DROVE PRIVACY POLICY

DROVE NETWORK LTD., its subsidiaries and affiliated companies (“Company” or “we”, “us”, or “our”) considers user privacy paramount, and we utilize great care in keeping the information of users private and secure. This privacy policy (“Privacy Policy”) details our practices in relation to all data collected or processed when you (i) visit our website available at: www.drove.com ; (ii) use our mobile app; or (iii) register and as a leader on the Drove platform (“Platform”) and create a campaign or use our management tools (“Leaders”) or register as a follower on our Platform and follow or support a campaign or page (“Follower”) (collectively, “Service(s)”). Note, as detailed below, this Privacy Policy will also govern certain data we receive from the Leaders with regards to their designated followers.

We have included below information about which data is collected, how we process and use your data, but before, we would like to explain the lawful basis on which we do so, all subject to the EU General Data Protection Regulation (“GDPR”) as well as other applicable data privacy regulations:

(i)Where a user registers for any of our Services, we process such data in order to perform our contract with the user;
(ii)When visitors access our website, we have the legitimate interest to process online identifiers such as IP address, cookies or agents (“Online Identifiers”);
(iii)If you are a registered user or if you have requested to join our newsletter, we will process certain data for direct marketing purposes, which we have legitimate interest; or,
(iv)We will also process your certain data where you have provided us with consent to do so, either by contacting us or other forms.

As defined under the GDPR Drove acts as a Processor of certain data, such as the data uploaded by our Leaders, the Controller, which may include the Controller’s followers’ name, contact details, etc. all as detailed below. We do not use this data or even access it, however, once the Leader uploads this data to the system we will follow the Leader instructions and process it as requested (i.e., send emails, SMS, etc.).

Further, Drove can also be a Controller of certain data such as when you contact us or when a Leader or Follower directly register through the Platform.

For more detail regarding the terms and conditions for use of the Services and our obligations as a Controller or Processor please read our Terms of Use (“Terms of Use”), which together with this Privacy Policy, govern your use, access and activity through the site and Service. Terms that are capitalized but are not defined in this Privacy Policy have the applicable meaning set forth in the Terms of Use.

1. The information we collect

Depending on your interaction with us (meaning, if you are just browsing our site, or if you have registered to our Services), we may collect three types of information you, as follows:

Information we collect from visitors of our site or app:

The table below details and discloses the data we collect when you access the site or app. If you also register and become a Follower or Leader, please also review the next table designated to registered users.

Type of Information How Do We Use It?
When you access our site or app we collect aggregated usage information and technical information, such as: the type of device (e.g. smartphone or tablet, iOS or Android), operating system, browser type, carrier, internet network provider, device model and manufacture, browser language, network status (e.g., WiFi, 3G, 4G), your navigation and click stream within the site, time zone, and language (“Technical Information”). We use this Technical Information for (i) operating, providing, maintaining, protecting, managing our site; (ii) enhancing your experience; and (iii) our legitimate interests of auditing and tracking usage statistics.
In the event you contact us for support or other inquiries either through the site or by sending us an email, you will provide us with your name, phone number and email address. We will use this information solely for the purpose of responding to your inquiries and provide you with the support or information you have requested.
Online Identifiers We (directly or indirectly, by third party service providers) collect you Online Identifiers and process it for our legitimate interests of operating, providing, maintaining, protecting, managing, customizing and improving our site.
If you voluntarily subscribe to our newsletter, you will be asked to provide us with your email address. You can unsubscribe at any time using the unsubscribe option within the body of the newsletter or by contacting our data protection officer at: privacy@drove.com We will use your email address in order to send you information related to our Services and to keep you up to date regarding new Services.

Information we collect from registered users

If you registered, created an account and are operating as either a Follower or Leader on our Platform, the table below will disclose, detail and explain which information we collect or process and for what purpose.

Type of Information How Do We Use It?
In the event you will wish to comment, like or share a post, you will be required to register and open an account for the purpose of becoming a Follower (as defined herein above). During the registration you will provide us with your name, profile picture and email address and will be required to choose a password, at which you thereby represent and warrant that you are solely responsible for maintaining the confidentiality of your details and password. Further you represent and warrant that the information provided by you is accurate and complete. You may also sign in with a social network account, such as Facebook, that may provide us with access to certain information about you as stored therein (e.g. full name, e-mail and any other information which you made public). We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested (e.g. allow you to comment on a post or share your comment of the social networks, etc.).
As a Follower you also have an option to donate, contribute or purchase merchandise from you Leader, by doing that you will be required to provide payment details. Drove does not process the payment nor store any payment data, we use third parties to do so and we recommend you review their privacy policy as well: We, or our third party payment processors, use the payment information solely for the purpose of executing the payment you requested. Any payment or data practices will be subject to such third-party payment processors privacy practices and terms of service.
In order to use as the Services and create a campaign as a Leader (i.e., donation, petition, newsletters, CRM, sell of merchant, etc.), you will be required to register and open an account. During the registration flow you provide us with certain information such as your full name and company name, title email address, profile picture, and phone number. During the registration process you will be required to create a password, at which you thereby represent and warrant that you are solely responsible for maintaining the confidentiality of your details and password. Further you represent and warrant that the information provided by you is accurate and complete. You may also sign in with a social network account, such as Facebook, that may provide us with access to certain information about you as stored therein (e.g. full name, e-mail and any other information which you made public). We will use this information for the purpose of performing our contract with you, provide you with the Services you have requested, and designate your account in order to display the applicable information on your account dashboard. We will use your email address and phone number solely for direct marketing and communication related to the Service (e.g., invoices, newsletter, etc.).
We may collect certain precise location, provided that you enable the “Location Services” on your device. Thus, when you check in to an event through the Platform or upload UGC, we may obtain information regarding where and when the photo was shot, and other information concerning your location while using the Platform. We use this data solely to provide the Services and is subject to your consent.
While using the Service, either as a Leader or Follower, you are able to comment and upload certain content to the Platform such as text, images, video clips, GIF, etc. (collectively, “User Generated Content” or “UGC”). The UGC may include Personal Data or even Sensitive Data (i.e., political views) about you or other individuals. The UGC is subject to the applicable obligations and requirements available in out Terms of Use When you upload the UGC you acknowledge that by making this content public you have provided the consent to process such data (including Sensitive Data).
You can voluntarily upload third party email addresses to send such third parties your content and newsletter, you thereby represent and warrant that you have all of the rights and consent required in accordance with applicable laws to upload such third-party email address. The third party can unsubscribe at any time using the unsubscribe option within the body of the newsletter or by contacting our data protection officer at: privacy@drove.com We will use such third party email address in order to facilitate your sending of information regarding your cause.
We also collect certain Technical Non-Personal Data and Online Identifiers as a visitor to the site. See the table above.
Newsletter: if you consent, during the registration to receive newsletters, we will also use your email address for this purpose. We will use this information solely if you provided us with consent to send you newsletters or if we have legitimate interest to send direct marketing. Nonetheless, you may object and unsubscribe at any time.

Information we Process on behalf of our Leaders

Our Services include providing our Leaders with a CRM platform, management tools, payment processing platform, network to promote a cause or campaign as well as send broadcast emails and online messages. As the Service provider Drove will process this data as the Leaders Processor and shall not use the data for any other purpose except as instructed by the Leader and detailed herein below.

Contact Information We will use this information solely to send the required messages to you from the Leader.
As detailed above, we will also process data on you as a Follower such as any applicable purchases, comments, UGC, etc. We will use this information solely to provide you with the services you required.
The Drove Platform stores the content and correspondence between you and the Leader. This information is solely used for the purpose of providing CRM and additional Services to the Leader.
We also collect certain Technical Non-Personal Data and Online Identifiers as a visitor to the site. See the table above.

2. How we collect information

Depending on the nature of your interaction with the Services, we may collect information as follows:

3. Cookies

When you access or use the site, or interact with Platform, we may use “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to customize the Service and content as well as enhance your experience of the Services. The use of cookies is a standard industry-wide practice. Most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.

We may permit third parties to use cookies or other technology to collect information about your online and application usage activities across our Services, this data may include Online Identifiers therefore we recommend you review our cookie policy carefully:

Cookie Purpose Privacy Policy and Opt-Out
Zendesk chat, support, help center https://www.zendesk.com/company/customers-partners/privacy-policy/
Active Campaign Marketing tool https://www.activecampaign.com/tos/
250ok Mailing optimization https://250ok.com/privacy/
Facebook Analytics Enable use of the Service https://www.facebook.com/policies/cookies/
Facebook Connect Enhance the use of the Site https://www.facebook.com/full_data_use_policy
Facebook Custom Audience Marketing https://www.facebook.com/full_data_use_policy
Google AdWords Marketing and Remarketing https://policies.google.com/privacy
Google Analytics Analytic purposes www.google.com/policies/privacy/partners, https://tools.google.com/dlpage/gaoptout
Google Tag Manager Marketing https://policies.google.com/privacy
MixPanel Analytic purposes https://mixpanel.com/legal/privacy-policy/
HotJar Analytic Purposes https://www.hotjar.com/legal/policies/privacy
XVerify Email Verification https://www.xverify.com/privacy-policy.html
Linkedin Media https://www.linkedin.com/legal/sas-terms

4. Sharing information with third parties

We may share the information we collect in the ways that are described below:

5. Data security and retention

Company uses appropriate industry-standard security measures to protect the information it collects about you, which include the use of firewalls and encryption. We have implemented technical, physical and administrative security measures to protect the Personal Information. The data collected by us is stored in the AWS data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security. For additional information regarding our security measures please see www.drove.com/policies/security

Further, in the event of a security incident, in which we discover your Personal Data may be at risk, we will take reasonable efforts to notify you and the applicable authority (if required, subject to applicable laws). The Company retains an internal security policy and educates its employees to secure Personal Data as well as notify the DPO in the event of a security breach.

Data Retention Policy

Type of Data Retention Policy
Personal Data associated with your account Company stores this data for as long as it is necessary to provide the Service, hence, until you delete your account or request we delete your account or associated data, or if we no longer need the data to provide the Service, we will store the registration data and account activity data. Note that, even if we will delete your account, we will not delete certain information required under applicable law or otherwise, required for the legitimate purposes of our business. For example, we will not delete any invoices sent to you as we are required to retain such data under applicable tax laws.
Contact information If you unsubscribe we will no longer keep you data. Further, if we process your contact information on behalf of a Leader, we will store the information until the Controller (i.e., Leader) will instruct us otherwise.
Online Identifiers of site visitors. Are deleted within 60 days. Note, if you are a Follower and Leader we will keep your IP and time stamp to keep evidence of “actions” such as acceptance of the terms, opening an account on through a payment processor such as WePay, purchase items through our Platform, etc.
UGC The uploaded UGC may not be deleted, however following your request we may anonymize it.
Aggregated Non Personal Data We will collect and use such data for as long as needed to provide the Service, however, in no event will we keep this data for more than 12 months

6. User rights

Individuals have the right to know what information we hold about them and, in some cases, to have such information communicated to them. Individuals may also ask for our confirmation as to whether or not we process their Personal Data. Subject to the limitations in applicable law, individuals may also be entitled to obtain from us the Personal Data they have provided to us in a structured, commonly-used, and machine-readable format, and may have the right to transmit such Personal Data to another party.

The principal rights under applicable data protection law in relation to Personal Data are detailed in our user right policy available at: www.drove.com/policies/user-right

If you wish to exercise any or all of the above rights, download the user right form and send it to us to: dpo@drove.com. Note you can exercise many of your rights through your page or account.

Where we are not able to provide you with the information for which you have asked, we will endeavor to explain the reasoning for this and inform you of your rights, including the right to complain to the supervisor authority. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any such information in accordance with applicable law. In addition, the process of locating and deleting the data may take up to one (1) month (following the receipt of the validation proof we require) in accordance with applicable law.

7. Children’s privacy

Drove is not directed towards children. Therefore, we do not knowingly collect any information about children under the age of 18 years old (“Child”). If we become aware that we have collected information about a Child, that information will be immediately deleted from our database. If you believe your child has provided us with personally identifiable information please contact us through email, at privacy@drove.co to have the data provided by or associated with your child deleted.

8. Data transfer outside the EEA

We may store or process your Personal Data in the US or in other countries. If you are a resident of the European Economic Area ("EEA") we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

9. Changes to this Privacy Policy

We reserve the right, at our discretion, to update or revise this Privacy Policy at any time. Any changes or modification will be effective immediately upon the “Last Updated” data stipulated below. In the event of a material change, we will make best efforts to send you a written notification. Your continuance of use of the Platform, site or Services shall be acknowledgment of the revised Privacy Policy.

10. Contacting us

Please feel free to direct any questions or concerns regarding these Privacy Policy by contacting us through email at privacy@drove.com.

Drove Network Ltd.

30 Ibn Gvirol, Tel Aviv, Israel

11. Data Protection Officer

If you have any requests regarding the data processed under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@drove.com

Last Updated: December 17, 2018