Privacy Policy
BACKGROUND
Knowunity understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website or the app Knowunity (“our Platform”) and only collect and use your personal data as described in this Privacy Policy. Any personal data we collect will only be used as permitted by law.
Please read this Privacy Policy carefully and ensure that you understand it. In the following, we provide information about the collection of personal data when using:
our website https://knowunity.co.uk
our app “Knowunity”
our profiles in social media.
Information About Us
Our Platform is owned and operated by Knowunity GmbH
Registered address: Julie-Wolfthorn-Straße 1, 10115 Berlin
Registered at: Stuttgart District Court
Registration Number: HRB 771043
Sales Tax number: DE326705352
Representative/ Director: Benedict Kurz
Email address: [email protected]
Postal address: Julie-Wolfthorn-Straße 1, 10115 Berlin
Data Protection Officer: heyData GmbH
Email address: [email protected]
Postal address: Kantstr. 99, 10627 Berlin, Germany.
What Does This Policy Cover?
This Privacy Policy applies only to your use of our Platform. Our Platform may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
What Is Personal Data?
Personal data is defined by the UK General Data Protection Regulation and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 14.
The right to access the personal data we hold about you. Part 9 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 14 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 14 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 14.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office or equivalent authoritative body. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 14.
What Personal Data Do You Collect and How?
Subject to the following, we do not collect any personal data from you. We do not place cookies on your computer or device, nor do we use any other means of data collection.
Our Platform collects certain information automatically, including:
Your IP address
Type of browser you are using, date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Amount of data transferred in each case
Website from which the request comes
Operating system type or version and its interface
Display resolution
Language and version of the browser software
This data is stored in log files. It is deleted when its storage is no longer necessary, at the latest after 14 days.
If you send us an email, we may collect your name, your email address, and any other information which you choose to give us. For the purposes of the Data Protection Legislation, we are the data controller responsible for such personal data.
The lawful basis under the Data Protection Legislation that allows us to use such information is article 6(1)(f) of the UK GDPR which allows us to process personal data when it is necessary for the purposes of our legitimate interests, in this case, the proper operation and functionality of the Platform. If you contact us as described above, you will be required to consent to our use of your personal data to contact you. In this case, our lawful basis for using your personal data will be article 6(1)(a) of the UK GDPR, which allows us to use your personal data with your consent for a particular purpose or purposes.
How Do You Use My Personal Data?
Where we collect any personal data, it will be processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the Data Protection Legislation at all times. For more details on security see Part 7, below.
As stated above, we do not generally collect any personal data directly from you, but if you contact us and we obtain your personal details from your email, we may use them to respond to your email. The other technical data referred to above is necessary for the technical operation of our Platform and will not normally be used in any way to personally identify you.
Any and all emails containing your personal data will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted, i.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons. No other personal data will be retained for any longer than is necessary.
We will not share any of your personal data with any third parties for any purposes other than storage on an email and/or web hosting server.
How and Where Do You Store My Data?
We store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Reference below to the GDPR are references to the UK GDPR or the EU GDPR as applicable.
Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
Please contact us using the details below in Part 14 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
Personal data security is essential to us, and to protect personal data, we take the following measures:
limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (article 45 para. 3 GDPR).
If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer is usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to article 46 of the GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
It is our legitimate interest to provide a website, so that the legal basis for data processing for this is article 6, para. 1 (f) GDPR. We may contract with the following third parties for hosting, content delivery/ management and data storage purposes:
Our Platform is hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sarl, 38 avenue John F. Kennedy, L-1855, Luxemburg. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/.
We use a content delivery network to help provide our Platform. The provider is Cloudflare Inc., 106 East 6th Street, Suites 350 and 400, Austin, TX 78701, USA (privacy policy: https://www.cloudflare.com/en-gb/privacypolicy/). The provider thereby processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data.
We use a content delivery network to help provide our Platform. The provider is Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA (privacy policy: https://aws.amazon.com/de/privacy/?nc1=f_pr). The provider thereby processes the personal data transmitted via the website, e.g. on content, usage, meta/communication data or contact data.
We use a content management system to help provide our Platform. The provider is Prismic.io Inc, 185 Alewife Brook Parkway, Suite 210 Cambridge Massachusetts 02138, USA (privacy policy: https://aws.amazon.com/de/privacy/?nc1=f_pr). The provider thereby processes the personal data transmitted via the Platform, e.g. on content, usage, meta/communication data or contact data.
If any of your personal data is transferred to a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 7.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 7.
If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Sign-on Procedure
Apple
Site visitors can log in to our Platform using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using a single sign-on procedure, we receive information from the provider that the site visitor is logged in with the provider and the provider receives information that the site visitor is using the single sign-on procedure on our Platform. Depending on the settings of the site visitor in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the site visitor who logs in to our site with the account (article 6 para. 1 (a) GDPR). The provider of the procedure is Apple Inc, Infinite Loop, Cupertino, CA 95014, USA (privacy policy: https://www.apple.com/legal/privacy/de-ww/).
Site visitors can log in to our Platform using a single sign-on procedure. In doing so, they use the login data already created for another provider. The prerequisite is that the site visitor is already registered with the respective provider. When a site visitor logs in using a single sign-on procedure, we receive information from the provider that the site visitor is logged in with the provider and the provider receives information that the site visitor is using the single sign-on procedure on our Platform. Depending on the settings of the site visitor in his account on the provider's site, additional information may be provided to us by the provider. The legal basis of this agreement is the consent of the site visitor who logs in to our site with the account (article 6 para. 1 (a) GDPR). The provider of the procedure is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (privacy policy: https://policies.google.com/privacy).
Payment processors
For the processing of payments, we use payment processors who are themselves data controllers within the meaning of article 4, para. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfil the contract concluded with our customers (article 6 para. 1 (b) GDPR).
These payment processors are:
Apple Inc., USA (for Apple Pay)
Google Ireland Limited, Ireland (for Google Pay)
Klarna Bank AB (publ), Sweden (for "Klarna Sofort")
Mastercard Europe SA, Belgium
PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxemburg
Shopify Inc., Canada (for Shop Pay)
Stripe Payments Europe, Ltd., Ireland
RevenueCat Inc., USA
Third Parties
We use the following technologies and services from third-party providers on the basis of the user’s consent.
Google Webfonts
We use Google Webfonts for fonts on the Platform. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. However, the processing only takes place on our servers. We process meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is article 6, para. 1 (a) GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until revocation.
Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.
AppsFlyer
We use AppsFlyer for analytics. The provider is AppsFlyer Ltd., 14 Maskit st. Herziliya, Israel. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for the processing is article 6, para. 1 (a) GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.appsflyer.com/legal/privacy-policy/.
Google Tag Manager
We use Google Tag Manager for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.
The legal basis for the processing is article 6 para. 1 (a) GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (article 46 para. 2 (c) GDPR) adopted by the EU Commission in accordance with the examination procedure under article 93 para. 2 of the GDPR, which we have agreed to with the provider.
We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.
Snap Pixel
We use Snap Pixel for analytics. The provider is Snap Group Limited, 7-11 Lexington Street, London W1F 9AF, Great Britain. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is article 6, para. 1 (a) GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (article 46 para. 2 (c) GDPR) adopted by the EU Commission in accordance with the examination procedure under article 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.snap.com/en-GB/privacy/privacy-policy.
Facebook Conversion API
We use Facebook Conversion API for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is article 6, para. 1 (a) GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (article 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under article 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.facebook.com/policy.php.
Google Analytics
We use Google Analytics for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is article 6, para. 1 (a) GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (article 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under article 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://policies.google.com/privacy?hl=en-US.
hCaptcha
We use hCaptcha to manage authentications. The provider is Intuition Machines, Inc., 350 Alabama Street, San Francisco, CA 94110, USA. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for the processing is article 6, para. 1 (a) GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.
The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (article 46 para. 2 (c) GDPR) adopted by the EU Commission in accordance with the examination procedure under article 93 para. 2 of the GDPR, which we have agreed to with the provider.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy at https://www.hcaptcha.com/privacy.
Google AdMob
We provide Google with advertising space within our app via the Google service AdMob. In order to avoid displaying irrelevant and annoying advertisements, we also rely on direct advertising. In order to identify relevant advertisements for the respective user, AdMob collects and processes personal data and may also carry out profiling.
Microsoft Clarity
This website uses Microsoft Clarity, an analytics tool from Microsoft Corporation (One Microsoft Way, Redmond, WA 98052-6399, USA; “Microsoft”). For this purpose, Microsoft Clarity uses cookies enabling an analysis of your use of our website (e.g. entry to the page, navigation, scrolling and clicking behavior). Pursuant to § 25 para. 1 TTDPA, these are only set after their express consent. The information generated by the cookies will be transmitted to a Microsoft Clarity server (possibly in the USA) and stored in order to enable session recording and to generate so-called heat maps. We use Microsoft Clarity in the default settings, so that the data transmitted to Microsoft does not contain any sensitive input data such as names or addresses, to rule out any direct personal reference. Microsoft will use this information to evaluate your use of the website, to compile reports on website activities, and provide the website’s operator with further services related to website and Internet usage, including profiling for advertising purposes. Microsoft may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Microsoft’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
You can find further information about Microsoft Clarity here: https://clarity.microsoft.com/
The legal basis for the processing of your personal data is Art. 6 para. 1 lit. a GDPR.
Social Media
We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behaviour, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behaviour in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.
If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, the legal basis for which is article 6, para. 1 (f) GDPR.
We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. It is possible to object to data processing via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are joint controllers for processing the data of visitors to our profile on the basis of an agreement with Facebook within the meaning of article 26 GDPR. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will receive a faster response if they contact Facebook directly.
We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.
Snapchat
We maintain a profile on Snapchat. The operator is Snap Inc, 3000 31st Street, Santa Monica, California 90405, USA. The privacy policy is available here: https://snap.com/de-DE/privacy/privacy-policy.
Tiktok
We maintain a profile on Tiktok. The operator is musical.ly Inc, 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA. The privacy policy is available here: https://www.tiktok.com/de/privacy-policy.
YouTube
We maintain a profile on YouTube. The operator is Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland. The privacy policy is available here: https://policies.google.com/privacy?hl=de.
We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. It is possible to object to data processing via the settings for advertisements: https://twitter.com/personalization.
We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. It is possible to object to data processing via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 14.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your subject access request. You will be kept fully informed of our progress.
How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Data Protection Officer: heyData GmbH
Email address: [email protected]
Postal address: Kantstr. 99, 10627 Berlin, Germany.
Changes to this Privacy Policy
We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be immediately posted on our Platform and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Platform following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 31 August 2022.