Introduction
Yugen Films ("we," "us," "our," or "Company") is committed to protecting your privacy and ensuring you understand our practices regarding the collection and use of your personal data. This Privacy Policy explains how we collect, use, disclose, and otherwise process your personal information in accordance with the General Data Protection Regulation (GDPR), the Dutch Data Protection Act (UAVG), and other applicable privacy laws.
Company Details:
Yugen Films
KVK: 93349327
Registered in: The Netherlands
Contact: hello@yugenfilms.co
1. Information We Collect
We collect personal data in the following ways:
1.1 Information You Provide Directly
- Waitlist Signup: When you join our waitlist, we collect your name and email address to keep you informed about our product launch and early access opportunities.
- Contact Forms: If you contact us, we collect the information you provide, including your name, email, and any messages you send.
- Account Information: If you create an account, we collect profile information, contact details, and any content you upload or provide.
1.2 Information Collected Automatically
- Google Analytics 4 (GA4): We use Google Analytics 4 (Measurement ID: GA_MEASUREMENT_ID) to understand how visitors interact with our website. This includes tracking page views, session duration, bounce rates, and user flows. GA4 uses cookies to collect this data.
- Cookies and Similar Technologies: We use cookies and similar tracking technologies to enhance your user experience and analyze website performance.
- Server Logs: Our web servers automatically record information such as your IP address, browser type, pages accessed, and the date and time of your visit.
2. Legal Basis for Processing
Under the GDPR, we process your personal data based on the following lawful bases:
- Legitimate Interests (Article 6(1)(f) GDPR): We process data to improve our website, understand user behavior, and optimize our services. We conduct balancing tests to ensure your rights are respected.
- Consent (Article 6(1)(a) GDPR): For cookies used for analytics and tracking that are not strictly necessary, we obtain your explicit consent before collecting or storing such data.
- Contract Performance (Article 6(1)(b) GDPR): We process data necessary to provide our services and fulfill your requests.
- Legal Obligation (Article 6(1)(c) GDPR): We may process data as required by applicable laws, regulations, or legal processes.
3. Cookie Types and Usage
We use the following types of cookies:
3.1 Necessary Cookies
These cookies are essential for the website to function properly. They do not require consent and include:
- Session cookies to maintain your user session
- Security cookies to prevent fraud and protect data integrity
- Functionality cookies to remember your preferences
3.2 Analytics Cookies
Google Analytics 4 sets cookies to track your interaction with our website, including pages visited, time spent, and user journey. These cookies require your explicit consent (where required by local law) before being set.
- _ga: Stores a unique client ID
- _ga_*: Used by Google Analytics to persist session state
You can opt out of Google Analytics tracking by visiting Google's Analytics Opt-out Browser Add-on.
4. International Data Transfers
Important: Google Analytics is operated by Google LLC, a company based in the United States. Your data may be transferred to, stored in, and processed in the United States or other countries where Google operates data centers.
To comply with GDPR requirements for international transfers, we rely on:
- Google's Standard Contractual Clauses (SCCs) between Google Ireland Limited and Google LLC
- Google's Binding Corporate Rules (BCRs) and commitments under the EU-U.S. Data Privacy Framework (where applicable)
By using our website, you acknowledge that your data may be transferred to countries outside the EU/EEA. We take appropriate safeguards to ensure your data receives adequate protection.
5. Data Retention Periods
We retain your personal data for the following periods:
- Waitlist Data (Name & Email): Retained until you unsubscribe or request deletion, typically up to 12 months if inactive, unless we notify you of our product launch.
- Google Analytics Data: Retained by Google for 14 months by default. You can adjust this in your Google Analytics settings.
- Server Logs: Retained for 90 days for security and debugging purposes.
- Account Data: Retained for the duration of your account and 12 months following account termination unless legally required otherwise.
- Contact Form Data: Retained for 12 months to handle follow-up communication or legal claims.
After the retention period expires, we will securely delete or anonymize your data, unless we are required to retain it for legal or legitimate business purposes.
6. Data Subject Rights
Under the GDPR and the Dutch Data Protection Act, you have the following rights regarding your personal data:
6.1 Right of Access (Article 15 GDPR)
You have the right to request a copy of the personal data we hold about you, including information about how we process it, the purposes, and the recipients.
6.2 Right of Rectification (Article 16 GDPR)
You can request correction of inaccurate or incomplete personal data held about you. We will update your information promptly upon request.
6.3 Right to Erasure ("Right to be Forgotten") (Article 17 GDPR)
You can request deletion of your personal data in certain circumstances, such as when the data is no longer necessary, or if you withdraw your consent. Note: We may retain data if required by law or for legitimate purposes.
6.4 Right to Restrict Processing (Article 18 GDPR)
You can request that we limit how we use your personal data while we verify its accuracy or assess whether we have a legitimate reason to continue processing it.
6.5 Right to Data Portability (Article 20 GDPR)
You can request your personal data in a structured, commonly used, machine-readable format (e.g., CSV, JSON) and ask us to transmit it to another controller.
6.6 Right to Object (Article 21 GDPR)
You have the right to object to processing based on our legitimate interests. Upon receiving such an objection, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
6.7 Right to Withdraw Consent (Article 7 GDPR)
If we process your data based on your consent, you can withdraw that consent at any time without affecting the lawfulness of processing before withdrawal. This applies to analytics cookies, marketing emails, and other consent-based processing.
6.8 Rights Related to Automated Decision-Making (Article 22 GDPR)
You have the right not to be subject to a decision based solely on automated processing that produces a legal or similarly significant effect. We do not currently use fully automated decision-making processes.
7. How to Exercise Your Rights
To exercise any of the above rights, please contact us at:
Include in your request: Your full name, the date range for which you're requesting information, and a clear description of your request (e.g., access, deletion, portability).
We will respond to your request within 30 days of receipt. If your request is complex or we receive multiple requests, we may extend this period by up to two additional months, in which case we will inform you of the extension and reasons.
You will not incur any cost for exercising your rights. However, if your requests are manifestly unfounded or excessive, we may charge a reasonable fee or refuse to respond.
8. Data Protection Authority
If you have concerns about our privacy practices or believe your rights have been violated, you have the right to lodge a complaint with the competent supervisory authority:
Dutch Data Protection Authority
Bezuidenhoutseweg 30
2594 AV The Hague
The Netherlands
Website: autoriteitpersoonsgegevens.nl
Phone: +31 70 888 85 00
You also have the right to lodge a complaint with the supervisory authority in your country of residence or place of work if applicable.
9. Third-Party Services and Processors
We use the following third-party service providers who may process your personal data:
- Google Analytics 4 (Google LLC): Website analytics and user behavior tracking. Data is transferred to the US. Google Privacy Policy.
- Email Service Providers: For sending transactional emails and newsletters (if applicable). These providers are contractually bound to process data only as instructed and in compliance with GDPR.
- Web Hosting Provider: For storing and serving website content securely.
All third-party processors have signed Data Processing Agreements (DPAs) binding them to confidentiality, security, and GDPR compliance.
10. Security Measures
We implement technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit (SSL/TLS protocols)
- Secure data storage with access controls
- Regular security assessments and penetration testing
- Firewalls and intrusion detection systems
- Limited access to personal data on a need-to-know basis
- Employee training on data protection and confidentiality
While we strive to protect your data, no security measure is completely impenetrable. We cannot guarantee absolute security. If a data breach occurs, we will notify affected individuals and relevant authorities as required by law.
11. Your Rights and Choices
11.1 Email Communications
If you subscribe to our mailing list, you can unsubscribe by clicking the "unsubscribe" link at the bottom of any email we send. You can also contact us to be removed from our mailing list.
11.2 Cookie Management
Most browsers allow you to refuse cookies or alert you when cookies are being sent. You can manage your cookie preferences through your browser settings. Note that disabling necessary cookies may affect your ability to use certain features of our website.
11.3 Do Not Track (DNT)
We honor Do Not Track (DNT) browser signals. If your browser is set to "Do Not Track," we will not load Google Analytics or other non-essential tracking technologies.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website and updating the "Last updated" date at the top of this page.
Your continued use of our website after such modifications constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your data.
13. Children's Privacy
Our website and services are not directed to children under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13 without proper parental consent, we will promptly delete such information and notify the parent or guardian.
For children between 13 and 16 in certain EU jurisdictions, we obtain explicit consent from parents or guardians before processing their data.
14. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please don't hesitate to contact us:
Email: hello@yugenfilms.co
Website: app.yugenfilms.co
Country: The Netherlands
KVK: 93349327
We will respond to all inquiries, complaints, and data subject requests in accordance with applicable privacy laws within the stipulated timeframes.
15. Additional Information
Trademark Notice: Yugen Films® is a registered trademark in the European Union. Unauthorized use is prohibited.
EU Representative: While we are based in the Netherlands, if you are outside the EU/EEA and have privacy concerns, you may contact us at the address above.