UNBOX COMMERCE LTD PRIVACY POLICY

INTRODUCTION

Who are we?

We (“Unbox”, “we”, “us”), are:

Unbox Commerce Ltd, incorporated in England and Wales, with a registered address of 5th Floor, 167-169 Great Portland Street, London, England, W1W 5PF, UK
Unbox Commerce (USA), Inc., incorporated in Delaware, with a registered address of 224 W 35th St, Ste 500 # 2346, New York, NY 10001, USA

Where we decide the means of, or purposes for, processing your personal data, we are the “controller."

What’s this notice about?

This notice explains how we process personal data, as a controller, in the following situations:

When you visit our website (“Website Visitors”)
When we provide services to you (if you are a sole trader) or your company (“Customer Personnel”)
When we review or analyse information relating to you, in order to deliver services to our customers or improve our services (“Social Media Creators”)

We update this notice from time to time, so you should check back in on a regular basis. Where appropriate, we will actively notify you of changes.

Please note that other websites or services mentioned on our website or platform may not be operated by us. You should refer to the privacy notices on those websites to understand how they process personal data.

What are your rights?

You have the following rights, although these rights may be limited in some circumstances:

● Ask us to send a copy of your personal data to you or someone else

● Ask us to restrict, stop processing, or delete your personal data

● Object to our processing of your personal data

● Object to use of your personal data for direct marketing purposes

● Ask us to correct inaccuracies in your personal data

How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: privacy@unbox-commerce.com.

If we cannot resolve your issue, you can contact the relevant regulator or supervisory authority in your country. If you are based in the United Kingdom, you can get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns.

HOW WE USE YOUR PERSONAL DATA

Website Visitors

What information? – We collect and use the following information:

Technical data: includes (i) information relating to the device which you use to access our website, and information relating to such device (including IP address, screen resolution, operating system, and browser type and version); (ii) identifiers used to identify you when you visit our website; and (iii) information about how you interact with content on our website (such as the pages you visit or the content which you engage with). [We collect this information using the technology described in Section 4 of this Privacy Notice.
Recruitment data: includes your name, email address and any information relating to you which you share with us (including your CV) for recruitment purposes. We collect this information when you submit job enquiries to us at hello@unbox-commerce.com or via forms on our website or third-party websites.
Enquiry data: includes your name, email address and any other information relating to you which you share with us. We collect this information when you email us at hello@unbox-commerce.com, or message us via the “Get in touch” page on our website.
Marketing data: includes your name, email address, phone number, company and company URL. We collect this information when you procure services from us, or when you opt-in to receive marketing communications from us.

Why are we using this information?

Technical data: (i) to correct technical errors and bugs on our website, make technical updates and improvements to our website, understand how you use our website; and (ii) to show you advertisements relating to services which we think you might be interested in.
Recruitment data: to receive job enquiries, assess whether individuals are suitable to work with or for us (by considering skills, experience, qualifications and general competency), communicate with applicants about recruitment processes, and maintain appropriate records relating to recruitment processes.
Enquiry data: to respond to your questions, requests and complaints.
Marketing data: to send you information about our business, services and products (including in relation to our beta program).

How are we using this information / what is our legal basis for doing so? –

Technical data: in some cases, we can use this information because you have given your consent to us doing so. In other cases, we can use this information because it is necessary for our legitimate interest in promoting the success of our business and furthering our commercial interests, or our mutual legitimate interest in improving our services and products.
Recruitment data: we can use this information because it is necessary for our mutual legitimate interest in ensuring that you are the right candidate for the role, suitably qualified and experienced, and that the terms of your prospective employment or engagement meet our mutual expectations and business objectives.
Enquiry data: we can use this information because it is necessary for our legitimate interests in promoting the success of our business and furthering our commercial interests; or our mutual legitimate interest in improving our services and products, ensuring that you have a positive experience when interacting with Unbox and using our services, and ensuring that you receive good customer care.
Marketing data: in some cases, we can use this information because you have given your consent to us doing so. In other cases, we can use this information because it is necessary for our legitimate interest in promoting the success of our business and furthering our commercial interests, or our mutual legitimate interest in ensuring that you are informed about products, services and business updates which you may be interested in.

Who are we sharing this information with? – This information may be shared with third-party service providers whose services, platforms or tools we are using in order to make our website and its functionalities available to you, as well as support the purposes and objectives set out above. As a result, the above information may be shared with third-parties who provide us with analytics services and technology, marketing and sales intelligence platforms, customer service and ticketing platforms, and recruitment agencies.

How long do we use this information for? We retain this information for as long as it is reasonably necessary to do so, taking into account the purpose for collecting and using the relevant information. The specific retention period may vary based on factors such as:

Technical data:

When this data is used to correct technical errors and bugs etc.: any retention requirements imposed by third-party service providers which are used to collect this information; whether the error or bug which the information relates to, has been resolved; or whether we need to continue retaining the information in order to finalise any updates or improvements to our website, or maintain the ongoing safety and security of our website.
When this data is used for advertising purposes: any retention requirements imposed by the third-party service providers which are used to collect this information; or whether it is otherwise necessary to retain this information in order to further our commercial interests.

Recruitment data: whether you are successful with your job application (where we will retain this information for [two] years following the end of your employment or engagement with us), or unsuccessful (where we will retain this information for [two] years following the submission date of your application).

Enquiry data: whether the issue which the enquiry relates to has been resolved.

Marketing data: whether you inform us that you no longer wish to receive Unbox’s marketing communications.

Customer Personnel

What information? – We collect and use the following information:

Business data: includes your name, work email address, work telephone number, company, role and any information relating to you which is included in any correspondence, materials or other information which you or your company share with us, in relation to the provision of Unbox’s services. We collect this information from you in advance of, and during, the provision of services to you or your company.
Platform data: includes information about your activity on the Platform (such as pages and files viewed, and which features and tools you use), as well as any feedback which you provide on the Platform (including via surveys). We collect this information when you use our Platform.

Why are we using this information? – We use the business data to provide you or your company with our services, and administer our relationship with you and/or your employer. And we use the platform data to suggest features on the Platform that may be of relevance to you.

How are we using this information / what is our legal basis for doing so? – In some cases, we can use this information because it is necessary for the performance of the terms which we have in place between us and you. In other cases, we can use this information because it is necessary for our legitimate interest in promoting the success of our business, delivering high-quality services and furthering our commercial interests.

Who are we sharing this information with? – This information may be shared with third-party service providers whose services, platforms or tools we are using in order to deliver our services. This includes cloud storage service providers, and third-parties who provide Unbox with productivity software and cloud-based services.

How long do we use this information for? – We retain this information for as long as it is reasonably necessary, taking into account the purposes and objectives set out above. The specific retention period may vary based on factors such as:

The nature and status of the relationship between Unbox and you (or your company).
Any legal or contractual obligations, which Unbox is subject to, which dictate how Unbox shall retain the relevant information.
Whether Unbox needs the relevant information to improve its services and products.

Social Media Creators

What information? – We collect and use the following information:

Profile data: your name, social media avatar, any personal data contained within content published or uploaded to your social media channel, your area(s) of interest, your location (city and country) and any other information relating to you which is contained on your social media channel.
Follower data: information relating to your social media followers (such as number of followers, age-range of followers and other follower demographic information).

This information is shared with us by our customers, whom you collaborate with to deliver social commerce campaigns.

Why are we using this information? – We use this information to provide our services to our customers, and to improve the delivery of those services.

How are we using this information / what is our legal basis for doing so? – We use this information because it is necessary for our legitimate interest in promoting the success of our business, delivering high-quality services and furthering our commercial interests.

Any legal or contractual obligations, which Unbox is subject to, which dictate how Unbox shall retain the relevant information.
Whether Unbox needs the relevant information to improve its services and products.
Any retention requirements imposed by the third-party social media platforms from which our clients access this information.

STORAGE, TRANSFERS AND DISCLOSURE

Storage & Transfers

We are based in the United Kingdom, however we may occasionally collaborate with partners based in other countries or use subcontractors based in other countries. Where we transfer personal data internationally, we implement certain contractual measures in order to safeguard such transfers, where required by applicable data protection laws to do so. For more information, please contact us using the contact details at the start of this notice.

Disclosure

Other than as set out above, we may disclose your personal data:

Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud. Legal basis: our legal basis for this processing is likely to be: compliance with legal obligation, or in order to pursue our legitimate interests in: (i) obtaining advice in relation to legal and similar proceedings; (ii) communicating with relevant third parties in relation to legal and similar proceedings; and/or (iii) protecting and defending ourselves from legal and similar proceedings.
With our partners, suppliers and subcontractors, as necessary for the purposes (and on the legal basis) set out in this notice.
If involved in a re-organisation of our organisation or its assets, personal data we hold may be shared in order to pursue the legitimate interests of us, our beneficiaries and other parties involved within such re-organisation, unless those interests are outweighed by prejudicial impacts upon you. Legal basis: our legal basis for this processing is likely to be: in order to pursue our legitimate interests, which would typically include our interest in undertaking the relevant reorganisation.

COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

Cookies, pixels and other technologies store and access data on devices to help websites and apps work. Where we use cookies, we will list them below explain their purpose, how long they last, and who else can access their data. We get consent to use them unless they’re essential to provide the applicable services.

We currently use the following cookies or similar technologies:

Cookie/data technology: PostHog
How long is the data stored?: One month
Purpose: Website analytics
Provider information: www.posthog.com