Last updated: February 27, 2020
USR (a division of UNICOM Global) and its international subsidiary and branches (referred to herein as USR) are committed to protecting the personal information that you provide to USR, in adherence to Data Protection Legislation (defined below) and best business practice.
This Privacy Notice describes USR’s practices in relation to the use of its websites, web portals and FTP servers (“Websites”) and the related products, applications and services offered by USR. This Privacy Notice sets out how USR uses and protects any personal data that you provide to USR, including personal data provided through its Websites.
USR provides software products and services to its customers and as a result may collect and process personal data about individuals (“Services”).
USR maintains the same practices with data that is collected off-line and this notice may be relied upon with respect to those methods of data collection and use.
USR may modify or update its Privacy Notice at any time without prior notice. You can check the “Last updated” date above to see when the notice was last changed.
If you have any questions regarding your personal data and how USR may use it, including any queries relating to this Privacy Notice, please complete the online form at the bottom of this page (for product compliance inquiries contact email@example.com or visit our Regulatory Compliance and Export Control page), or write to the “Privacy and Risk Management Committee” at UNICOM Systems, Inc., 15535 San Fernando Mission Blvd, Mission Hills, CA 91345, United States or call +1 818.838.0606 and ask to speak with a member of our Privacy team.
It is important that the personal data USR holds about you is accurate and current. Please keep USR informed if your personal data changes during your relationship with USR.
USR’s data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").
For the purpose of Data Protection Legislation:
Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
USR will only collect basic personal data about you, such as your name, email address, business type, work address, job title (“identity data”) and any product/solution interests that you have shared (“preferences data”) and information relating to your use of USR Websites (“usage data”). Unless otherwise agreed with you, this information will not include any special categories of personal information (often known as “sensitive personal data”).
USR uses different methods to collect personal data from and about you including through:
Where USR needs to collect personal data by law, or under the terms of a contract USR has with you (or our customer whom USR acts for) and you fail to provide that data when requested, USR may not be able to perform the contract it has or is trying to enter. In this case, USR may have to cancel the Services but it will notify you (or where appropriate, its customer) if this is the case at the time.
USR will only use your personal data when the law allows it to, i.e. if USR has a legal basis for doing so, as outlined in this Privacy Notice or as notified to you at the time in which USR collects your personal data, and for the purposes for which it was collected for, unless USR reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If USR needs to use your personal data for an unrelated purpose, USR will notify you and will explain the legal basis which allows it to do this. Please note that USR may process your personal data without your knowledge or consent, where this is required or permitted by law.
USR will use your personal data to carry out its contractual obligations and, in addition, to keep you up-to-date with its products and services that you have expressed an interest in. Where USR act as the data controller for customer contact information, it has set out below in the table a description of all the ways it plans to use your personal data, and which of the legal bases USR relies on to do so. USR has also identified what its legitimate interests are, where appropriate.
Note that USR may process your personal data for more than one lawful grounds depending on the specific purpose for which USR is using your data. Please contact USR if you need details about the specific legal ground that it is relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you or the company that you are connected to as a new customer and verify your identity (where required)||Identity / contact data||Performance of a contract Consent (for use of special categories of data, if applicable)|
|To perform credit checks||Identity / contact data||Legitimate interests|
|To process and deliver the Services including:
(a) Manage accounts, payments, fees and charges
(b) Contacting you and corresponding about the Services
|Identity / contact data||Performance of a contract
Necessary for USR’s legitimate interests (to recover debts due to USR)
|To respond to queries and enquiries||Identity / contact data||Legitimate interests|
|To undertake marketing to you||Identity / contact / preferences data||Legitimate interests|
Where USR acts as a data processor of personal data on behalf of its customers, in accordance with USR’s customers’ instructions or in order to comply with a legal or regulatory obligation.
Where USR acts as the data controller for customer contact information, or where permitted by USR’s data controller customers, personal data processed by USR may be shared as follows:
USR requires all third parties to respect the security of your personal data and to treat it in accordance with the law. USR does not allow its third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with USR’s instructions.
USR will not share your information for marketing purposes with third party companies outside of its group of companies.
You can choose to unsubscribe from USR marketing communications at any time using the unsubscribe option on any electronic communication sent from USR. You may continue to receive further communications where a contractual or legitimate interest exists.
USR may use third party companies when processing your personal information. If you would like to find out which third party processors are used by USR, please contact USR as outlined above.
Where USR acts as a data controller, it will not keep your personal information longer than is necessary for the purpose in which it was provided, unless required by law, or for other legitimate reasons that need it to be retained for longer (for example, if necessary for any legal proceedings). Where USR acts as a data processor on behalf of its customers, USR will only hold on to personal data for the period notified to USR by the data controller customer, or for the period required for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.
Under Data Protection Legislation, you have the following rights in certain circumstances:
To exercise any of the above rights please complete the online form at the bottom of this page. (NOTE: this email is for GDPR and Privacy related requests. For product compliance inquiries contact firstname.lastname@example.org)
Where you exercise your right to erasure or where information is deleted in accordance with USR’s retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period USR retains the data.
Where you exercise your right to request access to the information USR processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, USR may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, USR may refuse to comply with your request in these circumstances.
USR will try to respond to all legitimate access requests within one month. Occasionally it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, USR will notify you and keep you updated.
USR Websites are not intended for children and USR will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.
If you have concerns about how USR has handled your personal data, including in relation to any of the rights contained herein, please please complete the online form at the bottom of this page outlining the concerns that you have.
You may also make a complaint to the ICO (the UK supervisory authority). You can find further information about the ICO and their complaints procedure at: https://ico.org.uk/concerns/.
USR Websites may collect your Internet Protocol (IP) address. This information is collected for internal security and system administration purposes. This information may also be used to trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of USR’s Websites.