Effective Date: August 30th, 2018
Effective Date: August 30th, 2018
1. Our Commitment to Privacy
2. Scope and Application
3. What is Personal Information
“Personal information” is personally identifiable information such as your name, residential address, business address, and e-mail address, or any other information that can be used to identify an individual or about an identifiable individual. We are not in the business of collecting anyone’s personal information except to the extent it’s needed in relation to our business, namely, helping Users connect with each other to either have snow removed from their property or provide the snow removal service requested by another User, or supporting our Services and communicating with Users and prospective Users.
We collect personal information only when you specifically and knowingly provide it to us, such as if you choose to communicate or register with us to open an account after downloading any of our Apps or if you visit our Website and choose to provide us with details about yourself, including your name, telephone number, business mailing address, and email address to participate in any services we offer.
4. Collection of Information
4.1 Collecting, Using, and Storing of Personal Information You Provide to Us. We collect personal information you provide directly to us, such as when you create or modify your account, request snow removal services from other Users, contact our customer support, or otherwise communicate with us. This personal information may include: your name, email, phone number, street address, profile picture, online payment method, services requested,
notes for us or other Users providing snow removal services at your request, and other information you choose to provide. We have security measures in place to prevent the loss, misuse, and alteration of the information we obtain from you. In addition to receiving personal information from Users for purposes of facilitating snow removal, Dryft may, in its sole and absolute discretion, monitor or review your access to and use of our Apps and Service at any time. In the normal course, we do not expect to review or monitor information, communications, photographs, or other content which you may generate, upload,
transmit, copy, or otherwise make available arising from any use of our Service (collectively, the “Content”), except as follows:
(a) as permitted under the terms of the License Agreement you entered into after installing
but before using any of our Apps; or
(b) as necessary to maintain or provide our Website and the Service, including without limitation
(i) to respond to service requests;
(ii) to restore the applicable Content at your request in the event of a service interruption;
(iii) to conform to legal requirements or comply with legal process as deemed necessary or advisable by Dryft in good faith;
(iv) to detect, prevent, or otherwise address fraud, security, or technical issues; or
(v) to enforce the terms of our License Agreement, including investigation of potential violations thereof.
4.2 Information We Collect Through Your Use of Our Services.
When you choose to use our Services, we collect personal information about you in the following general categories:
- Location Information: When you use any of our Apps, we collect precise location data about you from our App if you are a User providing another User requested snow removal services.
- Contacts Information: If you permit our App to access the address book on your device through the permission system used by your OS, we may access and store names and contact information from your address book to facilitate offers from us for the use of our Services and for other purposes described in this Policy applicable to our Users.
- Transaction Information: We collect transaction details related to your use of our Services, including the type of snow removal service requested, date and time the service was provided, amount charged, distance traveled, and other related transaction details. Additionally, if someone else uses a promotional code provided to you, we may associate your name with that person.
- Call and Text Data; Using our Apps facilitate communications by and between Users with respect to requesting and providing snow removal services. In connection with facilitating this service, we receive call data, including the date and time of the call or text messages, the Users’ phone numbers, and the content of text messages.
- Log Information: When you interact with the Services, we collect server logs, which may include information like your mobile device IP address, access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.
4.3 Non-Personal Information
We also collect non-personally identifiable information about Users in a number of ways, including tracking activities through your IP address, mobile device settings, or most-recently visited URL. We do this to generate aggregated statistical data with a view to improving the quality of our Services to Users and improving the User experience. In addition:
- Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
- Location Information: If you permit our App to access location services through the permission system used by your mobile software operating system (the “OS”), we may also collect the precise location of your device when the App is running in the foreground or background. We may also derive your approximate location from your IP address.
4.4 Important Information About Mobile Device Software Operating System Permissions
Most mobile device operating system software platforms (such as iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The Apple iOS platform used on iPhones and iPads will alert you the first time our App wants permission to access certain types of data stored on your mobile device and will provide you with the option to consent (or not consent) to that request. Devices using the Android operating system will notify you of the permissions that our App seeks before you first use the app, and your use of the app constitutes your consent.
4.5 Information We Collect From Other Sources.
We may also receive personal information from other sources and combine that with information we collect through our Services. For example, if you choose to link, create, or log in to your Dryft account with a payment provider (e.g., Google Wallet) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
5. We do not release Personal Information in the normal course
We use Amazon Web Services Inc., and Stripe Inc. to process and store the personal information of our Users. This personal information is stored in the United States. Unless you specifically authorize us to release your personal information, or release is required or permitted by law, we will not disclose, sell, rent, lease, license, or trade your personal information to any other third parties. Thus, personal information may be subject to disclosure in accordance with the laws applicable in Canada or the United States, and the jurisdictions where Amazon and Stripe physically locate their servers in relation to the software services provided to Dryft. Your personal information may be accessible to regulatory, law enforcement, and national security authorities of those jurisdictions, and may be subject to disclosure in accordance with the laws of those countries. Such laws may or may not provide the same level of protection for personal information as do the applicable laws of the jurisdiction in which you ordinarily reside. We only share personal information with third parties, such as Amazon and Stripe in the normal course of using their software services offered to us for purposes of operating our Services in the normal course of business. If Dryft is involved in a merger, acquisition, or any form of sale of some or all of our assets, we may transfer any and all personal information we collect to the relevant third party.
6. Use of Information and Informed Consent
We will only request personal information that we need and will only ask for it when it’s needed. We may use the personal information we collect about you to:
- provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users, develop safety features, authenticate Users, and send updates to our Apps and administrative messages;
- perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
- to send or facilitate communications:
(i) between Users, so that if you requested snow removal services from another User, the
other User providing such services can coordinate estimated times of arrival (ETAs) at the
relevant location for the snow removal services to then be performed, or
(ii) between you and a contact of yours in connection with your use of certain features,
such as referrals, invites, or ETA sharing;
- send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of or by Dryft and other companies, where permissible and according to local applicable laws;
- personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements. For example, we provide your name, photo (if you provide one), and rating information (if provided) given by other Users who have had experiences with you in using our Services.
7. Sharing of Information
We may share your personal information with other Users to enable you to receive, or provide, the snow removal services requested via our App. We also may share your personal information in the following circumstances:
- with third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;
- with the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public;
- with third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate;
- entities that provide services or conduct data processing on our behalf such as Amazon and Stripe, as noted above;
- when you make a request through our App to obtain snow removal services, we automatically provide certain personal information to other Users who specifically perform snow removal services to facilitate such request. This information includes your name, may include your photograph if you included it as part of your account with us, the location where you have requested the snow removal services to be performed, your phone number, email address, and reviews about you as a customer. This information is provided to other Users in the general area who perform snow removal services as if you contacted the snow remover individual directly, with a view to getting your request fulfilled as soon as reasonably possible in the circumstances.
If you provide a mobile phone number in connection with your request, Dryft or another User willing to provide you with snow removal services may send you text messages regarding your request. And Dryft also requires you to provide credit or debit card or other online payment protocol information in setting up your account with Dryft in the first instance;
- when you respond to a request through our App to perform snow removal services for another User requesting the same, we automatically provide certain personal information provided by you to that other User to facilitate that performance of services by you. This information includes your name, may include your photograph if you included it as part of your account with us, your vehicle details, your phone number, email address, and reviews about you as a provider of snow removal services. This information is provided to each User requesting snow removal services for which you have indicated an interest in providing as if you were contacted directly by the individual customer looking for assistance with snow removal, with a view to getting that prospective request fulfilled by you as soon as reasonably possible in the circumstances. If you provide a mobile phone number in connection with your willingness to perform snow removal services, Dryft or the prospective customer requesting snow removal services may send you text messages regarding your availability, anticipated arrival, and other related queries. And Dryft also requires you to provide bank, credit or debit card, or other online payment protocol information in setting up your account with Dryft in the first instance.
- by submitting your bank account, credit or debit card, or other online payment protocol account information (like PayPal) (such payment account or card details are called, the “Payment Information”) through our Services, to the extent permitted by applicable law, you expressly consent to the sharing of your personal information with our third-party payment processor Stripe, and other third-party service providers (including, but not limited to, vendors who provide fraud detection services to us and other third parties), and you further agree to the following terms:
• when you provide your Payment Information to open an account with Dryft, we provide your Payment Information (including card number and expiration date, but excluding the CVV number) to our third-party payment service provider;
• when you initially provide your Payment Information through our App in order to set up an account with us to use our Services, we provide this Payment Information to our third-party payment service provider. This third party may store your Payment Information so you can request and benefit from or provide snow removal services to Users in the future to the extent permitted by local law.
• for information about the security of your Payment Information, see Section 8, below.
- in response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
- with law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with the terms of our License Agreement Users must agree with in order to open an account with us, or to protect the rights, property, or safety of Dryft or others;
- if necessary to enforce the terms of our License Agreement for use of any of our Apps;
- to detect, prevent, or otherwise address fraud, security, or technical issues;
- in connection with, or during negotiations of, any merger, sale of our company’s assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
- if we otherwise notify you and you consent to the sharing; and
- in an aggregated and/or anonymized form which cannot reasonably be used to identify you.
7.2 Social Sharing Features
The Services may integrate with social sharing features and other related tools which let you share actions you take on or using our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of personal information with your friends or
the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. Our Website and App may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.
7.3 Analytics and Advertising Services Provided by Others
8. Security of your Personal Information
Dryft takes commercially-reasonable technical, administrative, and physical security measures designed to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. When your Payment Information is being transmitted to us via the Apps or through our Website, it will be protected by cryptographic protocols. To be clear, Dryft does not itself store your Payment Information, and we do not have direct control over or responsibility for your Payment Information. We use third party payment processors that are the controllers of your Payment Information. Our contracts with third parties that receive your Payment Information require them to keep it secure and confidential.
Nonetheless, we cannot guarantee that transmissions of your Payment Information or your other personal information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by Dryft or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your personal information due to errors in transmission, unauthorized third-party access, or other causes beyond our control. You play an important role in keeping your personal information secure. You should not share your account user name, password, or other security information for your Dryft account with anyone. If we receive instructions using your account user name and password, we will consider that you have authorized the instructions. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately at firstname.lastname@example.org.
9. Your Choices
9.1 Accurate Information.
If you have questions about the accuracy of factual information about you, you will have access to that information in order to verify and update it. All required registration information that you provide to us must be current, complete, and accurate and must be kept up to date with Dryft on a prompt, timely basis. You may correct your account information at any time by using our App. If you wish to cancel your account, please email us at support@Dryftnow.com. Please note that in some cases, we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated the terms of our License Agreement entered into when opening an account with us in the first instance, we may seek to resolve the issue before deleting your information.
9.2 Location Information.
As we have noted above, we request permission for our App’s collection of precise location details from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of our Services. Additionally, if you are a User providing snow removal services to other Users, disabling our App’s collection of precise location from your device will not limit our ability to collect your trip location information from your device nor our ability to derive approximate location from your IP address.
9.3 Contact Information.
We may also seek permission for our App’s collection and syncing of contact information from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, iOS Users can later disable it by changing the contacts settings on your mobile device. The Android platform does not provide such a setting.
9.4 Promotional Communications.
You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about using our Services, or our ongoing business relations.
9.5 Cookies and Advertising.
Please refer to Section 11 below for more information about your choices around cookies and related technologies.
9.6 Deleting your Information
You have the right to request that your personal information is erased by us. Please provide any request to erase your personal information in writing, sent to email@example.com and provide sufficient detail to identify the personal information sought. We will respond to all requests for erasure within a reasonable amount of time or provide you with written notice of an extension where we need additional time to fulfill your request. If you ask us to erase your personal information, we’ll use commercially reasonable efforts to remove your personal information from our files, however, we may not be able to delete some of your personal information to the extent that it’s still necessary in relation to the purposes for which it was collected, or in relation to a legal obligation we have. We may also retain, use, and share your “non-personal” information that we previously collected prior to your request for erasure.
11.1 Using Cookies
11.2 Cookies Overview
Cookies are small text files that are stored on your browser or mobile device by websites, apps, online media, and advertisements. There are different types of cookies. When using our Services, cookies served by Dryft are called “first party cookies.” Cookies served by companies that are not operating our Apps or our Website are called “third party cookies.” For example, we may allow Google to set a cookie on your browser while you visit www.dryftnow.com, and that would be a third-party cookie. Cookies may also endure for different periods of time. “Session Cookies” only last only as long as your browser is open. These are deleted automatically once you close your browser. Other cookies are “persistent cookies” meaning that they survive after your browser is closed. For example, they may recognize your device when you re-open your browser and browse the internet again. They may also save you the inconvenience of having to log-in to our App with your password to access your account.
11.3 Other Identification Technologies
In addition to cookies, we use other identification technologies in association with the provision of our Services. “Pixel tags” (also called beacons or pixels) are small blocks of code installed on (or called by) a webpage, app, or advertisement which can retrieve certain information about your device and browser, including for example: device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, and other similar information, including the small text file (the cookie) that uniquely identifies the device. Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner. “Local storage” refers generally to other places on a browser or device where information can be stored by websites, ads, or third parties (such as HTML5 local storage and browser cache). “Software Development Kits” (also called SDKs) function like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the SDK) from partners in the app, and thereby allow the partner to collect certain information about User interaction with the app and information about the User device and network information.
11.4 Your Choices
You have the right to choose whether or not to accept cookies. However, they are an important part of how our Services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the Services. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser, which are usually located within the “Help” or “Preferences” menu. Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have indicated where this is possible in the table below. Removing or rejecting browser cookies does not necessarily affect third-party flash cookies which may be used by us or our partners in connection with our Services. For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit www.allaboutcookies.org.
11.5 Types and Purposes of Cookies
The following table sets out the different categories of cookies that our Services use and why we use them. The lists of third-party cookie providers are intended merely as illustrative and are not comprehensive.
|Type Of Cookie||Purpose||Who Serves (for example)|
These cookies (including local storage and similar technologies) tell us when you’re logged in, so we can show you the appropriate experience and features such as your account information, trip history, and to edit your account settings
|Security & Site Integrity|
We use these cookies to support or enable security features to help keep Dryft safe and secure. For example, they enable us to remember when you are logged into a secure area of the Services and help protect your account from being accessed by anyone other than you.
|Site Features & Services|
|Analytics & Research|
These are used to understand, improve, and research Services, including when you access our App or the Website and other, related websites and apps from a computer or mobile device. We and our partners may use these technologies and the information we receive to improve and understand how you use websites, apps, products, services and ads.
Things like cookies and pixels are used to deliver relevant ads, track ad campaign performance, and efficiency. For example, we and our ad partners may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites. Similarly, our partners may use a cookie, attribution service, or another similar technology to determine whether we’ve served an ad and how it performed, or provide us with information about how you interact with them. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/ choices if you reside in the United States.
Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited. If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to help make our website appealing. This constitutes a justified interest pursuant to Art. 6 (1) (f) DSGVO. Further information about handling user data, can be found in the data protection declaration of YouTube under https://policies.google.com/privacy.
13. Google Web Fonts
14. Plugin: Smush
14. Applicable Law
15. Contact Us