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Unit Network Privacy and AML/KYC Combatment Policies
Last updated: November 15, 2022
Our main priority is to make the platform 100% secure and easy to use for all clients and partners.
Our goal is to keep the personal information we receive completely confidential at all times. While we do not forward or distribute your personal information outside of our organisation, we still have to tell you what we collect from you and how we use it. We may update this policy from time to time. Your continued use of all associated Unit Network sites indicates your agreement to the following terms.
We collect specific types of personal information directly from you.
Depending on how you interact with our website and platforms, we may collect the following personal information about you:
- Identity Data, which may include first name, last name, title.
- Contact Data, which may include location address, email address, and phone numbers.
- Profile Data, which may include username and password, purchases or buy/trade orders made by you, customer service requests, your photo, bio, interests, preferences, feedback and survey responses; and preferences in receiving marketing and non-marketing communications from us.
- Information and content, which includes content, communications and other information you provide when you use our platforms, including when you sign up for an account, create or share content, and message or communicate with others.
- Transaction Data, which includes deposit snapshots, account balances, trade history, withdrawals, order activity and distribution history. This transaction data is monitored for suspicious trading activity for user fraud protection, and legal case resolution.
- Website Technical Data, which includes the following information if you use our online platform and services: Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and the ways in which you use or interact with our online platform and services.
- Data from Device Settings, which includes information you allow us to receive through device settings you turn on, such as access to your GPS location, camera or photos.
We only use your personal information for specific business purposes related to the goods and services we provide, e.g.:
- To process and deliver customer orders
- To manage payments, fees and charges
- To administer and protect our business and services, including troubleshooting, and performing data analysis, testing, system maintenance, support, reporting and hosting of data
- To defend our interests in the event of a dispute
- To comply in good faith with applicable laws, legal processes, and lawful government requests
- To understand what may be of interest to a customer
- To deliver relevant news, offers and other content to a customer and measure and understand the effectiveness of the content
- To ask and enable a customer to take a survey
- To use data analytics to debug, optimise, and improve our products and services, marketing, customer relationships and experiences
For the purposes mentioned above, we may share your personal information with the following categories of business partners:
- Our Service Providers: We may share your personal information with our service providers for the purposes we outline above. For example, we may rely on service providers to host and maintain our online services, perform backup and storage services, process payments, transmit communications, and perform analytics services.
- Government Agencies, Regulators and Professional Advisors: Where required by applicable law, we may also need to transfer your personal information to government agencies and regulators (e.g., tax authorities, courts, and government authorities).
We would like to specify that both we and our service providers currently process personal information on servers located in the Republic of Ireland and thus in the EU. We therefore abide by the rules and regulations established by the European Union, specifically, the GDPR. In connection hereto, you as a subject of data processing are entitled to the rights that the GDPR grants every individual located in the EU.
You specifically have legal rights to access, update, review or demand deletion of certain personal information as well as restrict or object to the use thereof. For your security, we may need to request specific information from you to verify your identity.
To review your personal information and/or to exercise your rights in accordance with the GDPR as well as in case of further questions, we encourage you to reach out to our Data Protection Officer, Alex Berstein, per email at: privacy(at)unit.network
We have put in place technological, physical and administrative procedures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information. In case of a suspected breach of personal information, we will notify you and any local regulator without a delay.
As mentioned in our other privacy disclosures, we don’t sell your personal information, but the privacy laws of California, including the California Consumer Protection Act of 2018 (“CCPA”), require us to provide some information about our data processing practices to California residents.
As a California resident, you have the right to request that we disclose what personal information we collect, use, and disclose about you specifically (“right to know”), and the right to ask that it be deleted. To submit a request to exercise the right to know or to delete, please submit a request, with the details you would like to know or delete, by email to privacy@Unit LLC and include “California Request to Know or Delete” in the subject line.
We may need to verify your identity, and/or ask you to confirm your request. If we deny your request, we will explain why.
You also have the right to opt-out of the sale of your personal information by a business. We do not sell personal information, so there is no need to opt-out. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.
You have a right not to receive discriminatory treatment based on the exercise of your privacy rights under the CCPA.
We do not currently offer any financial incentives in exchange for the retention or sale of California residents’ personal information.
You can designate an authorized agent to make a request under the CCPA on your behalf if your authorized agent is a natural person or a business entity registered with the Secretary of State of California, and you sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request under the CCPA, please have the authorized agent take the following steps in addition to the steps described in Section 1 above: (1) Email a notarized copy of your written declaration authorizing the agent to act on your behalf to the address listed below and (2) Provide any information we request from you to verify your identity and that you provided the authorized agent permission to submit a request under the CCPA on your behalf.
If you are located in the European Economic Area, the United Kingdom, or Switzerland (EEA+), and access our website, subscribe for Unit LLC services in your personal capacity, or use Unit LLC services as an authorized user of an organization that subscribes for Unit LLC services, this Supplemental EEA+ Privacy Notice applies to you.
As mentioned in our other privacy disclosures, we don’t sell your personal information, but the data protection laws of the EEA+, including the General Data Protection Regulation (“GDPR”), require us to provide information about our data processing practices to certain people in the EEA+.
The controller of data responsible for collection, processing and storage of your personal data is Unit LLC.
We minimize the amount of data collected from you to the minimum extent required by the business reasons and rely on the following legally defined goals for processing:
- collection of data necessary to perform a contract with you or take steps at your request prior to entering into a contract (“Contract Performance”), to comply with an applicable legal obligation or to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests (“Legitimate Interests”);
- acquisition of your consent (“Consent”); and
- protection of your vital interests or those of another person (“Vital Interests”).
More information is provided below. Please contact us if you need details.
We may transfer your personal data to service providers and business partners outside of the EEA. Some of these recipients are located in countries, for which the European Commission has issued adequacy decisions, in which case, the transfer is recognized as providing an adequate level of data protection under European data protection laws (GDPR Art. 45).
Some recipients of your personal data may be located in countries outside of the EEA for which the European Commission has not issued an adequacy decision in respect of the level of data protection there, e.g. the United States. In such cases, we will enter into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EU and/or 2004/915/EC) as referred to in GDPR Art. 46(5) or other adequate means, and establish that such recipients will provide an adequate level of data protection and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. You may ask for a copy of such appropriate data transfer agreements by contacting us using the contact details below.
We will only store personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may keep your personal data for a longer period of time in the event of a complaint or litigation.
We use small files known as cookies to collect information about how individuals interact with our online services.
Functional Cookies: We use “functional cookies” to enhance users’ experience on our online services and for internal operational purposes, including to collect aggregated information about how users of our website interact with it, and remember choices they make while using our website.
You can delete, restrict and block cookies from being set on your device via the settings of your browser. To do so, please refer to the Help function within your browser or visit www.allaboutcookies.org, a website that contains a large amount of comprehensive information on how to disable cookies on a wide variety of desktop browsers.
Regarding your personal data, you have the right to:
- Request access (commonly known as a "data subject access request") - enables you to receive a copy of the personal data we hold about you and information about how it is processed.
- Request correction - enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure - enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
- Object to processing - where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
- Request restriction of processing - enables you to ask us to suspend the processing of your personal data if, (i) you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
To exercise these rights, please contact us using the details below.
You are not required to provide personal data to us but if you do not provide any personal data to us, you may not be able to use our website or we may not be able to authenticate and assist you with your orders, inquiries or requests, and we generally will not be able to provide you with our products and services.
You may contact us using the following details:
Data Protection Officer Unit LLC: Alexander Berstein, email address: privacy(at)unit.network
No content of this document, nor any link is a public offer of a security or any other financial instrument in relation with any company including the Unit team or any of its associated companies including (without excluding any other) Unit Technologies.
This white paper or any other associated content does not constitute any advice to buy, sell, or any solicitation of any offer by the provider of the UNIT tokens (the "token provider") to purchase any UNIT tokens nor shall it or any part of it.
The fact of its presentation does not form the basis nor is to be relied upon in connection with any contract or investment decision.
The sale and transfer of the UNIT tokens will be performed by the Unit team. The proceeds of sale of the UNIT tokens will be deployed to fund the herein described cryptocurrency projects, businesses and operations.
No person is bound to enter into any contract or binding legal commitment in relation to the sale and purchase of the UNIT tokens. Any agreement as between the token provider and yourself as a purchaser and in relation to any sale and purchase of UNIT tokens (as referred to in the white paper or this website) is to be governed solely by a separate set of documents setting out the terms and conditions of such agreement. In the event of any inconsistencies between the Terms and Conditions and the content of this website or the white paper, the Terms and Conditions shall prevail. You are not eligible to purchase any UNIT tokens in the Initial Sale Offer (as referred to on this website or in the white paper) if you are a citizen, resident (tax or otherwise) or green card holder of the USA, China, Singapore, Iran, North Korea or Syria.
No regulatory authority has examined or approved of any of the information set out on this website or in the white paper. No such action has been or will be taken under the laws, regulatory requirements or rules of any jurisdiction. The publication, distribution or dissemination of any content of this website, the white paper or any linked content does not imply that the applicable laws, regulatory requirements or rules of a specific country have been complied with.
The sale of UNIT, website or white paper, any part thereof and any copy thereof must not be taken or transmitted to any country where distribution or dissemination of the white paper is prohibited or restricted. There are risks and uncertainties associated with the UNIT token sale that should be taken into account. The companies of the Unit team and/or the token provider and their respective businesses and operations, the UNIT tokens, the initial sale of Unit including the loss of value of the issued token which can result in a complete loss of value.
To the maximum extent permitted by the applicable laws, regulations and rules, the companies of Unit and/or the token provider as operator of this website shall not be liable for any indirect, special, incidental, consequential or other losses of any kind, contract or otherwise (including but not limited to loss of revenue, income or profits, and loss of use or data), arising out of or in connection with any acceptance of or reliance of the pre-sale, initial token sale or the white paper or any part thereof by you.
Any claim or legal conflict arising from the sale of UNIT tokens, this white paper or any associated material or link included or information offered or given access through this website or any associated material shall be governed by the laws of Singapore and the courts of Singapore shall have the sole and exclusive jurisdiction.
Unit Networks’ Anti-Money Laundering and Know Your Customer Policy (hereinafter - the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of our company being involved in any kind of illegal activity.
Both international and local regulations require us to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from our clients and partners.
AML/KYC Policy covers the following matters:
- Verification procedures
- Sanctions and PEP lists screening
- Monitoring Transactions
and consists of the following steps:
- Collecting Users’ identification information
- Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations
- Monitoring transactions and investigating any significant deviations from normal activity
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs
- Updating risk assessment regularly
- Providing law enforcement with information as required under the applicable laws and regulations.
One of the international standards for preventing illegal activity is customer due diligence. Unit LLC establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
Our identity verification procedure may require the individual to provide reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes we reserve the right to collect your identification information and to take steps to confirm the authenticity of documents and information reserving the right to investigate certain Users who have been determined to be risky or suspicious.
In addition, we reserve the right to request up-to-date documents, even though they have passed identity verification in the past.
Once your identity has been verified, we will be able to avoid situations where our services are used to conduct illegal activities, which is why the KYC process is essential for our cooperation model.
In line with the international requirements, we have adopted a risk-based approach to combating money laundering and terrorist financing ensuring measures to prevent or mitigate money laundering and terrorist financing in relation to the identified risks.
Hereby, we screen against recognised Sanctions Lists and Politically Exposed Persons (PEP) lists.
For the screening purposes, we may - among other sources - use our service providers data integrated into the proprietary software.
We also would like to emphasize that in case of possible suspicions of any illegal activities, we are entitled to terminate your account and all business transactions in connection hereto as well as to interact with law enforcement organizations reporting any kind of violations of the applicable legal regulations.
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