Privacy Policy

1. INTRODUCTION AND SCOPE

1.1 About Unicore.

Unicore Growth Partners, Inc. ("Unicore," "we," "us," or "our") is a governance, risk management, and compliance services and technology company providing advisory, licensing, readiness, operational, assessment, assurance, and technology-enabled services, including access to Unicore's proprietary technology platform (collectively, the "Services" and the "Platform").

"Affiliates" means any entity that directly or indirectly controls, is controlled by, or is under common control with Unicore.

"Personal Information" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (including individuals acting in a business or professional capacity) or, where and to the limited extent required by applicable law, a household, as defined under applicable privacy and data protection laws. "Personal Information" and "personal data" have the same meaning.

Trust, security, and transparency are foundational to Unicore’s business. Unicore is committed to protecting Personal Information entrusted to Unicore and to maintaining clear, accurate disclosures regarding Unicore’s data practices.

Unicore’s Services, Platform, and business activities are directed exclusively to organizations and their personnel acting in a business or professional capacity. Unicore does not offer consumer-facing services or process Personal Information for personal or household purposes except where required by applicable law.

1.2 Purpose.

This Privacy Policy explains how Unicore collects, uses, discloses, and otherwise processes Personal Information when Unicore acts as a "Controller" (the entity that determines the purposes and means of processing Personal Information) or as a "Business," as those terms are defined under applicable privacy and data protection laws.

This Privacy Policy applies to Personal Information processed by Unicore in connection with:

1. Unicore’s websites at unicoregp.com and related subdomains, online properties, and digital communications that link to this Privacy Policy (the "Sites");
2. marketing, demand generation, paid advertising, events, webinars, and related communications;
3. contracting, onboarding, and relationship management with customers, partners, and vendors; and
4. other business interactions where Unicore determines the purposes and means of processing Personal Information.

1.3 Scope Exclusions.

This Privacy Policy does not apply to:

(a) Client Data that Unicore processes solely on behalf of a customer as a "Processor" or "Service Provider" pursuant to a written agreement, including any applicable data processing addendum ("DPA"), in which case the customer determines the purposes and means of processing and the customer’s privacy notice and the applicable written agreement govern;
(b) information that has been de-identified, aggregated, or is otherwise excluded from the scope of applicable privacy and data protection laws; or
(c) Personal Information collected in the context of Unicore’s workforce, including job applicants, employees, officers, directors, and independent contractors, which is addressed in separate notices where required by law.

Where Unicore processes Client Data on behalf of a customer, Unicore does so solely in accordance with the customer’s documented instructions and applicable contractual requirements.

1.4 Priority.

This Privacy Policy is not a contract and does not modify or supersede agreements between Unicore and its customers. In the event of a conflict between this Privacy Policy and a written agreement, the written agreement controls, except where applicable law requires otherwise.

This Privacy Policy is provided for transparency purposes only and does not create contractual obligations, representations, or warranties beyond those expressly set forth in the applicable written agreement.

Without limiting the foregoing, this Privacy Policy does not constitute a representation regarding Unicore’s compliance with any specific law, regulation, regulatory examination manual, audit or assurance standard, professional framework, or contractual obligation, all of which are addressed solely in applicable written agreements and, where relevant, Unicore’s documented compliance program materials and independent assurance reports made available under appropriate confidentiality terms.

1.5 Definitions.

"Business" means an entity that determines the purposes and means of processing Personal Information and that is subject to applicable privacy and data protection laws (including, where applicable, certain United States state privacy laws).

"Client Data" means data, information, content, records, or materials submitted to or otherwise made available to Unicore through the Services or Platform by or on behalf of a customer, including Personal Information to the extent included therein, that Unicore processes on the customer’s behalf as a Processor or Service Provider in connection with the Services or Platform, as described in the applicable written agreement (including any DPA).

"Controller" means the entity that determines the purposes and means of processing Personal Information, as defined under applicable privacy and data protection laws.

"GPC" means Global Privacy Control, a browser-based signal indicating a request to opt out of the sale or sharing of Personal Information for targeted advertising, where such concepts apply under applicable law.

"Inferences" means conclusions drawn from Personal Information to understand general engagement trends, service utilization, or business-to-business interests, as further described in "Use of Inferences".

"Platform" means Unicore’s proprietary technology platform.

"Processor" means an entity that processes Personal Information on behalf of a Controller pursuant to documented instructions, as defined under applicable privacy and data protection laws.

"Sensitive Personal Information" means Personal Information that is considered sensitive under applicable privacy and data protection laws.

"Service Provider" means a third party that processes Personal Information on behalf of a Business pursuant to a written agreement that restricts the use of Personal Information to specified purposes and requires appropriate security measures, as defined under applicable privacy and data protection laws (including, where applicable, certain United States state privacy laws).

"Services" means Unicore's advisory, licensing, readiness, operational, assessment, assurance, and technology-enabled services, including access to the Platform, and may include licensing application preparation and submission, compliance audits, independent reviews, or assessment services intended to result in a final written report, but only to the extent expressly identified in an applicable Order Form. References to Services in this Privacy Policy do not imply third-party reliance, legal advice, Legal Support Services, litigation use, or expert services unless expressly agreed in a written contract.

"Sites" means Unicore’s websites at unicoregp.com and related subdomains, online properties, and digital communications that link to this Privacy Policy.

1.6 Product-Specific Notices.

Unicore publishes a product-specific privacy notice for an application through which Unicore processes data this Privacy Policy does not cover. The notice states the application it covers and the processing it describes. Where an application requires a notice, Unicore publishes that notice before it makes the application available.

The Atlas for Google Docs™ add-on is described in the Atlas for Google Docs™ Privacy Notice at unicoregp.com/privacy/atlas-google-docs.

2. UNICORE'S ROLES AND RESPONSIBILITIES

Under applicable privacy and data protection laws, Unicore may act as:

1. a Controller (or Business, where such concept applies), when Unicore determines the purposes and means of processing Personal Information, including in connection with the Sites, marketing activities, events, sales, contextual business-to-business advertising, security monitoring, analytics, vendor management, and internal compliance activities; or
2. a Processor (or Service Provider, where such concept applies), when Unicore processes Personal Information solely on behalf of a customer pursuant to a written agreement and documented customer instructions.

Unicore does not sell Personal Information as "sell" (or similar terms) are defined under applicable privacy and data protection laws (including, where applicable, certain United States state privacy laws). Unicore does not share Personal Information for cross-context behavioral advertising or targeted advertising. Where applicable law treats certain disclosures via cookies or similar technologies as "sharing," Unicore honors opt-out signals and requests for the applicable browser, device, and context to the extent required by applicable law, including GPC where required.

Unicore limits advertising to first-party, contextual, or business-to-business communications and does not track individuals across third-party properties for advertising purposes.

3. PERSONAL INFORMATION UNICORE COLLECTS

3.1 Categories of Personal Information.

Depending on the nature of the interaction with Unicore, Unicore may collect the following example categories of Personal Information:

3.2 Sensitive Personal Information and Restricted Data.

Unicore does not intentionally collect or use Sensitive Personal Information except where necessary to provide the Services, comply with legal obligations, or as otherwise permitted by law.

Unless expressly authorized under an applicable written agreement, customers must not provide, and the Services and Platform are not intended to process: (a) protected health information under the Health Insurance Portability and Accountability Act of 1996, (b) payment card data subject to the Payment Card Industry Data Security Standard, (c) nonpublic personal information as defined under the Gramm-Leach-Bliley Act, or (d) other sensitive data requiring heightened safeguards (collectively, "Restricted Data").

3.3 Sources of Personal Information.

Unicore collects Personal Information from:

1. individuals or their organizations directly, including through calls that may be recorded (where required by applicable law, Unicore provides notice of recording at the start of the call and obtains consent);
2. customers and partners in connection with the Services;
3. Service Providers supporting Unicore's operations, such as hosting, analytics, customer relationship management, and marketing providers;
4. sign-in providers, when an individual signs in to the Platform or to an application Unicore makes available, which provide the individual's email address and account identifier and, where the individual authorizes it, their name;
5. publicly available or professional sources; and
6. automated technologies when individuals interact with the Sites or Platform.

3.4 Disclosure Summary.

The following table summarizes the categories of Personal Information Unicore collects, the sources, purposes, and categories of third parties to whom Unicore discloses Personal Information for business purposes:

3.5 Use of Inferences.

Unicore derives Inferences from the categories of Personal Information described above solely to understand general engagement trends, service utilization, and business-to-business interests. Unicore does not use Inferences to evaluate personal characteristics, predict individual behavior, create consumer profiles for targeted advertising, or make decisions producing legal or similarly significant effects on individuals.

4. HOW UNICORE USES PERSONAL INFORMATION

Unicore uses Personal Information for the following purposes:

1. operating, maintaining, securing, and improving the Sites, Services, and Platform;
2. communicating with customers, prospects, partners, and vendors;
3. recording and transcribing calls for quality assurance, training, and dispute resolution purposes, with notice provided at the time of collection where required by applicable law;
4. marketing, demand generation, event management, and contextual business-to-business advertising;
5. managing contracts, billing, accounting, and business relationships;
6. conducting analytics, research, and service improvement;
7. maintaining security, fraud prevention, monitoring, and system integrity;
8. confirming that an account is used by the individual it belongs to, and recording that an individual accepted a privacy notice and which version;
9. complying with legal, regulatory, and professional obligations; and
10. evaluating and completing corporate transactions, such as financings, mergers, acquisitions, or restructurings.

Where required by law, Unicore relies on appropriate legal bases for processing, including performance of a contract, legitimate interests (such as marketing Unicore's Services, improving the Platform, maintaining security, and managing business relationships), compliance with legal obligations, and consent.

4.1 Automated Processing and Human Oversight.

The Platform may use artificial intelligence and machine learning technologies to support compliance analytics, risk assessment, workflow automation, and information retrieval. These technologies surface information, identify patterns, and generate insights for human review.

Unicore does not use automated processing to make decisions that produce legal or similarly significant effects on individuals.

Unicore uses third-party language model providers to deliver certain Platform features. Where a feature requires it, Unicore sends content and prompts to those providers under written agreements that limit their use of that content to delivering the feature. Unicore does not use, and does not permit those providers to use, customer content or Personal Information to train, fine-tune, or improve any model. Providers keep a copy of what Unicore sends and returns for a limited period so that they can investigate misuse of their own services, then delete it. Unicore names its current providers, their retention periods, and their processing locations at trust.unicoregp.com. That page is public and requires no account. Unicore updates it before engaging a new provider.

Outputs generated through automated processing undergo meaningful human review, and human reviewers make final determinations, recommendations, and decisions. The customer retains sole responsibility for evaluating and acting on outputs generated by the Platform.

Platform functionality, automated outputs, dashboards, alerts, workflows, or analytics do not constitute legal advice, audit opinions, conclusions, certifications, or attestations, and do not replace professional judgment. Customers retain sole responsibility for evaluating and acting on Platform outputs and for compliance outcomes.

Nothing in this Privacy Policy alters or expands Unicore’s obligations, representations, or warranties regarding the Services or Platform as set forth in the applicable agreement.

5. COOKIES AND SIMILAR TECHNOLOGIES

5.1 What the Sites Use.

The Sites use cookies and browser storage to keep the Sites secure and working, and to measure how the Sites are used. The web pages of the Sites use no advertising, session recording or cross-site tracking technologies.

5.2 Strictly Necessary.

These run for every visitor and cannot be turned off, because the Sites cannot be offered securely without them.

5.3 Analytics.

Unicore uses Google Analytics to count visits and see which pages are read, so it can improve the Sites. Google Analytics sets the cookies _ga and _ga_RNB8PRDS1T, which last up to two years, and sends information about your visit to Google. Unicore has turned off Google's advertising features and data sharing for its Google Analytics account. Google Analytics does not run for visitors in the European Union, the European Economic Area, the United Kingdom, Jersey, Guernsey, the Isle of Man or Gibraltar, or when Unicore cannot determine a visitor's country.

5.4 Your Choices.

You can turn analytics off at any time under "Privacy choices" at the foot of every page; turning it off deletes the analytics cookies. If your browser sends a Global Privacy Control signal, Unicore treats it as a choice to turn analytics off. You can also block or delete cookies in your browser's settings. Unicore does not respond to "Do Not Track" signals.

6. DISCLOSURE OF PERSONAL INFORMATION

Unicore may disclose Personal Information to:

1. Service Providers and professional advisors acting on Unicore's behalf, including cloud hosting providers, analytics providers, customer relationship management providers, payment processors, and other vendors contractually obligated to use Personal Information only for the purposes for which it was disclosed and to maintain appropriate security measures;
2. Affiliates within the Unicore corporate group;
3. Language model providers that process content solely to deliver Platform features the customer has requested, under written agreements that prohibit any other use, including model training;
4. Customer organizations and partners, as necessary to provide the Services or Platform (for example, to provision accounts, administer access, and support the customer relationship);
5. Regulators, courts, or law enforcement where required by law or legal process; and
6. Transaction counterparties and advisors in connection with corporate transactions.

Unicore does not sell Personal Information as "sell" (or similar terms) are defined under applicable privacy and data protection laws (including, where applicable, certain United States state privacy laws). Unicore does not share Personal Information for cross-context behavioral advertising or targeted advertising. Disclosures to Service Providers for marketing purposes are limited to contextual and business-to-business advertising and do not constitute a "sale" or "sharing" under applicable law.

7. DATA RETENTION

Unicore retains Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with legal, regulatory, and professional obligations, resolve disputes, enforce agreements, and maintain appropriate records. Retention periods may vary based on contractual requirements, regulatory obligations, professional standards, litigation holds, audit requirements, or operational needs.

Illustrative retention periods (which may be extended as described above) include:

These illustrative retention periods are subject to extension where required by applicable law, regulation, professional standards, audit requirements, or legal hold obligations.

Unicore may retain de-identified or aggregated information indefinitely where permitted by law. Where a product-specific privacy notice states a retention period for data processed through that product, that period controls.

8. DATA SECURITY AND TRUST PROGRAM

8.1 Security Program.

Unicore maintains an information security program protecting the confidentiality, integrity, and availability of Personal Information. To the extent required by law, Unicore notifies applicable individuals or customer organizations of confirmed unauthorized access to or disclosure of Personal Information constituting a reportable security incident and cooperates in incident response as required by law.

8.2 Certifications and Assurance.

Unicore maintains a certified information security and artificial intelligence management program. Unicore has achieved certification under ISO/IEC 27001 (Information Security Management Systems) and ISO/IEC 42001 (Artificial Intelligence Management Systems), as assessed by an accredited certification body.

In addition, Unicore undergoes independent SOC 2 Type II examination covering applicable systems and controls and conducts periodic security testing, which may include penetration testing and vulnerability assessments performed by qualified third parties.

The scope, timing, methodology, and results of any certification, examination, or security testing are determined by Unicore based on risk and industry practices and may vary over time. Such certifications, examinations, and testing do not cover all systems, Services, data, or processing activities and do not constitute representations, warranties, guarantees, or third-party rights regarding the security of Personal Information or the absence of vulnerabilities.

Unicore publishes its Trust Center at trust.unicoregp.com, which states Unicore's current certifications, its Service Providers and language model providers, the role each serves, its retention period, and its processing location. That page is public and requires no account. Unicore provides certification reports, attestations, and detailed security documentation on request, subject to appropriate confidentiality and nondisclosure restrictions.

8.3 Infrastructure.

Unicore may process Personal Information using cloud infrastructure provided by reputable third-party cloud service providers that maintain their own security certifications and compliance programs.

8.4 No Guarantee.

No security program eliminates all risk. This Privacy Policy does not create and should not be interpreted as creating any guarantee, warranty, or assurance regarding the security of Personal Information or the prevention of unauthorized access, disclosure, alteration, or loss. By using Unicore's Services or providing Personal Information to Unicore, individuals acknowledge that no method of electronic transmission or storage is completely secure.

9. INTERNATIONAL DATA TRANSFERS

Unicore and Unicore's Service Providers operate in multiple jurisdictions. Unicore may process Personal Information in jurisdictions outside an individual's place of residence, including in any country where Unicore or Unicore's Service Providers maintain facilities or engage personnel.

Where required by applicable law, Unicore implements appropriate safeguards for cross-border transfers, such as standard contractual clauses or other approved transfer mechanisms recognized under applicable privacy and data protection laws. Where transfers occur between jurisdictions with recognized equivalent data protection standards, additional transfer mechanisms may not be required.

10. PRIVACY RIGHTS

10.1 Applicable Laws.

Unicore complies with applicable privacy and data protection laws to the extent such laws apply to Unicore’s processing of Personal Information based on an individual’s residency, Unicore’s activities, and Unicore’s role as a Controller or Business.

10.2 Rights of Individuals.

Subject to applicable law and certain exceptions, individuals may have the following rights:

Global Privacy Control. Where required by applicable law, Unicore honors the GPC signal as a valid opt-out request for the applicable browser, device, and context.

10.3 Submitting Requests.

Individuals may submit requests using the contact methods described in "Contact Unicore".

When submitting a request, include:
(a) full name and email address associated with interactions with Unicore;
(b) a description of the right to be exercised;
(c) sufficient information to verify identity; and
(d) preferred method of response.

10.4 Verification.

Unicore may need to verify an individual's identity before responding to a request. Unicore verifies identity by matching information provided against information Unicore maintains. For certain requests, Unicore may require additional documentation or information to confirm identity and authority.

10.5 Authorized Agents.

Individuals may designate an authorized agent to submit a request on their behalf by providing the agent with signed written permission. If an authorized agent is used, Unicore may require the individual to verify identity directly with Unicore and confirm that the agent was authorized to act on the individual's behalf. Unicore may deny requests from agents that do not submit proof of authorization.

10.6 Response Timeframes.

Unicore responds to verifiable requests within the timeframe required by applicable law, generally within forty-five (45) days of receipt. If Unicore requires additional time due to the complexity or volume of requests, Unicore informs the individual of the reason and extension period in writing. Unicore does not take longer than ninety (90) days to respond to a request, or such shorter period as required by applicable law.

10.7 Appeals.

If Unicore declines to take action on a request, Unicore informs the requestor of the reasons and, where required by applicable law, the right to appeal.

To appeal a decision, submit a request to [email protected] with "Privacy Appeal" in the subject line. Unicore responds to appeals within the timeframe required by applicable law. Where required by applicable law, Unicore also provides information on external recourse available to the requestor.

10.8 Direct Marketing Disclosures.

Certain privacy laws permit individuals to request information regarding whether a business has disclosed Personal Information to third parties for such third parties’ own direct marketing purposes. Unicore does not disclose Personal Information to third parties for their own direct marketing purposes.

This disclosure is provided for statutory transparency purposes only and does not limit or modify Unicore’s obligations under other applicable privacy and data protection laws.

10.9 Other Jurisdictions.

Individuals may have rights under applicable privacy and data protection laws that vary by jurisdiction. Where such laws apply to Unicore’s processing of Personal Information, Unicore complies with those laws as required.

Depending on the applicable law and Unicore’s role as a Controller or Business, such rights may include the right to request access to, correction or deletion of Personal Information, to object to or restrict certain processing, to request portability, and to lodge a complaint with a competent supervisory authority. Any such rights are subject to applicable conditions, limitations, and exceptions under the relevant law.

This Section does not create rights beyond those provided under applicable law and does not apply to Client Data processed by Unicore solely as a Processor or Service Provider on behalf of a customer pursuant to a written agreement, which is governed by the applicable data processing agreement and the customer’s privacy notice.

11. CHILDREN'S PRIVACY

The Sites and Services are not directed to children, and Unicore does not knowingly collect Personal Information from children under the age of sixteen (16). If Unicore becomes aware that Unicore has collected Personal Information from a child under 16, Unicore takes steps to delete such information. If a parent or guardian believes a child has provided Unicore with Personal Information, contact Unicore as described in "Contact Unicore."

12. THIRD-PARTY WEBSITES AND SERVICES

The Sites may contain links to third-party websites or services. Unicore is not responsible for the privacy practices of those third parties. Individuals are encouraged to review the privacy policies of third-party websites they visit.

13. CHANGES TO THIS PRIVACY POLICY

Unicore may update this Privacy Policy from time to time to reflect changes in Unicore's practices, technologies, or legal requirements. Unicore posts updates with a revised effective date.

For material changes that significantly affect how Unicore uses or shares Personal Information, Unicore provides prominent notice on the Sites or, where required by applicable law, notifies individuals by email prior to the changes taking effect.

Unicore assigns a version number and an effective date to this Privacy Policy and to each product-specific privacy notice. Unicore keeps superseded versions of this Privacy Policy and provides them on request to [email protected].

14. CONTACT UNICORE

If individuals have questions or requests regarding this Privacy Policy or Unicore's privacy practices, including requests to exercise privacy rights, contact Unicore at:

Email: [email protected]

Mail:
Unicore Growth Partners, Inc.
Attn: Privacy
4300 Biscayne Blvd, Suite 203
Miami, FL 33137

15. TRADEMARKS

Google Docs™ is a trademark of Google LLC. Unicore is not affiliated with, endorsed by, or sponsored by Google LLC.