This policy applies (i) immediately to new users who use or access the Service on or after the Effective Date and (ii) on the Effective Date to users who use or access the Service before the Effective Date.Please contact us if you have any questions or comments about our privacy practices.
You can reach us online at firstname.lastname@example.org for more information.
TRANSFERS OF PERSONAL DATA: The Service is hosted and operated in the United States (“U.S.”), with development, support and maintenance operations in other countries (and hosting soon to come in the European Union (“EU”), through GoDaddy and its service providers. If you do not reside in the U.S., laws in the U.S. (and other countries) may differ from the laws where you reside. By using the Service, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Draven Grey in the U.S. and will be hosted on U.S. servers, and you authorize Draven Grey to transfer, store, host and process your information to and in the U.S., and possibly other countries, but only within the confines of Draven Grey.
You hereby consent to transfer of your data to the U.S. pursuant to either, at Draven Grey’s discretion, the EU-U.S. Privacy Shield Framework, the details of which are further set forth below, or the standard data protection clauses promulgated by the EC, a copy of which can be obtained at:
EU PERSONAL DATAIf you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your Personal Data, as further described below. Draven Grey will be the controller of your Personal Data processed in connection with the Service.
NOTICE OF WHAT INFORMATION WE COLLECT AND HOW WE USE IT:
Types of Personal Data We Collect: Draven Grey collects Personal Data about you when you provide it directly to us, when third parties such as our business partners (e.g. companies with whom we integrate our Service), service providers (such as our advertising service providers) provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Service. We collect the following Personal Data from you in connection with the Service:
We also collect usage and performance information that is not Personal Data or that we aggregate or de-identify so that it no longer personally identifies an individual. We also associate some data that is not Personal Data with Personal Data.
We collect Personal Data when a user (i) creates an account (a “User Account”); (ii) logs into the Service; (iii) interacts with the Service; (iv) uploads or generates User Content; (v) communicates with us; and (vi) responds to a communication or interaction from us. Some of the methods and tools we use to collect Personal Data are:
Unique Identifiers: We use unique identifiers such as cookies, e-mail or your pseudonymous customer ID to track individual usage behavior on our Service, such as the length of time spent on a particular page and the pages viewed during a particular log-in period. Unique identifiers collect information about a user’s use of our Service on an individual basis.
Mobile Device Identifiers: Mobile device identifiers are identifiers stored on your mobile device that track certain data and activities occurring on or through your device. Mobile device identifiers enable collection of Personal Data (such as media access controls) as well as non-personally identifiable information (such as usage and traffic data).
Cookies, Web Beacons, and Other Tracking Tools: We and our third party service providers collect information about you, your device, and your use of the Service through cookies, clear gifs (a.k.a. web beacons/web bugs) (“Web Beacons”), and other tracking tools and technological methods (collectively, “Tracking Tools”). Tracking Tools collect information such as computer or device operating system type, IP address, browser type, browser language, mobile device ID, device hardware type, the website or application visited or used before or after accessing our Service, the parts of the Service accessed, the length of time spent on a page or using a feature, and access times for a webpage or feature. These Tracking Tools help us learn more about our users and analyze how users use the Service, such as how often users visit our Service, what features they use, what pages they visit, what emails they open, and what other sites or Websites they used prior to and after visiting the Service.
Cookies: Like many websites and mobile application operators, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Service. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Service. For more information on cookies, including how to control your cookie settings and preferences, visit
Web Beacons: Web Beacons help us better manage content on our Service by informing us what content is effective. Web Beacons are embedded in, or otherwise associated with, certain emails or other communications that you receive from us or our partners. Web Beacons help us track your responses and interests and deliver relevant content and services to you. For example, they may let us know when you take actions based on the emails that we send. Web Beacons also allow us to enhance our Behavioral Advertising (defined below), which is further discussed below in the section titled “Online Behavioral Advertising” below.
Third Party Sources: We may use third-party services, such as open search tools and social networks, to obtain information about you (such as your name or company) and to enrich your personal information by obtaining publicly available information about you, such as your job title, employment history and contact information.
Online Behavioral Advertising: Some of our advertising (“Behavioral Advertising”) involves using Tracking Tools to collect information about a user’s online activities over time and across non-affiliated websites and Websites and providing ads to the user based the user’s interests (as inferred from the user’s online activity) or use of our Service. Behavioral Advertising may appear on our Service or on other websites or services. We work with third parties to provide Behavioral Advertising, such as advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers, and other third-party service providers (collectively, “Advertising Service Providers”). Advertising Service Providers perform services such as facilitating targeting of advertisements and measuring and analyzing advertising effectiveness on the Service (collectively, all such services, “Targeting Services”). Targeting Services help us display Behavioral Advertising, prevent you from seeing repeated ads, and enable us to research the usefulness of ads.We adhere to self-regulatory principles for online behavioral advertising issued by the Digital Advertising Alliance (“DAA”) and the European Interactive Digital Advertising Alliance (“EDAA”) (collectively, the “OBA Principles”). More information about the OBA Principles can be found at http://digitaladvertisingalliance.org/principles and http://www.edaa.eu/european-principles/.You have the option to opt out of Behavioral Advertising. For more information, see the section below titled “Opting Out of Behavioral Advertising and Tracking Tools.”
Use of Personal Data: Draven Grey uses Personal Data to: (i) provide, administer, and improve our Service; (ii) better understand your needs and interests; (iii) fulfill requests you make; (iv) personalize your experience; (v) provide Service announcements; (vi) provide you with information and offers from Draven Grey, Draven Grey Affiliates, and our business partners; (vii) protect, investigate, and deter against fraudulent, harmful, unauthorized, or illegal activity and (viii) comply with legal obligations.For example, we use Personal Data to:
We will only use your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.
HOW AND WITH WHOM DOES DRAVEN GREY SHARE PERSONAL DATA?
We don’t share personal data, except that which third parties, such as Facebook, Twitter, PayPal, Instagram, etc. do so by law.
There are cases in which your data might be shared, of your own accord, for example:
We will only share Personal Data when we believe it is necessary to:
We also share information with third parties when you have given us consent to do so.
YOUR PRIVACY CHOICES: Opting Out of Behavioral Advertising and Tracking Tools You can opt-out of certain Behavioral Advertising activities by doing one or more of the following. Please note that you will need to opt-out of each browser and device for which you desire to apply these opt-out features.
(for iTunes, visit https://itunes.apple.com/us/app/appchoices/id894822870?mt=8,
for Android, visit https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en)
Please note the following with respect to opting out of Behavioral Advertising:
Emails: We will give you the ability to opt-out of marketing-related emails by clicking on a link at the bottom of each such email. You cannot opt-out of receiving certain non-marketing emails regarding the Service.
SECURITY: We believe the security of your information is a serious issue and we are committed to protecting the information we receive from you. We use commercially reasonable security measures to protect against the loss, misuse, and alteration of your information under our control based on the type of Personal Data and applicable processing activity, such as data encryption in transit, data encryption at rest (for customers that elect to purchase our “private cloud” solution), pseudonymous, and enforcement of least privilege and need-to-know principles.To the extent the Service requires you to provide any Financial Account Information, such as when you purchase subscriptions to the Service, that information will be collected and processed by third-party PCI-compliant service providers. We do not store Financial Account Information transmitted through the Service. All sessions through, by, with, or for Draven Grey are confidential. All precautions will be taken to make sure that the privacy of your personal contacts with Draven Grey are kept secret, safe, and secure.
DATA RETENTION: We retain Personal Data about you for as long as you use the service. Opting out of email will prevent us from being able to retain data stored on any of Draven Grey owned websites.
WHAT RIGHTS AND CHOICES DO YOU HAVE REGARDING YOUR PERSONAL DATA?
Accessing, Correcting, and Deleting Your Personal Data and Other Data Subject Rights: You have certain rights with respect to your Personal Data, and we want to help you review and update your information to ensure it is accurate and up-to-date.We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).For more information as to tools available to you and your account administrator, please refer to email@example.com if you have any additional requests or questions:
For the following, please email us at firstname.lastname@example.org
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