This Privacy Policy (“Policy”) explains how Qubeletum OÜ (“we”, “us”, “our”), registry code 17316925, Pille tn 11/1-32, Kesklinna linnaosa, Tallinn, 10138, Estonia, processes personal data collected through the website https://unlocksy.net (the “Website”) and related services including purchases, user accounts, support, and community interactions. This version complies with the strictest standards applied by European banks and payment service providers (PSPs) for onboarding and acquiring.

Controller: Qubeletum OÜ (registry code 17316925) is the data controller responsible for all personal data collected via unlocksy.net.
Processor: Itemare OÜ (registry code 17309345) provides operational and technical services to Qubeletum OÜ under a Data Processing Agreement (Art. 28 GDPR).

We process data based on:

• Contract performance (Art. 6(1)(b)) — account, purchases, support.
• Legal obligations (Art. 6(1)(c)) — accounting, tax, AML compliance.
• Legitimate interest (Art. 6(1)(f)) — fraud prevention, service improvement, security.
• Consent (Art. 6(1)(a)) — analytics, marketing, cookies, newsletters.

We retain data only as long as necessary:

We do not activate non-essential cookies (analytics, marketing) before consent. The cookie banner provides equally prominent 'Accept all' and 'Reject all' options. Continuing browsing or scrolling does not constitute consent. Full details are available in our Cookie Policy.

We share data only with trusted providers under GDPR-compliant contracts:

• Payment providers (PSPs) — to process transactions securely.
• Anti-fraud vendors — for bot mitigation and risk scoring.
• Hosting and CDN — EU-based infrastructure.
• Analytics tools — only with consent.
• Email and CRM — only for opted-in communications.

Where data is transferred outside the EEA (e.g., to the USA), we rely on:

• The EU–US Data Privacy Framework (DPF) if the recipient is certified; or
• Standard Contractual Clauses (SCCs) with supplementary measures (Schrems II compliance).

We conduct DPIAs for processing activities that may pose high risks to individuals (e.g., payment data, fraud detection) and implement appropriate safeguards to minimize those risks.

We apply encryption in transit and at rest, Secure/HttpOnly cookies, restricted access controls, least privilege principles, and routine vulnerability reviews. No full card data is stored on our servers.

You have the right to access, rectification, erasure, restriction, data portability, and objection (Arts. 15–22 GDPR). You may withdraw consent at any time without affecting prior processing. You also have an absolute right to object to direct marketing (Art. 21 GDPR).

We do not engage in automated decision-making producing legal effects. Limited profiling may be used exclusively for fraud prevention or security purposes under human supervision.

Our services are not directed to children under 16. We do not knowingly collect children’s data. If you believe a child has provided data, please contact us for immediate deletion.

For any inquiries regarding data protection, contact our DPO:
Email: privacy@unlocksy.net
Address: Qubeletum OÜ, Pille tn 11/1-32, Tallinn, 10138, Estonia.

You may lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon): https://www.aki.ee/en, or with your local EU supervisory authority.

We update this Policy periodically. Changes will be posted with a new Effective Date. Material updates will be communicated before they take effect.