14 April 2020
Welcome to Ungraded. We may process personal data as defined in the General Data Protection Regulation (hereinafter: "Personal Data") when you visit our website https://ungraded.video/ (hereinafter: the "Website") and when we provide you our services (hereinafter: the "Services").
In this Privacy Statement we explain to you what Services we provide, which Personal Data we collect from you and for what purposes we do that. We recommend that you read this document carefully. This document was last amended on 14 April 2020.
We provide our Services through the Ungraded platform (hereinafter: the “Platform”). On the Platform drone pilots (hereinafter: “Suppliers”) can provide drone footage and users (hereinafter: “Users”) can purchase licenses to the provided drone footage.
Your privacy is important to us
Careful handling of Personal Data is of great importance to us. Personal Data is therefore processed carefully and in accordance with this Privacy Statement and the applicable laws and regulations. This means we:
- clearly specify our purposes before we process Personal Data, by using this Privacy Statement;
- limit our collection of Personal Data to only the Personal Data needed for our purposes;
- first ask for explicit and specific permission to process your Personal Data in cases where your permission is required;
- take appropriate security measures to protect your Personal Data and we demand the same from parties who process Personal Data on our behalf;
- respect your rights to access, correct, object or delete your Personal Data held by us.
Your Personal Data is safe with us and we will use your Personal Data properly. In this Privacy Statement we explain to you what we do with your Personal Data when you visit the Website and/or you use our Services.
If you have any questions or want more information about what Personal Data we collect for what purposes, please contact us by using the contact details listed at the bottom of this document.
Your Personal Data as a User
When you – as a User – make use of our Services, we request that you provide us the following data, including Personal Data:
- First name(s);
- Last name; and
- Email address.
After providing the aforementioned data an account is created with which you can order licenses to drone footage available on the Platform. We need the above required information to know who you are in order to create an account.
The legal basis for the processing of these Personal Data is article 6 (1) (b) GDPR: processing of this Personal Data is necessary for the performance of the contract concluded between User and Ungraded.
When ordering a license to the footage as a User, we process the following (additional) data, including Personal Data:
- Invoice data:
- (company) name;
- zip code;
- country; and
- payment method);
- the IP address through which the payment is made.
We need the the aforementioned additional data to send you an invoice for the ordered license(s) and for our administration.
We save the aforementioned information during the time that your account on the Platform is in use, unless there is a legal obligation under which we have to save the information for a longer period. This may, for example, be a tax retention obligation.
The legal bases for the processing of these Personal Data are article 6 (1) (b) GDPR: processing of this Personal Data is necessary for the performance of the contract concluded between User and Ungraded and article 6 (1) (c) GDPR: processing is necessary for compliance with a legal obligation to which the Ungraded is subject, such as a tax retention obligation.
Your Personal Data as a Supplier
When providing drone footage to the Platform through the Service, we request that you – as a Supplier – provide us the following data, including Personal Data:
- First names;
- Last name;
- Company name;
- Email address;
- Drone footage; and
- Payment details:
- International Bank Account Number (IBAN); or
- PayPal address (name, email address or mobile phone number).
After providing the aforementioned data an account is created with which you can upload drone footage to the Platform. We need the above required information (1-5) to know who you are in order to create an account. We need the drone footage (6) to provide the Service to you as a Supplier. We need the payment details (7) to pay out profit shares for sold licenses to the by you provided drone footage.
We save the aforementioned information during the time that your account on the Platform is in use, unless there is a legal obligation under which we have to save the information for a longer period. This may, for example, be a tax retention obligation. However, the drone footage you have added to the Platform will remain available, until Ungraded removes the drone footage from the Platform in accordance with the agreement.
The legal basis for the processing of these Personal Data is article 6 (1) (b) GDPR: processing of these Personal Data is necessary for the performance of the contract concluded between the Supplier and Ungraded.
Payment Service ProviderWhen purchasing licenses to drone footage on the Platform, you have to make a payment through the secured Mollie payment module (https://www.mollie.com). Mollie is a Payment Service Provider (PSP) and handles payments between us and PayPal, your bank or your credit card provider.
Mollie receives your payment details (bank account number, credit card number or PayPal-account name), your IP address, the name of your internet browser, device type, your name and your address. Mollie only lets us know if the payment was successful and it then transfers the payment to us. The payment will be shown on your bank statement under the following text: "Mollie", "Stg Mollie Payments" or "Stichting Mollie Payments".
We only have access to the transaction details and the used payment method. The to us accessible transaction details depend on the used payment method. We have access to your full name and:
- your bank account number (when paid by bank transfer);
- the last 4 numbers of your credit card number and the credit card country (when paid with credit card); or
- your email address (when paid with PayPal).
Mollie is located in the European Union.
Because Mollie itself is responsible for processing your Personal Data, we would like to refer you to the privacy statement of Mollie for more information. Please read this document carefully.
You can subscribe to our newsletter by filling in the form on our Website. In the newsletter you can read news, tips and information about our Website, Services, offers and/or new services. You can cancel this subscription at any time. Every newsletter contains an unsubscribe link.
Your email address will only be added to the list of subscribers with your explicit permission. Your email address is saved until you cancel the subscription.
In sending our newsletter we work together with email service provider Mailchimp (created by The Rocket Science Group, LLC) that can receive the above mentioned Personal Data from us. Mailchimp is located outside the European Union, namely in the United States.
The legal basis for the use of this service is article 6 (1) (a) GDPR: consent of the data subject. You gave freely consent for the subscription to our newsletter.
Google AnalyticsWe use Google Analytics to keep statistics on the use of the Website and our Services. These statistics help us to, for example, only show you information that is relevant to you. Cookies may be placed to use this service. The cookies are set by Google Inc. The information obtained with the cookie (such as your IP address) can be transferred by Google to servers in the United States.
We have asked Google to anonymize your IP address. This means Google Analytics anonymizes the IP address as soon as technically feasible at the earliest possible stage of the collection network. The IP anonymization feature in Google Analytics sets the last octet of IPv4 user IP addresses and the last 80 bits of IPv6 addresses to zeros in memory shortly after being sent to the Analytics Collection Network. The full IP address is never written to disk in this case.
The legal basis for the use of this service is article 6 (1) (f) GDPR: processing is necessary for the purpose of our justified interest. Our justified interest in using this service is based on analyzing and optimizing the operation of our Website.
Google AdsWe use Google Ads to measure if online advertisements are successful and for remarketing. The remarketing function allows us to present to visitors of our Website advertisements based on their interests. For this purpose, the interaction of visitors on our Website is analyzed, for example which offers the user was interested in, in order to be able to display targeted advertising to users on other websites after visiting our Website. Cookies may be placed to use this service. The cookies are set by Google Inc. This cookies are valid for a limited time.
The legal basis for the use of this service is article 6 (1) (a) GDPR: consent of the data subject. You gave freely consent for the placement of the cookie in the cookie notification.
Segment.ioWe use Segment.io for bringing together and analysing the personal usage data from various sources, including your use of our Website and the Services, and to carry out and measure the effectiveness of our (personalised) marketing campaigns. Cookies may be placed to use this service. The cookies are set by Segment.io, Inc. The information obtained with the cookie (such as your IP address) can be transferred to servers in the United States.
The legal basis for the use of this service is article 6 (1) (f) GDPR: processing is necessary for the purpose of our justified interest. Our justified interest in using this service is based on analyzing and optimizing the operation of our Website, Service and online advertisements.
Please read the privacy statement of Segment.io.
SecuritySecurity of Personal Data is very important to us. We ensure that your data is properly secured with us. We always adjust the security and pay close attention to what can go wrong.
We ensure that only the necessary people have access to your data, that access to your Personal Data is protected and that our security measures are regularly checked and evaluated. Among others, we take the following security measures:
- Physical measures for access security;
- Logical access control on our computers and systems, using passwords;
- Organizational measures for access security;
- Encryption of digital files; and
- Security of network connections via Secure Socket Layer (SSL) technology.
Providing Data to Third PartiesWe will not provide your Personal Data to other parties than the parties mentioned in this Privacy Statement, unless this is necessary for our Services or if we are legally obliged to do so (for example if the police so require in the event of a suspicion of a crime). We will inform you about which other parties will receive your information.
We place a number of cookies for functional purposes, such as for the WordPress Content Management System and to keep track of your session.
In addition, we also place cookies for analytical purposes. With the help of cookies placed by, Google Analytics, Google Ads, and Segment.io we keep statistics of the use of the Website. Reports can also be obtained to see how visitors use the Website. For more information see the explanation under the heading “Google Analytics”, ” and/or “Segment.io”.
With your permission our advertisers can store tracking cookies on your devices. These cookies are used to keep track of the pages you visit on the advertiser’s network, in order to build up a profile of your online surfing habits. This profile is also built on the basis of comparable information they get from your visits to other websites from their network. This profile is not linked to your name, address, email address or other Personal Data known to us, but only serves advertisements to tune in to your profile so that they are relevant as possible for you.
To this regard, Ungraded uses advertising cookies of Google Ads. These cookies are used to serve ads based on your prior visits to our Website. The cookie also enables Google and its partners to serve ads to its users based on your visit to the Website and/or other sites on the internet. For more information see the explanation under the heading “Google Ads”.
Access, modification, transportation and/or removal of your Personal DataYou can always contact us if you have any questions regarding our Privacy Statement or wish to access, modify, transport or delete your Personal Data.
You have the following rights:
- Being informed on which Personal Data we have and what we are using it for;
- Inspection of the Personal Data that we keep from you;
- To exercise your right to data portability;
- Having incorrect Personal Data corrected;
- Request to delete outdated Personal Data;
- Revoke your consent;
- Object to certain uses of Personal Data.
Please note that you always make clear who you are, so that we can assure we do not modify or remove the Personal Data from the wrong person.
ComplaintsIf you think that we are not helping you in the right way, you have the right to lodge a complaint at the supervising authority. For The Netherlands, this is the Autoriteit Persoonsgegevens.
Contact detailsUngraded B.V. Schaverijstraat 11 3534 AS Utrecht The Netherlands firstname.lastname@example.org