Unsettled Privacy Policy

Version 1.1

Effective Date: December 1, 2017

Unsettled, Inc. its subsidiaries and other entities within its corporate group structure (collectively, “we”, “us”, “our” or “Unsettled”) respect the privacy of our users and we are committed to informing you about how we collect, use, and share Personal Information about you which is submitted by you or on your behalf. This Privacy Policy describes our practices with respect to the information we collect from or about our users in connection with the Unsettled website, portal, and/or mobile application (collectively, the “Unsettled Platform”) and Services (as defined in the Participant Terms and Conditions). This Privacy Policy applies to persons anywhere in the world who use the Unsettled Platform or Services. For clarity, Services includes the Unsettled Platform.

Please read this Privacy Policy carefully to understand how we will treat your Personal Information (as defined below) and by continuing to browse the website or purchase or use any of our services you are deemed to have accepted the terms of this Privacy Policy.

In addition, we recommend that you review our Privacy Policy periodically, because we may revise it at any time. We are constantly trying to improve Unsettled, so this Privacy Policy may need to change. We reserve the right to change the Privacy Policy at any time, but if make material changes, we will bring them to your attention by placing a notice on beunsettled.co, by sending you an email, and/or by some other means. The “Effective Date” at the top of this page indicates when our Privacy Policy was last revised.  Each time you use the Unsettled Platform or provide us with information, you accept the practices described in this Privacy Policy as applicable at that time.

Personal Information and Other Information Processed by Unsettled

Unsettled processes both Personal Information and Other Information about its users through their use of and in connection with the Services.  For purposes of this Privacy Policy (i) “Personal Information” is information relating to a person who is identified in that data or who is, together with other data, identifiable; and (ii) “Other Information” is any additional information that Unsettled collects about our users that is not Personal Information.

Personal Information you provide: you may give us your Personal Information directly, for example, when you fill in forms on the Unsettled Platform, correspond with us in any method of communication (for example, without limitation, by email, phone, skype, zoom, or chat), register to use the Unsettled Platform, access our mobile applications or services, create an account with us or otherwise use the Unsettled Platform. The Personal Information you give us directly may include your name, address, email address, social media details, contact details, emergency contact details, financial  information, photos, videos, voice recordings and information about your family and friends. It also includes the information provided in your application forms.

We may use your contact information to send you information about the Services. You may unsubscribe from some of these messages by using the unsubscribe link provided in each email, although, we reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

Personal Information we collect: we may combine Personal Information collected through the Unsettled Platform with Other Information that we or third parties collect about you in other contexts—such as our communications with you via email, phone or otherwise or your customer service records and travel details.  Additionally, if you register for or access the Unsettled Platform using a third party service, we may receive Personal Information that you allow such third party service to share with us.  You acknowledge that this information may be personal to you, and by creating an account and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous.

We will treat all such information, to the extent combined with Personal Information, as Personal Information and protect it in accordance with this Privacy Policy.

Other Information we collect: each time you log onto your account or use the Unsettled Platform, we may, in some cases automatically, collect the following information:

• through your device: we may collect information from or through the device you use to connect to the Unsettled Platform, including, for example, the type of device, the IP address, the approximate location derived from an IP address, the mobile network, the operating system and version, the browser and version or the timezone setting or unique device identifiers.

• log information: we automatically receive and record certain details about your use of the Unsettled Platform, including but not limited to, web traffic data, web logs and communication data, information about your activity on the Unsettled Platform.

• other information from other sources: we work with third parties (including, for example, providers in technical, payment services, advertising networks, analytics providers and search information providers), and we may receive, collect, store, and use information about you from them. We may partner with certain third parties to collect the Other Information and to engage in analysis, auditing, research and reporting or for use in providing online interest-based advertising on our behalf.  These third parties may use web logs or web beacons, and they may set and access cookies or similar technologies on your device.  They may also use information about your use of the Unsettled Platform to help target non-Unsettled advertisements based on your online activity in general. Additionally our website is hosted by Webflow.

• information from email communications: we may communicate with you via email, SMS, MMS or other text message (collectively, “Text Message”) or push notifications (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email. We use this information to improve the Services, including without limitation our customer service.

• financial information: financial information, such as your payment method, valid credit card number, type, expiration date or other financial information, is collected and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy.  We do not currently store financial information.

• information related to cookies: we collect information through our use of cookies. Please see the section below titled ‘Cookies’ for more information.

• information related to advertising and use of beacons: to support and enhance the Services, we may serve advertisements, and also allow third parties advertisements, through the Unsettled Platform. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.”  Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. Advertisements served through the Unsettled Platform may be targeted to users who fit a certain general profile category and may be based on (i) anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age); (ii) Unsettled Platform usage patterns or (iii) user activity on third party services. We do not provide Personal Information to any ad networks for use outside of the Unsettled Platform. To increase the effectiveness of ad delivery, we may deliver a file (known as a “web beacon”) from an ad network to you through the Unsettled Platform. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site. You can opt out of certain types of targeted advertising as further described in the section below titled ‘Your Rights.’

• aggregate information: we collect statistical information about how both unregistered and registered users, collectively, use the Unsettled Platform (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your account or your web browser.

How We Use Your Personal Information

Unsettled may use the information that we collect from you:

• to provide services to you: we use Personal Information to provide our services to you through the Unsettled Platform, Unsettled trips/programs and events, to process and complete payments or transactions and to provide customer support. We may use the information we collect from you in the following ways: to personalize user's experience and to allow us to deliver the type of content and product offerings in which you are most interested; to improve our website in order to better serve you; to allow us to better service you in responding to your customer service requests; to administer a contest, promotion, survey or other site feature; to quickly process your transactions; to send periodic emails regarding your order or other products and services; to follow up with them after correspondence (live chat, email or phone inquiries). We also may use Personal Information to improve the Services.

• to contact you: subject to applicable law, we or our third-party service and business providers may send you communications. Such communications are designed to make your Unsettled experience more efficient and may include, but are not limited to: notifications about the Services (including important news that could affect your relationship with us), communications about our services, promotions and our mobile application features.  These types of communications may also contain content from third-parties, commercial messages, such as banner ads and special offers.  By using the Services, you consent to the receipt of such communications and marketing information.

• for legal purposes: we may use and share Personal Information for legal purposes, including as described below in the section titled ‘How We Share Information with Third Parties’ (including the transfer of such Personal Information to third parties in countries outside your country of residence where data protection laws may be less adequate compared to your own country’s data protection laws).

• for our business purposes: we may use Other Information to help us efficiently operate Unsettled and the Unsettled Platform, to count and recognize visitors to the Unsettled Platform, to enable certain features on the Unsettled Platform and for other purposes related to managing our business.

• for other purposes: subject to applicable law, we may use Other Information for any additional purposes..

Unsettled may link Other Information with Personal Information. In those circumstances, we will treat the combined information as Personal Information.

 

How We Share Information with Third Parties

Subject to applicable law, we may share your Personal Information and Other Information:

• with partners and other third-party service providers: to operate Unsettled Services, including processing your transactions and supporting your activities on a Unsettled trip or the Unsettled Platform, we may share your Personal Information with our partners and other service providers. These service providers may provide us with support services such as origination of communications, receipt or support services, customer relationship management services and order fulfillment.

• with Unsettled group entities: we may share your Personal Information or Other Information with our parent company and other subsidiary or sister entities, each of whom will comply with the terms of this Privacy Policy with respect to its use and disclosure of such Personal Information.

• with third-parties through their websites: the Unsettled Platform may enable you to share information directly on or through websites or online services operated by third parties. For example, the Unsettled Platform may contain links to third-party websites. If you choose to browse such websites, you may disclose your Personal Information to those third-party websites. Unsettled is not liable for the content or action of such third-party websites.

• user information: some of your activity and information provided on and through the Unsettled Platform may be public (such as your name, profession, and participation in a program). Please remember that if you choose to provide Personal Information using certain public features of the Unsettled Platform, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Unsettled Platform. Additionally, profile information including your name and other information you enter may be displayed to other participants to facilitate participant interaction within the Unsettled Platform. We will not directly reveal user email addresses to other participants.

• with our agents: we also employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

• for legal purposes and the protection of others: we may disclose your Personal Information and Other Information for Unsettled’s legitimate business interests or to comply with applicable law, investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions and Privacy Policy or to cooperate with regulatory authorities or law enforcement, to establish, exercise or defend our legal rights or defend against legal claims. We also reserve the right to disclose any information to respond to user support requests or protect our rights, property or safety, our users, and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

• pursuant to business transfers: in some cases, we may choose to buy,sell or lease assets. In these types of transactions, user information may be  transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

• aggregated information: from time to time, Unsettled may also share anonymized and aggregated information about users of the Services such as by publishing a report or providing information to our business partners on trends in the usage of the Services and demographic of users. We use and share this type of data so that we and our business partners can understand how and how often people use our and their services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these business partners may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

• financial information: as stated above, we do not currently collect financial information, as that information is collected and stored by our Payment Processor. However, we may from time to time request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Unsettled Platform, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business.

• information we share with your consent: except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

Cookies

Cookies are small data text files that save on your computer or mobile device when you access a website. Your browser stores cookies in a manner associated with each website you visit. Cookies enable websites to remember your actions and preferences (such as login, language and other display preferences) over a period of time. To make the Unsettled Platform work properly, we sometimes use cookies. Unsettled uses cookies to enable our servers to recognize your web browser and tell us how and when you visit and otherwise use our services and website through the Internet, to analyze trends, and to learn about our user base.

We may combine non-personally identifiable information collected through cookies with other Personal Information that we have about you, for example, to tell us who you are or whether you have an account.  We may also supplement the information we collect from you with information received from third parties in order to enhance our services, or to offer you information that may be of interest to you.

Most browsers automatically accept cookies, and have an option for turning off the cookie feature, which will prevent the browser from accepting new cookies, as well as (depending on the sophistication of the browser software) allowing the user to decide on the acceptance of each new cookie in a variety of ways. If you choose to decline cookies, some parts of the Unsettled Platform may not work as intended or may not work at all. For more details, see aboutcookies.org.

Please reference the chart below to learn more about the kinds of cookies we use and for what purpose.

• Essential Cookies

Essential cookies are cookies that enable you to navigate and use all the features provided through our Services. Without these, you would not be able to navigate between pages and be served various pages.

Examples: encrypted and cryptographically signed session cookie, used to identify you to our servers after you log in; flash: temporarily stores messages and alerts that we display on-screen to you.

• Functionality Cookies

These cookies enable us to remember you have visited us before, including any preferences you have provided and/or selected to give you a tailored experience.

Tags: _rails_app_session, rack.session, ryu_brid

• Performance and Analytical Cookies

This information is used to help us understand your interactions with the Services. We use this information with various analytics applications to improve the Services and better target various offerings to users. Examples: ga : Google Analytics identifier.

We use third parties, for example, Google Analytics, to analyze statistical information from users of our Services.

Tags: Google Analytics (Analytics), Google Optimize, Facebook Pixel (Conversions), Bing UET Conversion Pixel

• Retargeting or Advertising Cookies

Third parties may also use such tracking technologies to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the Unsettled Platform and on other websites and online services. Targeting and advertising cookies we use may include Google Analytics, Facebook Pixel, LinkedIn Insights tag and others.

Tags: Google Analytics (Audiences), Google Optimize, Facebook Pixel (Custom Audiences), Bing UET Retargeting Pixel, LinkedIn Insights tag - If you are not a LinkedIn member, learn more about cookies and how to opt out.

We use cookies to help us improve, promote, and protect our services. By continuing to use the Unsettled Platform, you agree to our cookie policy. This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

 

Storing Your Information

All information and content submitted by you and collected by us on the Unsettled Platform of through third-parties may be retained by us indefinitely, even after you terminate your account. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information, as described in this Privacy Policy. The information that we collect from you may be transferred to, and stored at, a destination (a “third country”) outside the country or region in which you are resident or use the Unsettled Platform, including in the United States of America where data protection laws are not deemed to be as adequate as other regions (e.g. Europe). The data protection laws in these third country countries may be less adequate compared to your country of residence. By using the Unsettled Platform, you agree to this transfer, storing or processing of your laws in such third countries.

 

Our Security Precautions

Unsettled uses commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information against loss or unauthorized access, use, modification or deletion but no security program can be guaranteed to be 100% secure. As a result, Unsettled cannot guarantee the security of any information obtained or processed by Unsettled or its service providers, and you use the Unsettled Platform at your own risk. Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible. We use regular Malware Scanning. Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology. We implement a variety of security measures when a user places an order to maintain the safety of your Personal Information. All transactions are processed through a gateway provider and are not stored or processed on our servers.

We will take commercially reasonable steps to ensure that your data is treated in accordance with this Privacy Policy.

Additionally, you are responsible for preventing unauthorized access to your account and Personal Information by protecting your account credentials and limiting access to your devices.

 

Your Rights

You may, under applicable law, have the right to ask us not to process your Personal Information for marketing purposes.  If you do not wish to receive marketing communications from Unsettled, please follow the opt-out instructions contained in each such communication or any time by contacting us at media@beunsettled.co.  Please note that you may not be able to opt-out of certain non-marketing communications about your account or communications that are reasonably necessary to provide services to you, and that opting-out of receiving text messages or other communications, as applicable, may impact your use of the Unsettled Platform or may limit Unsettled’s ability to provide services to you.

Please note that it may take up to 30 days for your withdrawal to be reflected in our systems following confirmation of your request to opt-out.  Therefore, you may still receive certain communications during this period.California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Unsettled, Inc. 8 The Green, STE 4981, Dover, DE 19901.

Opting out of Interest Based Advertising

We use Google and Facebook services to advertise to you. Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy. We have implemented demographics and Interests Reporting.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties and to opt out of receiving certain cookies and certain trackers, please visit the DAA’s or NAI’s consumer opt out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices or http://youronlinechoices.eu.

Do Not Track

Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites.  The Unsettled Platform does not currently support the Do Not Track options offered by most major browsers. For more information about DNT signals, visit  http://allaboutdnt.com.

 

Accessing & Editing Your Information

Unsettled provides you with the ability to view, update, access, edit and correct your Personal Information by contacting our Onboarding team at hello@beunsettled.co (if your program has not yet launched), by contacting your program leaders (if your program has launched). Personal Information transmitted through boards, chats, polls or any other means may remain in our databases, except to the extent prohibited under applicable law.

You may have additional rights under applicable law to access information we hold or share about you but any access request may be subject to a reasonable fee, to the extent permissible under applicable law, to meet our costs in providing you with details of such information.

 

Children's Privacy

The Services are designed for adults only and are not available to children (i.e. persons who are under 18 years of age) or users who have had their user account temporarily or permanently deactivated. By becoming a user, you represent and warrant that you are an adult and that you have the right, authority and capacity to enter into and abide by the terms and conditions of this Privacy Policy. We reserve the right to verify your information and can exercise our absolute discretion not to provide any Services to you if we are not satisfied that you are an adult. If a child has provided us with Personal Information, a parent or legal guardian of that child may contact us as described below. Upon confirmation, we will then make reasonable efforts to delete the child’s Personal Information from our applicable database.

Contact

Questions, comments, and requests regarding this Privacy Policy should be addressed to hello@beunsettled.co.