Effective Date as of March 2024
This is the Privacy Policy of ULN (hereinafter referred to as "ULN," "we," "us" or "our"). Our Privacy Policy explains how we collect, use, share and protect personal information as well as your related choices regarding use, access, and correction. We process personal data in a manner that is in accordance with the General Data Protection Regulation. We may update this policy from time to time by publishing a new version on our website.
ULN is responsible for the processing of your personal data with respect to the use of our website, purchase of services and/or products and the conclusion of Affiliate agreements (as defined hereafter) as shown in this Privacy Policy.
Contact details:
To exercise your rights or for any questions regarding the use, collection, or processing of your personal information, please contact our Data Protection Officer at privacy@unlimitnetwork.com
We collect the following information you provide us with directly during the order process or registration process:
- Your username, password and e-mail address when you register for an ULN account;
- Your first and last name
- Country of residence
- Date of Birth
- Financial data, including credit card / bank details
- Profile information that you provide for your user profile such as your phone number;
- Personal details you choose to give when corresponding with us by phone, email or other communication methods between you and ULN or otherwise visiting and interacting with our website.
If you register with us as an Affiliate (e.g., as an individual or business entity that enters into an
Affiliate Agreement with us for the promotion and sale of ULN services and/or products and/or opportunities, hereinafter “Affiliate”) we will process the following additional personal data from you:
- business name
- business address
- telephone number
- country of residence,
- IP address,
- one or more of the following: cryptocurrency wallet addresses, company registration number, Personal identity card number, tax identity number, social security number, a scanned copy of your passport, driver’s license or personal identity card.
Your personal data will be processed by us only for the following purposes:
- to communicate with you by email, phone, or other communication methods
- for the provision of our services and products
- for calculations and traceability of your compensation
- for processing (compensation) payments
- bills and other payment-related documentation
- credit control
- for creating and maintaining an account
- the processing and fulfilment of orders
After you place an order on our website you will need to make payment for the services or products you have ordered. To process your payment, you may have to provide financial information such as credit card numbers, expiration dates and security codes. This information is not processed or stored by our service, and it is only sent directly from you to a third-party payment processor over an encrypted connection. Your payment will be processed by payment processor in accordance with their privacy policies. Please see payment processor’s privacy policy for information about how they handle your data.
When you create an Affiliate account, you may be asked to provide your unencrypted wallet public key in order to request payment via cryptocurrency. Under no circumstances do we ever collect an unencrypted private key from you.
If you want to use our services or order a product from us, we ask you to register a personal account. We process your username, password, and email address to register your account. We also store this information so that you can log in easily every time. We display this information in your account so that you can adjust this information yourself. We also use your e-mail address for support, for example if you want to create a new password, we will send you an e-mail with which you can reset your password. If you access certain parts of our website with a password, you are responsible for the confidentiality of this password. We ask you not to share your password with others.
If you have signed up as an Affiliate, we may ask you to validate your identity and address online as part of the “Know Your Customer” (“KYC”) procedure. The images that you make of your passport, driving license or national identity card or other identification documents specific for certain countries as requested and the profile you create are processed for the purpose of validation. The data necessary for validation is abstracted, the images are compared using a combination of “facial biometric system” and where applicable manually by real people. It is only possible to make use of online validation if you give your explicit consent. ULN engages third party service providers for identity verification purposes. For that purpose, the personal data needed for the check (surname, first name, date of birth, address, and copies of your passport, driving license, national identity card and other identification documents) is passed on to the relevant third party. ULN itself does not store, hold, process, or access identity verification information. ULN reserves the right to reject activation of an Affiliate account if the result of identity verification is negative. Your identity verification will be processed in accordance with their privacy policies.
As an Affiliate, you will have access to the ULN web office. In this web office, you will have an overview of the services and products that you have ordered. For this purpose, you will see the following data: your profile information including first name, last name, address, email, phone number, language, date of birth, bitcoin wallet address, passwords, transactions, subscription packages, downloads, promotions, and tickets ordered, order date, payment status.
You can also obtain a team overview in the web office. Here, you will be given information on the Affiliates that you have acquired in your downline. For this purpose, you will see the following
data: username, place of residence and country, number of Affiliates, number volume points acquired by your team members, merchants, career progression rank and position of the Affiliate.
This information is only used for the calculation and traceability of your commission claims.
We may offer you the option to use marketing tools to understand your leads better and to target them appropriately. This Privacy Policy does not apply to the data we process on behalf of an Affiliate in our capacity as a processor. Your use of our marketing tool as an Affiliate will be governed by a Data Processing Agreement. The use of our marketing tool as a contact of an Affiliate, including use of our associated mobile applications (“Mobile Apps”), is covered under the Privacy Policy of such marketing tool.
We may use your information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. We may use email and other communication channels to send you direct messages with personalised advertisements and special offers, such as postal mail, mobile push notifications or social channels.
We do this only if you have explicitly given your consent to us to do so. You may unsubscribe from our advertisements, offers and from e-mails to which you have subscribed at any time by clicking on the unsubscribe link in the e-mail. If you have opted to receive personalised advertisements and offers through mobile push notifications, you can unsubscribe by changing your smartphone settings (for mobile push notifications). Visit the website of your social network provider for more information on how to unsubscribe from receiving personalised advertisements and offers through social channels. You may always contact us to unsubscribe from receiving messages containing advertisements and offers.
Like most websites, we use Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website. Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. We consider Google to be a third- party data processor (see section about “International Transfer” below). Google may also transfer this information to third parties where required to do so by law or where such third parties process this data on Google’s behalf. Google states that it will never associate your IP address with other data held by Google.
GA makes use of cookies, details of which can be found on Google’s developer guides and on our Cookies Policy. You can prevent cookies from being installed by adjusting the settings on your browser software accordingly. You should be aware, however, that by doing so you may not be able to make full use of all the functions of our website.
We collect and store information through the use of “cookies” and other automated means whenever you visit our website. This information may include information such as your computer's Internet Protocol address, browser type, browser version, your login attempts, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics. This enables us to improve our website and deliver a better service to you. We collect your IP address to track technical issues and errors so we can improve our website. We use your IP address and log activities to be able to avoid or eliminate fraudulent use of your account. This way we can see if there is an irregular amount of login attempts on your account to allow us to detect fraud. In such an instance we may request you to verify your identity using your Account Information. We store your IP address and your activities on our website for this purpose in our logs. You may always contact us if you wish to delete this information and/or personal data from our files. Find out more about the cookies we use in our “Cookie Policy”.
We are also active on social media platforms such as Facebook, Twitter, LinkedIn, YouTube, and Instagram. From time to time, we may promote our events, celebrate your achievements, organize contests and other promotions. If you contact us via social media, we process your data in order to reply to questions you may ask via social media, to contact you for congratulatory purposes or when you participate in a contest or promotion on our social media page(s). If you participate in a contest or promotion, we ask for your name (including your social media handles), address and / or e-mail address. We need this information to announce and inform the prize winner(s). We only collect this information with your consent. You will find more details on each contest or promotional activity.
For congratulatory purposes, such as celebrating your achievements or for sending out birthday wishes to you, we may ask for your name, a picture of you, your day of birth and your rank. We only collect and publish this information on our social media accounts with your consent. We may use your personal data for purposes other than those described in this Privacy Policy. We will inform you about those purposes when you register for the service, event, contest, or promotion.
From our social media pages and campaigns, we receive visitor statistics. Although ULN and our social media service provider are responsible for those visitor statistics, the respective social media service provider is your primary point of contact and handles requests to exercise your rights and any complaints you may have. Where necessary, we assist you or the respective social media service provider in responding to your requests or complaints. For more information on the personal data that we receive from social media network providers and how to change your settings, please check the websites and privacy policies of the social media network providers.
We may disclose your data with our parent company and our service providers insofar as reasonably necessary for the performance of the agreement you have concluded with us. Our parent company and all such service providers are governed by this Privacy Policy or are bound by the appropriate confidentiality and data transfer agreements, an oath or legal obligation. We may send your personal information to:
- your sponsor
- your downline
- professional advisors, such as banks, insurance companies, auditors, lawyers, accountants, other professional advisors
- payment services
- platform for identity and address verification
- platform for calculation and tracing compensation
- self-billing platform
- customer care support, including chat and messaging service provider
- email provider
- hosting party
- software suppliers
- telephone provider
- Google Analytics
- Social media platforms
- government agencies
If we sell or otherwise transfer part or the whole of ULN or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information may be among the items sold or transferred. The buyer or transferee will have to honour the commitments we have made in this Privacy Policy.
We may access, preserve, and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. We may also access, preserve, and share information when we have a good faith belief it is necessary to: detect, prevent, and address fraud and other illegal activity; to protect ourselves, you, and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed, and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
ULN has taken appropriate technical and organizational measures to ensure that the regulations and requirements relating to data protection are observed and upheld both by ourselves and by our external service providers. We use the latest technologies to protect your information against loss or unlawful processing. We use safeguards to help keep the information collected through the Service secure; requesting a unique password to verify your identity before granting you access to your account, tracking of user log-in attempts, encryption of sending personal data via our website (SSL) and regularly updating our systems are examples of these measures. If you think that your data is not properly secured or if you have indications that your data is being misused, please send us an email. However, ULN cannot ensure the security of any information you transmit to ULN or guarantee that information on the website may not be accessed, disclosed, altered, or destroyed. We request you to do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and ULN, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.
In principle, your personal data will not be transferred to and maintained on computers located outside the European Economic Area (“EEA”). However, in the case of some of the non-European service providers that we engage, data processing outside the EEA cannot be excluded, for example: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (Analytics).
In order to comply with EU legislation, we carefully consider whether an adequate level of protection can be provided. These service providers are only permitted to use the information insofar as reasonably necessary for the performance of the agreement you have concluded with us. Where necessary, we conclude data transfer agreements with these service providers based on standard contractual clauses established by the European Commission. These service providers may be obliged to provide access to your data based on their applicable laws and regulations. For more information about safeguards for international transfers, please contact us using the contact details provided in this Privacy Policy.
In accordance with the law, ULN does not retain your personal data any longer than is reasonably necessary for attaining the purposes for which they were collected outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. We will retain your personal data as follows:
Type of personal data Retention period
|
Customer data (First name, last name, address, email address, telephone number) |
Up to 5 years after the last transaction due to the statutory limitation period for claims for damages. This information may serve as evidence. |
|
Affiliate data (Company name, name of contact person, business address, business email address, business telephone number) |
Up to 5 years after deactivation of the Affiliate account or termination of the Affiliate agreement, whichever is later, due to the statutory limitation period for claims for damages. This information may serve as evidence. |
|
Account information Customer (username, email address, password) |
As long as your account is active. It will take 30 days for the account to be completely removed from all our systems. |
|
Account information Affiliate (username, email address, password) |
5 years after termination of the Affiliate agreement. Thereafter the account will be anonymised, which will no longer be considered personal information. |
|
Affiliate financial records such as a cryptocurrency wallet address and other payment details you choose to provide |
7 years due to our legal administration obligation. If and to the extent that your public key and other wallet information represents personal data, any personal information stored on the blockchain as part of a transaction will remain there indefinitely due to the nature of blockchain technology. |
|
Correspondence |
Up to 5 years after the last transaction due to the statutory limitation period for claims for damages. This information may serve as evidence. |
|
Marketing communications (email address, WhatsApp number, messenger ID, postal information) |
Until you unsubscribe. If you decide that you no longer wish to receive the marketing communications, we will keep the withdrawal of your request. You may unsubscribe from our advertisements, offers at any time. |
|
Personal data obtained through social media |
If used in connection with each promotional activity, the data will not be provided to third parties and will be destroyed once the promotional activity is no longer valid. If used in connection with congratulatory purposes and publishing on social media account(s),
as long as you ask us to remove the posts, which you can do so at any time. |
Upon expiry of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
If you would like details of the retention periods for a particular aspect of your personal information which is not detailed above, please contact us at privacy@unlimitnetwork.com.
You have the statutory right to know what personal data of yours we have stored and to whom we have disclosed it. You are entitled to request information at no cost about your data at any time and without charge, and to demand its correction, deletion or blocking. You may also revoke your consent to the processing methods at any time with immediate effect for the future.
You can easily access most of your data (including the data provided by you) and rectify/correct such data though your registered account. If you have created an account on our website as a customer, you can delete your account by sending us an email to remove your account.
If you have created an account on our website as an Affiliate, you can send us an email to deactivate your account. Your position within your team will remain visible, but we will anonymise your personal information, in which case it is no longer considered personal information.
If you wish, we can send your personal data to you so that you can transfer it to another party. You can make a request to that effect by sending an email to us. Most likely, in such case we will no longer be able to continue our service as we can no longer guarantee the safeguard of your personal data.
In addition, you can ask us to restrict the processing of your personal data (for example if you deem the information to be incorrect, the processing is unnecessary or the processing is unlawful) or the termination of use of your personal information.
Also, you have the right to not be subject to a decision based solely on automated processing. Remember, you can always object to the processing of your personal data.
We are not responsible for the practices employed by any applications, websites or services linked to or from our website, including the information or content contained within them. Please remember that when you use a link to go from our Service to another application, website or service, our Privacy Policy does not apply to those third-party applications, websites, or services. Your browsing activity and interaction on any third-party application, website, or service, including those that have a link on our website, are subject to that third party's own rules and policies.
We do not intend to address to children (under 13 in the US, under 16 for EU residents, or other age as required by local law) ("Children"). We do not knowingly collect personally identifiable information from Children. If you are a parent or guardian and you are aware that your Children has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under the age of 16 (or the applicable age in their territory) without verification of parental consent, we take steps to remove that information from our servers.
We may modify or update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy of the Service, please send an email to our Data Protection Officer at privacy@unlimitnetwork.com
