LAST UPDATED: 01.27.2021
By visiting the Site or using any of our Services, you acknowledge and agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Drop Terms of Service are incorporated by reference into this Policy.
About Creative Bot, Inc. d/b/a Drop
We provide our customers (e-commerce brands) with technical solutions to interact with their audiences. For example, our customers may deploy a virtual assistant ('chatbot') or provide an SMS service offering to enable 1-to-1 conversations at scale with their subscribers on our customer’s digital service offerings. Our customers may choose to integrate additional third-party solutions that allow their audiences to purchase and pay for our customer’s products and services. We also provide our customers with professional services and dedicated client strategists.
Information We Process on Behalf of Our Business Customers
Where our customer incorporates Drop Services into their digital service, our customer is responsible for the personal information of their users If you are a user of one of our customer's digital services, which incorporates Drop, you should refer to the privacy statements of the relevant customer for more information. This Policy does not apply to the personal information that we process on behalf of our customers, which is governed by the agreements we have with our business customers. In the event the European Union's General Data Protection Regulation and similar laws are applicable to us and our processing of personal information, we will act as a processor for our customer, who will be the relevant controller of your personal information. Similarly, in the event the California Consumer Privacy Act (“CCPA”) is applicable to us and our processing of your personal information, we will act as a Service Provider for our customer, who will act as the Business as defined under the CCPA. If you have any questions or concerns about how such information is handled or would like to exercise your rights, you should contact the business customer who has contracted with us to use the Services to process their information. Our business customers control the personal information in these cases and determine the security settings, access controls and use of personal information. We will, however, provide assistance to our business customers/data controllers to address any concerns you may have, in accordance with the terms of our contract with them and applicable law.
The Information We Collect About You
We collect information about you directly from you and from third parties such as internet service providers, operating systems and platforms, advertising networks, data analytics providers, social networks, government entities, data brokers and business customers during your use of our Site or Services.
Information We Collect Directly From You.
The information we collect from you depends on how you use our Services. To create an account as a Drop customer, you must provide your full name; company / organization name; email and physical address; and password. You may also provide a phone number or profile image, but this is not mandatory to create an account. Finally, you will need to provide billing information, but we would expect this to be the information associated with your company or organization.
Information We Collect Automatically.
We automatically collect information about your use of our Site through cookies, local storage objects, java scripts and other technologies. The information collected includes the time you access our Site; the pages you view and links you click on; your approximate geo-location; your browser and operating system; your IP address; the length of time you visit our Site and/or use our Services; and the referring URL or the webpage that led you to our Site.
To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
- To create a customer account and provide you with access to our platform and our Services.
- To administer your account and carrying out billing.
- To communicate with you about your use of our Services, to respond to your enquiries, and for other customer service purposes, including through the use of our chat feature.
- To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services and out Site.
- To register your potential interest in our Services and to generate and qualify sales leads.
- To send you newsletters and promotional communications (including by email, text message and push notification) about our Services and those of our affiliated entities, subject to your right to opt-out of these at any time.
- To assist us in advertising on third party websites, and other online services, and to evaluate the success of our adverting campaigns through third party channels (including our online targeted advertising and offline promotional campaigns).
- To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site and App are more (or least) used by users, and we will use this information.
- To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.
- To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
Aggregated or Deidentified Information.
We may also generate aggregated or otherwise deidentified information - which does not constitute personal information - about users for marketing, advertising, research or similar purposes.
Lawful Basis. Where the GDPR and similar laws apply, we are required to establish a "lawful basis" for each activity which involves the use of your personal information.
Our legal bases are as follows:
Account Administration (including billing)
• Necessary to enter into or perform a contract with you (upon your request), where you are contracting with us as an individual.
• Our legitimate business interest in creating a managing an account for your company or organization.
• Our legitimate business interest in tailoring the Site, platform and other Services to your preferences and location.
• Your consent, where this is required under applicable law (e.g. for the purposes of setting non-essential cookies which are necessary for the personalization).
Generating and Qualifying Sales Leads
Marketing and Promotions
Advertising and Referrals
• Our legitimate business interest in assessing and promoting interest in our Services for the purposes of generating new 'business-to-business' customer relationships and expanding current relationships.
• Your consent, where required by applicable law for marketing or advertising purposes.
Analytics and Improvement
Surveys and Questionnaires
• Our legitimate business interest in understanding how our Site and Services are used, in order to improve the same.
Protect Our Rights and Prevent Misuse
Verify Identity and Detect Fraud
Comply with Legal Obligation
• Compliance with a legal obligation.
• Our legitimate business interest in establishing, defending or protecting our legal interests.
General Business Operations
• Compliance with a legal obligation.
• Our legitimate business interest in establishing, defending or protecting our legal interests.
How We Share Your Information
We may share your information, including personal information, as follows:
- Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers only process your personal information on our instructions and subject to appropriate contractual restrictions and protections.
- Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries for the purposes listed above.
- Third Party Advertisers and Ad-Networks. See the section "Third Party Ad-Networks" below for more information.
We also disclose information in the following circumstances:
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
- In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and Services.
- Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
Third-Party Ad Networks
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.
Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.
Users in the European Union can opt-out of ad networks on the Your Online Choices page.
Third-Party Links and Service Offerings
Our Site may contain links to third party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of Your Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Retention of Your Personal Information
We will maintain your personal information only for as long as is it is necessary for a purpose identified in this Policy or by applicable law. In particular, we may store your personal information for specified periods of time where we are required to do so in accordance with legal, regulatory, tax, accounting requirements. We may also retain your personal information so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Access To Your Personal Information
If you are an existing customer, you may modify personal information by navigating to Settings > Profile in your account and updating or changing the relevant information.
Personal Information Rights
Certain laws provide for rights for individuals relating to the use of their personal information. These rights will only be available to you if a relevant law applies to our use of your personal information, or if we, in our absolute discretion, choose to extend any such right to you. Other than where permitted by law, we do not charge for your exercise of these rights but in certain cases may require further proof of your identity. Where you are entitled to a right, we will respond to your request within the timeframe set out by law, or where we provide answers on a voluntary basis within a reasonable timeframe.
Please note that we only respond directly to you in cases where we are the controller of your personal information. As explained in the section "About Creative Bot, Inc. d/b/a Drop" above, if you are using a digital service which incorporates our Services, the relevant controller will be our customer, and not us.
Access, Rectification, Portability and Deletion.
You may have the right to access, rectify (correct), or delete your personal information held by us. You may also have the right to ask for an overview or copy of your personal information or to request that certain of your personal information be exported to another provider where technically feasible. On some of our Sites and Services, you may access, rectify, or delete your personal information by making the change directly on your account page. You may also make these requests by sending an email to firstname.lastname@example.org.
Please note that there are some limitations to these rights. For example, we will not be able to delete your personal information if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your personal information may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. If we cannot fulfill your request we will inform you about why we cannot comply with your request.
Withdrawal of Consent.
Where we process your personal information on the basis of your consent, you may have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. To exercise your rights email email@example.com (or contact us as indicated in the ‘Contact Us’ section below). Please keep in mind that certain services may not be available if you withdraw your consent, or otherwise delete or object to our processing of certain personal information
Object to Processing.
You may have the right to object to processing (including profiling) based on legitimate interest grounds, where we are relying upon legitimate interests to process personal information. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal information for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.****
Right to Lodge a Complaint.
You may have the right to lodge a complaint with your local supervisory authority for data protection, if you consider that the processing of your personal information infringes applicable law.
Object to the Sale.
Where applicable, you may have the right to object to the sale of your personal information (although exceptions may exist for business transfers such as sales of our stock or assets).
We may send periodic promotional emails or SMS messages to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email, or by contacting firstname.lastname@example.org. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you non-promotional emails about your account or any services you have requested or received from us.
Drop is headquartered in the United States of America. The personal information we collect from you may be transferred to, stored at or processed in countries other than your country of residence, including the United States or outside the European Economic Area, which may not provide equivalent levels of data protection as your home jurisdiction.
If your personal information is subject to a restricted international transfer (including through our use of third party service providers) we will take steps to ensure that it receives an adequate level of protection. Safeguards may also include adequacy decisions by the EU Commission or putting in place standard contractual clauses as approved by the European Commission or other appropriate transfer mechanisms.
Our Services are not designed for children. If we discover that a child has provided us with personal information, we will delete such information from our systems.
Additional Information for California Residents under the CCPA
As a Service Provider under the CCPA, we process or maintain personal information on behalf of our Business customers that provide the personal information to us in compliance with written contracts that we enter into with our Business customers directly. In accordance with the CCPA, we use and disclose personal information we receive from our Business customers as necessary to provide the Services to our Business customers, to retain or employ another Service Provider where that Service Provider meets the requirements of a Service Provider under the CCPA, for our internal use to build and improve the quality of our Services as permitted under the CCPA, to detect security incidents or protect against fraudulent or illegal activity and for the purposes enumerated under CCPA Civil Code section 1798.145(a)(1) through (a)(4) or as otherwise required by the CCPA.
This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
In general, when we operate as a Service Provider, we will handle requests to know or requests to delete on behalf of our Business customer as they require under our agreement, which allows us to comply with the CCPA by acting on their behalf according to their instructions or by responding to a consumer that the request cannot be acting upon because the request has been sent to a Service Provider.
In general, under the CCPA, Businesses must notify and provide California residents with the following rights with respect to their personal information:
- Do-not-sell (opt-out): to opt-out of the sale of their personal information.
- Right of deletion: to request deletion of their personal information collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
- Right to know: with respect to the personal information collected in the prior 12 months, disclose the following (up to twice per year and subject to certain exemptions):
- categories of personal information collected;
- categories of sources of personal information;
- categories of personal information disclosed or shared with a third party for a business purpose;
- categories of third parties to whom their personal information was sold and for each the specific categories of personal information sold;
- the business or commercial purposes for collecting or selling personal information; and
- a copy of the specific pieces of personal information collected about them.
- Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
Submitting CCPA Requests.
California residents may submit CCPA requests by contacting our Business customers directly or by emailing us at: email@example.com. When you submit a request to know or a request to delete, we, if and as requested by our Business customers, will take steps to verify your request by matching the information provided by you with the information we and/or our Business customers have in our or their records. In some cases, additional information may be requested in order to verify your request or where necessary to process your request. If we and/or our Business customers are unable to adequately verify a request, we and/or our Business customers will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting our Business customers directly or emailing us at firstname.lastname@example.org. Authorized agents will be required to provide proof of their authorization, and our Business customers and/or we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
For more information about our privacy practices, please see the Contact Us section below.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please email us at email@example.com or write to us at Creative Bot, Inc. d/b/a Drop, 1156 W 26th Street, San Pedro, CA90731.
Changes to this Policy
This Policy is current as of the Last Updated date set out above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site.