Privacy Policy

Last updated: April 1, 2024

At United4Digital Ltd., we prioritize your privacy with the utmost seriousness. We are committed to safeguarding your data across our websites, applications, services, and interactions with you, adhering strictly to this Privacy Policy. We encourage you to carefully review this policy as it contains crucial details about the collection, storage, usage, sharing, and other processing activities of your Personal Information (as defined below). Furthermore, it delineates your rights regarding your Personal Information and offers guidance on how to contact us with any inquiries or concerns you may have.

Key terms

In this Privacy Policy, we define the following key terms:

• United4Digital Ltd., we, us, our: These terms refer to United4Digital Ltd., also known as "United4Digital Ltd.," "we," "us," or "our."
• United4Digital Ltd.: Refers to United4Digital Ltd., including any subsidiary companies owned and controlled by United4Digital Ltd.
• Personal Information: Refers to any information relating to an individual or household (as applicable), from which that individual can be identified, whether directly or indirectly.
• You or Your: Refers to the individual to whom the Personal Information relates.
• Services: This Privacy Policy applies to the United4Digital Ltd. sites directly linking to this Privacy Policy (including associated sub-domains) and related services offered therein. It does not apply to sites and services lacking this Privacy Policy or having their own privacy policies.

Throughout this Privacy Policy, we employ these key terms as defined above.

The personal data we gather about you

The Personal Information we process about you varies depending on how you engage with our Services. For instance:

• Information you provide directly to us:
  • Any details you submit when filling out forms or query fields on our Services, registering for or subscribing to them (such as your name, email address, or relevant demographic data like age).
  • Details included in messages, emails, or other communications exchanged with us when you reach out to us (including your contact information and the content of such communications).
  • Information contained within and linked to any content you post on our Services.
• Information we gather through automated data collection or tracking technologies.

As you utilize our Services, we may employ automated data collection or tracking technologies to gather specific information about your device, browsing behaviour, and usage tendencies, which include:

• Details regarding your utilization of our Services, encompassing traffic data, referral data, location data, logs, communication data, and the resources accessed or retrieved on our websites and applications, along with any advertisements or links to third-party websites accessed, acquired, or considered, along with related metrics.
• Information concerning your computer or other device and internet connection utilized to access or engage with our Services, such as your IP address, operating system, device type, device ID, and browser type.
• Additional data related to electronic network activities, like browsing history, viewing history, search history, and details of interactions with our websites or Services (where applicable).

If applicable, we may also utilize these technologies to gather information about your online activities across various third-party websites or other online services you may utilize (e.g., behavioural tracking).

The information collected automatically is typically in the form of statistical data. However, we may retain or link it with Personal Information collected through other means or received from third parties we collaborate with. This information aids us in enhancing our products and services, including our Services, and in delivering superior, more efficient, and more personalized services to our users over time.

The tracking technologies utilized for this automated data collection may include:

• Cookies (or browser cookies): These are small files stored on your computer's hard drive.
• Flash Cookies: Certain features of our Services may use local stored objects (or "flash cookies") to collect and retain information about your preferences and navigation to, from, and within our Services.
• Web Beacons: Certain parts of our Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs). These enable us to, for instance, count users who have visited pages, track referring sources, monitor and report conversions, and generate other relevant website statistics (such as recording the popularity of specific website content and ensuring system and server integrity).
• Depending on your location when accessing our Services, you have the option to decline the use of these technologies by adjusting the settings on your browser or, if applicable, by withholding consent for their use when accessing our Services. However, if you choose not to consent to the use of such technologies, please be aware that certain parts of our Services may become unavailable or may not operate as intended.

The methods and purposes for which we employ your Personal Information

We utilize your Personal Information solely for the purposes outlined in this Privacy Policy, or for purposes that are compatible with those described herein. If you choose not to provide your Personal Information to us, or if circumstances prevent us from processing your Personal Information, it may result in delays or prevent us from offering certain aspects of our Services to you.

In certain regions, particularly the EEA and the UK, we are legally obliged to establish a lawful basis for the collection and processing of your Personal Information. The following description outlines the purposes for which we utilize your Personal Information and the lawful bases upon which we rely. When depending on our (or a third party's) legitimate interests, we have carefully evaluated that such interests do not supersede your own rights and interests in your Personal Information.

1. Providing our Services to you:

This includes delivering content, advertisements, and personalized recommendations, as well as detecting errors or outages.

Legal Basis: We rely on either your consent (where required by law) or our legitimate interests, such as ensuring user satisfaction and positive return rates.

2. Maintaining records and providing updates:

We keep records of our interactions with you and provide updates or notices about your queries, accounts, or requests.

Legal Basis: Depending on the circumstances, we may rely on fulfilling legal and regulatory obligations or our legitimate interests, such as maintaining and strengthening our relationship with you.

3. Notifying you of changes and providing support:

We inform you of any changes to our Services and offer customer support and responses to inquiries.

Legal Basis: For our legitimate interests, ensuring you are informed about significant changes to our Services and supporting your access to and the quality of our Services provided to you.

4. Serving advertisements:

We may serve advertisements to you on our Services

Legal Basis: We rely on consent (where required by law) or our legitimate interests, such as supporting the provision of free online content.

5. Enforcing legal rights and compliance:

This involves enforcing legal rights, complying with laws, fraud prevention, and defending legal proceedings.

Legal Basis: Depending on the circumstances, we may rely on legal and regulatory obligations or our legitimate interests, such as protecting our business, interests, and rights.

6. Formulating business strategy:

We analyze usage statistics to inform business planning and product development.

Legal Basis: We rely on our legitimate interests, such as improving our Services and the effectiveness of our business strategy.

7. Marketing our Services:

We may market our Services to you.

Legal Basis: We obtain consent from recipients before sending marketing communications, as required by law. Alternatively, we may rely on our legitimate interests, such as promoting our business.

8. Enabling interactive features:

We enable participation in interactive features on our Services.

Legal Basis: For our legitimate interests, providing useful and valuable features to our users ensuring user satisfaction and positive return rates.

9. Processing payments:

We process payments where applicable.

Legal Basis: For our legitimate interests, ensuring remuneration for Services subject to fees.

10. Other communicated purposes:

We may use your Personal Information for any other purposes communicated to you.

Legal Basis: With your consent.

Recipients of Your Personal Information:

Our disclosure of your Personal Information entails engagement with multiple entities, as delineated herein. As mandated by the purposes elucidated above, we may disclose your Personal information to:

• Members of the United4Digital Ltd.;
• Third-party IT vendors (such as hosting, cloud services, networking, cybersecurity platforms, telecom providers, managed services providers, customer service platforms, technical support service providers, and payment processors);
• Third-party media, advertising, and marketing vendors, along with monetization partners;
• Data analytics providers, social media networks, native advertising networks, programmatic advertising platforms, search engines, monetization partners, syndication and distribution partners, customer engagement services, and push notification providers (to offer services including, but not limited to, product recommendations, delivering marketing messages, including advertisements, and sending relevant offers);
• Partners collaborating with us to enhance our Services and/or business processes;
• Third parties with whom we have obtained your explicit consent to share your Personal Information;
• Our external auditors, professional advisors, law enforcement agencies, courts, tribunals, and regulatory bodies to comply with our legal and regulatory obligations;
• Other entities that have or may gain control or ownership of some or all of our business (along with their professional advisers) in connection with significant corporate transactions or restructuring, such as mergers, acquisitions, asset sales, initial public offerings, or in the event of our insolvency—typically, information will be anonymized, although this may not always be feasible. Any recipient of your information will be bound by confidentiality obligations.

Additionally, we may disclose aggregated and deidentified information that does not identify any individual.

Hyperlinks to external websites and content provided by third parties

Our Services may contain links to external websites or content operated by third parties. We do not have control over these third-party sites, services, or content, and we do not assume responsibility for their privacy practices. When you navigate away from our Services by clicking on a link or advertisement, it's essential to review the privacy policy of the respective third-party site or service. Please note that our linking to a website or displaying an advertisement does not imply endorsement, authorization, or affiliation with that third party. Additionally, it does not signify an endorsement of their privacy or information security policies and practices.

Duration your Personal Information will be stored for

We maintain your Personal Information for a duration deemed reasonably necessary to fulfil the purposes for which it was collected. This includes providing requested Services and supporting our business objectives, as outlined in the section and table titled "What We Use Your Personal Information For," as well as described in the subsequent section titled "Business or Commercial Purposes for the Collection and Processing of Personal Information." Consequently, various retention periods apply to different types of data. Upon the conclusion of the relevant retention period, we will either delete or anonymize your Personal Information. However, Personal Information may be retained for extended periods if required to adhere to legal or regulatory obligations, or in connection with legal disputes or claims. Even if a deletion is requested, we may need to retain your information as necessary to comply with legal or regulatory requirements (such as maintaining transaction records), to establish or defend legal claims, and/or to safeguard against fraudulent or abusive activity on our Services.

The Personal Information we have gathered.

In the past 12 months, we may have gathered or handled the following categories of Personal Information:

• Identifiers: This includes details like name, email address, device specifications (such as device type, web browser, operating system), or similar identifying information.
• Unique online identifiers: Examples include IP addresses, device IDs derived from device type, or other comparable identifiers.
• Specific commercial information: This involves details regarding accessed, acquired, or considered Services, advertisement offerings, links to third-party websites, and related metrics.
• Other electronic network activity information: This encompasses browsing history, search history, and information about interactions with our websites or Services.
• Location information: This covers geo-location data about where you access our Services. For instance, if you access our Services on a mobile or tablet device, we may collect information about your device's precise location, to the extent feasible.
• Online viewing activities and habits: This includes details such as videos viewed and pages visited.
• Consumer's precise geolocation (if applicable).
• Certain demographic data: For instance, gender, age, etc., where applicable.

We may have gathered these categories of Personal Information for the following purposes (as well as any other purposes outlined in this Privacy Policy):

• Operating, managing, and maintaining our businesses and infrastructure.
• Providing, developing, improving, repairing, and maintaining our products and Services.
• Conducting services on behalf of our various businesses, such as user retention, providing content recommendations, and processing information.
• Preventing fraud and crime.
• Debugging errors in systems.
• Marketing and advertising.
• Performing accounting, audit, and other internal functions, such as internal investigations.
• Ensuring compliance with laws, legal processes, and internal policies.
• Conducting internal research, analytics, and development, such as user-preference analytics.
• Developing, maintaining, provisioning, or upgrading networks, products, services, or devices.
• Processing payments and verifying transactions where applicable.
• Providing customer support and handling inquiries.

We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about individuals.

Sources of Personal Information:

• Directly from you, including technical and usage information when you use our Services.
• From linked sites, such as social media sites, and other third-party platforms.
• From our various affiliated entities.
• From our joint-ventures and promotional and strategic partners.
• From information suppliers.
• From distributors, service providers, and other vendors.
• From marketing mailing lists.

Retention of Personal Information: Our retention practices are outlined above in the section titled "Duration your Personal Information will be stored for".

Categories of Personal Information we disclose: As detailed in the section titled "Recipients of Your Personal Information", we share your Personal Information with companies such as third-party media and marketing vendors, data analytics providers, social media networks, native advertising networks, programmatic advertising platforms, customer engagement services, push notification providers, and others. This sharing of Personal Information may be considered a "sale" or "sharing" of information under applicable state law. For instance, under California law, a "sale" refers to the disclosure of Personal Information to a third party for monetary consideration or anything of value, and a "share" refers to the disclosure of Personal Information to a third party for cross-context behavioral advertising, regardless of whether monetary or other valuable consideration is involved.

The categories of Personal Information we disclose in this manner include:

• Identifiers, such as email address, device type, web browser, operating system, or similar identifiers.
• Unique and online identifiers, such as IP address, device IDs derived from device type, or similar identifiers.
• Certain commercial information, such as Services accessed, acquired, or considered.
• Internet or other electronic network activity information, such as browsing history, search history, and information regarding interactions with our websites or Services.
• Location information, such as geo-location information about where you access our Services.
• Online viewing activities and habits, such as videos viewed and pages viewed.
• Consumer's precise geolocation, where applicable.

Some of our processing activities may constitute "targeted advertising" as defined in applicable law.

Transfers of data between countries or across international borders.

When we transfer your Personal Information, we ensure it is protected in accordance with relevant data protection laws. For Personal Information originating in the UK or the EEA, these safeguards may include implementing Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum with the recipient. United4Digital Ltd. is obligated to protect Personal Information processed from the UK or the EEA as per applicable European data protection laws. For more details on our international data transfers and the safeguards in place, please reach out to us using the contact information provided in the "How to contact us" section of this Privacy Policy.

Information tailored for individuals located in the European Economic Area (EEA) and the United Kingdom (UK).

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), you may have the following rights regarding the Personal Information we process about you. Please note that these rights are not necessarily absolute, and certain qualifications may apply. If you have questions concerning these rights and how they apply to you, please feel free to contact us.

• Access: You have the right to receive information about the Personal Information we process concerning you and to obtain a copy of your Personal Information.
• Rectification: You have the right to request the correction of any inaccuracies in your Personal Information, where applicable.
• Erasure (Right to be Forgotten): You have the right to request the deletion of your Personal Information in certain situations, such as when we processed the information based on your consent, and you have withdrawn that consent.
• Restriction of Processing: You have the right to request the limitation of processing your Personal Information in certain circumstances, such as when you contest the accuracy of the data.
• Data Portability: You have the right to receive the Personal Information you provided to us in a structured, commonly used, and machine-readable format, and to have that information transmitted to a third party in certain circumstances, where technically feasible.
• Right to Object: You have the right to object to the processing of your Personal Information for direct marketing purposes or in certain other situations, unless there are compelling legitimate grounds for the processing to continue.
• Right Not to be Subject to Automated Individual Decision Making: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Right to Withdraw Consent: If we rely on your consent as the basis for processing your Personal Information, you have the right to withdraw that consent at any time.
• Right to Complain: You have the right to submit a complaint about our processing of your Personal Information to us at any time. You also have the right to lodge a complaint with a data protection supervisory authority.

If you would like to exercise any of the rights mentioned above, please:

• Email us: See below under "How to contact us."
• Provide enough information: to allow us to verify your identity, which may include your name or, where applicable, a customer account number, and any additional identity information we may reasonably request from you.
• Specify the right you want to exercise and the Personal Information: to which your request relates.

Privacy rights and disclosures specific to individual U.S. states.

This section pertains solely to Personal Information collected about consumers residing in the United States. Depending on your state of residence and how you interact with us and our Services, you may have additional disclosures regarding the Personal Information we collect about you, as well as certain rights concerning that Personal Information.

Your U.S. state privacy rights may include (if applicable):

• The right to know what Personal Information we have collected about you, including categories, sources, purposes for collection, sharing, or selling, third-party recipients, and specific pieces of information collected.
• The right to confirm whether we are processing your Personal Information.
• The right to receive a copy of your previously provided Personal Information in a portable and usable format.
• The right to request deletion of Personal Information collected from or about you, subject to exceptions.
• The right to correct inaccurate Personal Information, subject to exceptions.
• The right to opt out of the sale or sharing of your Personal Information, targeted advertising, and profiling that produces significant effects concerning you.
• The right to limit the use or disclosure of sensitive Personal Information.
• The right to withdraw consent for processing sensitive Personal Information, if required.
• The right not to face discriminatory treatment for exercising your privacy rights.

You can contact us with your request through the contact methods described in the "How to contact us" section. We may ask for information to verify your identity to fulfill your privacy rights request. Some states allow consumers to authorize an agent to make requests on their behalf.

You may also have the right to appeal our decisions regarding your request, which can be done through the contact methods provided.

Furthermore, you can request information about our practices related to disclosing your Personal Information to certain third parties for their direct marketing purposes. You may be able to opt out of our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes under certain circumstances.

Your right to opt out of the sale or sharing of Personal Information can be exercised by contacting us through the methods provided or by clicking on the "Do Not Sell or Share My Personal Information" link at the bottom of the page.

However, please note that while you may opt out of the sale or sharing of your Personal Information, your use of our website may still be tracked by us and our vendors or partners for necessary business functions, such as website hosting and fraud prevention. These entities are obligated to keep this information confidential and to use it solely for providing services to our businesses.

Ensuring the security of your Personal Information remains a top priority.

We employ suitable security protocols to prevent unauthorized access to Personal Information. Access to your Personal Information is restricted to individuals with a legitimate business requirement and who are bound by confidentiality obligations. Depending on the risk level associated with processing your personal data, we implement the following security measures:

• Organizational measures, including staff training and policy development.
• Technical measures, such as physical data protection, pseudonymization, and encryption.
• Ensuring ongoing availability, integrity, and accessibility, including appropriate data backups.

Additionally, we have established procedures to address suspected or confirmed data security breaches. We will notify you and relevant regulatory authorities of any data security breaches in accordance with legal requirements.

Individuals under the age of 16

The utilization of our Services is not intended for, nor directed at, individuals under the age of 16. We do not knowingly collect, sell, or share Personal Information from children under 16, nor do we knowingly target our Services to individuals under the age of 16. Individuals under 16 years of age are prohibited from using or providing any Personal Information through our Services. If we become aware that we have collected or received Personal Information from a child under the age of 16, we will promptly delete that information in accordance with applicable law. If you believe we may have collected information from or about a child under the age of 16, please contact us.

Modifications to this Privacy Policy

Our Privacy Policy was last revised on April 1, 2024. We commit to updating any modifications to our Privacy Policy on this page. It is your responsibility to check this Privacy Policy periodically for any changes. Should we make significant alterations to how we handle our users Personal Information, we will notify you through a notice accessible during your use of our Services following the implementation of such changes. Ensuring we possess an up-to-date, active, and deliverable email address for you, where relevant, is your responsibility.

How to contact us

If you have any inquiries regarding this Privacy Policy or the information we may have on record about you, wish to exercise your rights under applicable data protection laws, file a complaint, or seek further information, please do not hesitate to contact us.