The Counsel Privacy Policy

Welcome to The Counsel Privacy Policy

Last updated: 19 July 2023

Our Commitment to your Privacy

The Counsel does not sell or share any personal data as defined under California Law, in any event, see ‘Notice for United State Citizens’ for your rights.
Your privacy is our priority. We appreciate that you entrust us with your personal data and want you to know that we respect your privacy. Our privacy practices are based on these core principles:

We design our platforms and services with your privacy in mind.
We strive for transparency about how we process your personal data. We work hard to provide clear and straightforward descriptions of our privacy practices because we want you to understand them.
We are dedicated to the protection of your personal data. We continually assess data security risks and test and monitor our security practices to protect against them.

What’s in this document?

Our Privacy Policy

Our Privacy Policy
What is The Counsel?
What information does The Counsel collect and why?
How does The Counsel share personal data?
What are The Counsels’ lawful basis for processing personal data?
How does The Counsel honour privacy rights requests?
Where does The Counsel process personal data?
How does The Counsel protect Personal Data?
For how long will The Counsel retain Personal Data?
When and why does The Counsel update this Privacy Policy?
How do I contact The Counsel?
Notice for United States Citizens

This Privacy Policy describes how Myunidays Limited and its affiliates (collectively “UNiDAYS”, “our”, “us” or “we”) collects and processes your personal data and how you can exercise your privacy rights.

If you are located in the EU or the UK, the data controller for the personal data that UNiDAYS collects is Myunidays Limited of 2 Castle Boulevard, Nottingham, Nottinghamshire, United Kingdom NG7 1FB. The ICO registration number is Z2692580.

If you are located in the US or Canada, the legal entity responsible for personal data processing is Unidays Inc., Penn Plaza 9th Floor 132 W 31st St. New York City NY 10001, United States.

If you are located in India, the legal entity responsible for personal data processing is UNiDAYS Private Limited, with its principal place of business at 4th Floor, Vedwati Apartments, Opposite Agriculture College, Shivaji Nagar, Pune, Maharashtra, India 411005.

For all other jurisdictions, the legal entity responsible for personal data processing is MYUNIDAYS LTD of 2 Castle Boulevard, Nottingham, Nottinghamshire, United Kingdom NG7 1FB.

MYUNIDAYS LTD is incorporated and registered in England and Wales with company number 07552253, VAT number 130053865, and registered office at 2 Castle Boulevard, Nottingham, Nottinghamshire, NG7 1FB.

We have appointed QuMind (a trading name of QuMind Ltd) to host our Research Panel service ‘The Counsel’. QuMind is a full service Research Agency, specialising in online interviewing and is our data processor. This Privacy Policy has been created to provide information to those who are part of The Counsel community, or are considering taking part in our online panels, surveys and discussions.

You have the right to end your participation in The Counsel community at any time, please see the section "Your Rights" below.

When we refer to our “Site”, we mean https://myunidayscounsel.com/.

This Privacy Policy applies to the students, graduates, and others who are eligible to create The Counsel account and to those who browse the public sections of our Site.

YOU ACKNOWLEDGE THAT THIS PRIVACY POLICY DESCRIBES HOW WE PROCESS YOUR PERSONAL DATA WHEN YOU USE OUR SITE.

If you are in the UK or the EU, the UK/EU-specific requirements to the Privacy Policy take precedence over all other provisions.

To learn how you can exercise your privacy rights:

If you are resident in the United States of America, please see our US State Privacy Notice below.
For everyone else, please see below.

What is The Counsel?

The Counsel is an online community for UNiDAYS members to take part in relevant research activities (including online panels, surveys, polls and discussions), designed to help market research. The Counsel is where members can get rewarded for sharing their thoughts to help UNiDAYS shape an excellent experience for members.

In order to become a member of The Counsel, each individual is required to complete and submit the registration survey by clicking on “Sign up” on the www.myunidayscounsel.com website homepage. The participation on all questionnaires is voluntary and in accordance with the Terms and Conditions.

What information does The Counsel collect and why?

If you are resident in the United States of America, please see our US State Privacy Notice available below.

We collect information that you share through your participation in The Counsel community, for example, information provided by you:

At the time of registering to use The Counsel
By participating in our online surveys, polls and discussions or prize draws
By posting material on The Counsel
By submitting enquiries using the contact details posted on The Counsel
We may also ask you for information if you report a problem with The Counsel.

In order to participate in the The Counsel community, we require certain personal data from you. This will generally include:

Your first and last name
Your email address
Date of birth
Gender
Ethnicity
Region of residence
Type of educational institution attended
Name of institution
Duration of education
Year of study
Employment during education
Areas of interest.

We collect these personal data for the following purposes:

Segmentation allows us to provide a more tailored and relevant community experience as well as research activities. As a result, from time to time we will use this information to send relevant research activity to you in the form of surveys and to take part in discussion groups and online polls.
To help us verify your identity and in doing so enabling us to administer the above activities effectively and allowing us to contact you if the need arises, for example if a member has a query about the community which requires us to respond via email.
Account administration allowing members to amend community preferences.
Contact for rewards or special projects as part of research projects and activities.
Trend analysis and behaviours formed from aggregated and anonymous research results data.
To improve our services, and help partners understand how to improve products and services.

Information that specifically identifies you will never be passed on by The Counsel unless you have given prior permission.

UNiDAYS remains the data controller of the information collected. The way the service works is that QuMind will share aggregated information with UNiDAYS who may share the same aggregated information with their third party clients; unless you allow us otherwise. We may, on occasion, match your answers to other information held about you on other databases to assess the frequency of visits by you and other members of the panel and to work out whether you are more likely to interact in a particular way. Again, this will only be reported back to third party clients as aggregated data.

Where information is required to identify a winner of a competition or draw this will be used for the purposes of the prize draw. Please refer to individual competition rules which will fully describe any publicity of winners names.

Generally, data from research activity is reported in aggregate format only. That is, no names, addresses or telephone numbers are attached to any answers, but instead answers are provided as counts and percentages.

We will only ask for information such as your postal address when it is necessary as a part of the research that we send something to you in the post, for example if you have won a prize.

How does the Counsel share personal data?

We share your personal data with parties (including employees and contractors, where appropriate) that help us provide The Counsel and to carry out our business.

We also share your personal information when you give us your consent.

We share personal data with organisations that help operate The Counsel, when we are legally required to do so, and otherwise as described in this Privacy Policy.

We share personal data with the following categories of recipients:

Professional advisors, such as lawyers, accountants, and information security and forensics experts;
Our contractors and vendors, to enable them to work for us;
Competent law enforcement, government regulators, courts, or other third parties when we believe disclosure is necessary (i) to comply with the law, (ii) to exercise, establish or defend our legal rights, or (iii) to protect the vital interests of Members, Partners or another third party;
Potential or actual acquirers or investors and their professional advisers in connection with any proposed merger, acquisition, or investment in or of all or any part of our business. We will use our best efforts to ensure that the terms of this Privacy Policy apply to personal data after the transaction or that you receive notice of any changes to your personal data processing;
To any other third party with your permission.

What are The Counsels’ lawful basis for processing personal data?

Under EU and UK data protection law, we may collect and process your personal data only when we follow the lawful bases specified in EU and UK data protection law and inform you of the specific lawful bases on which we rely:

Consent: we will process your personal data when you provide your consent. Consent will be obtained where sensitive data are being collected or you wish to take part in a prize draw and wherever we need to, it will be clear to you when this is the case.
Performance of a contract: we operate the Site and related services on the basis of a contract with you, which are our Terms of Service.
Our legitimate interests: we may base the processing of personal data on our legitimate interests as a business to:
- Generate insights that can be used to enhance The Counsel experience for members - improved UX, generally through an aggregated analysis of member attitudes, behaviour, trends for partners;
- In the interests of our members, to provide a community and connect members to share ideas, thoughts and experiences;
- For organisational reasons and to monitor performance, to update member details and preferences, and to enhance our products and services and improve performance;
- efficiently operating, maintaining and managing the Site and related services;
- tailoring the Site and related services to suit our users;
- ensuring the security of the Site;
- preventing and detecting fraud;
- communicating with you in accordance with your wishes and expectations;
- responding to and handling any requests or complaints;
- maintaining internal administrative records;
- undertaking quality control and business planning;
- Compliance with a legal obligation to which we are subject. When we rely on our legitimate interests as our basis for processing personal data, we balance our interests with strong privacy protections tied to fairness and purpose limitation and which are designed to minimise the risks to our Members, visitors, and others.
Compliance with a legal obligation to which we are subject.

If we ask you to provide personal data to comply with a legal obligation or to perform a contract with you, we may not be able to comply with our legal obligation or enter into or perform the contract if you do not provide that personal data. We will advise you whether providing your personal data is mandatory and the possible consequences if you do not provide your personal data.

If another legal basis or legitimate interest is relevant to particular personal data processing, we will make that clear when we collect that personal data. If you have questions or need further information concerning the legal basis on which we process your personal data, please contact us using the contact details provided below.

If you are located in the EU or the UK, the data controller for the personal data that The Counsel collects is Myunidays Limited of 2 Castle Boulevard, Nottingham, Nottinghamshire, United Kingdom NG7 1FB. The ICO registration number is Z2692580.
If you are located in India, the legal entity responsible for personal data processing is UNiDAYS Private Limited, with its principal place of business at 4th Floor, Vedwati Apartments, Opposite Agriculture College, Shivaji Nagar, Pune, Maharashtra, India 411005.
If you are located in the U.S. or Canada, the legal entity responsible for personal data processing is Unidays Inc., Penn Plaza 9th Floor 132 W 31st St. New York City NY 10001, United States.
For all other jurisdictions, the legal entity responsible for personal data processing is MYUNIDAYS LTD of 2 Castle Boulevard, Nottingham, Nottinghamshire, United Kingdom NG7 1FB.

Our Data Protection Officer is available via dpo@myunidays.com.
Our EU representative is available at unidays_eu_representative@planit.legal.

If you are in the EU, the following will apply to you in addition to (and, in case of any inconsistencies, takes precedence over) the other provisions of this section:

If we process your personal data based on your consent, the legal basis is Art. 6(1)(a) of the U.K and EU General Data Protection Regulations (GDPR). You can withdraw your consent at any time (Art. 7(3) GDPR), effective for the future. This will not affect the legality of processing that took place before you withdraw your consent.
If the processing of your personal data is based on the performance of a contract, the legal basis is Art. 6(1)(b) GDPR.
If the processing of your personal data is based on legal obligations that we must fulfil, the legal basis is Art. 6(1)(c) GDPR.
If the processing of your personal data is based on our legitimate interests, the legal basis is Art. 6(1)(f) GDPR. Insofar as the processing is based on legitimate interests, you have the right to object to the processing (Art. 21 GDPR).
Pursuant to Art. 77 GDPR, you have a right to lodge a complaint related to the processing of your personal data, which you may exercise by submitting a complaint to your local data protection supervisory authority of the EU Member State of residence or where the issue that is the subject of the complaint occurred. We hope you will allow us to address your concerns by contacting us at info@myunidays.com,dpo@myunidays.com or unidays_eu_representative@planit.legal before you approach a supervisory authority, but otherwise, the contact details are available at https://edpb.europa.eu/about edpb/board/members_en.

How does The Counsel honour privacy rights requests?

You can always reach out to us with any questions or concerns regarding your data privacy rights.

If you are a resident in the United States of America, please see our US State Privacy Notice, which supplements this Privacy Policy and is available below.

For personal data for which we are the data controller, we honour the following privacy rights in accordance with applicable law:

If you wish to review, correct, update, suppress, restrict or delete your personal data:
For deletion, please contact us using the contact details provided below.
For access to the personal data that The Counsel has about you, please contact us using the contact details provided below.
For other requests, please contact us using the contact details provided below.
You can object to the processing of your personal data, request restrictions on the processing of your personal data, or request the portability of your personal data. To exercise these rights, please contact us using the contact details provided below.
You can opt-out of (or unsubscribe from) The Counsel’s email marketing communications by clicking the “unsubscribe” or “opt-out” link in one of our marketing emails or through your account settings. Please note that you cannot unsubscribe from certain communications, such as messages relating to business relationships, or system updates or system issues.
If we process your personal data based on your consent, you can withdraw your consent at any time by contacting us using the contact details provided below. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on a lawful basis other than consent.
If we process your personal data based on our legitimate interests, you have the right to object to that processing, subject to certain exceptions, by contacting us using the contact details provided below.

We will review your request as soon as reasonably practicable and respond within the time periods required by applicable law. In any request you submit to us, please make clear the personal data that are the subject of your request.

We respond to all requests we receive from individuals wishing to exercise their privacy rights in accordance with applicable data protection laws. Please know that the rights described above are not automatic rights and may not apply in all circumstances. When this occurs, we will notify you in our response to you.

For your protection, if you are a Member, we only fulfil requests for the personal data associated with the email address in your account and, if you are not a Member, we only fulfil requests for the personal data associated with the email address that you use to send us your request. We may need to request information from you to help us confirm your identity and ensure your right to access personal data. When we make these requests for more information, we do so as a security measure to ensure that your personal data are not disclosed to someone who has no right to receive your personal data. We also may contact you to ask you for further information in relation to your request to speed up our response.

Please note that we may need to retain certain personal data for recordkeeping purposes prior to requesting a change or deletion. Our databases and other records may have residual personal data which we cannot and will not remove. We also may not allow you to review certain personal data for legal, security, or other similar reasons.

Generally, no fee is associated with exercising your privacy rights but The Counsel may charge a reasonable fee if your request is unfounded, repetitive, or excessive.

IF YOU ARE LOCATED IN A JURISDICTION WITH PRIVACY LAWS THAT OFFER YOU PRIVACY RIGHTS NOT DESCRIBED IN THIS PRIVACY POLICY, PLEASE CONTACT US AT DPO@MYUNIDAYS.COM.

If you are in the EU or the UK, the following applies in addition to (and, in case of any inconsistencies, takes precedence over) the other provisions of this section:

You have the right to confirmation as to whether personal data relating to you are processed by The Counsel and the right to access this personal data or request a copy of it (Art. 15 GDPR), a right to rectification of your incorrect data (Art. 16 GDPR), a right to erasure (Art. 17 GDPR), and a right to restrict (block) your data (Art. 18 GDPR).
In addition, in the case of processing on the basis of Article 6(1)(e) or (f) GDPR, you may object to the processing (Art. 21 GDPR).
If you have provided the data, you can request the transmission of the data (Art. 20 GDPR).
If the processing is based on consent within the meaning of Art. 6(1)(a) or Art. 9(2)(a) GDPR, you can revoke consent at any time with effect for the future (Art. 7(3)(1) GDPR). You also have the right to contact the competent data protection supervisory authority (Art. 77 GDPR

Whether and to what extent these rights are effective in individual cases and under what conditions they apply is stipulated by law

The Counsel mostly uses session cookies that expire as soon as you close your Internet Browser. We only use persistent cookies to maintain the state of your questionnaire should you browse away from a survey and wish to continue where you left off. Please see our Cookie Policy for further detail.

If you decide to withdraw your consent to participate in the panel, your personally identifiable data will be deleted from The Counsel in line with data protection laws. QuMind on behalf of The Counsel reviews the panel every 6 months and removes non-active members. You will be contacted beforehand to make you aware of any inactivity on your account. Any member data in relation to The Counsel held thereafter will be in aggregate format for research purposes ONLY to allow for tracking long term trends in consumer behaviour. That is, no names, addresses or telephone numbers are attached to any answers, but instead answers are provided as counts and percentages.

Where does The Counsel process personal data?

Generally, we process personal data in the United Kingdom, Ireland and the United States, depending on the circumstances. We transfer data only as permitted by applicable law.

Your personal data may be transferred to and processed someplace other than where you live. These other jurisdictions may have privacy laws that are different from the laws of where you reside (and, in some cases, not as protective).

The Counsel servers are primarily located in Ireland but we store and replicate your personal data on servers in other places in order to provide speed of access, robustness, and protection against server failure. The other primary jurisdictions where personal data are processed by or on behalf of The Counsel are the United States of America and the United Kingdom.

Where your personal data is transferred by us or on our behalf, we use appropriate safeguards to protect your personal data in accordance with this Privacy Policy and applicable law. These safeguards include entering into Standard Contractual Clauses for transfers of personal data where applicable. We also may require additional safeguards depending on where personal data are transferred. Please contact us using the contact details below for more information.

When we share personal data with a third party acting as our processor, we do so subject to contractual obligations that require that the processor protect your personal data in accordance with this Privacy Policy.

How does The Counsel protect personal data?

We take care to secure and safeguard your personal data using various technological measures as required by applicable law.

Like any other organisation, we cannot fully eliminate security risks associated with the processing of personal data but The Counsel uses technical, physical, and administrative safeguards intended to protect the personal data that we process. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal data and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and a procedure for regularly testing, assessing, and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing of personal data.

You are responsible for maintaining the security of your account credentials. We will treat access to the Site through your account credentials as authorised by you.

We may suspend your use of all or part of the Site without notice if we suspect or detect any breach of security. If you believe that information you provided to us or your account is no longer secure, please notify us immediately at info@myunidays.com.

If we become aware of a breach that affects the security of your personal data, we will provide you with notice as required by applicable law. When permitted by applicable law, we will provide this notice to you through the email address associated with your account.

UNAUTHORISED ACCESS TO PERSONAL DATA AND THE SITE – INCLUDING SCRAPING – IS PROHIBITED AND MAY LEAD TO CRIMINAL PROSECUTION.

For how long will The Counsel retain personal data?

We only keep personal data as long as permitted by applicable law. We also anonymise certain personal data for our records.

We will only retain your personal data for as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements or to protect against fraud). We may retain your personal data for a longer period to address a complaint or if we reasonably believe that litigation in respect to our relationship with you is possible.

When we have no ongoing legitimate business need to process personal data, we will either delete or anonymise that personal data.

If we are not able to delete or anonymise certain personal data (for example, because your data are stored in backup archives or due to a legal requirement), then we will securely store the personal data and isolate the data from any further processing until deletion or anonymization is feasible.

The Counsel online resources are appropriately secured with firewall, packet filtering, port blocking software and updated with the latest security patches.

When and why does The Counsel update this Privacy Policy?

The Counsel may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update this Privacy Policy, we will post the updated version and change the “Last Updated” date above. We also will take appropriate measures to inform you so that you have an opportunity to review significant changes to this Privacy Policy, but please regularly check this Privacy Policy to ensure you are aware of the updated version.

How do I contact The Counsel?

For questions about this Privacy Policy or The Counsel’s’ personal data processing, please contact us at:

By Email: dpo@myunidays.com or unidays_eu_representative@planit.legal.
By Post: Myunidays Limited, ℅ DPO, 2 Castle Boulevard, Nottingham, Nottinghamshire, United Kingdom NG7 1FB
By Phone: +44 (0)115 985 3070

Our European Representative pursuant Art. 27 GDPR is PLANIT//LEGAL.

By Email: unidays_eu_representative@planit.legal.
By Post: PLANIT//LEGAL, Jungfernstieg 1 20095, Hamburg, Germany

Contact details

UNiDAYS appointed Data Protection officer: Email: DPO@myunidays.com

If you would like to change or deactivate personal information you have submitted in a survey in The Counsel, you can email us at unidays@qumind.raiseaticket.com

Counsel - US State Privacy Notice

Last updated: 19 July 2023

Notice for Citizens of the United States

Your privacy is our priority. We appreciate that you entrust us with your personal data and want you to know that we respect your privacy. Therefore, we have taken one approach to respecting and protecting US citizens’ privacy rights. In other words, we combined the highest degree of privacy rights granted by various US state laws that can be exercised by a US citizen indiscriminately. For completeness we have also added details of some state laws for awareness.

What rights can I exercise?

Right to Know/Access: You have a right to request that we disclose, up to two times per year: (1) the categories of personal information we have collected, sold, or shared about you; (2) the categories of sources from which your personal information was collected, sold, or shared; (3) the business or commercial purpose for collecting, selling, or sharing your personal information; (4) the categories of third parties to whom we’ve sold, shared, or disclosed for a business purpose your personal information; and (5) the specific pieces of personal information we have collected about you. You have a right to access your personal information subject to certain exceptions, and obtain a copy of the personal information in a portable format.
Right to Delete. You have a right to request that we delete the personal information we hold about you, subject to certain exceptions available under applicable law.
Right to Correct. You have a right to ask that we correct inaccurate or incorrect personal information we have collected about you, subject to certain exceptions available under applicable law. Also you can login to your account and make any correction to your personal information, as may be necessary.
Right to Opt-Out. You have a right to opt-out of the sale or sharing of your personal information or the use of your personal information for targeted advertising.
Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against.

How do I exercise my rights?

To submit a request for Right to Delete, please contact us at dpo@myunidays.com;
To submit a request for Right to Know/Access, please contact us at dpo@myunidays.com;
To submit a request for Right to Correct, please contact us at dpo@myunidays.com.
To submit a request to opt-out of the sale of your personal information, please contact us at dpo@myunidays.com.
To submit a request to opt-out of the sharing of your personal information, please contact us at dpo@myunidays.com.
To submit a request to opt-out of the use of your personal information for targeted advertising, please contact us at dpo@myunidays.com

Notice for California Residents - California Consumer Privacy Act

Definitions

Personal information. Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household.
Sensitive personal information. Social security number, driver’s license number, state identification card, passport number, account log-in and password, financial account and password, debit or credit card number and access code, precise geolocation information, race, ethnic origin, religious or philosophical beliefs, union membership, the content of your mail, email or texts other than those communications with us, genetic data, biometric information, health information, and information that concerns your sex life or sexual orientation.
Sell, sale, or sold. Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for money or other valuable consideration.
Share, shared, or sharing. Shearing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for cross-context behavioural advertising, whether or not for monetary or other valuable consideration.

Your Rights

You may designate an authorised agent to submit a request for any of the rights below on your behalf. When you use an authorised agent, you must provide the authorised agent with a signed written permission to do so. We may also ask you to verify your own identity directly with us. To submit a request for the Right to Know and Delete set out below please contact us on the contact details provided below.

Right to Know: You have a right to request that we disclose, up to two times per year: (1) the categories of personal information we have collected, sold, or shared about you; (2) the categories of sources from which your personal information was collected, sold, or shared; (3) the business or commercial purpose for collecting, selling, or sharing your personal information; (4) the categories of third parties to whom we’ve sold, shared, or disclosed for a business purpose your personal information; and (5) the specific pieces of personal information we have collected about you.
Right to Delete. You have a right to request that we delete the personal information we hold about you, subject to certain exceptions available under applicable law.
Right to Correct. You have a right to ask that we correct inaccurate or incorrect personal information we have collected about you, subject to certain exceptions available under applicable law.
Right to Opt-Out of the Sale or Sharing of Your Personal Information. You have a right to opt-out of the sale or sharing of your personal information.
Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against.

Notice of Collection

Below we identify the categories of personal information we have collected about California residents in the 12 months preceding the date this US State Privacy Notice was last updated. This list includes information about: (1) whether this information includes sensitive personal information; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting, selling, or sharing the personal information; and (4) the categories of third parties with whom we disclose such information.

Identifiers: Information such as your name, email address, type of educational institution attended, name of institution, duration of education, year of study, employment during education, date of birth, region of residence, account log-in, account name.
Sensitive Personal Information: Information used to secure your account (account log-in email address, password and account name)
Characteristics of protected classifications under California law: gender, ethnicity and age.
Internet or other Electronic Network Activity Information: Includes information about your interaction with our websites and applications, advertisements, and browsing history on our site.
Geolocation Information, such as your country or city-level location or time zone.
Inferences, derived from the above information, excluding Sensitive Personal Information to create a profile reflecting an individual’s preferences and characteristics.

Disclosure	Categories	Description
How do we collect this information?	Identifiers	We collect this category of information from you directly.
	Sensitive Personal Information*	We collect this category of information from you directly when you log in to the website or app.
	Characteristics of protected classifications under California law	We collect this category of information from you directly.
	Internet or other electronic activity information	We collect this category of information from you or your device(s) when you provide it to us or interact with us online (such as through our website).
	Geolocation information	We collect this category of information from you or your device(s) when you provide it to us or interact with us online.
	Inferences	We draw inferences about you from the information we collect from you or your device(s) when you provide it to us or interact with us online.
Does this include sensitive personal information?	Yes. * Denotes which categories may include sensitive personal information
Is the information “sold” or “shared”?	No.
What is our business purpose for collecting your information?	See “What Information does The Counsel collect and why”.
Who do we disclose this information to?	See “How does the Counsel share personal data”.
How long do we keep this information?	We keep the information identified above for so long as is reasonably necessary and proportionate to the original purpose for which we collected the information. We base our criteria in determining appropriate retention periods on regulatory and legal requirements, contractual requirements, business needs, and the expectations of you.

Notice of Disclosure for a Business Purpose
In the last 12 months preceding the date this Privacy Notice was last updated, we have not shared any information with third parties, for a business or commercial purpose, the types of information described in the “Notice of Collection” section above.

Notice of Sale and Sharing
In the last 12 months preceding the date this Privacy Notice was last updated, we have not shared or sold your personal information, as defined under California law.

Notice of Processing Sensitive Personal Information
We do not use California resident sensitive personal information to infer characteristics about California residents.

US-wide Metrics on Consumer Rights Requests for 2022

The following chart shows details about the consumer rights requests we received in the United States from January 1, 2022 to December 31, 2022:

Request Type	Received	Complied with in whole	Complied with in part	Denied	Average Days to Respond
Requests to Know	0	N/A	N/A	N/A	0 Days
Requests to Delete	0	N/A	N/A	N/A	5 Days
Requests to Opt-Out of Sales	243	243	0	0	0 Days

California’s “Shine in the Light” law

If you are a California resident and The Counsel customer, you have the right to request information from us once per calendar year regarding the customer information we share with third parties for the third parties’ direct marketing purposes. To request this information, please send an email to DPO@myunidays.com with ‘Request for California Privacy Information’ in the subject line and in the body of your message. We will provide the requested information to you via an email response.

California’s “Eraser Button” law

If you are a California resident under 18 years old and a registered user of the Site (as defined above), you can request that we remove content or information that you have posted to our website or other online services. Fulfilment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please contact us at DPO@myunidays.com

Notice For Virginia, Colorado, Utah, and Connecticut Residents

Definitions

Personal information. Information that is linked or reasonably linkable to an identified or identifiable individual.
Sensitive personal information. Information that includes data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation or citizenship or immigration status, the processing of genetic or biometric data for the purpose of uniquely identifying an individual, personal data collected from a known child, or precise geolocation data.
Sell, sale, or sold. The exchange of personal data for monetary or other valuable consideration.
Targeted advertising. Displaying advertisements to a consumer where the advertisement is selected based on personal data obtained or inferred from that individual’s activities over time and across nonaffiliated Internet web sites or online applications to predict such individual’s preferences.

Notice of Collection

To learn more about the categories of personal information we collect about you and how we use it, please see ‘What information does The Counsel collect and why’. To learn more about with whom we may share your personal information, please see ‘How does the Counsel share personal data’.

Your Rights

Right to Know and Access: You have a right to know whether The Counsel is processing your personal information, access such personal information subject to certain exceptions, and obtain a copy of the personal information in a portable format. The process for exercising this right is described above.
Right to Delete. You have a right to request that we delete your personal information. The process for exercising this right is described above.
Right to Correct. You have a right to ask that The Counsel correct the personal information it has about you, subject to certain exceptions. The process for exercising this right is described above.
Right to Opt-Out. You have a right to opt-out of the sale or use of your personal information for targeted advertising. The process for exercising this right is described above.
Right to Non-Discrimination. You have a right not to be discriminated against for the exercise of your rights described herein.

Notice for Nevada Residents

If you are a Nevada resident, you have the right to submit a request directing us not to make any sale of your personal information. The Counsel does not sell your personal information under Nevada law. However, to request email confirmation that we do not sell your personal information, please send an email to dpo@myunidays.com with “Request for Nevada Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you via an email response.