Last updated : 24 april 2024
Unlockt.me is an application that allows a person (the “Uploader”) to upload content on Unlocktme’sserver, in order to make it available to third parties (“Downloaders”) through a URL hyperlink againsta payment.
The Application is provided by UNLOCKT.ME SAS, a company incorporated in France. Our registeredoffice is located at 14 RUE CHARLES-V 75004 PARIS. We are registered with the Delaware Division ofCorporations. Hereinafter, we shall be referred to as 'Unlocktme', 'we', 'us', or 'our'.
This Privacy Policy applies to Uploaders that use the Unlocktme Application to upload Files and makethem available to Downloaders.
The following definitions apply to this Privacy Policy :
Account : Online account on the Application assigned to Uploader, and accessible through theApplication with the Uploader’s Credentials.
Credentials : an Account’s dedicated e-mail address and password, which are necessary to Uploaderto access its account, and are personal and private to each Uploader.
Data Protection Laws : means (i) the Regulation (EU) 2016/679 (General Data Protection Regulation)of the European Parliament and of the Council on the protection of natural persons with regard to theprocessing of personal data and on the free movement of such data as currently in effect and as maybe amended from time to time, France’s Law no°78-17 of 6 January 1978 on data processing, files andfreedoms and any regulation(s) that complete or replace such law and France’s Law no°2018-493 of20 June 2018; (ii) where applicable, regulations adopted within the European Union and local lawsthat may apply to Personal Data processed within the scope of the Uploader Terms of Use.
Downloader : Any natural person that navigates a Download Page and uses it to download a Fileagainst payment.
Download Page : Webpage published by Unlocktme and accessible with a dedicated URL address, onwhich the Downloader can access and download a File.
File : Digital file that an Uploader uploads by using the Service, to make it available for access anddownload against a payment.
Parties : Unlocktme and the Uploader, together.
Application : The Application through which the Services are available to Uploader.
Services : File uploading and downloading services that allow Uploader to upload a file onUnlocktme’s servers and make it available to a Downloader against a payment, as described inUnlocktme’s Uploader Terms of Use.
Stripe :
For Uploaders based in the United States of America : Stripe, Inc., a Delaware registeredcorporation, registered at 185 Berry Street, Suite 550, San Francisco, CA, 94107, USA.
For Uploaders based in the European Union : Stripe Payments Europe, Ltd, an Irish PrivateCompany Limited by Shares, registered at A&L GOODBODY, IFSC, North Wall Quay, D01 H1O4,
Dublin, Ireland.
For Uploader based in the United Kingdom : Stripe Payments UK, Ltd, a UK registered privatelimited company, registered at 9th Floor, 107 Cheapside, London, EC2V 6DN, UnitedKingdom.
Other entities may be applicable when Uploader resides in another country. More information athttps://stripe.com/fr/legal.
Uploader : Any natural person that makes Files available on the Application thanks to the Services.
1. General
For the purposes of this Privacy Policy, the terms "Personal Data" “Data Controller” and “DataProcessor” have the meaning defined in the Data Protection Laws. Each of the Parties is responsiblefor complying with its respective obligations under the Personal Data Protection Laws in accordancewith the terms and conditions set forth below.
2. Personal Data categories
The Personal Data that may be collected and/or processed by Unlocktme as Data Controller are :- E-mail address ;
- Credentials ;
- Transaction Information (Payment amount, date, etc.) ; - Banking information (IBAN) ;
- Information about the Uploader's device (IP address, technical characteristics and identification data) and Uploader’s use of the application.
3. Collection of Personal Data
Unlocktme collects and processes Personal Data provided by the Uploader when the Uploadercreates an Account and uses the Application.
4. Legal basis and purposes of processing
Unlocktme uses this Personal Data to carry out these Terms of Use allowing access to and use of theApplication and Services.
5. Retention period of Personal Data
Personal Data is kept for a period not exceeding that necessary for the purposes for which it isprocessed. The Personal Data relating to the Uploader are deleted when the Uploader deletes itsAccount except to the extent that legal and/or regulatory requirements applicable to Unlocktmejustifies a longer retention period.
Transactional and/or tax data is retained for the duration of the contractual relationship, plus theapplicable statute of limitations for tax purposes, i.e., 10 years from the date the Service wasperformed.
6. Exercise of the Uploader’s rights
In accordance with the Personal Data Protection Laws, the Uploader may exercise, where applicable, the following rights:
- Right of access: the Uploader may obtain information concerning the processing of his PersonalData and a copy of the same;
- Right of rectification: if the Uploader considers that his Personal Data is inaccurate or incomplete, they may request that they be modified accordingly;
- Right to erasure: the Uploader may request the deletion of his Personal Data, to the extent permitted by law;
- Right to limit the processing: the Uploader may request the limitation of the processing of theirPersonal Data;
- Right to object: the Uploader may object to the processing of their Personal Data for reason srelating to their particular situation. The Uploader has the absolute right to object at any timeto the use of his Personal Data for commercial prospecting purposes, or for profiling purposes if such profiling is linked to commercial prospection.
- Right to Withdraw Consent: If the Uploader has given consent to the processing of theirPersonal Data, they may withdraw that consent at any time. However, processing carried outfor the performance of these Terms of Use does not rely on the Uploader's consent.
- The right to define directives concerning the conservation, deletion or communication of theirPersonal Data, applicable after their death.
- Right to the portability of Personal Data: where permitted by law, the Uploader may request thereturn of the Personal Data they have provided, or, where technically possible, the transfer ofsuch data to a third party.
If the Uploader wishes to exercise any of the above rights, the Uploader may send a request by e-mailto contact@unlockt.me. The Uploader must include a scan/copy of his or her proof of identity, wherenecessary, to enable Unlocktme to identify the Uploader.
In accordance with applicable law, in addition to the rights mentioned above, the Uploader may file acomplaint with the relevant Data Protection Authority, such as the CNIL (Commission Nationale del'Informatique et des Libertés) in France, or to any other competent national data protectionauthority.
7. Recipients of Personal Data
In order to achieve some of the purposes mentioned in this article, Unlocktme may transferUploader’s Personal Data to Stripe (e-mail address, transaction data, IBAN).
We use Stripe for payment. Stripe collects and processes personal data under its own liability,including identifying information about the devices that connect to its services. Stripe uses thisinformation to operate and improve the services it provides to us, including for fraud detection andprevention. You can learn more about Stripe and its processing activities via privacy policy at https://stripe.com/privacy.
8. Transfer of Personal Data outside of the EEA.
The Personal Data processed by Unlocktme for the provision of the Services is processed, stored andphysically located in the European Economic Area (EEA).
However, in order to carry out payments under these terms of services, transfer outside of the EEAmay be necessary. In such cases, Unlocktme ensures to set adequate appropriate safeguards andcompliance measures to ensure an adequate level of protection of personal data transferred outside the EEA and Switzerland. These measures include the updated EU Commission’s SCCs toaccommodate international data transfers.