UPDATED AS OF: 06/25/2021

 

1) INTRODUCTION

Venice Innovation Labs, d/b/a Drops ("DROPS", "we", "us", or "our") is committed to maintaining your confidence and trust as it relates to the privacy of your information. This policy describes how we collect, protect, share and use your information, both offline and online, including (as part of our websites), software, online services and apps (collectively, "Platforms"), and your rights and choices in connection with your information. When we ask you to provide certain information by which you can be identified when using our services, you can be assured that it will only be used in accordance with this Policy.

This Policy is in compliance with the requirements of the European Union's General Data Protection Regulation (GDPR) which came into force on May 25, 2018, and the California Consumer Privacy Act (CCPA), which came into effect January 1, 2020. This policy does not diminish any additional rights you may have under the laws of your country.

 

WHO WE ARE

 

DROPS is a part of Venice Innovation Labs, Inc, based in Los Angeles, California in the United States. This policy applies to all DROPS companies and businesses. All DROPS offices operate under this Policy.

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2) GDPR LEGAL BASIS

 

Some DROPS businesses are compliant with provisions of the GDPR for users located in the European Union (EU).

DROPS asserts that it is in our legitimate interest to collect and store personal data from our customers. DROPS leverages robust, best practice methods to optimize communication between ourselves and our customers and their employees. At present, the immediate and universally supported communication method is email. It is in the legitimate interests of DROPS to use email, cellphones and landlines to apprise customers and prospects regarding the status of their services; to provide timely updates regarding the progress of support issues; to send advisories regarding account security or planned service outages; and to determine customer preferences and priorities in the marketplace.

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3) PERSONAL INFORMATION WE COLLECT

 

DROPS (and the vendors we hire to perform business functions on our behalf) collect, receive and develop several categories of personal information about you based on the nature of your interactions with us.

Identifiers: We collect your name, email address, phone number, mobile phone number, birthday, preferred pronouns, zip code, Spotify-linked information, and DROPS account usernames and passwords.

Preference Information: We collect records of your product activations and notification subscriptions.

Browser, Usage, and Device Information: We, or our analytics providers, may use tracking tools like cookies to automatically collect information about your interactions with our Platforms, including your IP address, computer name, operating system and other hardware metrics of your device or computer.

 

4) SOURCES OF PERSONAL INFORMATION

 

Directly from you: We, along with our service providers, collect personal information from you when you use the Platforms, for example to create an account, update your information, complete form submissions, subscribe to features or notifications, use certain features, create a profile, or indicate your preferences or settings.

Automatically from your devices or computers: The computers or devices you use to connect to DROPS Services and Platforms may send us information about which features and functions you use most frequently. This data will be anonymous and will not contain your personal information.

Vendors and service providers: We receive information about you from our vendors and business directory providers that we hire to help us run our business, including those that host, protect or operate our Platforms; analyze data; provide customer service; send emails for us; process payments; conduct surveys; fulfill orders; provide electronic coursework or training materials; or provide marketing or advertising services.

Combined information: Information obtained from various sources may be combined to identify patterns in various customer groups.

 

5) HOW WE USE THE INFORMATION WE GATHER

 

We may use each of the above-referenced categories of personal information as follows:

• To respond to your questions and requests (Identifiers);

• To provide customer service (Identifiers; Preference Info);

• To control your access to certain areas and features of the Platforms, such as product-specific support information, documentation and materials (Preference Info);

• To communicate with you about your account and activities on the Platforms, such as changes to any DROPS policy (Identifiers);

• To notify you about updates to your open support issues including progress in resolving issues or changing the status of your issues;

• To administer the Platforms; diagnose problems with our services; and facilitate site navigation;

• For market research;

• To notify you about available software updates; service bulletins; planned network or service outages; or known software or service issues;

• To improve the Platforms, their features and usability;

• To track effectiveness of advertising (such as measuring how many people view or click an ad) and for advertising attribution, analytics and reporting;

• To personalize your DROPS customer experience, including knowing your preferences for feature operation or notification messages;

• To send you marketing and promotional messages;

• To notify you of any security breaches involving your information;

• To protect against fraud, online threats, protecting the rights of our clients and subscribers; detecting illegal activity; and responding to legal or regulatory compliance obligations;

• To verify your identity; authenticate you and provide activation or communication services to you; and provide file downloads;

• For other lawful purposes disclosed at the time we collect your information or otherwise with your consent.

 

INFORMATION COLLECTED BY ACTIVITY

 

Some information we collect from you varies based on the nature of your activity:

a. When you visit our websites or request information online

When you visit our websites, including DROPS.com, DROPS will collect the IP address of your computer, and the date, time and length of your visit.

Our web sites use cookies to store information on your computer or device. This information consists of your username and, if you invoke the Remember Me function, a hash of your password. Cookies expire after one year.

 

6) SHARING YOUR INFORMATION

 

DROPS shares personal information as described below:

 

6.1 Vendors and Service Providers: DROPS may share some personal information with third parties in order to facilitate, process or streamline our communications with you, deliver our products and services to you, and obtain information about your preferences or your satisfaction with our services and products. These third parties process personal information at request and on behalf of DROPS.

DROPS does not sell personal information to third parties.

 

6.2 Third Parties: The third parties to which DROPS may disclose personal information are:

• Google Analytics

• Google Play Store

• Apple App Store

 

6.3 Business transfers: As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, or assets related to the Platforms, your information may be disclosed to such entity as part of the due diligence process and may be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal compliance: DROPS may transfer and disclose your information to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of other parties, visitors to our Platforms, or the public.

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Other disclosures: We may share personal information for other reasons we may describe to you from time to time as permitted by law.

 

Non-personal information: We may share information that has been de-identified or aggregated such that it does not identify or relate to you, with other parties for any purpose. This may include aggregated user statistics about the Platforms or aggregated demographic information about our users.

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7) SECURITY OF YOUR INFORMATION

 

We are committed to ensuring that your information is secure by using reasonable technical, administrative and physical security measures designed to protect your information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Platforms and provide us with your information at your own risk.

 

DROPS routinely performs penetration testing on network nodes to ensure the security technology and protocols are adequately protecting the network and stored information.

 

If a breach of security is discovered and the breach is likely to pose risk to the persons whose data is impacted, DROPS will report the breach. The DROPS IT department is instructed to identify and report any issues of data breach to the designated company officer, who will notify any relevant governing bodies within 72 hours. All impacted users will also be notified of any breach.

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8) OTHER SITES

 

The Platforms may contain links to other sites we do not own or operate. This includes links from service providers, and advertisers. We do not control, recommend or endorse, and are not responsible for these sites or their content, products, services, privacy policies or practices. These other sites may send their own cookies to your browser or Device, they may independently collect data or solicit personal information, and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms, including those linked from an email or on a social media site.

The Platforms may make chat rooms, forums and message boards available. Remember that any information you disclose in these areas becomes public information and is not subject to the provisions of this Privacy Policy.

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9) CONTROLLING YOUR PERSONAL INFORMATION

 

You may choose to restrict the collection or use of your personal information from your profile page when you log in to DROPS.com.

If you are an EU resident, please note that DROPS is currently intended for use in the United States only. At a future date, if and when DROPS becomes available in the EU, you may request details of personal information that we may hold about you. If applicable, we will promptly correct any information found to be incorrect. Contact DROPS for assistance at [email protected].

If you are a California resident, you have options under the California Consumer Privacy Act (CCPA). See item 10 below for more information.

Marketing Communications: If you do not want to receive promotional communications from us, including advertisements, surveys or other marketing announcements, you can unsubscribe by:

• Updating your app push notification settings

• Replying “STOP” or “UNSUBSCRIBE” to any SMS or Email-based communications

• Contacting us at [email protected]

 

Please note that if you opt out of marketing oriented communications, we may still send you non-marketing communications such as those regarding your account or ongoing business relationships.

Do Not Track: Some browsers allow for the setting of a Do Not Track marker that conveys a request that the web site visited should not store information about the visitor during the course of their interaction with the web site. Because this is a deprecated technology without uniform implementation and support from most browsers, DROPS does not observe the Do Not Track requests sent by browsers.

 

REMOVAL OF YOUR PERSONAL INFORMATION

 

DROPS will erase your personal information from our systems upon request sent to [email protected].

 

In accordance with routine data maintenance or housekeeping, DROPS may delete certain records that contain personal information about you. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information.

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REMOVAL PROCEDURE FOR CALIFORNIA RESIDENTS

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If you wish to request deletion under provisions of the CCPA for residents of California, you may request deletion of your data from the DROPS Privacy Request center by writing [email protected].

DROPS will confirm your request within 30 days and, if valid, will complete the erasure or explain why it was unable to do so within 30 days.

 

10) CCPA AND YOUR RIGHTS

 

Residents of California have rights under the provisions of the CCPA (California Consumer Privacy Act), including the rights:

 

1.  to request a summary of the personal information we have about you

2.  to request erasure of the personal information we have about you

3.  to request that your personal information is not sold

4.  to know the categories of personal information DROPS has collected in the past 12 months (see Section 3 above)

5.  to know the categories of personal information DROPS has sold in the preceding 12 months (see next section)

6.  to know the categories of personal information DROPS has disclosed for a business purpose in the preceding 12 months (see next section)

7.  to not receive discriminatory treatment by DROPS for exercising privacy rights under the CCPA.

To request any of the first three listed items, please contact us at [email protected].

If you exercise any of your rights, DROPS may ask you for information to confirm your identity and, where applicable, to help DROPS find your personal data. After confirming your request is authentic, DROPS will respond within 30 days with the requested report or confirmation of deletion or a reason why the request could not be fulfilled.

 

c. ADDITIONAL CCPA DISCLOSURES

Under the provisions afforded by CCPA, DROPS makes the following disclosures about the categories of Personal Information it collects, sells or uses for a business purpose, and indicates the sources and uses of data collected:

 

Categories of Personal Information Collected in preceding 12 months:

• Name

• Contact Info

• Demographic info

• Digital Interactions

• Usage data

• Sources: customers, analytics providers, business partners, third party industry directories

 

Categories of Personal Information Sold in preceding 12 months:

(none)

DROPS does not sell Personal Information.

 

Categories of Personal Information shared with third parties in preceding 12 months:

• Name

• Contact Info

 

Usage Categories of Personal Information

• Providing customer support including account management

• Training scheduling

• Sending marketing or support messages

• Web site operation

• Compiling analytics

• Fulfilling orders and processing online payments

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11) CHILDREN

The Platform is not directed to children under 13. We do not knowingly collect, use or disclose personal information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her personal information without the parent/guardian's consent. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

 

12) CHANGES TO THIS POLICY

We reserve the right to update this Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites, and as required, obtaining your consent. Any updates will become effective immediately after posting the updates to this Policy and apply to all information collected about you, or where required, upon your consent. You agree that you will review this Policy periodically.

If we make any changes to this Policy, we will change the "Last Updated" date above.

The provisions of the CCPA require that this policy shall be updated at least once yearly.

If we make any major changes to this Policy - including, but not limited to, changes that materially impact previously collected information about you - we will contact you by email to obtain your prior express consent.

If you do not agree or consent to these updates or changes, do not continue to use the Platform.

 

13) CONTACT US

If you have any questions about this Policy, or concerning information we may have collected about you and the manner in which it is used, please contact us by email at [email protected].