Last Updated: June 5, 2018
This policy describes the types of information we may collect from you or that you may provide when you apply for a Cryptocurrency Secured Loan and/or access or use the Site or other Unchained Capital Services or other features, functions, services or products, and our practices for collecting, using, maintaining, protecting and disclosing that information.
THIS POLICY APPLIES TO INFORMATION WE COLLECT OR MAY COLLECT:
- In accessing and using the Site.
- In accessing and using the other Unchained Capital Services.
- In registering and creating an account to apply for a Cryptocurrency Secured Loan.
- In applying for a Cryptocurrency Secured Loan.
- In e-mail, text, telegram and other electronic messages sent through or use of the Site and the other Unchained Capital Services.
- In phone conversations that you have with Unchained Capital.
- When you interact with Unchained Capital and the other users of the Site and the other Unchained Capital Services.
- When you send any content through the Site or any of the other Unchained Capital Services.
- Through services provided to us by third-party companies, agents or contractors.
IT DOES NOT APPLY TO INFORMATION COLLECTED BY:
- Us offline or through any other means, including on any other website operated by Unchained Capital or any third party; or
- Any third party, including through any application or content (including advertising) that may be accessible from or on the Site or any of the other Unchained Capital Services.
MINORS UNDER THE AGE OF 18
None of the Unchained Capital Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site or the other Unchained Capital Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through any of the Unchained Capital Services or any of its features or register on the Site use any of the interactive or public comment features of any of the Unchained Capital Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
This section discusses certain rights and information for users located in the EU, particularly those users whose personal information is governed by the European Union’s Regulation EU 2016/679 (General Data Protection Regulation or “GDPR”).
Your rights under GDPR
- Be informed whether we store your data.
- Be granted access to your data (with some caveats or exceptions – see GDPR Article 15 for the precise terms).
- Correct any errors in our records – for instance, update your email address.
- Request that your records be erased.
- Restrict our processing of your data. This means that we will continue to store your data, but will not use it.
- Object to our use of your data.
- Request the data we hold be provided to you or to another service. See GDPR Article 20 for the precise terms.
- Not be subject to decisions based entirely on automated processing.
Exercising some of these rights might interfere with our ability to provide you with our services. In addition, our relationship with you as a borrower or customer, or our obligations to preserve records under KYC, AML or other regulations may prevent us from complying with every request.
To exercise any of these rights, or if you wish to raise a complaint on how we have handled your personal data, please email email@example.com. If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the supervisory authority in the country of your habitual residence, place of work, or the place where you allege an infringement of one or more of your rights has taken place.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect or may collect several types of information from and about Borrowers and other users of the Site and the other Unchained Capital Services, including:
- Information by which you may be personally identified, such as name, business name, e-mail address, mailing address, Telegram ID, phone number, social security number and date of birth (“personal information”);
- Financial information including bank statements, personal and business credit history, bank account information, and tax ID number;
- Information that you provide in connection with any testimonials or other comments that you provide to Unchained Capital regarding the Cryptocurrency Secured Loans or any other Unchained Capital Services or anything else;
- Analytics information;
- Information that is about you but individually does not identify you, such as IP address and date and time of visit;
- Information from your computer, mobile phone and other devices, including IP address, device information including , but not limited to, unique device identifier, device name and type, operating system, location, mobile network information, standard web log information, browser type, language, wireless network, and mobile network information (including the mobile phone number);
- Usage details and information, including how you communicate with Unchained Capital and other users of the Site and the other Unchained Capital Services;
- Location information when you use the Site;
- Information that you provide by registering or creating an account on or through the Site. This includes information provided in connection with applying for a Cryptocurrency Secured Loan;
- When you report a problem with the Site or any of the other Unchained Capital Services;
- Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or
- Details of transactions you carry out through the Site and any of the other Unchained Capital Services.
We collect this information:
- Directly from you when you provide it to us, including when you apply for a Cryptocurrency Secured Loan, in emails or Telegrams that you send to Unchained Capital and phone conversations you have with Unchained Capital.
- Automatically as you navigate through or use the Site and the other Unchained Capital Services.
- From third parties, such as other Users and our customers, business partners and other third parties that provide us or you with certain services.
Certain web transactions may also involve you calling us or our calling you. Please be aware that we may monitor and in some cases record such calls for staff training or quality assurance purposes.
Unchained Capital may now or in the future request or permit the submission of testimonials and other comments (in the form of written comments or voice or video recordings) regarding the Cryptocurrency Secured Loans and the other Unchained Capital Services (collectively, the “Testimonials”). If you submit any Testimonials, Unchained Capital shall own and have the unrestricted right to use any Testimonials (and your name in connection with such Testimonials) without restriction or payment of any kind to you, including the right to display, distribute and otherwise exploit your Testimonial and name for advertising and other purposes. We cannot control the actions of other users who view, download or share any of your Testimonials.
When you apply for a Cryptocurrency Secured Loan, access the Site or use any of the other Unchained Capital Services, we or companies (e.g., Google Analytics) that we work with may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:
- Recognize you as an Unchained Capital user;
- Customize Unchained Capital Services, content, and advertising;
- Measure promotional effectiveness; and
- Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
We use both session and persistent cookies when you access our Site or any other Unchained Capital Services. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
DO NOT TRACK POLICY
Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services.
THIRD-PARTY RESPONSIBILITIES AND SERVICES.
We may use or partner with other third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers”), including, ACH transactions, wire transactions, verification of Borrower’s bank details, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. This may include information we request from credit reporting agencies such as Experian and from other partners, which may include your credit history and credit scores, in order to determine your creditworthiness if you are a borrower, assess risks related to your potential loan, and to assess and report on our loan portfolio. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. Many Services Providers have adopted their own privacy policies, which are not subject to control by Unchained Capital. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information.
The Service Providers may also transmit cookies to your computer or device, when you click on ads that appear on or through the Service. Also, if you click on a link to a third party website, such third party may also transmit cookies to you. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any our Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.
USE OF REMARKETING WITH GOOGLE ANALYTICS
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information:
- To provide you the Cryptocurrency Secured Loans and the other Unchained Capital Services and the content and the other products and services that you request from us.
- To provide the Site and its contents to you.
- To provide the other Unchained Capital Services and customer support you request.
- To process your application and determine whether or not you qualify for a Cryptocurrency Secured Loan.
- To process your Cryptocurrency Secured Loan account, including deducting automatic payments.
- To resolve issues and troubleshoot problems.
- To conduct research and analyses to better understand our customers.
- To register you as a user and identify you when you sign in to your account.
- Prevent and investigate potentially prohibited or illegal activities, and/or violations of the Terms.
- Customize, measure, and improve Unchained Capital Services, including the content on the Site.
- Verify your identity and conduct appropriate diligence by comparing your personal information against third-party databases.
- To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers and events. and providing other news or information about us, our customers and our select partners.
- To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations.
- To fulfill any other purpose for which you provide it
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to the Site and the other Unchained Capital Services.
- To allow you to participate in interactive features on or through any of the Unchained Capital Services.
- To enhance the safety and security of all of the Unchained Capital Services.
- To verify your identity and prevent fraud or other unauthorized or illegal activity.
- To enable marketing, remarketing and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and on-line behavioral advertising regarding our own and third party products and services that we believe may be of interest to you, including advertisement on third party websites.
- To perform targeted and other advertising on third party websites.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Some of the information that we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Site and the other Unchained Capital Services, and to deliver a better and more personalized service, including enabling us to:
- Estimate our audience size and better understand usage patterns.
- Store information about your preferences, enabling us to customize the Site according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Site.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain Unchained Capital Services or features may not be available to you.
We collect the minimum amount of information needed to provide our products and services when we have a lawful basis for it. These lawful bases can include: (a) contract (where it is necessary for the performance of a contact with you (e.g. to deliver the Services you have requested)); (b) consent (where you have given your consent such as through opting in); and (c) our other legitimate interests. When your consent is the basis for us to process your personal information, you may revoke your consent at any time. Where we rely on our legitimate interests, you have a right to object. If you have questions about the lawful bases upon which we collect and process your personal information, please email us at firstname.lastname@example.org.
STORAGE AND TRANSFER OF YOUR INFORMATION
We may store any information that we collect (personal or otherwise) ourselves or in databases owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Site or any of the other Unchained Capital Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Unchained Capital and you. By allowing Unchained Capital to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.
Although users from all over the world may access the Site and the other Unchained Capital Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country. This includes data for our users who reside in the European Economic Area (EEA).
DISCLOSURE OF YOUR INFORMATION
We may use and disclose aggregated information about our users, and information that has been anonymized so that it does not and cannot be used to identify a specific user, without restriction.
- To our subsidiaries and affiliates.
- To other users in your organization in connection with any Cryptocurrency Secured Loans.
- To Service Providers that provide verification services in order to prevent fraud. This allows Unchained Capital to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
- To Service Providers that verify your bank account information
- To other Service Providers, contractors and other third parties we use to support our business, including ACH transactions, wire transactions, verification of a Borrower’s bank details, relationship building, the marketing and growth of our business and the performance of services and technology services. We use commercially reasonable efforts to ensure that our contracts with our Service Providers require them to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
- To Financial institutions with which we partner;
- To a potential or actual buyer. assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Unchained Capital’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Unchained Capital about Borrowers and other users of the Site is among the assets that may be or are actually transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply the Terms and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Unchained Capital, our customers or others.
We will never sell or rent your personal information to third parties.
Except as otherwise provided in this policy, before Unchained Capital shares your information with any third party that is not acting as a Service Provider or an agent or representative to perform services on behalf of and under the instructions of Unchained Capital, Unchained Capital will use commercially reasonable efforts to enter into a written agreement requiring that the third party provide at least the same level of privacy protection as required hereunder.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from Unchained Capital. If you do not wish to have your e-mail address/contact information used by Unchained Capital to promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email. This opt out does not apply to information provided to Unchained Capital as a result of a service or product purchase, warranty registration, product service experience or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: https://www.aboutads.info and https://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at https://preferences-mgr.truste.com.
ACCESSING AND CORRECTING YOUR INFORMATION
You may change, correct or delete most personal information that you have provided to us through your account. Certain information (e.g., social security numbers) can only be changed by contacting us by e-mail at email@example.com. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org or write to us at: Unchained Capital, Inc., P.O. Box 662, Austin, TX 78767.
HOW WE PROTECT AND STORE PERSONAL INFORMATION
We understand that the security of your personal information is important. We take reasonable precautions to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We store and process your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, on our computers in the United States and elsewhere in the world where Unchained Capital facilities or our service providers are located, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. We use computer safeguards such as firewalls and data encryption, enforce physical access controls to our buildings and files, and authorize access to personal information only for those employees who require it to fulfill their job responsibilities. For more information about how we store and process personal and transactional information, please go to https://unchained.com/security.
Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site or the other Unchained Capital Services.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to and use of certain parts of the site and/or the other Unchained Capital Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of any of the Unchained Capital Services.
We store our customers’ personal information securely throughout the life of the customer’s Unchained Capital Account in accordance with this policy. Unchained Capital will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.
© Copyright Unchained Capital, Inc. 2017