Privacy Policy

Effective date: June 1st, 2021 Welcome to Unbanks’s privacy policy.
Unbanks ("us", "we", or "our") is a website which uses your banking data to provide a Data Union for the Streamr Marketplace. By using Unbanks, you agree to the collection and use of information in accordance with this policy. Unbanks respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our services. Please also use the Glossary at the end of this document to understand the meaning of some of the terms used in this privacy policy.

Important Information and Who We Are

Purpose of This Privacy Policy This privacy policy aims to give you information regarding the collection, use, and disclosure of banking data when you use the Unbanks application. In addition, this privacy policy will tell you about your privacy rights and how the law protects you. Unbanks is not intended for children and we do not knowingly collect data relating to children. In order to protect the privacy of children, the minimum age for signing up to Unbanks is 18 years. Controller Unbanks LLC is the controller and responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. Contact Details If you have any questions about this policy or if you would like to exercise your rights to your personal data described further below, please contact our data privacy manager in the following ways: You have the right to make a complaint at any time with the data protection authorities concerning our processing of your personal data. You can make the complaint with the data protection authority of the EU member state where you have your permanent residence or where you work, or where you find that a potential breach with regard to your personal data has occurred. Changes to This Privacy Policy We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Third-Party Links This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

How We Collect Information from You

Unbanks is an application that allows you to sell your banking data. The Unbanks application allows you to connect your bank account and anonymously sell your data on the Streamr Marketplace. We use a third party provider Turelayer to collect your banking data using PSD2 open standards. You must re-authorise connection to your bank account after three (3) months.

Information We Collect

Each module of Unbanks collects several different types of information. Please see the “Data collectors” section of this Privacy Policy below for examples of the different types of data collected by Unbanks. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy. We do not collect any special categories of personal data about you unless you give your express consent(this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Data Collectors In this section all Unbanks data collectors and a short description for each one of them are listed. Data collected We collect these data points from your bank account when you connect it:
Collector name Collector description
Banking Data You must authorise us to collect your banking data using a third party called Truelayer
transaction_id Unique identifier of the transaction in a request. It may change between requests
timestamp Date the transaction was posted on the account
description Original description of the transaction as reported by the Provider
transaction_type Type of the transaction
transaction_category Category of the transaction
transaction_classification Classification of the transaction (array can be empty if classification has not been successfully assigned)
merchant_name OPTIONAL (if merchant has been identified). Name of the merchant
amount Amount of the transaction
currency ISO 4217 alpha-3 currency code
meta A collection of additional Provider specific transaction metadata

What We Do with the Collected Data

We use your data to provide a Data Union for the Streamr Marketplace. Unbanks aggregates the collected banking data to create a Data Union. We push the collected data to the Streamr Marketplace for selling as Data Union. For every module, we send all the collected data to a predefined stream on the Streamr Network. A Data Union has been defined on Streamr Marketplace to aggregate these data. Buyers can subscribe to the streams of this product for a specific period of time by paying the requested cost. WE ARE NOT RESPONSIBLE FOR ANY MISUSE OF DATA PROVIDED TO THE BUYERS. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Please see below, to find out more about the types of legal basis that we will rely on to process your personal data. Purposes for which we will use your personal data We may process your personal data to do the following: Legal Basis for Processing Your Data The processing of your personal data is necessary for the performance of the contractual relationship between Unbanks and you. We may also process your personal data based on our legitimate interests. This means that we have a legitimate interest to process your personal data for example based on our relationship with you as a user, there is a limited privacy impact on you, and you should reasonably expect your data to be used that way. Unbanks has a legitimate interest, for example, to process your personal data to develop its business, based on the contractual relationship between you and Unbanks. We may also process your personal data for specific purposes based on your consent, if we have separately requested and obtained your consent.

Your Controls and Choices

Controls and choices We provide you with certain controls and choices regarding the data collected:

Disclosures of Personal Data

In addition to including your data in the Data Unions, we may share your personal data with the parties set out below for the purposes set out in section “Purposes for which we will use your personal data” above.

Transfer of Data

The data that has been collected by Unbanks, may be transferred to - and maintained on – Streamr network nodes located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Any transfer of your personal data to a country outside the EU or the EEA will be made only provided that the EU Commission has decided that the third country ensures an adequate level of protection in accordance with the EU General Data Protection Regulation (679/2016) or, if such decision has not been made for the country in question, in accordance with the EU Commission’s standard contractual clauses for data transfers. For more information about such clauses, see this link: nsfer-personal-data-third-countries_en. For clarity, the EU Commission has determined that Switzerland is a country with an adequate level of protection. Your consent to this Privacy Policy followed by your consent for collecting data in Unbanks application represents your agreement to that transfer. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security of Data

Unbanks is concerned about the security of your data. We have implemented technical security measures that are designed to help protect your information from unauthorized access, disclosure, use and modification. From time-to-time, we review our security procedures to consider appropriate new technologies and methods. Please be aware, though, that despite our efforts, no security measures are perfect or impenetrable. We cannot ensure, and do not warrant or guarantee that the information you transmit to Streamr nodes will remain secure, nor do we guarantee that this information will not be accessed, disclosed, altered, destroyed or used in an unauthorized manner. If we learn of a security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on our website or in the Unbanks extension if a security breach occurs. Depending on where you live, you may have a legal right to receive a notice of a security breach in writing.

Data Retention

We will retain your personal data only for as long as it is relevant for the purpose for which it was collected and will delete any personal data that is no longer relevant. This means that we will keep your personal data that is necessary to implement our agreement with you for as long as you maintain a Unbanks user account or for as long as reasonably necessary to fulfil the purposes we collected it for, whichever is longest, as well as until the expiry of any applicable claim periods after this. We will also comply with any applicable laws or statutes which obligate us to retain your personal data for a specific time period, such as the mandatory retention periods under accounting laws and regulations. As regards any personal data that we process based on your consent, we will retain such data for as long as it is relevant for the purpose for which the data was collected, unless you withdraw your consent before that. You may request to close your Unbanks account at any time. After we receive your request to close the account, we will do so without delay, as long as you have no outstanding obligations as a data provider on the Streamr Marketplace. We will delete all your personal data when your account is closed, unless there are applicable laws or statutes which obligate or allow us to retain your personal data longer. If you have entered into a contract with a third party data provider, any such contract may contain further obligations as to for how long the personal information is kept.

Your Legal Rights

You have various rights with regard to your personal data. Please note that the particular rights may be subject to qualifications or specific requirements arising from, for example, applicable laws, that are not fully described here.