Last modified: 9 May 2022
Protecting your data, privacy and personal information is very important to Unibuddy Limited, registered in England and Wales, having its registered office address at 5 New Street Square, London, United Kingdom, EC4A 3TW, and registered in the USA, having its registered office at Corporation Trust Center, 1209 Orange Street, in the City of Wilmington, County of New Castle, Delaware 19801 (“our”, “us” or “we” or “Unibuddy”).
“Ambassador” means a person acting on behalf of a Unibuddy Customer as its representative and interacts with End Users.
“End User” means any individual that has access to or engages with the Unibuddy Platform, including Customer Staff.
“Consumer” means any End User, website visitor or job applicant.
“Controller” has the meaning under the GDPR. Where indicated “Controller” also refers to a “Business” under the CCPA.
“Customer” means an entity that subscribes for a licence to use the Unibuddy Platform.
“Customer Staff” means any employee or authorised representative of the Customer who has access to the Unibuddy Platform.
“Partner” means a third party that hosts the Unibuddy widget on their website or an entity that has an established commercial relationship with Unibuddy
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations (collectively the “Data Protection Laws”).
“Unibuddy Community” means a feature of the Platform that enables End Users, Ambassadors and Customer Staff to engage in communications in an open forum, coordinated by the Customer.
“Unibuddy Events” means a feature of the Platform that enables the Customer to stream video content over the internet to recipients that have a Unibuddy account and the ability to host live streams with or without multiple chat channels, when applicable, stream live events in a conference configuration.
“Unibuddy Events Recording” means a feature of Unibuddy Event that will allow for Customers to record their events livestream and live sessions, and download them to share and reuse as they see fit. For avoidance of doubt, the recording will only contain the presenter/s video and other presentation material when the presenter’s screen is shared.
For the purpose of the General Data Protection Regulation (the “GDPR”) and the California Consumer Privacy Act of 2018 (the “CCPA”):
Platform and Website Users
Where you are using your Unibuddy account or Unibuddy Platform directly, Unibuddy acts as the “Data Controller” of such personal Data (as defined in the GDPR) or “Business” (as defined under the CCPA) and for some of our products, we act as Joint Controller, together with the Customer as described below in the section titled “2.Information we collect about you”.
Where Customers jointly agree with Unibuddy to collect additional Personal Data in the creation of Unibuddy accounts, we may act as a Joint Controller, together with the Customer. Where this applies, this will be specifically agreed with Customers on a case by case basis and made clear to End Users.
Where users are accessing the Platform via the Customer (Ambassadors and other Customer Staff), the Customer acts as the Data Controller. Unibuddy shall process personal information as a Data Processor on behalf of the Customer, who uses our services (see “Information We Receive from Other Sources” below). For all respective occasions above we ensure that we comply with existing Data Protection Laws.
In respect of Personal Data of individuals/consumers collected where you apply for a role at Unibuddy, we will be the Data Controller and certain aspects of this Policy will apply to our processing of your personal information.
Minimum User Age
Our Platform is only intended for use by persons above the age of consent in their respective jurisdiction. End Users are required to submit their date of birth for age verification purposes. Where there is a justifiable reason to use the Platform below the relevant age of consent, parental consent will be required for such use.
How to contact us
Please contact the Controller/Business party in the first instance to address your rights with respect to your data.
1. HOW INFORMATION IS PROVIDED TO US
You will be asked to provide us with your information when you:
- fill in forms on our Website, Platform, or correspond with us by phone, email or otherwise;
- register to use our Platform (creating a Unibuddy account);
- use the Platform;
- report a problem with our Platform; or
- complete any surveys we ask you to fill in (although you do not have to respond to these if you do not want to).
Where you enter any details relating to a Third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.
2. INFORMATION WE COLLECT ABOUT YOU
Unibuddy acting as a Data Controller or Joint Controller
In respect of all End Users, with regard to each of your visits to our Website or use of the Unibuddy Platform, we may automatically collect the following information:
- device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
- technical information about your computer, including where available, your IP address, operating system and browser type, for system administration and analytical purposes; and
- details of your visits to our Website, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs), details of whether you are using the Website or the Unibuddy Platform.
In respect of End Users of the Platform we collect contact information set out below in the table in section 4 (HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE). We work with our Customers to determine what Personal Data we will collect from End Users and how it will be used. We operate as either Data Processors of the Personal Data collected where the Customer is the Data Controller, or as Joint Controllers with our Customers in relation to the Personal Data as described in the next paragraph. For other processing activities and to the extent that we determine how the Personal Data should be used for the purposes set out in section 4, we are the Data Controller of the Personal Data.
In addition, Customers may request and agree with Unibuddy to collect certain additional Personal Data from End Users, in which case Unibuddy acts as a Joint Controller of such Personal Data. Such Personal Data may include but is not limited to:
- Additional contact information such as telephone numbers or addresses;
- IP address;
- Country of origin;
- Field of study;
- Personal interests;
- Education level; or
- Any other relevant Personal Data requested by the Customer;
Unibuddy acting as a Processor
Where Customers provide Personal Data of their Ambassadors and End Users, Unibuddy acts as a Processor of such Personal Data. Such Personal Data may include but is not limited to:
- Contact information such as telephone numbers or addresses;
- IP address;
- Country of origin;
- Field of study;
- Personal interests;
- Education level;
- Any relevant Personal Data collected and provided by the Customer; or
- Any other Personal Data, including conversation data, voluntarily provided by End Users through the use of the Platform services including but not limited to the widget, and Unibuddy Events;
3. INFORMATION WE RECEIVE FROM OTHER SOURCES
When using our Platform, we will be in contact with third parties who may provide us with certain information about you in order to enable your use of the Platform:
- Customers. Unibuddy receives the Personal Data as set out below to enable Customer’s End Users to access the Unibuddy Platform.
- Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Platform, or third parties may help us provide you with customer support. We also use customer experience companies who conduct user interviews, for example, who may share your personal data with us when we want to find out more about your opinion and experience of using our services. You will be notified by those third parties before they share your personal data with us.
- Social networks connected to the services. If you provide your social network account credentials to us via the bio field or otherwise sign in to the Platform through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.
- Partners. If you sign up to access Unibuddy through a third party partner website, Unibuddy and/or our partner may indicate that certain data will be shared with that third party.
4. HOW WE USE YOUR INFORMATION AND JUSTIFICATION OF USE
- Consent: where you have consented to the use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying Us or the Customer);
- Contract performance: where your information is necessary to enter into or perform a contract with you;
- Legal obligation: where we need to use your information to comply with legal obligations;
- Legitimate interests: where we use your information to achieve the University’s legitimate interest and the reasons for using it outweigh any prejudice to your data protection rights; and
- Legal claims: where your information is necessary to defend, prosecute or make a claim against you or a third party.
In respect of the use of the Platform, Unibuddy (whether acting as Controller, Joint Controller or Processor) uses information held about you (and information about others that you have provided us with) in the following ways: