This Privacy Notice ("Notice") for Unchained Capital, Inc. and its Affiliates (Unchained Trading, LLC, B&C Lending LLC, and Bitcoin Collateral Services LLC), collectively referred to as “Unchained” ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services (collectively, our "Services"), such as when you:
This Notice does NOT cover Gannett Trust Company, LLC or Sound Advisory, LLC (d/b/a Gannett Wealth Advisors). Customers of these entities are covered by different privacy notices.
If you are a resident of a U.S. state that may provide additional privacy rights, please refer to the State Privacy Rights section below.
If you have questions about this notice or your data, you can contact us via email at escalations@unchained.com.
By using our Services, you acknowledge that you’ve read and understood this Privacy Notice. If you do not agree with our policies or practices, please do not use our Services.
Information we collect. We collect personal information depending on how you interact with Unchained, the choices you make, and which Services you use.
Sensitive information. We may process certain sensitive personal information (like financial or identity information) when necessary with your consent or as otherwise permitted by applicable law.
Information from others. We may receive information from public databases, marketing partners, social media platforms, and other outside sources.
How we use your information. We process your information to provide, improve, administer, and secure our Services; communicate with you, prevent fraud; and comply with legal obligations. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
Sharing your data. We may share personal information only in specific circumstances, such as with trusted service providers or to meet legal requirements.
Keeping your data safe. We apply organizational and technical safeguards and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology/system can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Your rights. Depending on where you live, you may have certain rights regarding your personal information according to the applicable privacy law.
Exercising your rights. You can submit a request through our Data Subject Rights Request Form or contact us directly at escalations@unchained.com. We will consider and act upon any request in accordance with applicable privacy laws.
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE DISCLOSE INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
In Short: We collect personal information that you provide to us.
We may collect personal information that you voluntarily provide to us when you create an Unchained account, register or apply for any of our Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — are collected automatically when you visit our website and/or leverage our Services.
We may automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information. The primary use of this information is to maintain the security and operation of our Services and for our internal analytics and reporting purposes.
In Short: We may collect limited data from third-party sources in certain situations. This could include, but is not limited to identity or other verification services, public databases, marketing partners, and other outside sources.
We may obtain information about you from other sources to enhance your experience in using our Services including for fraud prevention, connected services, and to enhance our ability to provide relevant marketing, offers, and services to you.
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and comply with law. We may also process your information for other purposes with your consent.
We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
The General Data Protection Regulation ("GDPR") and United Kingdom GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.
We may disclose information in different ways and to different persons as permitted or required by law.
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use authorized third parties to collect information about your use of our Services and other websites and online services over time through cookies, device identifiers, or other tracking technologies. The information collected includes your IP address, web browser, mobile network information, pages viewed, time spent, links clicked, and conversion information. We and our third-party partners use this information to, among other things, analyze and track data, determine the popularity of content, and deliver advertisements targeted to your interests on our Services and other platforms, as well as to provide advertising-related services to us such as reporting, attribution, analytics, and market research.
For more information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://unchained.com/cookies.
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" section in this Notice, in the United States, and other countries.
If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We retain your personal information for as long as necessary to achieve the original purpose(s) for which we collected it and to comply with relevant laws. For example, we may retain certain information for the duration of your relationship with us and for a period of up to 5 years after the relationship ends. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We may also keep your personal data for a longer period if required by law, in connection with an ongoing or potential claim, or for another legitimate legal or regulatory reason.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
Unchained products and services are not intended for minors. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at escalations@unchained.com.
If you would at any time like to review or change the information in your account or terminate your account, or if you have any questions or comments about your privacy rights, you can contact us using the contact information provided below in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.
Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/. For further information, please see our Cookie Notice: https://unchained.com/cookies.
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent. If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications. You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link included within the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing distribution lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
The following table displays the information categories and our collection processes.
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Unchained collects and shares your personal information via the following methods:
More information about our data collection and sharing practices can be found in this privacy notice and our Cookie Notice: https://unchained.com/cookies.
You can opt out from the selling of your personal information by disabling cookies in Cookie Preference Settings and clicking on the Do Not Sell My Personal Information link on our homepage.
You may contact us by email at hello@unchained.com, by calling toll-free at 844-486-2424, or by referring to the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” section at the bottom of this notice .
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf in order to deliver and/or facilitate the delivery of our Services to you. We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered "selling" your personal information.
Unchained has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" in this Notice.
Unchained has sold the following categories of personal information to third parties in the preceding twelve (12) months: The categories of third parties to whom we sold personal information are:
Right to request deletion of the data — Request to delete. You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know. Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to non-discrimination for the exercise of a consumer’s privacy rights. We will not discriminate against you if you exercise your privacy rights.
Upon receiving your request, we will verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of proper verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete any information provided additionally as soon as we finish the verification process.
Other privacy rights:
To exercise these rights, you can contact us by email at escations@unchained.com, by calling toll-free at 844-486-2424, or by referring to the contact details in the “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” section. If you have a question or concern about how we handle your data, we would like to hear from you.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated revision date found at the top of this notice. The updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at hello@unchained.com or by post to:
Unchained Capital, Inc.
PO Box 662
Austin, TX 78767
United States
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit https://unchained.com/ccpa_requests.