[3. November 2022]
1. General terms and Data Controller
1.3 Data Controller for the Website and apps is Linkwork (please find contact information in item 6 below)
2. Categories of personal data, that we collect, purpose and legal basis
2.1 When visiting the Website and apps, we collect information about you and your usage of the Website and apps. E.g., when you subscribe to our newsletter, participate in competitions etc. We also collect cookies. You can read more about cookies in the below.
2.2 Use of DNS and VPN services
2.3 When you purchase our DNS or VPN service or use the free trial, we register the following information about you:
When you create an account with us we ask for your email. This is the basis and unique identifier for your account. Based on your consent only, we will also use this email for sending emails about the Unlocator service and marketing offers. If you contact the support team we will also use your email in order to look up your account info and supply you with the best customer support experience possible.
This is optional and is not required for using the Unlocator service. However, if you use the affiliate link in your account and wish to have your commission paid out we will need your full name for accounting purposes.
When creating a paid subscription, we will need your full address in order to create a VAT compliant invoice. We also need the address if you wish to have a payout from the affiliate system.
Credit Card Information
When making a purchase you need to supply your credit card information. This information is not stored by us but by our PCI compliant payment gateways. We don’t have access to the full card information and it never touches our servers.
When signing up and using the Unlocator website and API we will record your IP address. This is vital for providing the Unlocator service. We use the IP both for authentication and support but also to prevent abuse of our service.
When using Unlocator VPN for Android, you can enable the option “Auto-Connect on Untrusted Networks” in the connection settings, to automatically establish a VPN connection when joining untrusted networks. Using the feature requires identification of the connected network name (SSID) through the location data permissions in background, to identify an untrusted network and trigger a connection. The data required to run this feature is not stored by Unlocator nor shared with any third-party, and the use of this connection setting is optional.
We do not store logs on the individual accounts. We keep a log at a personal identifiable level which is automatically purged at a 24 hour interval with no backups. The purpose of this log is to prevent abuse patterns from malicious usage of the service.
Cookies and tracking technologies
2.3.1 The purpose for processing the above listed information is to deliver the service and to fulfill our legal obligations according to our agreement with you, administering your rights. We are also processing the information about your purchase to meet legal requirements including bookkeeping and accounting. The legal basis for the processing of your personal data is based on the agreement with you and legal requirements.
2.2. Use of DNS service – free trial
2.3 When you use our free trial plan, we register e-mail and IP-address, only. Please read more on these types of data in section 2.2.
The purpose is to deliver the service to you. We are also processing the information to meet legal requirements including bookkeeping and accounting. The legal basis for the processing of your personal data is based on the agreement with you and legal requirements.
When the trial period ends, and if you do not decide to convert to a payment plan, we will retain the following information to prevent abuse of the free trial offer. This is in our legitimate interest to avoid abuse of free trial offers by same users.
2.4.1 When you subscribe for our newsletters, we are, with your consent, collecting personal data about your name, e-mail address and IP-address
The purpose is to deliver offers, targeted marketing, information and service e-mails to you. We will use profiling of your information, your purchase history, and relevant cookies, if any, to provide targeted advertising of products etc. of interest to you.
2.5 Contact via web or chat
2.5.1 When you contact us e.g., concerning an order, a request or a complaint, we process your identification information e.g., name, e-mail and other personal data about you, that you provide when you are contacting us. The purpose is customer service, replying inquiries, handling complaints etc. Our legal basis can be in our agreement with you as a customer, our legitimate interest in defending ourselves in case of legal claims and/or legal obligations.
3. Data protection of children
3.1 We are aware of the special need for data protection involving children.
3.2 We do not purposefully collect personal data about children below the age of 18. If you believe, that we may have unknowingly collected personal data about minors, we kindly ask you to contact us with a view to delete this information.
5. With whom do we share your personal data
5.1 Data Controllers
5.1.1 We are transferring your personal data, when necessary to be able to deliver the ordered service to you. These are typically Hosting Providers . In that case, your IP-adress will be transferred to one or more hosting providers handling the communication required to delivery the service.
5.2 Data Processors
5.2.1 We transfer personal data to data processors that are solely processing personal data on our behalf and are not allowed to use this data for their own purposes. We have entered into agreements with all data processors regarding a written data processing agreement and ensured that they are subject to confidentiality.
5.2.2 Data processers can be based in EU/EØS or other countries, provided that we can ensure that your personal data has been given sufficient level of processing security. We use data processors for technical operation and improvement of the Website and apps, distribution of newsletters and targeted marketing, including retargeting and for your review of our company and our services.
For a full list of processors please see our list of sub processors.
6. Your rights as Data Subject
6.1 You have the right to get access to your personal data
6.1.1 You can, at any time, get information about what personal data we are processing about you, from which source the personal data originate and what we use them for etc. You can ask for a copy of this personal data. The access may be limited in consideration of other data subjects’ rights, trade secrets and/or intellectual property protection.
6.1.2 You have, to some extent, the right to get a copy of your personal data delivered as an electronic copy or by transfer to another data controller, when the processing is taking place on the legal basis of a consent or a contract (so-called data portability)
6.2 You have the right to have incorrect personal data corrected or deleted.
6.2.1 If you believe, that the personal data, we are processing about you, is incorrect, you have the right to have it corrected.
6.2.2 You have the right to correct and delete information collected in connection with your sign-up and at your login to your user profile at unlocator.com. Irrespective of such actions, we may process your information in a short period to establishment, exercise or defense against legal claims.
6.2.3 In some cases, we are obliged to delete your personal data, e.g., if you withdraw your consent. If you believe that your personal data is no longer necessary to meet the purpose, we collected them for, you can request to have them deleted. You can also contact us, if you believe, that your personal data is being processed in violation with legislation or other legal obligations.
6.2.4 When you are contacting us with a request to have your personal data corrected or deleted, we look into whether the legal basis has been fulfilled and will in that case update or delete your personal data as soon as possible.
6.3 You have the right to object to our processing of your personal data.
6.3.1 You have the right to object to our processing of your personal data and to block it. You also have the right to object to our processing of your personal data for marketing purposes. If your objection is justified, we will see to it, that we terminate the processing of your personal data
6.4 The right to withdraw your consent
6.4.1 You have the right to withdraw a consent you have given us for any processing of personal data at any time. If you want to withdraw your consent,
6.6 How do you use your rights?
6.6.1 You can use your rights by contacting us at [email protected] .
6.7.1 If you want to complain about our processing of your personal data, you also have the possibility of contacting: Datatilsynet, Borgergade 28, 5., 1300 Copenhagen K. A complaint can be forwarded by e-mail to: [email protected] or by phone to :+45 33 19 32 00.
7. Contact information
7.1 If you have any questions or want to claim your rights, you can contact us on:
Hammerensgade 1, 2
1267 Copenhagen, Denmark
8. Deletion of personal data
8.2 If you withdraw your consent to receive our newsletter, we will register your un-subscription and you will not receive any further communication. We will store information about your un-subscription, as long as such documentation is required by law.
8.3 Information collected in connection with a purchase, you have completed on the Website and apps, will be stored for 5 years to the end of a financial year to meet the requirements of the Danish Law on Bookkeeping.
8.4 Information regarding free trial users will be retained as long as necessary to prevent abuse of free trial offers. This will be up to two years depending on the specific promotional offer.
9.1 We have of course taken technical and organisational measures to avoid that your personal data, by mistake or illegal conduct, is deleted, published, lost, deteriorated or come to the knowledge of third-party, being misused or, in general, processed in a manner against the law.
9.2 Only employees, with a relevant need to have access to your personal data in order to be able to perform their job, will be granted access to your personal data.
10.2 The current policy is available on the Website and apps and relevant services.
10. Governing law and venue