Privacy policy

This policy explains how UnityF Limited handles personal information in connection with its services and website. It covers the information we obtain, the reasons we use it, the people and organisations with whom it may be shared, and the choices and rights available to you.

1.1 UnityF Limited, referred to as Unity Finance, is incorporated under the laws of Marshall Islands, with the registration number 127542 and registered office located at Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960.

1.2 Unity Finance, its subsidiaries and its partners together form the “Group”. The Group acts as controller of your personal information and as processor for certain personal data, as described in this policy.

1.3 We collect personal data only for legitimate, relevant purposes and take all feasible steps to keep the information we hold accurate. We use it in accordance with this policy and collect, process, protect and transfer it in accordance with Marshall Islands privacy laws.

2.1 Under the General Data Protection Regulation (GDPR), you have the following rights in relation to your personal data:

• Access and copies: ask what personal information we hold about you and obtain a copy.
• Corrections: ask us to put inaccurate personal information right.
• Erasure: request deletion where the information is no longer needed for the purpose for which it was collected, or where you withdraw consent, where applicable.
• Restricted processing: ask us to limit use of your information in certain circumstances, including while you challenge its accuracy.
• Portability: request transfer of your personal data to another service provider in a structured, commonly used, machine-readable format.
• Objection: object to use of your data for direct marketing or to other processing based on legitimate interests.
• Withdrawal of consent: withdraw consent at any time where we rely on it. Withdrawal does not affect the lawfulness of processing carried out on that basis beforehand.

2.2 You can exercise these rights using the contact details in section 12. We will provide a response within 30 days, as required by law.

2.3 With your explicit consent, we may send promotional offers, information about new features and other communications that may interest you. You can opt out of marketing communications at any time using the contact details in section 12. We also record your marketing preferences to help tailor updates and promotions.

3.1 We obtain information directly from you when you complete website forms or communicate with us by email, telephone or chat. This includes information you choose to provide during those interactions.

3.2 Our website uses cookies and similar technologies to support secure account access, remember your preferences and understand how visitors use our services. We ask for your consent before placing optional cookies. You can accept or reject them through our cookie banner and change your preferences at any time using the Cookie Settings link. You can also delete or block cookies through your browser settings, although blocking essential cookies may affect website functionality.

3.3 We may receive information from payment processors, identity verification providers, credit reference agencies and fraud prevention services.

Customer identity and contact details

4.1 We collect names, addresses, email addresses and telephone numbers. We may also collect dates of birth, gender and country of residence. These details support registration, customer onboarding and communication about your account. We use them to administer the Service, provide account updates and tell you about changes to fees or service terms.

Identity checks and source of funds

4.2 For Know Your Client (KYC) checks, we collect passports, government-issued identification, photographs and documents evidencing the source of funds. We also collect results of KYC and politically exposed person (PEP) screening and information arising during those checks, such as turnover or the nature of a business activity.

4.3 This information enables identity verification and regulatory checks intended to prevent and detect fraud, money laundering, terrorist financing and identity theft, and to meet our related obligations.

Account access and preferences

4.4 Account information includes your password and the marketing preferences you select. We use it and store in readable form to support secure access, account management and interaction with our systems, protect account details, and provide updates and promotions reflecting your preferences.

Payments and customer devices

4.5 Transaction records include payment details, amounts, currencies and timestamps. For devices used to access our services, we collect information such as the operating system, IP address and login times.

4.6 We use these records to provide and improve services, administer our systems, monitor for fraud and adapt the experience to device capabilities. Device information also helps us compare access activity with our records, identify unauthorised logins and strengthen platform security.

Correspondence

4.7 We collect communications with us, including exchanges by email, telephone and social media. We use these records to respond to enquiries, provide customer support and carry out quality assurance.

Website visitors without accounts

4.8 If you browse without an account, we still collect device and usage information. This includes operating system, hardware settings, browser configuration, visit duration, pages clicked and referring URLs.

4.9 We analyse this information to understand traffic and visitor behaviour, identify website problems, support security audits and improve functionality. Usage patterns help us identify busy periods, popular content and areas for improvement, as well as opportunities for new services.

Sensitive information

4.10 Use of our services may reveal sensitive information, including incidentally during KYC checks. We process such information strictly to meet regulatory obligations and handle it with discretion and protection while fulfilling those duties.

Representatives of organisations

4.11 If you act for a corporate customer or supplier, we may collect your name, role, contact details and personal information supplied in correspondence. We use this information to manage professional relationships, communicate with corporate partners, improve our business-to-business services and deliver marketing materials relevant to corporate needs.

Promotions and research

4.12 If you represent an organisation in our promotional or marketing activities, we may collect your name, role, contact details and survey responses. Analysis of this information helps us understand preferences and market trends, refine marketing, improve services and develop new offerings. We may publish anonymised survey findings to share industry insights and develop our brand.

5.1 We process information to operate our services and meet our legal and regulatory responsibilities. These purposes include creating and managing accounts, completing transactions, providing support, verifying identity, preventing illegal activity, protecting the platform, communicating with customers and improving services. Legal compliance may require reporting to regulators, tax authorities and law enforcement.

5.2 The legal basis we rely on depends on the purpose of the processing:

• Contract: information is needed to perform our agreement with you, including enabling access to our services.
• Consent: you have agreed to the processing, for example by opting in to marketing communications.
• Legal obligation: processing is required for duties such as tax reporting, AML controls and KYC checks.
• Legitimate interests: processing supports our business interests, provided your rights and freedoms do not override them. Those interests include fraud detection, security, service improvement and marketing.

6.1 We do not sell, rent or trade your personal data. We may share it with trusted service providers to deliver our services. Those providers are subject to strict confidentiality agreements and may process information only for the purposes we specify.

6.2 Recipients may include:

• Payment processors, to carry out payments and protect financial transactions.
• Identity verification providers, to verify customers under AML and KYC requirements.
• Legal and regulatory authorities, including law enforcement, where disclosure is needed to meet legal obligations or respond to lawful requests.
• Lawyers, auditors, accountants and other professional advisers, where needed for legal or regulatory compliance.

6.3 If a merger, acquisition or asset sale takes place, we may transfer personal information to the acquiring entity, provided it agrees to follow this policy.

7.1 Our international operations may involve transferring your information to, and processing it in, countries outside your jurisdiction. Their data protection standards may differ from those in your home country.

7.2 Where this happens, we will put appropriate safeguards in place, such as standard contractual clauses approved by the European Commission. We take all necessary steps to keep the information secure and ensure it is handled in accordance with this policy throughout the transfer.

8.1 Personal information is retained only as long as needed for the purposes set out here, including any period required by law. The period depends on the category of information and the reason it was collected.

8.2 We keep account information while the account is active and for a period after closure where needed to meet legal obligations or resolve disputes. Transaction records are kept for the legally required period, typically for tax and financial reporting. Communications are retained to maintain customer service records and address potential future disputes. To comply with applicable anti-money laundering laws, Unity Finance retains copies of customer due diligence records and transaction histories for five years after the business relationship ends.

8.3 When the retention period ends, we securely delete the information or anonymise it so that it can no longer be linked to you.

9.1 We use technical and organisational measures to protect personal information from unauthorised access, use, alteration and disclosure. These include:

• Encryption of all sensitive personal data, including financial information, both during transmission and while stored.
• Access limited to authorised personnel who need the information for their duties.
• Regular reviews and audits of security systems to identify weaknesses and check compliance with industry standards.
• An incident response protocol to investigate and contain breaches and notify affected people and relevant authorities where the law requires it.

9.2 Although we take every reasonable protective measure, no system is completely secure. You must safeguard your account credentials, including your password, and notify us immediately if you suspect unauthorised access.

10.1 Our website may link to sites operated by third parties. We are not responsible for their privacy practices. Review their privacy policies before submitting personal information to them.

11.1 We review this policy regularly and may revise it or introduce specific instructions, policies and terms. Updates may reflect changes to our practices, legal requirements or services.

11.2 We will notify you of substantial changes using the contact information you have supplied. Significant changes will also be notified by a website notice or email. Where required by law, we will provide an opportunity to opt out using the method described in that notification.

11.3 Continuing to use our services after a change constitutes acceptance of the updated policy.

If you have any questions about this Privacy Policy, or if you wish to exercise any of your data protection rights, please contact us at:

UnityF Limited

Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960

Registration Number: 127542

Email: support@unityfinance.com