Privacy Policy

Effective Date: January 21st, 2022

This Privacy Policy applies to the websites (“Sites”) owned and operated. The provisions herein constitute the regulatory framework of the collection, usage, control and retention of personal information about users (“You”) of the Sites. This Privacy Policy does neither apply to data collected by any other means than accessing and using the Sites nor to data collected by third parties. The use of collected information shall be limited exclusively to the purposes defined under this Privacy Policy.

I. Collected Information

1. Visitor Data

UnlockStone uses cookies and scripts to collect non-personally identifiable information (“Non-PII”) about users of the Sites. These technologies may be used for analyzing trends, administering the Sites, saving user settings, authentication, tracking user behavior around the Sites and gathering general demographic information about the userbase.
You can control the use of cookies at your browser level. If you reject cookies, you may still use the Sites but your ability to use some features or areas of the Sites may be limited. We use Google Analytics to track user activity. If you are located in Europe, your IP address and personal information are neither stored nor shared with third parties.
For more general information or instructions on how to opt-out, please contact our Data Protection Officer at admin@unlockstone.com

2. Payment Data

If you purchase a service on the Sites, UnlockStone may collect the following PII to facilitate invoicing, financial reporting and the payment transaction through a thirdparty payment provider: Billing name, billing address including email address, selected payment method and IP address used for paying. In certain cases, additional data including but not limited to a photo of the payment card used (showing no Card Holder Data (CHD) or Sensitive Authentication Data (SAD) but only the last 4 digits of the card number), may be collected to facilitate transaction risk assessment as instructed by our third-party payment provider.
Any additional data, including but not limited to the full payment card data, is collected solely by the third-party payment provider and subject to their Privacy Policy. UnlockStone does at no point collect or store any Card Holder Data (CHD), Sensitive Authentication Data (SAD) or any other payment card data requiring PCI-DSS compliance.

3. Registration Data (Wholesale/B2B clients only)

Upon registration on the Sites, UnlockStone may, in addition to the information collected about visitors, also collect personally identifiable information (“PII”) about you: Full name/Company name, physical address, phone number, email address and IP address.

II. Use of Information

1. General Use

UnlockStone uses the collected information to operate and maintain the Sites, to interact with its users and to ensure compliance with Know Your Customer (KYC) regulations. The legal basis for this use of personal data is art. 6(1)(f) of the EU General Data Protection Regulation (GDPR).

2. Marketing Communications

UnlockStone may use the collected information to send you promotional emails regarding your previous or current order(s) with UnlockStone and your Wholesale/B2B account (Wholesale/B2B clients only), including but not limited to information about changes in service pricing and availability as well individual service discounts and offers. The legal basis for this use of personal data is art. 6(1)(a) of GDPR. If you no longer wish to receive these emails, you may opt out of them at any point by contacting us at admin@unlockstone.com

III. Information Sharing

1. General

UnlockStone does neither rent nor sell your personal information to third parties. However, UnlockStone may store personal information in locations outside of its direct control, including but not limited to servers or databases located at external hosting providers.

2. Legal Obligations

UnlockStone may disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if UnlockStone reasonably believes that such action is necessary to comply with the law and the reasonable requests of law enforcement, to enforce the Terms of Service or to protect the security or integrity of the Sites and to exercise or protect the rights, property, or personal safety of UnlockStone, its users or others.

3. Change of Control

UnlockStone may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information may be among the items sold or otherwise transferred in these types of transactions. UnlockStone may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified by email of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

4. Testimonials

UnlockStone may display personal testimonials of customers on the Sites in addition to other endorsements. With your consent, UnlockStone may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us at admin@unlockstone.com

IV. Storage and Processing

Your information collected by UnlockStone may be stored and processed in the United States and any other country in which UnlockStone or its subsidiaries, affiliates or service providers maintain facilities. UnlockStone may transfer collected information, including but not limited to PII, to affiliated entities or to other third parties across borders and in-between countries or jurisdictions worldwide.

V. Data Protection

UnlockStone values your privacy and data by ensuring state-of-art data protection technologies and methods to be applied at all stages of collecting, processing and storing your personal data. The Sites are protected by the Secure Sockets Layer (SSL) protocol which encrypts any personal information you enter into registration/login forms before it is sent from your computer to the Sites while all user data are stored on the UnlockStone servers using the latest encryption technologies.
Notwithstanding the aforesaid UnlockStone cannot ensure or warrant the security of any information you transmit to UnlockStone or guarantee that your information on the Sites may not be accessed, disclosed, altered or destroyed by breach of any of UnlockStone’s industry standard physical, technical or managerial safeguards. If you have any questions about security on the Sites, please contact us at admin@unlockstone.com

VI. Compromise of Personal Information

In the event that personal information is compromised as a breach of security, UnlockStone will promptly notify its users in compliance with applicable law.

VII. Your choices about your information

To review, correct, update or delete inaccuracies regarding the information about you that UnlockStone stores, please contact us directly at admin@unlockstone UnlockStone will address your request within seventy-two hours. Data protection law gives you a range of rights in connection with the processing of your personal data:

1. You have the right to request that UnlockStone rectifies or deletes the personal data or restricts the processing of your personal data if you think they are inaccurate.
2. You have the right to object against the processing based on UnlockStone’s legitimate interests as a legal basis. UnlockStone is required to assess and act on your request. Additionally, you also have the right to data portability, if applicable.
3. You have the right to lodge a complaint with your local supervisory authority. If you have any questions about this Privacy Policy or your rights under data protection law, please contact our email: admin@unlockstone.com

VIII. Enforcement and Dispute Resolution

In compliance with the EU-US Privacy Shield principle, UnlockStone commits to resolve complaints about your privacy and the collection or use of your personal information. EU Data Subjects with questions or concerns about the use of their Personal Data should contact us at admin@unlockstone . If your question or concern cannot be satisfied through this process, UnlockStone has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Framework to the BBB EU Privacy Shield, an independent dispute resolution mechanism operated in the United States by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint or if your complaint is not satisfactorily addressed by UnlockStone, EU Individuals and Data Subjects should visit http://bbb.org/EU-privacy-shield/for-eu-consumers/ for more information or to file a complaint. The services of the BBB EU Privacy Shield will be provided at no cost to you.

IX. Retention of Information

1. Visitors

If you are a visitor on the Sites, UnlockStone will retain your information for as long as necessary but for no longer than one year after your last visit to the Sites.

2. Registered Users (Wholesale/B2B clients only)

If you have a wholesale account on the Sites, UnlockStone will retain your information for as long as your account is active or as needed to provide you services. UnlockStone will retain and use your information as necessary to comply with legal obligations, resolve disputes and enforce user agreements.

X. Children’s Privacy

UnlockStone does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that UnlockStone gets to know about the collection of personal information from a child under age 13, UnlockStone will delete that information as quickly as possible. If you believe that UnlockStone might have any information from or about a child under 13, please contact us at admin@unlockstone.com

XI. Notification Procedures

UnlockStone provides notifications, whether such notifications are required by law or are for marketing or other business-related purposes, to you via email as determined by UnlockStone in its sole discretion. UnlockStone reserves the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

XII. External Links

UnlockStone is not responsible for the practices employed by websites or services linked to or from the Sites, including the information or content contained therein. This Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on the Sites, are subject to that third party’s own regulations and policies.

XIII. Social Media

The Sites may use social media features, such as the Facebook Like button and other widgets. These features may collect your IP address and which page you are visiting on the Sites and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Sites. Your interactions with these features are governed by the privacy policy of the organization providing it.

XIV. Changes to the Privacy Policy

All changes to this Privacy Policy are effective when they are posted on this page. If UnlockStone changes the policy in a material manner, UnlockStone will notify its users via email and/or a prominent notice on the Sites, prior to the change becoming effective and update the ‘effective date’ at the top of this page.

XV. Contact

If you have any questions about this Privacy Policy, please contact us at admin@unlockstone.com