1.1 Drone Industries Limited (t/a DroneLab) (CN: 9287815) (collectively referred to as "we", "us" or "our"
through your use of this website (including any data you may provide when you purchase a product or service,
or otherwise provide any data to us).
policy when you first visit our website.
or fair processing notice we may provide on specific occasions when we are collecting or processing personal
data about you, so that you are fully aware of how and why we are using your data. This privacy and cookie
policy supplements the other notices and is not intended to override them.
1.5 This website is not intended for children and we do not knowingly collect data relating to children.
2. Controller and third party links
2.1 We are the controller and responsible for your personal data.
2.2 [We have appointed a data privacy manager who is responsible for overseeing questions in relation to
your legal rights) please contact our Data Privacy Manager by either: (a) post at Drone Industries Limited
(t/a DroneLab), PROTO - Centre for Emerging Technology, Abbott's Hill, Gateshead, Tyne And Wear, England,
NE8 3DF; or (b) email at
2.3 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the
UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
2.4 This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy statements. When you
3. Collecting personal data
3.1 Personal data, or personal information, means any information about an individual from which that person
can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped
together as follows:
(a) Identity Data includes first name, maiden name, last name, username or similar identifier, marital
status, title, date of birth and gender.
(b) Contact Data includes billing address, delivery address, email address and telephone numbers.
(c) Financial Data includes bank sort code, account and payment card details.
(d) Transaction Data includes details about payments to and from you and other details of products and
services you have purchased from us.
(e) Technical Data includes internet protocol (IP) address, your login data, browser type and version,
time zone setting and location, browser plug-in types and versions, operating system and platform
and other technology on the devices you use to access this website.
(f) Profile Data includes your username and password, purchases or orders made by you, your interests,
preferences, feedback and survey responses.
(g) Usage Data includes information about how you use our website, products and services.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and our
third parties and your communication preferences.
3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage
Data to calculate the percentage of users accessing a specific website feature. However, if we combine
or connect Aggregated Data with your personal data so that it can directly or indirectly identify you,
we treat the combined data as personal data which will be used in accordance with this privacy and cookie
3.4 We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and biometric data). Nor do we collect
any information about criminal convictions and offences.
3.5 Where we need to collect personal data by law, or under the terms of a contract we have with you and
you fail to provide that data when requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with goods or services). In this case, we
may have to cancel a product or service you have with us but we will notify you if this is the case at
4. Personal data collection methods
4.1 We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms
or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide
(i) apply for our products or services;
(ii) create an account on our website;
(iii) subscribe to our service or publications;
(iv) request marketing to be sent to you;
(v) enter a competition, promotion or survey; or
(vi) give us some feedback.
(b) Automated technologies or interactions. As you interact with our website, we may automatically collect
Technical Data about your equipment, browsing actions and patterns. We collect this personal data
by using cookies, server logs and other similar technologies. We may also 2 receive Technical Data
13 – 16 for further details.
(c) Third parties or publicly available sources. We may receive personal data about you from various
third parties and public sources as set out below:
(d) Technical Data from the following parties:
(i) analytics providers such as Google based outside the EU;
(ii) advertising networks; and
(iii) search information providers based inside OR outside the EU.
(e) Contact, Financial and Transaction Data from providers of technical, payment and delivery services
based inside OR outside the EU.
(f) Identity and Contact Data from data brokers or aggregators.
(g) Identity and Contact Data from publicly available sources such as Companies House.
5. Using personal data
5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal
data in the following circumstances:
(a) Where we need to perform the contract we are about to enter into or have entered into with you.
(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests.
(c) Where we need to comply with a legal or regulatory obligation.
5.2 Generally we do not rely on consent as a legal basis for processing your personal data other than in
relation to sending third party direct marketing communications to you via email or text message. You
have the right to withdraw consent to marketing at any time by contacting us.
5.3 We have set out below, in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests
are where appropriate.
5.4 Note that we may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in
the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity (b) Contact
Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and
recover money owed to us
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts
due to us
To manage our relationship with you which will include: (a) Notifying you about changes to our terms
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary
for our legitimate interests (to keep our records updated and to study how customers use our
To enable you to partake in a promotion or complete a survey
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers
use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis,
testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration
and IT services, network security, to prevent fraud and in the context of a business reorganisation
or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness
of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop
them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services,
to keep our website updated and relevant, to develop our business and to inform our marketing
To make suggestions and recommendations to you about goods or services that may be of interest to
Necessary for our legitimate interests (to develop our products/services and grow our business)
5.5 If you submit personal information for publication on our website, we will publish and otherwise use
that information in accordance with the licence you grant to us.
5.6 Marketing - we strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising. We have established the following personal data control mechanisms:
(a) Promotional offers from us – we may use your Identity, Contact, Technical, Usage and Profile Data
to form a view on what we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased
goods or services from us or if you provided us with your details when you registered for a promotion
and, in each case, you have not opted out of receiving that marketing;
(b) Third-party marketing – we will get your express opt-in consent before we share your personal data
with any other company for marketing purposes;
(c) Opting out – you can ask us or third parties to stop sending you marketing messages at any time by
[contacting us] at any time. Where you opt out of receiving these marketing messages, this will not
apply to personal data provided to us as a result of a product/service purchase, warranty registration,
product/service experience or other transactions.
5.7 We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original purpose.
If you wish to get an explanation as to how the processing for the new purpose is compatible with the
original purpose, please [contact us].
5.8 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain
the legal basis which allows us to do so.
5.9 Please note that we may process your personal data without your knowledge or consent, in compliance with
the above rules, where this is required or permitted by law.
6. Disclosing personal data
6.1 We may have to share your personal data with the parties set out below for the purposes set out in the
table in paragraph 5 above:
(a) Internal Third Parties as set out in the [Glossary].
(b) External Third Parties as set out in the [Glossary].
(c) Specific third parties with whom we may need to share your personal data in order to provide certain
requested products or services to you, including our DroneLab and DroneHub products.
(d) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to
our business, then the new owners may use your personal data in the same way as set out in this privacy
6.2 We require all third parties to respect the security of your personal data and to treat it in accordance
with the law. We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in accordance
with our instructions.
7. International data transfers
7.1 Information that we collect may be stored and processed in and transferred between any of the countries
in which we operate in order to enable us to use the information in accordance with this privacy and
7.2 Information that we collect may be transferred to the following countries which do not have data protection
laws equivalent to those in force in the European Economic Area (EEA): the United States of America,
Russia, Japan, China and India.
7.3 Many of our external third parties are also based outside the European Economic Area (EEA) so their processing
of your personal data will involve a transfer of data outside the EEA.
7.4 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded
to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate
level of protection for personal data by the European Commission. For further details, see European
Commission: Adequacy of the protection of personal data in non-EU countries.
(b) Where we use certain service providers, we may use specific contracts approved by the European Commission
which give personal data the same protection it has in Europe. For further details, see European
Commission: Model contracts for the transfer of personal data to third countries.
(c) Where we use providers based in the US, we may transfer data to them if they are part of the Privacy
Shield which requires them to provide similar protection to personal data shared between the Europe
and the US. For further details, see European Commission: EU-US Privacy Shield.
7.5 You expressly agree to the transfers of personal information described in this paragraph 7.
7.6 Please contact us if you want further information on the specific mechanism used by us when transferring
your personal data out of the EEA.
7.7 Personal information that you publish on our website or submit for publication on our website may be
available, via the internet, around the world. We cannot prevent the use or misuse of such information
8. Security of personal data
8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to
your personal data to those employees, agents, contractors and other third parties who have a business
need to know. They will only process your personal data on our instructions and they are subject to a
duty of confidentiality.
8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.
8.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we
cannot guarantee the security of data sent over the internet.
8.4 You are responsible for keeping the password you use for accessing our website confidential; we will
not ask you for your password (except when you log in to our website).
9. Retaining personal information
9.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
9.3 In some circumstances we may anonymise your personal data (so that it can no longer be associated with
you) for research or statistical purposes in which case we may use this information indefinitely without
further notice to you.
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 This version was last updated on 29 March 2018 and historic versions can be obtained by contacting our
Data Privacy Manager.
sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests
(for example, a request for the transfer of your personal data) until May 2018, as we are still working
towards getting our systems ready for some of these changes.
10.4 You should check this page occasionally to ensure you are happy with any changes to this policy.
10.5 We may notify you of changes to this policy by email or through the private messaging system on our
11. Updating information
11.1 It is important that the personal data we hold about you is accurate and current. Please keep us informed
if your personal data changes during your relationship with us.
12. Your legal rights
12.1 Under certain circumstances, you have rights under data protection laws in relation to your personal
data. Please click on the links below to find out more about these rights:
(a) Request access to your personal data.
(b) Request correction of your personal data.
(c) Request erasure of your personal data.
(d) Object to processing of your personal data.
(e) Request restriction of processing your personal data.
(f) Request transfer of your personal data.
(g) Right to withdraw consent.
12.2 If you wish to exercise any of the rights set out above, please contact us and:
(a) you will not usually have to pay a fee to access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive
or excessive. Alternatively, we may refuse to comply with your request in these circumstances;
(b) we may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up
our response; and
(c) we try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In this
case, we will notify you and keep you updated.
13. About cookies
of letters and numbers that we store on your browser or the hard drive of your computer if you agree.
Cookies contain information that is transferred to your computer's hard drive. This helps us to provide
you with a good experience when you browse our website and also allows us to improve our site. [By continuing
13.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored
by a web browser and will remain valid until its set expiry date, unless deleted by the user before the
expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.
13.3 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored
by a web browser and will remain valid until its set expiry date, unless deleted by the user before the
expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.
13.4 Cookies can be used by web servers to identify and track users as they navigate different pages on a
website and identify users returning to a website.
14. Our cookies
14.1 We use both session and persistent cookies on our website. You block cookies by activating the setting
on your browser that allows you to refuse the setting of all or some cookies. However, if you use your
browser settings to block all cookies (including essential cookies) you may not be able to access all
or parts of our site.
14.2 We use the following cookies:
Strictly necessary cookies – these are cookies that are required for the operation
of our website. They include, for example, cookies that enable you to log into secure areas of our
website, use a shopping cart or make use of e-billing service;
Analytics/performance cookies – they allow us to recognise and count the number of
visitors and to see how visitors move around our website when they are using it. This helps us to
improve the way our website works, for example, by ensuring that users are finding what they are
looking for easily; 8
Functionality cookies – these are used to recognise you when you return to our website.
This enables us to personalise our content for you, greet you by name and remember your preferences
(for example, your choice of language or region);
Targeting cookies – these cookies record your visit to our website, the pages you
have visited and the links you have followed. We will use this information to make our website and
the advertising displayed on it more relevant to your interests. We may also share this information
with third parties for this purpose.
14.3 You can find more information about the individual cookies we use and the purposes for which we use
them in the table below:
This cookie enables us to:
Estimate our audience size and usage pattern.
Store information about your preferences, and so allow us to customise our site and to provide
you with offers that are targeted at your individual interests.
14.4 Please note that third parties (including, for example, advertising networks and providers of external
cookies are likely to be analytical/performance cookies or targeting cookies
15. Analytics cookies
15.1 We use Google Analytics to analyse the use of our website.
15.2 Our analytics service provider generates statistical and other information about website use by means
15.3 The analytics cookies used by our website have the following names: _ga, _gat, __utma, __utmt, __utmb,
__utmc, __utmz and __utmv. 9
15.4 The information generated relating to our website is used to create reports about the use of our website.
(a) Comply with a legal or regulatory obligation means processing your personal data where it is necessary
for compliance with a legal or regulatory obligation that we are subject to.
(b) Legitimate Interest means the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We do not use your personal data
for activities where our interests are overridden by the impact on you (unless we have your consent
or are otherwise required or permitted to by law). You can obtain further information about how we
assess our legitimate interests against any potential impact on you in respect of specific activities
by contacting us.
(c) Performance of Contract means processing your data where it is necessary for the performance of a
contract to which you are a party or to take steps at your request before entering into such a contract.
17.2 Third Parties
(a) Internal Third Parties
(i) Other companies within our group and who are based in the United Kingdom and provide IT and
system administration services and undertake leadership reporting.
(b) External Third Parties
(i) Service providers acting as processors which may be used to provide certain products and
services to you) based in the United Kingdom who provide database and other IT and system
(ii) Professional advisers acting as processors including lawyers, bankers, auditors and insurers
based in the UK who provide consultancy, banking, legal, insurance and accounting services.
(iii) HM Revenue & Customs, regulators and other authorities acting as processors based in the
United Kingdom who require reporting of processing activities in certain circumstances.
18. Your Legal Rights
18.1 You have the right to:
(a) Request access to your personal data (commonly known as a "data subject access request"). This enables
you to receive a copy of the personal data we hold about you and to check that we are lawfully processing
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete
or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the
new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have the right to ask us
to delete or remove your personal data where you have successfully exercised your right to object
to processing (see below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal reasons which will be notified
to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those
of a third party) and there is something about your particular situation which makes you want to
object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process
your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us to establish the
data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c)
where you need us to hold the data even if we no longer require it as you need it to establish, exercise
or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether
we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you, or
a third party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you initially provided consent
for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However,
this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide certain products or services to you.
We will advise you if this is the case at the time you withdraw your consent.