Legal

Unit.Foundation General Disclaimer, Privacy and AML/KYC Policies

Last updated: Apr 14, 2021

Unit.Foundation’ 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. And even though we would never forward or distribute your personal information outside of our organization, 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 this site indicates your agreement to the updated terms.

1. What Personal Information do we collect and how do we collect it?

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.

2. How and for what purpose do we use Personal Information?

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 manage our relationship with customers, such as communicating with them about our goods and services, providing customer service, and notifying them of changes to our terms or privacy policy

  • To administer and protect our business and services, including troubleshooting, and performing data analysis, testing, system maintenance, support, reporting and hosting of data

  • To detect, prevent, or otherwise address fraud, security or technical issues, including by monitoring and enforcing compliance with our terms of use, appropriate use policies, and privacy policies

  • 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, optimize, and improve our products and services, marketing, customer relationships and experiences

3. What happens with your Personal Information?

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.

If you are a resident of California, our CCPA Privacy Policy applies to you. If you are located in the European Economic Area, the United Kingdom, or Switzerland (collectively “EEA+”), our EEA+ Privacy Policy may apply.

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, Ekaterina Miroshnikova, per email at [email protected]

4. How do we Protect Personal Information?

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.

Unit.Foundation Supplemental CCPA Privacy Policy

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.

If you are a resident of California and not part of our workforce, this Supplemental CCPA Privacy Policy applies to you. However, this Privacy Policy does not reflect our collection, use, or disclosure of California residents’ personal information where an exception under the CCPA applies.

1. Your Personal Information: Right to Know, Request Deletion, and Opt-Out

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 [email protected] 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.

2. Right to non-discrimination for the exercise of Consumer’s Privacy Rights

You have a right not to receive discriminatory treatment based on the exercise of your privacy rights under the CCPA.

3. Right to be Informed of financial incentives

We do not currently offer any financial incentives in exchange for the retention or sale of California residents’ personal information.

4. Authorized Agent

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.

5. What We Collect

We have set out in the Privacy Policy the categories of personal information we have collected about California residents in the past 12 months as well as the sources, business or commercial purposes, and categories of third parties with whom we shared the personal information. We collect this information directly from California residents who use our website or subscribe to our services. We may also collect some information about a California resident’s interests and preferences from a third-party source where they or their organization make such information publicly available, such as on their organization’s public website.

Unit.Foundation Supplemental EEA+ Privacy Notice

If you are located in the European Economic Area, the United Kingdom, or Switzerland (EEA+), and access our website, subscribe for Unit.Foundation services in your personal capacity, or use Unit.Foundation services as an authorized user of an organization that subscribes for Unit.Foundation 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+.

1. Who Is the Data Controller?

The controller of data responsible for collection, processing, and storage of your personal data is Unit.Foundation.

2. Why and how do we process Personal Data?

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.

Purpose of Use or Disclosure

Legal Basis and Legitimate Interest

To manage our relationship with customers, such as communicating with them about our goods and services, providing customer service, and notifying them of changes to our terms or privacy policy

  • If we are legally obligated to respond to your request or inquiry, Legal Obligations Legal Basis. In all other cases, Legitimate Interest Legal Basis, including to maintain the quality of our keep our records updated, and understand how customers use our website so that we can improve them for you and others.

To process and deliver customer orders, and manage payments, fees and charges

  • Contract Performance Legal Basis based on our Terms of Service, Terms of Sale, or other applicable contract.

To administer and protect our business and services, including troubleshooting, and performing data analysis, testing, system maintenance, support, reporting, and hosting of data

  • If the processing is necessary to comply with an applicable contractual obligation with you, Contract Performance Legal Basis per the applicable contract.

  • If the processing is necessary to comply with an applicable legal obligation, such as under data security laws, Legal Obligations Legal Basis.

  • In all other cases, Legitimate Interest Legal Basis, including as necessary to run our business, provide administration and IT services, maintain network security, and prevent fraud.

To understand what may be of interest to a customer, deliver relevant news, offers and other content to a customer, and measure or understand the effectiveness of the content, in accordance with applicable laws

  • We process your personal data and contact you for direct marketing purposes on the Consent Legal Basis as required by applicable law.

  • In all other cases, Legitimate Interests Legal Basis as necessary to understand how customers use our products and services, to develop and improve them for you and others, to remain a competitive business, and to inform our marketing strategy.

To use data analytics to debug, optimize, and improve our products and services, marketing, customer relationships and experiences

  • Legitimate Interests Legal Basis as necessary to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy.

To detect, prevent, or otherwise address fraud, security or technical issues, including by monitoring and enforcing compliance with our terms of use, appropriate use policies, and privacy policies

To comply with legal obligations that apply to us, monitor and ensure compliance with our terms, and defend our legal interests in the event of a potential dispute

  • If necessary to protect vital interests of a natural person, Vital Interests Justification.

  • If necessary to comply with applicable laws, Legal Obligations Legal Basis per applicable laws.

  • In all other applicable cases, Legitimate Interest Legal Basis to prevent fraud, danger or other unlawful conduct, and to defend our legitimate legal interests.

Set any cookie on your device other than a “required cookie”

  • Consent Legal Basis

Disclose your personal data to our service providers (i.e., processors) as necessary to achieve the above purposes

  • The lawful bases listed above apply to any disclosure necessary to further the corresponding purpose.

Disclose your personal data to a prospective or actual purchaser or seller in the context of a merger, acquisition or other reorganization or sale of our business or assets.

  • If the confidential processing of your personal data is necessary for us to evaluate or execute such a transaction while protecting our trade secrets or sensitive business information and your privacy interests to not override such interests, Legitimate Interest Legal Basis based on the pursuit of such legitimate interests.

  • Otherwise, we will obtain your consent and rely on the Consent Legal Basis.

Disclose your personal data to courts, law enforcement or regulatory authorities as permitted or required by applicable law.

  • If necessary to protect vital interests of a natural person, Vital Interests Justification.

  • If necessary to comply with applicable laws, Legal Obligations Legal Basis per applicable laws.

  • In all other applicable cases, Legitimate Interest Legal Basis to prevent fraud, danger or other unlawful conduct, and to defend our legitimate legal interests.

3. How do we protect Personal Data?

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.

4. How long do we store Personal Data?

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.

5. How do we use Cookies?

We use small files known as cookies to collect information about how individuals interact with our online services.

Required Cookies: We use cookies that are strictly necessary to enable users to navigate around our online services and use their features, otherwise known as Required Cookies. Without these cookies, we would not be able to provide a secure log-in, or provide certain other core features of 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.

6. Your Rights

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.

7. Your Choices

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.

8. Contact Us

You may contact us using the following details:

Data Protection Officer Unit.Foundation: Ekaterina Miroshnikova, email address: [email protected]

General Disclaimer

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 pertaining to Unit.Foundation core team or any of its affiliated entities including Unit Technologies.

No document, file or any other content of this website constitutes a legally binding recommendation, advice, invitation or solicitation to create, buy, sell or distribute any amount of the unit tokens. The fact of the presentation of information on this website neither forms the basis of nor is to be relied upon in the course of any investment or contractual decision process.

Any agreement between the token provider and purchaser shall 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 in any form prepared or established by the contractual partner of Unit.Foundation and any file or part of the content of this website, the regulations prepared and attributable to Unit.Foundation shall prevail.

The purchaser bears the legal responsibility to verify his initial eligibility to participate in the sales transaction (as referred to on this website), specifically in case of citizenship or permanent residency in the following countries: USA, China, Singapore, Afghanistan, Iran, Iraq, North Korea, Sudan, South Sudan, Syria, and Yemen.

No regulatory authority has examined or approved of any of the information set

out on this website or in the white paper as presented on this website. All distribution of UNIT tokens, as well as the content of this website, may not be executed in any country where such course of actions may be prohibited or restricted.

There are risks and uncertainties associated with the unit token distribution that should be taken into account, specifically, direct or indirect decline or loss of value.

To the maximum extent permitted by the applicable laws, regulations and rules, the companies pertaining to Unit.Foundation, as well as affiliated entities 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, contractual 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.

Jurisdiction and Law

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.

The Policy of Combatment of AML and Completion of KYC Proceedings

Unit Foundation’ 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.Foundation 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.

The information will be collected, stored, shared, and protected strictly in accordance with the Privacy Policy and related regulations.

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 recognized Sanctions Lists and Politically Exposed Persons (PEP) lists.

For 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.

Copyright Notice

ALL CONTENT CREATED BY THE CONTRIBUTORS OF UNIT.FOUNDATION AND USED IN THE COURSE OF EVENTS, PRESENTATIONS, AND PROJECTS ORGANIZED AND CONDUCTED BY THE CORE TEAM AND COLLABORATORS OF UNIT.FOUNDATION IS PROTECTED BY ALL APPLICABLE COPYRIGHT LEGISLATION AND MAY NOT BE USED OR DISTRIBUTED WITHOUT THE EXPRESS PERMISSION BY UNIT.FOUNDATION.

THE USE OF ALL CONTENT INCL. MARKETING AND TECHNOLOGICAL INFORMATION, AS WELL AS IMAGE, PICTURE, VIDEO AND PHOTO FILES, IS ONLY ALLOWED IN THE COURSE OF COOPERATION BETWEEN UNIT.FOUNDATION AS THE COPYRIGHT OWNER AND THE INDIVIDUAL OR ENTITY WISHING TO USE THE INFORMATION.

IN ADDITION, ALL DATA AND INFORMATION PROVIDED BY THE INDIVIDUALS OR ENTITIES TO UNIT.FOUNDATION INCL. IMAGE, PICTURE, VIDEO, AND PHOTO FILES SHALL BE TREATED AS FREELY ACCESSIBLE AND DISTRIBUTABLE BY UNIT.FOUNDATION UNLESS AGREED OR INDICATED DIFFERENTLY IN THE CONTRACTUAL CONTEXT OF THE PARTIES’ COLLABORATION OR SPECIFICALLY OBJECTED TO BY EITHER PARTY.