Privacy Policy

Effective as of 25 May 2018

1. Introduction

At Untapped, we want to give you the best possible experience to ensure that you enjoy our service today, tomorrow, and in the future. To do this we need to understand your usage habits so we can deliver an exceptional and personalized service specifically for you. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data - as well as outline the controls and choices you have around when and how you choose to share your personal data.

That is our objective, and this Privacy Policy (“Policy”) will explain exactly what we mean in further detail below.

2. About this Policy

This Policy sets out the essential details relating to your personal data relationship with Untapped. The Policy applies to all Untapped services and any associated services (referred to as the ‘Untapped Service’). The terms governing your use of the Untapped Service are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”).

From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.

The aim of this Policy is to:

  1. Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
  2. Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Untapped Service; and
  3. Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

We hope this helps you to understand our privacy commitments to you. If you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Untapped Service.

3. Your rights and your preferences: Giving you choice and control

You may be aware that a new European Union law, called the General Data Protection Regulation or "GDPR" gives certain rights to individuals in relation to their personal data. Accordingly, we have implemented additional transparency and access controls in to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the ‘Contact Us’ form on our website. We will respond to your request within a reasonable period of time upon verification of your identity.

4. How do we collect your personal data?

We collect your personal data in the following ways:

  1. When you sign up for the Untapped Service - when you sign up to the Untapped Service, we collect certain personal data so you can use the Untapped Service such as your email address, birth date, gender, and country.
  2. Through your use of the Untapped Service - when you use the Untapped Service, we collect personal data about your use of the Untapped Service, such as the chat you post and the inspirational content you access.
  3. Personal data collected that enables us to provide you with additional features/functionality - from time to time, you also may also provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality. We will not collect precise mobile device location, voice data, or contacts from your device without your prior consent. You always will have the option to change your mind and withdraw your consent at any time.

We use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the Untapped Service, and developing new features and functionality within the Untapped Service.

5.What personal data do we collect from you?

We have set out in the tables below the categories of personal data we collect and use about you:

Personal data collected when you sign up for the Untapped Service

Categories of personal data

Description of category

Account Registration Data

This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Untapped Service. This includes your email address, gender, organisation.

Some of the personal data we will ask you to provide is required in order to create your account. You also have the option to provide us with some additional personal data in order to make your account more personalized.

The exact personal data we will collect depends on the type of Untapped Service plan you sign up for.

Personal data collected through your use of the Untapped Service

Categories of personal data

Description of category

Untapped Service Usage Data

This is the personal data that is collected about you when you are using the Untapped Service - this may include:

  • Information about your type of Untapped Service plan.
  • Information about your interactions with the Untapped Service which includes the date and time of any chat and your interactions with your Untapped Accelerators.
  • User Content (as defined in the Terms and Conditions of Use) you post to Untapped including messages you send and/or receive via Untapped and your interactions with the Untapped Customer Service team.
  • Technical Data which may include URL information, cookie data, your IP address, the types of devices you are using to access or connect to the Untapped Service, unique device IDs, device attributes, network and device performance, browser type, operating system, and Untapped application version.

Personal data collected with your permission that enables us to provide you with additional features/functionality

Categories of personal data

Description of category

Voluntary Mobile Data

We will not access any of the personal data listed below without first obtaining your consent:

  • Your photos - If you give us permission to access your photos or camera, we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image.
  • Your voice data - If you give us permission, this enables us to access the voice commands captured via your device microphone, to enable you to interact with the Untapped Service with your voice. Please note you will always have the ability to turn off the microphone feature;

6. What do we use your personal data for?

When you use or interact with the Untapped Service, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data used for these purposes:

Description of why Untapped processes your personal data (‘processing purpose’)

Legal Basis for the processing purpose

Categories of personal data used by Untapped for the processing purpose

To provide, personalize, and improve your experience with the Untapped Service and other services and products provided by Untapped, for example by providing customized, personalized, or localized content, recommendations, features, and feedback on your personal development.

  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Demographic information
  • Service Usage Data

To understand how you access and use the Untapped Service to ensure technical functionality of the Untapped Service, develop new products and services, and analyze your use of the Untapped Service, including your interaction with applications, products, and services that are made available, linked to, or offered through the Untapped Service.

  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Chat and application use
  • Service Usage Data

To communicate with you for Untapped Service-related purposes.

  • Performance of a Contract
  • Legitimate Interest
  • Account Registration Data
  • Service Usage Data

To provide you with features, information, or other content which is based on your specific location.

  • Consent
  • Voluntary Mobile Data
  • App use data

If you require further information about the balancing test that Untapped has undertaken to justify its reliance on the legitimate interest legal basis under the GDPR, please see Section 14 ‘How to contact us’ for further details on how to contact us.

7. Sharing your personal data

We have set out the categories of recipients of the personal data collected or generated through your use of the Untapped Service.

Information we may share

Categories of Recipients

Reason for sharing

Service Providers and Others

We use technical service providers which may operate the technical infrastructure that we need to provide the Untapped Service, in particular providers which host, store, manage, and maintain the Untapped application, its content and the data we process.

We use technical service providers to help us communicate with you, as described in Section 6 of this Policy.

Untapped Partners and Suppliers

We may share your personal data in anonymised format with our partners or suppliers, in specific circumstances to help us in delivering aspects of our Service to you.

You cannot be identified and will never be contacted by our partners or suppliers

Other Untapped Group Companies

We will share your personal data with other Untapped Group companies to carry out our daily business operations and to enable us to maintain and provide the Untapped Service to you.

Law Enforcement and Data Protection Authorities

We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.

We also will also share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

8. Data retention and deletion

We keep your personal data only as long as necessary to provide you with the Untapped Service and for legitimate and essential business purposes, such as maintaining the performance of the Untapped Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Untapped Service. For example, we keep your chat, inspirational content preferences and account information. Once you leave the service we completely anonymize your personal information. Where it is not possible to  anonymize information, we remove it.

If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:

9. Transfer to other countries

Untapped stores your data within the EU. Untapped may also subcontract processing to, or engage services with third parties located in countries other than your home country. Your personal data, therefore, may therefore be subject to privacy laws that are different from those in your country of residence.

In such instances Untapped shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organisational measures are in place such as the regulations within GDPR.

10. Links

We may display links from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party link, please understand that you are leaving the Untapped Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.

11. Keeping your personal data safe

We are committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymisation, full anonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Untapped Service.

12. Children

The Untapped Service is not directed to children under the age of 13 years. However, in some countries, stricter age limits may apply under local law. We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Untapped Service, and do not provide any personal data to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Untapped, please contact us using the ‘Contact Us’ form on our website.

If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Untapped account for that child.

13. Changes to this Privacy Policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Untapped Service or by sending you an email. We may notify you in advance.

Please, therefore, make sure you read any such notice carefully.

14. How to contact us

Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact our Data Protection Officer by using the ‘Contact Us’ form on our website

We hope you enjoy Untapped!

© Untapped 2018