Privacy Policy
Last updated: 11/7/2022
Introduction
Unlimited Industries Associates, Inc. (“UIA,” “we,” or “us”) understands and respects the need for privacy. This Privacy Notice (“Notice”) describes the information that we collect, the purposes for which it is used, and your choices regarding its use. UIA’s services also include financial services, which include, but are not limited to, issuing payment cards to our users. UIA collects user information directly from our users. This Notice applies to UIA's mobile applications and website (collectively “Services”). The Services are offered through one or more third-party companies (collectively “Service Providers”) that we have engaged to render some or all of the Services to you on our behalf. We encourage you to read this Notice in full to understand our privacy practices. If you are a California resident and would like to exercise your California privacy rights, please see our California Consumer Privacy Act (“CCPA”) Notice.
What This Policy Contains
- Information We Collect and Receive From You
- How We Use Information
- How We Share Information
- Your Choices
- Use of Cookies
- “Do-Not-Track” and Targeted Ads
- Accessing, Correcting, and Updating Your Information
- Data Transfers and Storage
- How Long We Retain Information
- How We Protect Your Information
- Information for European Economic Area (“EEA”) Individuals
- The Children’s Online Privacy Protection Act (“COPPA”)
- Third-Party Services, Applications, and Websites
- Changes to This Privacy Notice
- Contact Us
Information We Collect and Receive From You
UIA collects the following information with your consent through a user’s use of our Services. Sometimes, we receive information directly from you, such as name and email address, when you submit a contact form on our website or when users sign up for an account. In other cases, we receive information from our Service Providers, who collect the information from users, for regulatory and compliance purposes.
A. Information You Provide to Us
UIA collects certain information that website visitors provide directly to us. For example, if you contact us for support or to learn more about our Services using our website forms, we collect the following information:
- Contact information – Name, email address, phone number;
- Employment information – Company name, role, and location; and
- Any other personal information you choose to include in your message.
The Know Your Customer (“KYC”) identification process also requires us, or our Service Providers on our behalf, to collect and store the following information from users:
- Account information – Name, date of birth, address, email address, phone number;
- Identity verification information – Social security/tax identification number, driver license details, passport/visa details, national identity cards; and
- Address verification information – Bank statements, and/or utility bills.
Users provide this information either: 1) directly to us, during the registration process for one of our financial services, or 2) to our Service Providers during the User account registration process. We collect and use this information to comply with our legal obligations.
B. Information We Collect Automatically
When you use UIA’s Services, we automatically collect the following information:
- Usage analytics – UIA collects information to improve and optimize our Services, such as browser type, and usage details, such as time, frequency, and use pattern. Sometimes, we analyze information on specific end users such as the time spent on the platform.
- Device information – We also collect device information, like IP address, device type, operating system, manufacturer, model, and model number, push notification tokens, and unique device identifiers.
- Transaction information – UIA collects transaction information when you make purchases using our cards. The information that we collect includes, but is not limited to, the merchant name, the purchase amount, and date of purchase. This information is necessary for business purposes such as providing our services, resolving customer issues, maintaining the security of our Services, and conducting internal research to understand how customers interact with our Services. The information is also necessary to fulfill our financial compliance requirements.
To learn about your information collection choices and to opt-out of data collection, see the Your Choices section below.
C. Information We Receive from Third Parties
UIA also collects information about you from other sources, including:
- Our service providers – UIA receives user information when users apply for financial services provided by us through our Service Providers’ platforms. This helps us provide our financial services in a more efficient manner, for example to issue cards to users without independently integrating with issuing banks, processors, card printing facilities, and cardholder screening and authorization providers. This information is necessary for us to fulfill KYC compliance requirements. For more information on the KYC customer identification process, see the Information We Collect and Receive from You section above.
- Other third-party partners – We receive information from third-party partners to help us enhance our Services with useful information.
How We Use Information
The information that UIA collects is primarily intended to facilitate account access and provide smooth functionality of our Services. We use your information to:
- Communicate with you – UIA may contact you to respond to your inquiries, requests, and/or send important notices either via email, push notifications, in-app notifications, or text messages (SMS). This includes, for example, transaction confirmation, requests for additional information during KYC, and changes to cardholder agreements. See Your Choices section below to learn how to manage your communication preferences.
- Provide and improve our Services – We use collected information to provide and analyze how you use our Services, develop new products and services, and improve functionality, quality, and your experience. This includes using aggregated, anonymized data to improve our Services. For more information, see the definition of usage analytics in the Information We Collect and Receive from You section above.
- Market our Services – UIA may use information that you provide to us through our website contact forms to contact you about new features of our Services, promotional communications, or other UIA news and updates. See Your Choices section below to learn how to manage your communication preferences.
- Fulfill our compliance and legal obligations – UIA stores information about you and your transactions when you use our cards to make purchases, as required by law. For more information, see the definition of transaction information in the Information We Collect and Receive from You section above.
- Store data – We store data on servers hosted by third party providers in the United States. We use appropriate technical, administrative, and physical measures to secure your data during storage.
- Advertising – UIA does not contain or allow in-app advertising. We also do not use push notifications or in-app notifications to display advertisements
- Sale of Information (CCPA) – We do not sell personal information as defined by the CCPA. See more information in our CCPA Notice.
How We Share Information
We share your information with third parties only as needed to deliver our Services (e.g., with our card printing providers to print and ship cards to you). We do not sell information about you to advertisers or other third parties. We share information we collect about you in the ways described below:
- Sharing with third parties – UIA shares information about you with third parties only as described below:
- Consent provided: We do not currently share your information with third parties for marketing, but if that changes, we will obtain your consent first.
- External processing: We provide your information to other third parties to help us with our business activities, products, and Services. These companies may use your information only as necessary to provide these Services or perform them on our behalf. See our sub-processors chart below.
- Mergers and acquisitions: If your personal information is transferred to a party unaffiliated with UIA as part of merger, acquisition, or sale of all or a portion of our assets, we will provide you with notice about UIA’s arrangement with the new entity. Notice will be provided directly through UIA’s website.
- Legal purposes: We disclose your information when disclosure is (1) reasonably necessary to comply with any applicable law, regulation, subpoena, legal process, or enforceable governmental request; (2) necessary to enforce the Notice; (3) required to enforce our Terms and Conditions, including investigation of potential violations; or (4) necessary to protect against harm to the rights, property, or safety of UIA, you, or the public as required or permitted by law.
- Sub-processors – UIA contracts with sub-processors to help with our business operations. We use the following sub-processors to operate our Services. This list was last updated on January 31, 2020.
Third-Party Service or Vendor
Type of Service
Location of Third-Party Service or Vendor
EIG
Email, File Storage
USA
Each third party is responsible for maintaining its own privacy notice and practices related to the use and protection of your information. UIA requires that third-party service providers acting on our behalf or with whom we share your information also provide appropriate security measures under industry standards. However, UIA is not responsible for the privacy and data security practices of third parties outside of personal information we receive from or transfer to them.
Your Choices
Where appropriate or legally required, you will have a choice about how UIA uses your information. You can make a choice about the following categories of information:
- Push notifications – Users can opt-out of receiving push notifications through their devices settings. Opting-out of receiving push notifications may affect how our Services function.
- Mobile application information – Users can stop UIA from collecting information by uninstalling the Client’s mobile app. Users can use the standard uninstall processes available on their mobile device or via the mobile application marketplace or network. Users can also contact the Client to deactivate your account using the email address listed on our Client’s website or mobile application.
- Email – UIA does not currently send marketing emails, but if that changes, we will provide you with the ability to opt-out of receiving marketing emails. UIA sends emails to inform you about changes in our Services and important Services-related notices, such as security and fraud notices.
Use of Cookies
Many sites use “cookies,” which are small text files that reside on your computer to identify you as a unique user. We may use cookies on our Website to allow us to, among other things, measure activity and to personalize your experience. For instance, cookies may enable us to remember your preferences without requiring you to re-type a user name and password. Cookies may also allow us to track your status or progress when requesting products, services, or information. If you choose, you can set your browser to reject cookies or you can manually delete individual cookies or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Website, or that we may put on our Website in the future.
“Do-Not-Track” and Targeted Ads
Our Services do not participate in the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”) programs to opt-out of customized or targeted advertising online because we do not participate in marketing activities. UIA does not respond to web browser “Do-Not-Track” signals. We do not serve targeted advertisements in our Services at this time.
Accessing, Correcting, and Updating Your Information
A. Your Rights
You have certain rights in connection with the personal information UIA obtains about you. For California consumers, please see our CCPA Notice for information about your rights and how to exercise them. For other individuals, depending on your country or state and as required by law, you may have the right to:
- Request access to certain personal information we maintain about you;
- Request that we update, correct, amend, erase or restrict use of certain personal information; and
- Exercise your right to data portability.
Users can update preferences, correct information, or limit the communications received by contacting us using the email listed on our website, mobile application or Terms of Service Agreement. Anyone can submit a request to exercise your data rights by contacting us using the email listed on our website or mobile application or contacting us at the email or address in the Contact Us section.
B. Exercising Your Rights
To help protect your privacy and maintain security, we verify your identity before granting access to your information. We may also decline your access request, but if we do, we will explain our decision. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information that we or our Service Providers are permitted by law to retain. Sometimes you can withdraw consent you previously provided to us or object to the processing of your personal information, and UIA will apply your preferences moving forward. Where our Services are administered for you by an administrator (such as your employer or organization), you may need to first contact your administrator to assist with your requests. For all other requests, contact us using the email listed on our website or mobile application or contact us at the email or address in the Contact Us section to request assistance. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work, or where you feel your rights were infringed.
Data Transfers and Storage
UIA uses our Service Providers in the United States to host the information we collect from you, and we use technical measures to secure your information. We may transfer the personal information we obtain about you to other countries, which may have different data protection laws than the country in which you initially provided the information. To the extent required by applicable law, UIA will take measures to protect the cross-border transfer of your information. If you are located outside the U.S., by submitting personal information to us, you understand this information will be transferred to UIA in the U.S., which may not have equivalent privacy and data protection laws to the country in which you reside. If you do not want your personal information transferred to the U.S., please do not submit any information to us or use our Services. When UIA transfers information about European Union (“EU”) citizens outside the European Economic Area (“EEA”), we make use of European Commission-approved standard contractual data protection clauses or other appropriate legal mechanisms to safeguard the transfer.
How Long We Retain Information
The period for which UIA keeps your information depends on the type of information, as described in further detail below. We will either delete or anonymize your information or, if this is not immediately feasible (for example, the information has been stored in backup archives), then we will securely store your information and isolate it from further use until we can delete your data. These retention periods may change occasionally, depending on our legal and regulatory obligations.
- User information – UIA retains user account information for as long as the account is active and a reasonable period thereafter if the user decides to re-activate our Services. We also retain some of user information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for the improvement and development of our Services, we take steps to eliminate information that directly identifies the user.
- Transaction information – We may store user transaction data for up to 13 months, including the period in which a user can chargeback a transaction. We keep this information in case we need to support a refund request from our Clients.
- Authorization information – We store user “authorization data” including CVV2 and PIN, only until completion of the transaction authorization.
- Contact form information – UIA retains the information you submit to us through our website contact forms as long as needed to respond to your inquiries or requests.
How We Protect Your Information
UIA uses reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. We also require that third-party service providers acting on our behalf or with whom we share your information also provide appropriate security measures under industry standards. Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. For example, the transmission of information over the Internet using personal computers or mobile devices is not completely safe, and therefore, UIA cannot guarantee the security of information submitted to our platform. Any transmission of information is at your own risk. If you have questions about security of our Services, please contact us at the email or address listed in the Contact Us section.
Information for European Economic Area (“EEA”) Individuals
A. Legal Bases for Processing
If you are an individual from the EEA, we collect and process your personal information only where we have legal basis under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your personal information only:
- To fulfill our contractual obligations to you;
- To operate our business, including to improve and develop our Services, for fraud prevention purposes, improve your experience, or other legitimate interest; and/or
- As otherwise in compliance with law.
If you have questions about the legal basis for processing, please refer to the “Rights” section below or contact us at the email or address listed in the Contact Us section.
B. Rights Under EU Laws
Individuals from the EEA have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances as set out below. We also set out how to exercise those rights. We require you to verify your identity before we respond to any of your requests. The following rights are provided to EU citizens:
- Right of Access – You have the right to ask us to access the personal information we hold about you and be provided with certain information about how we use your personal information and who we share it with.
- Right to Rectification – You have the right to ask us to correct your personal information where it is inaccurate or incomplete and we endeavor to do so without undue delay.
- Right to Data Portability – In certain circumstances, you have the right to ask us for a copy of your data in a structured, machine readable format and to ask us to share (port) this information to another entity.
- Right to Erasure – In certain circumstances, you have the right to ask us to delete the personal information we hold about you:
- Where you believe that it is no longer necessary for us to hold your personal information;
- Where we are processing your personal information based on legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing;
- Where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; or
- Where you believe the personal information we hold about you is being unlawfully processed by us.
- Right to Restriction of Processing – In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information:
- Where you believe the personal information that we hold about you is inaccurate and while we verify accuracy;
- Where we want to erase your personal information as the processing is unlawful, but you want us to continue to store it;
- Where we no longer need your personal information for our processing, but you require us to retain the data for the establishment, exercise or defense of legal claims; or
- Where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.
- Right to Object – You can object to our processing of your personal information based on our legitimate interests. We will no longer process your personal information unless we can demonstrate an overriding legitimate ground.
- Objection to Marketing and Profiling – At any time you may object to our processing of personal information about you to send you promotions and special offers and other marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose. However, UIA does not engage in marketing profiling activities at this time.
- Withdrawal of Consent – Where you have provided your consent for us to process your personal information, you can withdraw your consent at any time by contacting us using the email listed on our website or mobile application or by contacting us at the email or address listed in the Contact Us section.
C. Exercising Rights Under EU Laws
To exercise these rights above, please contact us using the email listed on our website or mobile application or contact us at the email or address listed in the Contact Us section. These rights are limited, for example, where fulfilling your request would hurt others or company trade secrets or intellectual property, where there are overriding public interest reasons, or where we are required by law to retain your personal information.
The Children’s Online Privacy Protection Act (“COPPA”)
Our Services are not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13.
Third-Party Services, Applications, and Websites
Certain third-party services, websites, or applications you use, or navigate to and from our Services may have separate terms and privacy policies independent of this Notice. This includes, for example, websites owned and operated by our Service Providers or partners. We are not responsible for the privacy practices of these third-party services or applications. We recommend carefully reviewing the terms and privacy statement of each third-party service, website, and/or application before use.
Changes to This Privacy Notice
We periodically update this Notice to describe new features, products, or services, and how those changes affect our use of your information. If we make material changes to this Notice, we will provide notification through our Services and/or notify you directly. We encourage you to review this Notice for updates each time you use our Services.
Contact Us
If you have questions about this Notice or our information handling practices, please contact us using our contact form. For US mail our address is 318 Riverside Ave., Medford, MA 02155. Our business hours are Monday to Friday noon to 4:00pm.