- organizing it into the sections listed in the Table of Contents below,
- providing a series of examples that help illustrate how the policies may be implemented by Unaty and
- defining and capitalizing a few terms that are used more than once for simplicity and brevity. When we refer to “Unaty”, we mean the Unaty Technologies GmbH, Unertlstr. 27, D-80803 Munich, that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.
Table of Contents
Information We Collect and Receive
Unaty may collect and receive Customer Data, Content Data and data about data (“Metadata”) in a variety of ways:
Customers or individuals granted access to a Community by a Customer (“Administrators”) routinely submit Customer Data to Unaty when using the Services: To create or update a Community account, you or your Customer (e.g., your Club/Organization) supply Unaty with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a Products provide Unaty (or its payment processor Stripe, Inc.) with billing details such as credit card information, banking information and/or a billing address.
Unaty contains and therefore receives data that is created in the Communities like Events, Roles, Personal Messages and Conversations. Most of these data is directly connectable to Customers and Users and is therefore personal data. Unaty emphasizes explicitly that Content data is not used for any purposes but generating anonymous metadata (see below). Content Data is neither sold nor used for usable services for third parties or monetized in any other way. These Data is not accessible to Unaty employees or third parties.
Unaty collects, generates and/or receives general Metadata:
When an Administrator interacts with the Services, metadata is generated that provides additional context about the way Administrators work. For example, Unaty logs the Communitys, channels, people, features, content and links you interact with, the types of files shared and what Third Party Services are used (if any).
As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
Unaty collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Metadata often depends on the type of device used and its settings.
We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Unaty may also collect location information from devices in accordance with the consent process provided by your device.
Third Party Services
Customer can choose to permit or restrict Third Party Services for their Community. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Administrators to enable and disable these integrations for their Community. Once enabled, the provider of a Third Party Service may share certain information with Unaty. For example, if an E-Mail-Marketing application is enabled to permit email lists to be imported to a Community, we may receive user name and email address of Administrators, along with additional information that the application has elected to make available to Unaty to facilitate the integration. Administrators should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Unaty. When a Third Party Service is enabled, Unaty is authorized to connect and access Metadata made available to Unaty in accordance with our agreement with the Third Party Provider. We do not, however, receive or store passwords for any of these Third Party Services when connecting them to the Services. Generally, no one is under a statutory or contractual obligation to provide any Customer Data, Content Data or Metadata (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Community setup details, is not provided, we may be unable to provide the Services.
How We Use Information
Customer Data will be used by Unaty in accordance with Customer’s instructions, including any applicable Terms of Service for Customer, and as required by applicable law. Unaty is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Community, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services. Content Data is never used by Unaty for Business. Anonymous generated Data around Content Creation and Usage is collected as part of our Metadata, which is never connected to single Users or Customers. Unaty will make Content Data accessible only to public authorities when requested, for example when illegal use of Unaty is indicated.
Unaty uses Metadata in furtherance of our legitimate interests in operating our Services, Websites and business, always as required by applicable law, legal process or regulation.. More specifically, Unaty uses Metadata:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Metadata to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Administrator’s request.
- To develop and provide search, learning and engagement tools and additional features. Unaty tries to make the Services as useful as possible for specific Communities and Administrators. For example, we may improve search functionality by using Metadata to help determine and rank the relevance of content, channels or expertise to an Administrator, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new engagement features and products.
In the following cases, Unaty is allowed to connect Metadata to single Users or Organizations (Customers, Communities) which are then classified as Personal Data:
- For billing, account management and other administrative matters. Unaty may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Metadata to respond.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Unaty. These are marketing messages so you can control whether you receive them.
- To investigate and help prevent security issues and abuse.
How We Share and Disclose Information
This section describes how Unaty may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Unaty does not control how they or any other third parties choose to share or disclose Information.
- Customer’s Instructions. Unaty will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Customer Access. Owners, administrators, Administrators and other Customer representatives and personnel may be able to access, modify or restrict access to Metadata. This may include, for example, your employer using Service features to export logs of Community activity, or accessing or modifying your profile details.
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Metadata and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth at Unaty Subprocessors.
- Third Party Services. Customer may enable or permit Administrators to enable Third Party Services. When enabled, Unaty may share Metadata with Third Party Services. Third Party Services are not owned or controlled by Unaty and third parties that have been granted access to Metadata may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions.
- Corporate Affiliates. Unaty may share Metadata, like its User Growth, with its corporate affiliates, parents and/or subsidiaries.
- During a Change to Unaty’s Business. If Unaty engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Unaty’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Metadata may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Metadata for any purpose. For example, we may share aggregated or de-identified Metadata with prospects or partners for business or research purposes, such as telling a prospective Unaty customer the average amount of time spent within a typical Community.
- To Comply with Laws. If we receive a request for information, we may disclose Metadata if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Please see the Data Request Policy to understand how Unaty responds to requests to disclose data from government agencies and other sources.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Unaty or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Unaty may share Metadata with third parties when we have consent to do so.
To support delivery of our Services, Unaty Technologies GmbH may engage and use data processors with access to certain Customer Data (each, a “Subprocessor”).
Unaty currently uses third party Subprocessors to provide infrastructure services, and to help us provide customer support, website analytics and email/sms notifications. Prior to engaging any third party Subprocessor, Unaty performs diligence to evaluate their privacy, security and confidentiality practices, and executes an agreement implementing its applicable obligations.
||Country of Subprocessing Activities
|Meteor Development Group Inc.
||Cloud-Service Provider of the Unaty Platform
||Cloud-Service Provider of the Unaty Platform
|Amazon Web Services, Inc.
||Hosting of unaty.de
||Country of Subprocessing Activities
||Cloud-based customer support Services
||Cloud-based payment services
|Mailgun Technologies, Inc.
||Cloud-based email notification services
||Cloud-based sms notification services
||Cloud-based website analytics services
||Cloud-based website analytics services
Unaty takes security of data very seriously. Unaty works hard to protect Metadata you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Data we collect, process and store, and the current state of technology. Unaty undergoes the process of acquiring internationally recognized security certifications for ISO 27001 (information security management system) and ISO 27018 (for protecting personal data in the cloud). To learn more about current practices and policies regarding security and confidentiality of the Services, please see our Data Security page. Given the nature of communications and information processing technology, Unaty cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.
To the extent prohibited by applicable law, Unaty does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will takes steps to delete such information.
Data Protection Officer
At Unaty, there is only an extremely narrow circle of employees that gets in touch with your Personal Data. Therefore, Unaty is not required to register an official data Protection Officer to authorities. However, we designated one employee to explicitly take care of data protection. To communicate with him, please email firstname.lastname@example.org.
Identifying the Data Controller And Processor
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. The Unaty Technologies GmbH is the controller of Metadata and a processor of Customer Data.
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete (Right to be Forgotten) or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance.
If you are a Customer and want to make use of these rights, contact email@example.com Data Protection Authority
Subject to applicable law, you also have the right to
- restrict Unaty’s use of Metadata that constitutes your Personal Data and
- lodge a complaint with your local data protection authority or the Bavarian Data Protection Officer (https://www.datenschutz-bayern.de/), which is Unaty’s lead supervisory authority in the European Union.
For Customers and Administrators who use Communitys established for Customers in the US and Canada:
Unaty Technologies GmbH