey is not responsible for the privacy practices and policies of such linked websites.

Please note that when you shop with a vendor who is linked to Sites, even though you may have started your visit with Us and even though Our pages may still appear, your transactions are completed with a separate organization and not with us. We don’t share your Personal Information with them, but Personal Information you choose to share with them will fall under their privacy policies, which We suggest that you review. We carefully select other organizations with whom we do business, however, it is they that are responsible for the Personal Information You share and its further usage.

 

Business Transitions

In the event that UniKey goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information or Usage Information might be among the assets transferred. You will not be notified in advance of any such change in ownership or control of your Personal Information.

 

Transfer of Personal Information

Where we use third parties to perform certain services on our behalf, we grant these service providers access to Personal Information to carry out the services they are performing.  We do not authorize these service providers to use or disclose Personal Information except as necessary to perform certain services on our behalf or comply with legal requirements.  We require service providers to whom we disclose Personal Information and who are not subject to laws based on the European Union Data Protection Directive 95/46/EC or Swiss Federal Data Protection Law to either (i) subscribe to the Safe Harbor principles or (ii) contractually agree to provide at least the same level of protection for Personal Information as is required by the relevant Safe Harbor principles.

The Sites are operated in the United States and intended for users located in the United States. If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

 

Changes to the Policy

We reserve the right to change this Privacy Policy at any time. If we change this Policy, we will post the revised Policy on the Sites, so you should review it each time you access the Sites. All amended terms automatically take effect 30 days after they are posted.

 

Questions or Complaints

If you have any questions or suggestions regarding this Policy, please contact us at: Privacy Officer, UniKey Technologies, Inc., 111 West Jefferson St., Suite 100, Orlando, FL 32801, or by e-mail: privacy@unikey.com.


Updated as of September 22, 2016

[1] "Personal information" In this Policy means information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. UniKey does not consider personal information to include information that has been de-identified and aggregated or otherwise made anonymous so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

[2] A cookie is a data file placed on a Device when it is used to visit the Sites. Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please be aware that if you disable or remove cookies on your Device, some parts of our Sites may not function properly, and that when you revisit our Sites your ability to limit cookies is subject to your browser settings and limitations.

[3] Web Beacon is a small graphic image or other web programming code (also known as "1x1 GIFs" or "clear GIFs") which may be included in our Sites pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites, to monitor how users navigate the Sites, to count how many e-mails that were sent were actually opened, or to count how many particular articles or links were actually viewed.

[4] Embedded Scripts and ETags. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter. An ETag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner, ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies.