Privacy Shield

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SaGuLi Inc. (“Unlitics”) has adopted this Privacy Shield Policy (“Policy”) to establish and maintain an adequate level of Personal Data protection. This Policy applies to the processing of Personal Data that Unlitics obtains from persons located in the Delaware and New York, United States.

Unlitics complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information obtained from Data Subjects or Individuals in the European Union member countries and United States. Unlitics has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, please visit

The Federal Trade Commission (FTC) has jurisdiction with enforcement authority over Unlitics’s compliance with the Privacy Shield.

All Unlitics employees who handle Personal Data from Europe and United States are required to comply with the Principles stated in this Policy.

Capitalized terms are defined in Section 14 of this Policy.

Unlitics provides software and/or services that allow Corporate Customers to monitor their own website visitors’ online interactions. In doing so, Unlitics receives information from Data Subjects that visit Corporate Customers’ websites and Individuals that use Unlitics’s software and/or services on behalf of Corporate Customer. In the first case, Unlitics acts as a Data Processor. In the second case, Unlitics acts as a Data Controller and collects Personal Data from Individuals in order to provide and operate its software and/or services to a Corporate Customer.


Unlitics will prepare an internal verification on an annual basis.


Unlitics does not disclose personal information to third parties for purposes that are materially different than what it was originally collected for. If this practice should change in the future we will update this policy, identify the third parties, and provide an opt-out choice.


Unlitics also may disclose Personal Data for other purposes or to other Third Parties when an Individual or Data Subject has consented to or requested such disclosure. Please be aware that Unlitics may be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. Unlitics is liable for appropriate onward transfers of Personal Data to third parties.


Address:Unlitics by SaGuLi Inc., 188 Grand Street Unit #201 New York, NY 10013 Email Address: info@unlitics.comprivacy [at] Unlitics [dot] com

“Employee” means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Unlitics or any of its affiliates or subsidiaries, who is also a resident of a country within Europe or the European Economic Area (EEA).

“Europe” or “European” refers to a country in the European Union.

“Individual” means a Data Subject that is an employee, contractor, agent, or representative of a Corporate Customer.

“Personal Data” as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual’s name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, email address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For the United States, the term “person” includes both a natural person and a legal entity, regardless of the form of the legal entity.

Last updated on: 14 December, 2021