Privacy Policy

Your privacy is critically important to us. At Dröm, we have a few fundamental principles:

• We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We help protect you from overreaching government demands for your personal information.
• We aim for full transparency on how we gather, use, and share your personal information.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

This Privacy Policy applies to information that we collect about you when you use:

• Our websites (drom.date and drommatch.com);
• Our mobile applications (including the Dröm mobile app for Android and iOS).

This Privacy Policy also applies to information we collect when you apply for a job at Dröm. Throughout this Privacy Policy we'll refer to our websites, mobile applications, and other products and services collectively as "Services." Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from two sources: if and when you provide information to us, and automatically through operating our Services. Let's go over the information that we collect.

Information You Provide to Us

It's probably no surprise that we collect information that you provide to us directly. Here are some examples:

• Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Dröm account to provide an email address and password.
• Private Content information: We collect the information that you provide for your private profile: your selections of dealmakers & dealbreakers, profile videos, chat videos & chat text.
• Public Content information: You may submit new dealmakers & dealbreakers for the community to use. The Public Content you submit will remain anonymous and your name and identity will never be attached to it.
• Communications with us: You may also provide us with information when you respond to surveys, communicate with our engineers about a support question, or sign up for a newsletter. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
• Job applicant information: If you apply for a job with us, you may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services.
• Usage information: We collect information about your usage of our Services — in other words, who did what and when. We collect information about what happens when you use our Services (e.g., page views and interactions with other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, and verify user information.
• To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy or make our Services easier to use.
• To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users, advertising our Services, analyzing the results of our marketing campaigns, and understanding and forecasting user retention.
• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Dröm and others.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize the user experience. For example, to personalize your experience by serving you relevant content for our Services.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Dröm. If you don't want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we'll still send you important updates relating to your account.)
• To recruit and hire new employees. For example, by evaluating job applicants and communicating with them.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy:

• Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, and customer chat and email support services that help us communicate with you); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations; and other third-party tools that help us manage operations. We require vendors to agree to privacy commitments in order to share information with them.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Dröm, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Dröm goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
• Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

We do not sell our users' non-aggregated or identifiable data. We aren't a data broker, we don't sell your personal information to data brokers, and we don't sell your information to other companies that want to spam you with marketing emails.

Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly. That means new dealmakers & dealbreakers that you propose may be made available to others. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share publicly.

How Long We Keep Information

We generally discard information about you when it's no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we're not legally required to keep it. We retain web server logs that record information about a visitor for a period of time in order to, among other things, analyze traffic to Dröm's websites and investigate issues if something goes wrong on one of our Services.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
• Close your account: While we'd be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the "GDPR"), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act ("CCPA") requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. The CCPA also requires us to provide a list of the "categories" of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Characteristics protected by law (for example, you provide your gender);
• Internet or other electronic network activity information (such as your usage of our Services);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile video, if you uploaded one);
• Professional or employment-related information (for example, information you provide in a job application); and
• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the "Information We Collect section" section above. We collect personal information for the business and commercial purposes described in the "How and Why We Use Information section" section above. And we share this information with the categories of third parties described in the "Sharing Information section" section above. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

• Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
• Request deletion of personal information we collect or maintain;
• Opt out of any sale of personal information; and
• Not receive discriminatory treatment for exercising your rights under the CCPA.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren't able to or you'd like to contact us about one of the other rights, contact us. When you contact us about one of your rights under this section, we'll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Controllers and Responsible Companies

Dröm's Services are worldwide. Drom Match Inc is the controller for all of the processing activities across all of our Services worldwide:

Drom Match Inc
258 Devoe St, Apt 3
Brooklyn, NY 11211

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned, please contact us.

Other Things You Should Know

Transferring Information

Because Dröm's Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the "How and Why We Use Information section" section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

• In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
• In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Privacy Policy Changes

Dröm may change its Privacy Policy from time to time. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (like adding a statement to our website or sending you a notification through email). Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

Thank you

Thank you to the folks at Automattic for their Creative Commons Sharealike documents that this is based on.