Privacy Policy
1. Introduction
Ethink Ltd ("we", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and share your personal information when you use the Untl application and website (the "Service"). We act as the Data Controller for your personal data.
2. The Data We Collect
We collect the following categories of information:
- Identity Data: Name, username, date of birth.
- Contact Data: Email address.
- Technical Data: IP address, login data, device type, operating system.
- Usage Data: Information about how you use our App, including button clicks, feature usage time, and navigation paths.
- Content Data: Data you input into the App to utilize our services.
3. How and Why We Use Your Data (Lawful Basis)
Under the UK GDPR, we must have a lawful basis for processing your data. We rely on the following bases:
| Purpose / Activity | Type of Data | Lawful Basis |
|---|---|---|
| To register you as a new user | Identity, Contact | Performance of Contract |
| To process your subscription | Identity, Financial | Performance of Contract |
| To provide the Service | Usage, Content | Performance of Contract |
| To improve our Service & train AI models | Usage, Technical (Anonymized) | Legitimate Interests (to study how customers use our products, to develop them and grow our business) |
| To send renewal reminders | Contact | Legal Obligation (DMCCA requirements) |
4. Data Usage for Service Improvement and AI
We use machine learning algorithms to improve the user experience of our Service.
- Legitimate Interest: We have a legitimate interest in using your Usage Data to refine our algorithms and features. We have conducted a balancing test to ensure this does not override your rights.
- Anonymization: We prioritize the anonymization of data used for training. Once data is anonymized (so that you can no longer be identified from it), it is not personal data and is not subject to this Policy.
- Right to Object: You have the right to object to the processing of your data for these research purposes. You can do so by contacting us at hello@untl.app.
5. International Transfers
We are based in the United Kingdom. We may share your personal data with third-party service providers (e.g., cloud hosting, analytics) located outside the UK, specifically in the United States.
- UK-US Data Bridge: Where we transfer data to US organizations certified under the UK Extension to the EU-US Data Privacy Framework, we rely on this "Data Bridge" to ensure your data is protected.
- Other Transfers: For transfers to countries or organizations not covered by the Data Bridge, we use specific contracts approved by the UK Government (the International Data Transfer Agreement or Standard Contractual Clauses) to give your data the same protection it has in the UK.
6. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for.
- Account Data: Retained for the duration of your account life plus 6 years (to comply with legal limitation periods).
- Anonymized Analytics Data: Retained indefinitely for long-term trend analysis and AI training.
7. Your Legal Rights
Under the UK GDPR, you have rights including:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data (specifically for AI training).
- Request restriction of processing your personal data.
- Right to Withdraw Consent at any time where we are relying on consent.
To exercise any of these rights, please contact us at hello@untl.app.