Privacy policy

Effective as of June 20, 2021

This privacy policy is split into 2 sections:

a short summary for humans on key privacy questions
and a longer detailed full privacy policy for nerds 💜

Short Summary

What data DataUnlocker stores

📧 DataUnlocker collects minimally required Personal Data to provide its services: customer's email address, and, if provided by a customer, their Telegram messenger handle, solely for the purpose of communicating with customers and notifying them regarding their service usage.

📈 DataUnlocker additionally uses Google Analytics on dataunlocker.com and admin.dataunlocker.com websites to analyze general behavioral patterns of our customers and to improve our service. DataUnlocker doesn't track its customers individually.

💳 Payments on DataUnlocker are handled completely by Fondy, which is a PCI DSS-compliant payment provider. DataUnlocker does not store any card details on its side, except of a card token to execute recurring transactions, card expiration date and a masked card number. By deleting your card from DataUnlocker, its details (including the card token) is deleted from DataUnlocker's database.

🐾 DataUnlocker stores historical per-customer data related to the service usage, like the history of payments or proxy usage data (number of requests, etc) for particular customer websites. This data is stored for the purpose of being analyzed by customers themselves, and to some extent by DataUnlocker in the aggregated, anonymized form to continue providing and developing its services. DataUnlocker allows users to delete their data (properties) at any time.

🔏 DataUnlocker does not store nor log the proxied data (HTTP requests payload) which goes through its proxy servers. The only exception is last HTTP request per third-party service returning 4xx or 5xx HTTP status, which is stored for debugging purposes - being analyzed by the customer themselves.

Where DataUnlocker's data reside

📦 DataUnlocker stores its data in encrypted, cloud-based storage. This data is currently geographically stored in Netherlands.

🌍 Using DataUnlocker user interface usage generates some usage data which is stored within our third-party providers: Google Analytics (UI usage) and Fondy (the usage of the payment webpage). You can find their respective privacy policies on their websites to understand where they store this usage data.

📧 For any questions you may have, contact [email protected].

Full privacy policy

1. GENERAL INFORMATION

This privacy policy governs your visit and usage of the following websites:

https://dataunlocker.com
https://admin.dataunlocker.com
https://status.dataunlocker.com
The endpoint URL which DataUnlocker asks you to create for Properties

By accessing and using the websites above, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it at any given point in time, you have to stop using DataUnlocker.

2. DEFINITIONS

DataUnlocker Service (DataUnlocker): a proxy service operated by DataUnlocker, intended to proxy a portion of network requests when being used on customer websites.

You (Customer): a physical person, legal entity or both which represent a point of providing DataUnlocker Service and a point of contact between DataUnlocker and websites which use DataUnlocker Service.

Property: a configuration entity for your website you create on DataUnlocker. This typically references a configuration of your website or web application on DataUnlocker which is using DataUnlocker Service.

Personal Data: any personally identified or identifiable data in regards to an individual ("Data Subject"). This includes information you provide or generate when you browse or use either https://dataunlocker.com and all its subdomains. An example of personal data is user's email address.

Service Data: the data collected as a result of using DataUnlocker service by your website or web application. This data is displayed in DataUnlocker's user interface for each Property individually and is also used for billing purposes. For example, it includes the number of proxied requests per unit of time and per third-party service.

Proxied Data: the data which goes through DataUnlocker proxy service (DataUnlocker Service) to third-party servers like Google Analytics servers. Typically, this is the payload of HTTP requests issued by third-party libraries like Google Analytics, gtag.js, Google Tag Manager etc, which is forwarded to DataUnlocker servers via the DataUnlocker's script and later proxied to the original destination. DataUnlocker doesn't store nor log this data.

Third-Party Service: other companies, business or legal entities such as Google Analytics or Fondy.

3. DATA COLLECTED BY DATAUNLOCKER

For various purposes like improving our services and optimizing it DataUnlocker may collect and use the following Personal and Service Data. DataUnlocker values the privacy of our customers, and it collects only minimally required data for operating its services and providing smooth user experience.

This section specifies what data DataUnlocker collects.

3.1. Data you provide to us

DataUnlocker collects the following Personal Data:

Your email address
Optionally, your Telegram messenger handle

Some additional Personal Data may be collected in the process of communicating with [email protected], if voluntarily provided by you.

Additionally, DataUnlocker may collect parts of email communication written by yourself and sent to [email protected] or other text data which can considered as a feedback regarding DataUnlocker Service, or which was generated as a result of using DataUnlocker. For instance, this can be the data entered to a feedback form located at admin.dataunlocker.com/feedback.

3.2. Automatically collected usage data

DataUnlocker uses (a) cookies and (b) local storage to identify client sessions and allow you to log in, configure and operate DataUnlocker Service.

By using and browsing DataUnlocker, you consent to cookies being used according to our privacy policy. If you don't wish to allow cookies, you can opt out from using them. Keep in mind, however, if you opt out of cookies, DataUnlocker may not deliver the desired service for you.

DataUnlocker uses Third-Party Service Google Analytics to measure your use of DataUnlocker website and DataUnlocker's admin console so that DataUnlocker can make further improvements in terms of improving DataUnlocker Service. The data provided to this third party does not include Personal Data, neither the Service Data generated by DataUnlocker Service. The typical data collected is (c) website page visits, (d) link clicks and (e) other interactions with DataUnlocker. If you do not want to share the usage data with Google Analytics, please, opt out from using DataUnlocker.

3.3. Other data which is being collected

DataUnlocker uses Third-Party Service Fondy to accept, process and manage all billing-related activities on DataUnlocker: card payments, automatic purchases, etc. DataUnlocker will redirect you to their website for completing the payment. Fondy may additionally collect Personal Data and usage data according to their privacy policies and terms of use, but only in the limited scope of their own website (when the user is being redirected to the payment page). Fondy only shares the following Personal Data with DataUnlocker: (a) masked credit card number, (b) credit card's expiration data, (c) credit card's issuer (for instance, MasterCard) and (d) other metadata about the transaction. Fondy also provides DataUnlocker with (i) unique credit card token.

4. USAGE OF COLLECTED DATA

For various purposes like improving our services and optimizing it DataUnlocker may process Personal Data, and use aggregated Service Data. DataUnlocker values the privacy of our customers, and it accesses this data only for the purpose of providing DataUnlocker Service and improving it in future.

This section specifies what data DataUnlocker uses and how.

4.1. Communication with you

The primary goal of collecting Personal Data is to be able to contact you. DataUnlocker may reach out to its customers via email from [email protected] email address. Additionally, if you provide us with Telegram messenger handle, DataUnlocker may reach out to you via this messenger.

DataUnlocker may send automatic notification emails and messages in concern to your Properties. DataUnlocker may occasionally send you some informational emails regarding DataUnlocker Service in general.

4.2. Providing a service

Your Personal Data such as email address is used in the system to (a) uniquely identify customers and allow them to share access to their Properties with other DataUnlocker customers.

DataUnlocker uses your saved credit card data (a unique credit card token) to (b) charge your card for using DataUnlocker Service, according to agreed pricing. If you don't want your credit card token to be saved by DataUnlocker, you can stop using DataUnlocker's automatic purchases feature by deleting your saved card in DataUnlocker.

DataUnlocker uses generated Service Data in aggregated (anonymized) form to (c) analyze the service usage and ultimately (d) fix problems related to DataUnlocker Service and (e) develop new features and ship any other improvements which may benefit you and other DataUnlocker's customers.

4.3. Marketing purposes

DataUnlocker may use some collected Service Data for self-promotion purposes, such as advertizing itself on its own website dataunlocker.com or other internet resources. For this purpose, DataUnlocker may never: (a) share your Personal Data or (b) share your Service Data that can be in any way identified as your data or the data belonging to one of your Properties. In other words, DataUnlocker may share only anonymized Service Data, such as (c) a total number of customer registered on DataUnlocker, (d) a total number of traffic proxied by DataUnlocker Service, etc.

DataUnlocker values privacy of their users and never shares your Personal Data with other Third-Party Services, except of:

DataUnlocker shares your email address with Fondy, for the purpose of sending email notifications regarding the incomplete payment or getting the receipt. You can opt out from sharing your email address with Fondy by not entering your email address on the purchase or card authorization screen.

Other Third-Party Services such as Google Analytics cannot access your Personal Data.

DataUnlocker may share your Personal Data internally, for operational or investigation purposes, within its legal entity, which never means sharing it outside of the company (DataUnlocker).

6. DATA RESIDENCY

Your Service Data and Personal Data you provided to DataUnlocker is stored in Netherlands. Note that data protection laws in Netherlands (EU standard) may differ from those in your jurisdiction. DataUnlocker takes all appropriate and reasonably necessary steps to ensure the security of storing your Personal Data, Service Data and any other data you may generate by using DataUnlocker.

DataUnlocker uses Third-Party Service (cloud provider) DigitalOcean to run its proxy service and websites. Neither your Personal Data nor Service Data is shared with this service, but it is stored using DigitalOcean's provided services.

At the moment, DataUnlocker as a company legally resides in Kyiv, Ukraine and is represented by PE Nikita Savchenko. Your Personal or Service Data may also be accessed or processed under this jurisdiction, according to this Privacy Policy.

7. DATA SECURITY

Personal and Service Data is always processed by DataUnlocker in a manner that best ensures its security and prevents it from leaking. DataUnlocker uses end-to-end encrypted networking protocols as well as secure isolated storage, which prevents any third-parties providing network transporting capabilities from accessing this data.

DataUnlocker makes every effort to have reasonable security procedures in place to protect the data loss, misuse or alteration of information which is under our control. If you have any questions about the security of DataUnlocker Service, please reach out to [email protected].

8. DATA RETENTION

DataUnlocker will retain your Personal or Service Data for as long as it is necessary to keep it for the purposes of operating DataUnlocker Service. You may always delete your Personal or Service Data from DataUnlocker yourself, thus shortening the data retention period or completely deleting your data.

9. DATA AND INFORMATION DISCLOSURE

DataUnlocker might be obliged to to disclose your Personal Data and other information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. DataUnlocker will never disclose any personal data or related information with others unless legally required or explicitly permitted by a customer in the written (typed) form.

DataUnlocker complies with GDPR regarding the collection, use, and retention of personal information of DataUnlocker customers.

11. ACCESS TO YOUR PERSONAL DATA

All your personal data is always accessible via https://admin.dataunlocker.com user interface, when you log in with your email address. Additionally, you may contact [email protected] for any data-related questions or concerns.

12. CHANGES TO THIS PRIVACY POLICY

DataUnlocker may update its Privacy Policy from time to time. DataUnlocker will notify you of any changes by posting the new Privacy Policy on this page, or additionally using our Telegram announcements channel.

DataUnlocker will update the effective date at the top of this Privacy Policy, once the policy is updated. You are advised to review this Privacy Policy periodically. Changes to this Privacy Policy are effective, once posted on this page.

In case of significant changes that will affect your rights, DataUnlocker will send you a notification via email or to our Telegram announcements channel. You are responsible for ensuring DataUnlocker has your up-to-date active and healthy email address.

Continued use of DataUnlocker or DataUnlocker Service indicates your acceptance of all changes.

13. CONTACTS

If you have any questions or comments about this Privacy Policy or your Personal Data, please contact DataUnlocker representative via email [email protected].