DRUPE PRIVACY NOTICE
Last Revised: May 24th, 2018
Drupe Mobile Ltd. (“Drupe”, “Company”, “we”, “our” or “us”) respects the privacy of the users of our mobile application (“App”) and of our website available at: http://www.getdrupe.com/ (the “Site” and collectively with the App, the “Services”), and is fully committed to protect the personal information that its users share with it in connection with the use of our Services.
This Privacy Notice (the “Privacy Notice”) is intended to describe our practices regarding the information we may collect from you (the “User” or “you”) when you use our Services, the manners in which we may use such information, and the options and rights available to you.
Please note: you are not obligated by law to provide us with any personal information.
TABLE OF CONTENTS
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
HOW WE USE YOUR INFORMATION?
TO WHOM WE SHARE PERSONAL INFORMATION?
WHERE DO WE STORE USER’S PERSONAL INFORMATION?
TARGETED ADS, COOKIES AND OTHER TRACKING TECHNOLOGIES
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION?
THIRD PARTY SERVICES
COMMUNICATIONS FROM DRUPE
CHANGES TO THE PRIVACY NOTICE
HAVE ANY QUESTIONS?
1.WHAT INFORMATION DO WE COLLECT ABOUT YOU?
First - what is personal information?
Personal information is individually identifiable information about a person, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of private or sensitive nature information relating to an identified or identifiable natural person. Under certain applicable laws identification of an individual also includes association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.
Personal information does not include information that has been anonymized or aggregated so that it can no longer be used to identify a specific natural person.
We collect personal information from you when you use or interact with our Services
We collect personal information from you and from any devices (including mobile devices) you use when you install or have the App installed on your device, use or access our Services, provide us information on a web form, or through correspondence you and we conduct with each other.
More specifically we collect and use the following categories and types of information:
Personal information you give us when you use our App
In order to use certain features of the App, you may be asked to provide your phone number. In addition, you may also choose to use certain features that may be offered to you via the App and allow the collection and use of personal information, as detailed below:
The Caller Identification Functionality
If made available by Drupe in your territory and by your operating system, the User may choose if they want to share with us the names, numbers and e-mail addresses contained in your device’s address book (“Contact Information”), for the purpose of providing the Caller Identification Functionality. Please note that we don’t collect save, nor display, any information about the identity sources or network connection relating to your contacts (i.e. this means that once you provided your Contact Information to Drupe, we will not save the fact that any of these contacts have originated from you).
Please note that at any time during your use of the App you may change your mind and decide whether or not you want to share the Contact Information, and even decide to delist all the Contact Information already shared with us through the App settings. As part of this feature, Users can also help us improve our Caller Identification Functionality by suggesting better name to a number, or mark it as spam, and by doing so helping other Users.
If as part of your Contact Information (or otherwise) you provide us with personal information about someone else, you confirm that they are aware that you have provided their data and that they consent (and continue to consent as long as you share with us the Contact Information and use the Caller Identification Functionality) to our collection, processing and use of their data for the purpose of providing the Caller Identification Functionality and according to this Privacy Notice.
The Walkie Talkie Feature
If made available by Drupe in your territory and by your operating system, the User may choose to use the Walkie Talkie Feature, which is a direct communication channel powered by Drupe through which Users may send audio files to their contacts. In the event that a contact is not a Drupe User, he/she will receive an SMS message with a link allowing them to access the media files sent to them. In order to respond to such media files, such contact will need to download the Drupe App. When using the Walkie Talkie Feature, Drupe servers as the communication channel and as such collects and stores the media files, whether audio or image, in order to enable the communication and send to the recipient User. It also collects the telephone number of the contact to which the media files were sent. Please note we may retain such media files, which may contain personal information of you or of third parties you mention in your communication, for the minimal period of time required in order to provide you with this feature, no longer than seven (7) days, however, Drupe shall have no obligation to hold such media files and may choose, at its sole discretion, to delete such information at any earlier time.
The Images Feature
If made available by Drupe in your territory and by your operating system, Users may choose to send images to their contacts while conducting audio communication. In the event that a contact is not a Drupe User, he/she will receive an SMS message with a link allowing them to access the media files sent to them. In order to respond to such media files, such contact will need to download the Drupe App. When using this image sharing feature, Drupe servers collects and stores the image media files which may contain personal information of You or of third parties you mention in your communication, in order to send to the recipient User. Please note we may retain such media files, which may contain personal information of you or of third parties you mention in your communication, for the minimal period of time required in order to provide you with this feature, no longer than seven (7) days, however, Drupe shall have no obligation to hold such media files and may choose, at its sole discretion, to delete such information at any earlier time.
The Recording Feature
PLEASE NOTE THAT THE AFOREMENTIONED NOTIFICATION AND CONSENT REQUIREMENTS MAY VARY FROM STATE TO STATE, AND COUNTRY TO COUNTRY. YOU REPRESENT, COVENANT, AND WARRANT THAT (I) YOU WILL REVIEW ALL APPLICABLE LAWS, AND TO THE EXTENT REQUIRED, OBTAIN SUCH NEEDED LEGAL COUNSEL BEFORE YOU USE OR ALLOW OTHERS TO USE THE RECORDING FEATURE; AND (II) YOUR USE OF THE RECORDING FEATURE DOES NOT BREACH OR INFRINGE ON THE RIGHTS OF ANY THIRD PARTY, INCLUDING THE RIGHT FOR PRIVACY. YOU ARE SOLELY RESPONSIBLE FOR COMPLYING WITH ANY AND ALL APPLICABLE LAWS IN CONNECTION WITH YOUR USE OF THE RECORDING FEATURE.
Personal information you give us when you contact us through the Site
When voluntarily filling out the ‘contact us’ form in our Site, you may be asked to provide your name and email address, and you may voluntarily provide any other information you deem relevant.
Personal information we collect automatically when you use our Services
After installation of the App, we will collect and use certain information about your device, such as: device ID or other unique identifier, advertising ID, unique device token, device type, operating system (including version and settings), as well as your device screen resolution and keyboard language, all in accordance with this Privacy Notice.
We collect information about your interaction with our Services, in certain cases about your impressions of and reactions to our advertisements, and about our communications with you. This is information we receive from devices (including mobile devices) and software you use when you access our Services. This information could include the following: information regarding your clicks, views and engagement with our advertisement and Services, information concerning your traffic to and from the Services, and your referral URL.
Cookies & Similar Technologies
Please keep in mind that most mobile devices and auxiliary software, allow you to control or disable the use of certain collectable information including location services, by any application, in the device's settings menu.
Personal information collected from other sources
We allow you to use social platforms to create your Drupe account. These social platforms may give us automatic access to certain personal information retained by these social networks about you. This includes your Facebook Access Token, Twitter Sign-In Token, advertiser ID and information from your public profile, which may include date of birth and list of friends. You control the personal information you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the personal information retained by the respective social platforms about you. However, such information is not collected by the Company, and is being processed and saved locally on the User’s device.
2.HOW WE USE YOUR INFORMATION?
Legal basis for use
We collect, process and use your information for the purposes described in this Privacy Notice, based at least on one of the following legal grounds:
With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to provide you with personalized content and ads;
Purpose of Use
We may use information that we collect about you for the following purposes:
to provide you with and to operate the Service, including for statistical and research purposes and creation of aggregated anonymous data;
to personalize the Service and content provided to you, to customize your experience with the Services, to suggest you with recommendations based on your preferences and to enable you to retrieve your information;
to develop, improve and customize the Service, the experience of other users and the offering available through the Service;
to be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints and collect feedback in connection with performance of the Services;
to send you updates, notices, announcements, and additional information related to the Service;
to be able to reply to User online queries in connection with performance of the Services;
for customization and improvement of the Service’s accuracy and interface;
to display or send to you marketing and advertising material when you are using the Service, including in accordance with the section titled ‘Communications from Drupe’ herein;
to comply with any governmental agencies' legal requests or court orders, and/or with any applicable law, rule or regulation. Any statistical, aggregated or anonymous data may be used by us at our discretion for any purpose;
if applicable, to deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance;
if applicable, we collect Contact Information in order to provide you with the Caller Identification Functionality of our Services, which include, associating a name with a phone number through the name tagging functionality. The Caller Identification Functionality allows a User who receives a call from a phone number which is not associated with a name in the App database to indicate a name to be associated with that number. Drupe uses algorithmic methodologies to improve the reliability of the Caller ID feature taking account of the number of sources to support caller identification.
3.TO WHOM WE SHARE PERSONAL INFORMATION
We will not share any Personal Information we collect with any third party, except in the following cases:
Third Party Services
Drupe has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (such as AWS), data analytics services (such as Google Analytics and Facebook Analytics), and our business, legal and financial advisors (collectively, "Third Party Services"). Such Third Party Services may receive or otherwise have access to our Users' personal information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Drupe, as the controller of the information collected from its Users in connection with the use of the Services, remains responsible any personal information processing done by Third Party Services on its behalf, except for events outside of its reasonable control.
Governmental/Law Enforcement Agencies and Legal Requests or Duties
We may disclose or otherwise allow access to your personal information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.
Protecting Rights and Safety
We may share your personal information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Drupe, any of our Users, or any member of the general public.
Drupe Subsidiaries and Affiliated Companies
We may share personal information internally within our family of companies, for the purposes described in this Privacy Notice. In addition, should Drupe or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal information may be shared with the parties involved in such event.
For the avoidance of doubt, Drupe may share your personal information in additional manners, pursuant to your explicit approval. Additionally, we may transfer, share or otherwise use anonymized, aggregated or non-personal information in our sole discretion and without the need for further approval.
4.WHERE DO WE STORE PERSONAL INFORMATION?
Information regarding the Users will be maintained, processed and stored by Drupe and our authorized affiliates and service providers in the United States and in Israel, and as necessary, in secured cloud storage provided by our Third Party Services.
While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that the Company, its affiliates and service providers that store or process your Personal Information on the Company's behalf are each committed to keep it protected and secured, in accordance with this Privacy Notice and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.
You hereby agree to the storage location and transfer of information as described hereunder.
5.TARGETED ADS, COOKIES AND OTHER TRACKING TECHNOLOGIES
We use certain monitoring and tracking technologies, including ones offered by third party service providers. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of our Users’ preferences and authenticated sessions, (ii) secure our website by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our website, (iv) create and monitor analytics, and (v) deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance (For more information about this practice, click here: http://www.aboutads.info/choices/).
We use the following third party ad exchanges which may use one or more of the above tracking technologies:
Learn more about your choices and how to opt-out of tracking technologies:
If you have questions about how to opt out or limit mobile tracking, please contact us at firstname.lastname@example.org.
We take a great care in implementing and maintaining the security of the App, and our Users’ Personal Information. The Company employs industry standard procedures and policies to ensure the safety of its Users’ Personal Information, and prevent unauthorized use of any such information. However, we do not and cannot guarantee that unauthorized access will never occur.
7.YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
If you are an EU, EEA or Switzerland person and to the extent entitled under applicable law of your jurisdiction, you may contact us to exercise your right to access personal information, to request us to make corrections to your personal information that you have stored with us, to object to any form of processing, or to have such personal information deleted or exported in a portable copy. For this, please send us an e-mail to , or mail your request to the EU representative with a copy to Drupe Mobile Ltd., Aba Even Av 18, Herzelia, Israel, and we will respond within a reasonable timeframe and in accordance with applicable laws and regulations.
8.HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION
We will retain your personal information for as long as you maintain an account or as otherwise necessary to provide you the Services. Drupe will retain the information gathered through the use of the Walkie Talkie feature and the Images feature, for the minimal period of time required in order to provide you with these features, and namely to allow you to access the media files within a reasonable time of the communication, and no longer than seven (7) days; however, Drupe shall have no obligation to hold such media files and may choose, at its sole discretion, to delete such information at any earlier time. We will also retain your personal information as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements and/or protect our legitimate interests.
Where we no longer need to process your personal information for the purposes set out in this Privacy Notice, or following your request to delete your Personal Information, we will delete or anonymize your personal information from our systems.
To use the App, you must be over the age of sixteen (16). The Company does not knowingly collect Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the App. In the event that it comes to our knowledge that a person under the age of sixteen (16) is using the App, we may prohibit and block such User from using the App and will make all efforts to promptly delete any Personal Information with respect to such User.
10.THIRD PARTY SERVICES
11.COMMUNICATIONS FROM DRUPE
Drupe may contact you with information regarding our Services, or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, transactions performed, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages.
In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new services and special opportunities or promotions we think you will find valuable. We may contact you through the Services, or any other contact methods available to us, including with the help of our Third Party Services.
Accordingly, we shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, web chat, marketing calls, and similar forms of communication.
If you wish not to receive such promotional messages or calls, you may notify Drupe at any time by e-mailing us at email@example.com, or by following the "unsubscribe" or "stop" instructions contained in the promotional communications you receive.
12.CHANGES TO THE PRIVACY NOTICE
The Company reserves the right to change this Privacy Notice at any time, so please re-visit this page frequently. We will provide notice of substantial changes of this Privacy Notice on the App. Such substantial changes will take effect seven (7) days after such notice was provided on any of the abovementioned methods. Otherwise, all other changes to this Privacy Notice are effective as of the stated “Last Revised” date, and your continued use of the App after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.
13.HAVE ANY QUESTIONS?
If you have any questions (or comments) concerning this Privacy Notice, you are welcome to send us an e-mail at , and we will make an effort to reply within a reasonable timeframe.
Drupe has appointed a Data Protection Officer, for monitoring and advising on its ongoing Privacy compliance and serving as a point of contact on Privacy matters for data subjects and supervisory authorities. To contact the Data Protection Officer, in addition to emailing please also contact firstname.lastname@example.org.
EU Residents: Dr. Andreas Mätzler has been appointed as Drupe's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. email@example.com can be contacted in addition to emailing , however only on matters related to the processing of personal data of EU residents.
By contacting us, you represent that you are free to do so and that you will not knowingly provide Company with information that infringes upon third parties’ rights, including any intellectual property rights. You further acknowledge that notwithstanding anything herein to the contrary, any and all rights, including intellectual property rights in such information provided, shall belong exclusively to the Company, and Company may use or refrain from using any such information at its sole discretion.