Unplugged ("Unplugged" or "We") is committed to maintaining the privacy of its users ("you" or "user"). The following information describes how Unplugged collects and processes information about you when you use our website (the “Website”) and Services (as defined below).
What information we collect and why we collect it
How we use that information
Your rights with regard to the collection of such information
Unplugged provides various solutions designed to enhance the privacy and security of the Personal Information (as defined below) of its users. Such solutions include (the “Services”):
The UP Phone; a mobile smartphone, designed to prevent user tracking with enhanced security;
The UP Store; an alternative application store from which you can download the UP App Suite (UP Messenger, UP VPN and UP Antivirus) as well as other applications developed by third-parties.
The UP Messenger; a secure messaging platform that enables end-to-end encrypted communication services. This also includes the Messenger Web which enables access to the UP Messenger from a browser.
UP VPN; which offers IP masking via VPN locations.
UP Antivirus; an antivirus that scans your device for viruses and malicious files
The Website provides information on Unplugged and the Services and enables it users to contact Unplugged, with respect to the Website and Services.
Information from which you can be personally identified may also be processed by Unplugged, including but not limited to your name, email address, phone number and the IP through which you used the Website or Services (hereinafter: “Personal Information”). Unplugged shall only collect or receive access to your Personal Information for the provision of the Services and Website, via the methods detailed below:
1. Registration Details
In order for you to register to use the Services, we will process details that are required to identify you. Such details include your username, first name, last name, email address, phone number and registration IP.
2. UP Messenger Data Processing
Unplugged may receive certain access to data processed via the UP Messenger which integrates text, audio and video conversations. The below information describes Unplugged’s data processing practices with respect to the UP Messenger:
2.1 Private Conversational Data
When creating a chat with one or more users, the chat will be end-to-end encrypted by default which means that we or anyone else who is not a member of the chat cannot read any of its content. The encryption key is automatically generated by your Device. Keys can be backed up on a file which will be stored on your Device or on our servers under encryption with a key based on a phrase of your choice. If you lose the security phrase or the backup file, you will not be able to decrypt the historical data.
If the conversation was chosen by the user to be generated via a Private Conversation Room, the data shall be encrypted between every two users. This means that neither we nor anyone else (who is not a member of the chat room and participates in the relevant chat) can read the message.
2.2 Public Conversational Data
2.3 Video and Audio Calls
The UP Messenger enables to communicate via audio and video calls. These types of communications are peer-to-peer calls which are not recorded or stored anywhere. Our servers are establishing the secured connection between the parties ensuring the communication between Devices is encrypted. Please note that We do not have access to the encryption keys.
The Services also include the following data processing practices:
3. VPN Data Processing
When you activate your VPN, our servers can receive access to the username that generated the session and your IP. This enables us to verify your identity and establish the communication. After your connection terminates, this data is vanished and we do not keep logs of your sessions or websites you visited.
4. Antivirus Data Processing
The Antivirus is not sending any information to our servers so we are not exposed to any scans you perform nor their results.
5. Support and Contact Us
Support may be provided through the Website, email or in-app chat feature. We may request and record your registered details to identify you for providing support. Our support agents may also ask for additional information as deemed necessary to assist you with technical problems resolution. The details of a technical issue may be saved for the purpose of Service improvement. We will never save Private Conversational Data or other Personal Information except as provided above.
6. Financial Data
When you decide to use our Services, we may request your payment information. We use third parties for payment processing (e.g. Stripe) to assure that any payment information you provide will be secured according to the highest data security standard. Your payment with Stripe is subject to Stripe’s End User Terms of Service which are hereby incorporated by reference.
Use of Information
We use Personal Information we collect from you for a range of different business purposes according to different legal bases of processing. We may use or process your Personal Information for the following purposes. One or more purposes may apply simultaneously.
Providing the Requested Services
We collect your registration details as described above to enable you to register to use the Services.
We process Personal Information provided by you when using the UP Messenger and UP VPN solely as stipulated in the UP Messenger and UP VPN Data Processing sections above.
We will collect the Personal Information submitted by you when you contact us for support to facilitate your inquiry when you choose to contact us via the Website.
Such collection of information will enable us to provide you with technical and professional assistance, with regard to the Website and Service.
We process this information for the performance of the contract we have or may have with you.
2. Improvement and Development of the Services
We collect Personal Information to improve and develop our Website and understand feedback on Unplugged’s Services and to help provide more information on the use of Services quickly and easily.
We collect Personal Information for ongoing review and improvement of the information provided on our Website to ensure it is user friendly.
We collect Personal Information to improve the management and administration of our business and maintain compliancy with our internal policies and procedures.
We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve our Services, develop new features, and conduct audits and troubleshooting activities.
We process this information in light of our legitimate interest in improving the Website and Services, to allow our users to have the best experience.
3. Maintain a Safe and Secure Environment
We may use your information to detect and prevent fraud, abuse and security incidents and to enhance the safety and security of our Website and Services.
We process this information in light of our legitimate interest in improving our Website and Services by enabling our users to browse in a secure environment.
Disclosure of Information and Transfer of Data
In order to perform our contractual and other legal responsibilities or purposes, we may, from time to time, need to share your Personal Information with third parties. We may as well share your Personal Information with our affiliates, subsidiaries or any third party service providers and individuals to facilitate our Website and Services or any portion thereof, such as storage, data management or maintenance services. We may also share your information with analytics service providers for analytics services. Such analytics service providers set their own cookies or other identifiers on your computer, through which they can collect information about your usage of our Website and Services. This helps us compile aggregated statistics about the effectiveness of our Website and Services.
We may also transfer your information, including Personal Information, in connection with a corporate merger, consolidation, the sale of related assets or corporate division or other fundamental corporate changes. Furthermore, information about you may also be released in order to comply with any valid legal obligation or inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information in special cases, such as if you use the Website or Services to perform an unlawful act or omission or take any act or omission that may damage Unplugged, its property and goodwill, or if there is an attempted breach of the security of the Website or Services or a physical or property threat to you or others. You have the right to file a complaint any relevant supervisory authority according to the location in which you are situated.
You have the right at any time to request to access or modify your information. To exercise these options, please contact us at email@example.com or via the Contact Us form on our Website.
In some jurisdictions, in particular those located within the European Union (the “EU”) or within the European Economic Area (the “EEA”), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:
Request a rectification of your Personal Information where the information we hold about you is incorrect or incomplete.
Object to the processing of your Personal Information for direct marketing purposes.
Object to the processing of your Personal Information where our legal basis for that processing is that such processing is necessary for our legitimate interests.
Object to an automated decision-making (including profiling) in certain circumstances.
Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it;
Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us, which we process by automated means, where our processing is either based on your consent or is necessary for the performance of a contract with you.
Generally, with regard to information collected on our Website and Services, Unplugged is a “Data Controller”. Therefore, if you wish to exercise the above-mentioned rights, please contact us, and we will make our best efforts to fulfill your request.
If you wish to file a request regarding any of the above, you may contact us at: firstname.lastname@example.org or via the Contact Us form on our Website.
We may use “cookies” and/or other technologies or files and similar technologies to automatically collect information (collectively, “cookies”) and identify how visitors make use of the Website and Services. This aggregated tracking information may be used to help us improve and enhance the Website and Service experience for all of our users. In addition, cookies are used for adjusting the Website and Services to your personal preferences. Cookies contain information such as the pages you visited, the length of time you stayed on the Website and Services, the location from which you accessed the Website and Services and more.
Opt In or Opt Out
You are always in control of your data, and if you choose to receive information from us, or others, you can change your mind later. If, at any time, you would like to stop receiving such information or opt out of a feature, you may notify us by writing to email@example.com or via the Contact Us forms on our Website. You should be aware, however, that it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request.
Links to Other Websites
We deploy industry standard measures to ensure the security, confidentiality, integrity and availability of the Personal Information we process. We maintain physical, technical and administrative safeguards, and test and update these periodically. We endeavor to restrict access to Personal Information on a ’need to know’ basis for the provision of Website and Services to you. No such measures are perfect or impenetrable. In the event of a security breach, we will take all reasonable action to minimize any harm. Although we will do our best to protect Personal Information, we cannot guarantee the security of data transmitted to our Website and Services and transmission is at the users own risk.
Generally, Unplugged does not retain information longer than necessary to provide its Website and Services and for its reasonable business and lawful needs. If you withdraw your consent to us processing your Personal Information, we will erase your Personal Information from our systems, unless the Personal Information is required for Unplugged to establish, exercise or defend against legal claims or it is necessary for the performance of the requested Services.
The Website and Services are not intended for children under the age of 16. We do not, knowingly or intentionally, collect information about children who are under 16 years of age.
IF YOU ARE UNDER THE AGE OF 16 YOU MAY NOT USE THE WEBSITE AND SERVICES, UNLESS PARENTAL CONSENT IS PROVIDED ACCORDINGLY
This page was updated on May 24, 2022.