Online Cookies Notice

UNBLU INC.

Date: 22.05.2025  

Version 2.0    

Unblu Inc. with registered address at Gartenstrasse 143, 4052 Basel, Switzerland and its Affiliates (“Unblu”) are committed to ensure compliance with applicable data protection laws and regulations of Switzerland and the European Union, as well as other data protection requirement in any of the jurisdiction where Unblu operates including certain US jurisdictions and Canada. This Privacy Notice is based, among others on the principles and requirements of the European Union General Data Protection Regulation (“GDPR”), and other applicable national data protection laws, including Swiss New Federal Act on Data Protection (“nFADP”). By means of this Privacy Notice, Unblu informs the users (“You”, ‘’Your’’) of its website such as www.unblu.com (hereinafter the “Website”) about how and why Unblu collects, processes and uses Your personal data, and about Your privacy rights.

For the purposes of this Privacy Notice, Unblu is the Data Controller. For any requests regarding this Privacy Notice or the processing of Your personal data, please feel free to reach out to dpo@unblu.com.

Categories of personal data, purposes, legal bases for processing and data retention

Unblu process the following categories of personal data, for the purposes and due to the legal bases indicated below. Please note that not all the below information may be deemed personal data in your jurisdiction in all cases.

Unblu does not not use Your e-mail addresses and/or identification information to send commercial or marketing messages unless consent or an option to opt-out is provided.

If Your e-mail addresses and/or identification information change, the e-mail addresses and/or identification information may be corrected, updated, or deleted via a respective section of the Website or by contacting Unblu.

To know how Unblu process Your personal data through the use of cookies and similar technologies, see Section 5 (Cookies) below. For more information about the cookies Unblu uses, please take a look at the related settings page.

Security

Your personal data may be processed by both automated and non-automated means and may be stored at Unblu’s premises and on Unblu’s service providers’ servers. Unblu adopts technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, Unblu may also adopt data encryption using secure socket layer technology (SSL) and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and You should not provide any personal data if You want to avoid any sort of risks.

Sharing with Third Parties

Unblu may disseminate or disclose Your personal information to the following categories of recipients:

• Entities that undertake activities pertinent to Unblu’s business operations as outsourced data processors appointed in writing in accordance with data protection laws, or operating as independent data controllers (such as IT or storage service providers, suppliers of marketing services, and advertising networks and platforms);
• Public, judicial, or law enforcement authorities, within the limits established by applicable laws; and
• In the event of extraordinary corporate transactions or operations (e.g., bankruptcy, mergers and acquisitions, reorganizations, sale of businesses or assets, and in connection with due diligence related to such transactions) Your personal data may constitute part of the assets being transferred to a new proprietor.

Transfer of Your Personal Data to Third Countries or International Organizations

Unblu may need to transfer Your personal data outside the European Economic Area (EEA) and Switzerland, including the United States which may have different data protection laws than the country in which the information was provided. In the event where transfer to third countries or international organization becomes necessary, Unblu will take measures to protect that information including, as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses pursuant to article 46 of the General Data Protection Regulation (GDPR) or by putting in place other appropriate data transfer mechanism(s).  

Cookies

Cookies are small files downloaded to Your device when You visit the Website. They help recognize Your device during future visits, making the platform more user-friendly. Unblu use both first-party and third-party cookies, with most information being pseudonymized or anonymized. Your personal data is only processed with Your consent or when necessary for certain services.

Technical cookies

Technical cookies are essential for the correct functioning of the Website and to provide the service offered to and requested by You. For example, technical cookies can be used to monitor sessions, to store specific server access information related to the user configuration, to facilitate the use of online content, or to keep track of items in a shopping cart or information used to fill in a form. Technical cookies include the functional cookies You might find mentioned while browsing the Website.

The legal basis for the processing of these cookies is Unblu’s legitimate interest pursuant to Art. 6(1)(f) GDPR. The basis for Unblu’s legitimate interest is to guarantee the security and functionality of the Website.

Technical cookies do not need your consent.

Analytics cookies

Analytics cookies may be used to evaluate and improve the design of the Website or to help measure its traffic.

In other words, analytics cookies may be used to track the traffic and performance of the Website, by collecting aggregate data on the number of visitors and how they interact with the Website to improve its services. For example, analytics cookies may collect information about how You and other visitors access the Website, including the overall number of visitors, possibly grouped by geographical area, time slot, how long You stay on the Website for, what parts and number of pages of the Website You visit or other characteristics, including who viewed a particular section.

Unblu uses analytics tools to help its marketing team understand the Website performance. If the data is anonymized and does not identify You personally, Unblu may use these tools without Your prior consent. However, You can manage your cookie preferences at any time through the cookie settings on the Website.

Profiling cookies

Profiling cookies may be used to trace specific actions or recurring behavioral patterns in the use of the offered functionalities back to specific, identified or identifiable individuals for the purpose     of grouping the different profiles within homogeneous, multi-sized clusters. This is aimed in turn to enable Unblu to provide increasingly customized services beyond what is strictly necessary for the delivery of its Website service and also send targeted advertising messages in line with the preferences expressed by You during Your web-browsing activities. For example, profiling cookies can be used to create Your profile and offer content in line with Your interests, or to send targeted ads or messages. Profiling cookies include the performance, marketing and social media cookies You might find mentioned while browsing the Website. Profiling cookies need your explicit consent pursuant to Art. 6(1)(a) GDPR and Art. 22 GDPR.

Cookie settings

Most browsers automatically accept all cookies; however, You can decide for yourself whether or not we or external third parties can store cookies on Your device.

Consent Manager

When You visit the Website, a so-called Consent Manager opens up in a pop-up window. You can select in this Consent Manager which category of cookies you wish to accept. You can change your selection at any time by clicking on the link « Save Settings » at the bottom of the platform. Changing the settings does not automatically lead to the deletion of the cookies. To do this, follow the instructions below.

Browser settings

You can change Your browser settings at any time so that no more cookies are accepted or stored. You can also decide to have a warning message displayed each time before You accept cookies. Or You can set your browser only to accept cookies from specific websites. You can also delete cookies that were stored previously. If You delete all cookies, the so-called opt-out cookies, which are intended for the rejection of cookies, will also be deleted from Your device. On your next visit to the Website, the Consent Manager may then be displayed again. Therefore, You may also need to reset the rejections. Below You will find a general guide to managing cookies for the most common browsers:

• Google Chrome 
• Microsoft Internet Explorer
• Mozilla Firefox
• Apple Safari

Please note that with the links above You are visiting external websites that may not follow the same privacy, security or accessibility policies.

Links to Third Party external websites

The Website may contain links to third party external websites of interest. In case such links are followed and thereby the Website is left, please note that Unblu does not have any control over such third-party websites. Therefore, Unblu is not responsible for the protection and privacy of any information provided whilst visiting such third-party websites and such third-party websites are not governed by this Privacy Notice. The Website may include social media features and widgets which may collect users’ IP addresses and information about visited websites, and which may set cookies. It is to note that such features and widgets are either hosted by the third party or hosted directly by Unblu. Your interactions with these features are governed by the privacy policy of the third company providing it.

Amendments

Unblu may amend this Privacy Notice from time to time wherein in such a case the revised Privacy Notice will be posted on the Website. Such amendment of this Privacy Notice may result in using private information for new, unanticipated uses not previously disclosed in this Privacy Notice. Please periodically check the latest version of this Privacy Notice on the Website.

Your Rights

You have several rights over Your personal data and how it is used. These rights are summarized below. In order to assert any of these rights You may contact Unblu directly at the following email address: legal@unblu.com 

Unblu must respond to any of the below requests referring to Your rights under Articles 15 to 22 GDPR within one (1) month. This period can extend by two (2) months if needed, considering the complexity and number of requests. Unblu must inform You of any extension and its reasons within the first month.  

Right to access Your Personal Data  

You have the right to request a confirmation as to whether or not Unblu processes Your personal data. If Unblu processes Your personal data, You have the right to request access to the personal data and to obtain information regarding the purpose of the processing; the categories of personal data concerned; who else outside Unblu might have received the data; any available information what the source of the data was, if You did not provide it directly to Unblu; the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period. You may also request a copy of the personal data undergoing processing. If Unblu considers Your access request to be manifestly unfounded or excessive, it can either request a reasonable fee to deal with the request or refuse to deal with the request at all. In either case, it needs to justify its decision to You.  

Right to rectify Your Personal Data  

You have the right to obtain from Unblu without undue delay the rectification, e.g. correction of the record of Your personal data processed by Unblu, in the case it is inaccurate or incorrect or to have incomplete personal data completed, including by means of providing a supplementary statement.  

Right to erase Your Personal Data  

You have the right to request erasure of Your personal data if Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; if you have withdrawn Your consent; if You have objected to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing or You have objected to the processing pursuant to Article 21(2) GDPR; Your personal data have been unlawfully processed; Your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Unblu is subject. However, there may be reasons and legal grounds for keeping Your personal data despite Your request, e.g. if Unblu needs Your personal data to fulfill legal obligations, i.e. record keeping obligations by Union or Member State law to which Unblu is subject, for reasons of public interest in the area of public health, or for the establishment, exercise or defence of legal claims e.g., when Unblu handles an ongoing complaint. If Unblu needs to continue to process Your personal data, Unblu will tell You why Unblu needs to do so when responding to Your request.  

RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA  

You have the right to object to the processing of Your personal data on grounds relating to Your particular situation and circumstances if the processing of Your personal data is based on Article 6 (1)(e) or (f) GDPR, unless Unblu is able to demonstrate compelling legitimate grounds for the processing which override Your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to restrict the processing of Your Personal Data  

You have the right to restrict the processing of Your personal data. This means that You can limit the way Unblu processes and use Your personal data in the following cases: the accuracy of Your personal data is contested by You, for a period enabling Unblu to verify the accuracy of Your personal data; the processing is unlawful and You oppose the erasure of Your personal data and request the restriction of their use instead; Unblu no longer needs Your personal data for the purposes of the processing, but You require them for the establishment, exercise or defence of legal claims; You have objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of Unblu override Yours. In case a restriction of Your personal data is performed, such personal data shall, with the exception of storage, only be processed with Your consent or for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.  

Right to withdraw consent to process Your Personal Data  

Where consent is the legal basis for the processing of Your personal data, You have the right to withdraw Your consent at any time. However, withdrawal of consent takes effect for the future only.  

Right to portability of your Personal Data  

You have the right to request Unblu to move, transfer or copy Your personal data You have provided to Unblu so that You can use the personal data in a different service or with a different provider. You can request to receive a copy of the personal data in a commonly used and machine-readable format, so You can store it for further personal use. You can also request that Unblu transmits it directly to another organization.  

However, the right to data portability may be subject to limitations due to the technical feasibility of a transmission. The right to data portability does not create an obligation for Unblu to adopt or maintain processing systems which are technically compatible with those of other organizations.  

Right to lodge a complaint with the Data Protection Authority  

You have the right to lodge a complaint with the relevant Data Protection Authority if You believe that Unblu has not handled Your personal data correctly and lawfully or if You believe that Unblu has not dealt appropriately with Your requests.  

The relevant Data Protection Authority where the complaint should be made is the one that is competent for the place of Your habitual residence or place of work, or the one that has jurisdiction over the place where the alleged infringement has occurred. When You have lodged a complaint, the Data Protection Authority will inform You of the progress and outcome of the complaint.  

How to contact Unblu  

If You have any questions or concerns about this Privacy Notice, please feel free to contact our Data Protection Team at legal@unblu.com and dpo@unblu.com . 

Amendments to this Privacy Notice 

This Privacy Notice may be updated occasionally to reflect changes in Unblu’s privacy practices. Unblu will note the date of the most recent update at the top of this Privacy Notice. If any significant changes are to be implemented, Unblu will inform You via a notice on the Website or through other means before the changes take effect. By continuing to use Unblu’s products or services after these updates are applied, You acknowledge and accept the revised Privacy Notice. Unblu recommends that you review this Privacy Notice periodically to stay informed about Unblu’s latest privacy practices.