By accessing the Website, you understand and agree that your Personal Data are collected and processed by the Company.
Please read this Policy carefully to understand our policies and practices regarding your Personal Data.
Ubuntu Tribe Website and Application
Privacy Policy
(the “Policy”)
Date of issuance: 22.07.2023
The security and protection of your Personal Data is one of the top priorities of Ubuntu Global Holdings LLC, a company registered in Delaware state in the US, under number 6327402, having its registered office at 8 the green, Suite R, Dover 19901, Delaware, USA (“Company”), and which operates the website hosted at https://utribe.one (“Website”) and the application available or to be available on the Apple App Store and Google Play (“Application”).
The Company collects Personal Data from both and legal who browse the Website (“Visitors” or ”You”).
The Company uses privacy by default standards and undertakes to store such Personal Data in a secured manner and to Process it with all appropriate care and attention in accordance with Data Protection Laws.
Capitalized terms defined in the Terms of Use available at the following URL address [please add the address] apply to this Policy.
1. DEFINITIONS
Consent shall mean any freely given, specific, informed, and unambiguous indication of which the Data Subject, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him/her/it.
Cookie(s) shall mean a piece of information that is placed automatically on your electronic device’s hard drive when
Data Controller(s) shall mean the
For the purpose of this Policy, the Data Controller is the Company.
Data Protection Laws
Data Portability shall mean the right of the Data Subject to receive its Personal Data in a structured, commonly used, and machine-readable format and the right to transmit those Personal Data to another controller without hindrance from the Data Controller.
Data Processor shall mean a
Data Subject(s) shall mean the
Disclosure shall mean making Personal Data accessible, for example by permitting access, transmission, or publication.
EEA shall mean the European Economic Area.
Logs shall mean the log files that record events that occur in connection with any Visitors’ use of the Website and/or Users’ use of the Application. Log files are created when a Visitor views content or otherwise interacts with the Website and Application.
Newsletter shall mean the newsletter of the Company that may be sent to
Personal Data shall mean any type of data and information relating to
Processing shall mean any operation with Personal Data, irrespective of the means applied and the procedure, and in particular
Standard Contractual Clauses shall mean the Standard Contractual Clauses as attached to the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council.
Third-party(-ies) shall mean any
2. SCOPE
The Company provides this Policy to describe its policies and procedures regarding the Processing and Disclosure of Personal Data collected by the Company through the Website and the Application.
This Policy shall apply to any use of the Website and of the Application, whatever the method or medium used.
3. ACCEPTANCE
By browsing the Website and accessing the Application, Visitors acknowledge that:
(i) the Company may collect and process a certain number of Personal Data that relate to them,
(ii) the Company is free to use such Personal Data within the limits provided by law, especially Data Protection Laws and this Policy,
(iii) they have read and understood this Policy,
(iv) they agree to be bound by this Policy, and
(v) they agree to comply with all applicable laws and regulations in respect to matters covered by this Policy.
If You do not agree with the terms of this Policy, please refrain from using the Website and the Application.
1. PRINCIPLES FOR PROCESSING PERSONAL DATA
While Processing Personal Data, the Company will always respect the following general principles:
a. Transparency
The Data subject shall be informed of how his/her Personal Data is Processed.
When the Personal Data is collected, the Data subject shall be informed of:
– the existence of the present Policy;
– the identity of the Data Controller;
– the purpose of Personal Data Processing;
– Third-parties to whom the data might be transmitted
b. Restriction to a specific purpose
Personal Data Processed by the Company shall be adequate and relevant to the purpose for which it was collected. This requires ensuring that the types of Personal Data collected are not excessive but proportionate to the purposes.
c. Fairness and lawfulness
When Processing Personal Data, the individual rights of the Data Subjects shall be protected. Personal Data shall be Processed lawfully, in a fair manner and in good faith.
d. Consent of the Data Subject
Personal Data shall be collected directly from the concerned Data Subject and the Consent of the said Data Subject shall be required before such collection and further Processing
The Consent for the Processing of Personal Data is given or reiterated:
1. each time the Visitor ticks the box in a pop-up window which says, “I have read, understood and hereby agree with the Privacy Policy“”.
2. when the Visitor or the User freely submits Personal Data required to access a specific functionality of the Website or of the Application.
Personal Data can be processed without Consent if it is necessary to enforce a legitimate interest of the Company. Legitimate interests are generally of a legal (e.g., filing, enforcing or defending against legal claims) or financial (e.g. valuation of companies) nature.
The Processing of Personal Data is also permitted if national legislation requests, requires or allows
e. Accuracy
2. COLLECTED DATA
Website
This Policy applies to all Personal Data which is received during your visit to or use of the Website.
When you browse the Website, the Company automatically collects:
– your cookies in accordance with the Cookie Policy to be found at .
–
–
– geolicalization information and information provided by Google Analytics
When you subscribe to the Newsletter, the Company besides collects your name and email address for the sole purpose of sending you the Newsletter. Please note that you are entitled to unsubscribe from the Newsletter whenever you want and at your sole discretion
Application
This Policy applies to all Personal Data which is received during your access and use of the Website and/or Application.
To access the Application, the Company asks you to submit:
– your name and surname
– your email
– the chosen name for the wallet which will be associated with your user account on the Application
– the chosen password
– your cookies in accordance with the Cookie Policy to be found at https://utribe.one/cookie-policy/
– Logs.
– any content you may submit by sending the Company a message.
– geolicalization information and information provided by Google Analytics
–
3. USE OF DATA
Generally, the main reason why the Company collects Personal Data is to enable you to enjoy and easily navigate the Website and Application. Therefore, most of the Personal Data is collected through logs and cookies. It is also used to enable you to securely access the Application and enjoy its functionalities.
Cookies allow the Company to store information on the server (for example language preferences, technical information, click or path information, etc.) to help make the experience better for you and to conduct analysis and performance review.
Furthermore, if you contact the Company via email or post, the Company will keep a record of that correspondence.
4. THIRD PARTY DISCLOSURE
|
Processor |
Processed Data |
Purpose |
|
Sums up |
First name, last name, date of birth, place of birth, address
|
KYC procedure
|
|
Flashy.cash |
Payment card and mobile information |
Processing payments |
|
|
||
|
Google
|
Personal and browser information -Purpose Analytics |
Purpose Analytics |
The Company could further share your Personal Data with other relevant
In any case where a cross-border transfer is done, the Company ensures that an adequate protection is guaranteed for Personal Data to be transferred outside of Switzerland and the EEA by applying the Standard Contractual Clauses as made available by the European Commission and approved for use by the Swiss Data Protection Authority. These Standard Contractual Clauses will ensure an adequate level of protection abroad.
Unless otherwise stated, the
1. STORAGE OF YOUR PERSONAL DATA
You also agree that Processing may lead to your Personal Data being transferred and stored to countries offering a lower level of protection than your country of residence. In any such case, the Company ensures that an adequate protection is guaranteed for Personal Data to be transferred outside of Switzerland and the EEA by applying the Standard Contractual Clauses as made available by the European Commission and approved for use by the Swiss Data Protection Authority. These Standard Contractual Clauses will ensure an adequate level of protection abroad.
2. RETENTION OF YOUR PERSONAL DATA
In accordance with applicable laws, the Company will use your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected or to comply with applicable legal requirements.
3. SECURITY OF YOUR PERSONAL DATA
the Company applies high industry standards and will always apply adequate technical and organizational measures, in accordance with applicable laws to ensure that your data is kept secure.
In the event of a Personal Data breach, the Company shall without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the breach to the competent supervisory authority, unless said breach is unlikely to result in a risk to your rights and freedoms. If the breach is likely to result in a high risk to your rights and freedoms, the Company shall communicate this breach to you, if it is feasible,
4. ACCESS TO YOUR DATA AND INFORMATION RIGHTS
You have the right to request access to
Where provided by law, you, your successors, representatives and/or proxies may (i) request deletion, correction or revision of your Personal Data; (ii) oppose the data Processing; (iii) limit the use and Disclosure of your Personal data; and (iv) revoke Consent to any of our data Processing activities, if the Company is relying on your Consent and does not have another legal basis to continue Processing your data.
These rights can be exercised by contacting us through our contact form or writing to us at
The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such Personal Data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, the Company may charge you a reasonable request fee according to applicable laws.
the Company may refuse, restrict, or defer the provision of Personal Data where it has the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.
5. DATA PORTABILITY
You also have the right to receive your Personal Data, which you have provided to the Company with, in a structured, commonly used, and machine-readable format as to allow you to transmit those data to another Controller without hindrance from the Company.
This right can be exercised by
If the request is submitted by a person other than you, without providing evidence that the request is legitimately made on your behalf, the request will be rejected.
The request is free of charge unless your request is unfounded or excessive (e.g. if you have already requested such Personal Data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, the Company may charge you a reasonable request fee.
The Company may refuse, restrict, or defer the provision of Personal Data for Data Portability purposes where it has the right to do so, for example if fulfilling the request will adversely affect the rights and freedoms of others.
6. PRIVACY BY DESIGN AND BY DEFAULT
The Company will, both at the time of the determination of the means for Processing and at the time of the Processing itself, implement appropriate technical and organizational measures, such as pseudonymization, which are designed to implement data-protection principles, such as data minimization, in an effective manner and to integrate the necessary safeguards into the Processing in order to meet the requirements of the Data Protection Laws and to protect your rights.
The Company will implement appropriate technical and organizational measures for ensuring that, by default, only Personal Data which are necessary for each specific purpose of the Processing are processed. This obligation applies to the amount of your Personal Data We collect, the extent of their Processing, the period of storage and their accessibility. These measures will ensure that by default your Personal Data are not made accessible without your intervention to an indefinite number of third parties.
7. CONTACTING THE COMPANY AND COMPLAINTS
the Company
The Company’s representative for the data protection can be contacted at [email protected]
You have the right to make a complaint if you feel your Personal Data has been mishandled or if the Company has failed to meet your expectations. You are encouraged to contact the Company about any complaints or concerns, but you are entitled to complain directly to the relevant supervisory authority.
8. CHANGES TO THE PRIVACY POLICY
The most current version of this Policy will be made available on the Website.
The Company may modify this Policy from time to time. If a modification reduces your rights, a pop-up window will inform you immediately upon access to the Website, and you will have to accept such changes before further use.
9. DATA CONTROLLER
The Data Controller of the file is the Company.
10. LINKS
The Website may contain links which direct you to
Furthermore, the Data Subject acknowledges and agrees that using some functionalities on the Website could involve the download and use of other applications. Under no circumstances the Company shall be liable for the u
11. JURISDICTION AND GOVERNING LAW
This Policy and any questions relating thereto shall be governed by the laws of Delaware state, in the US, to the exclusion of any rules of conflict resulting from private international law.
Any dispute relating to this Policy shall exclusively be brought before the court having jurisdiction in Delaware.
To ask questions or make comments on this Policy or to make a complaint about our compliance with applicable privacy laws, please contact the Company at its email address: [email protected]
The Company will acknowledge and investigate any complaint pursuant to this Policy.
