Last Updated: June 29, 2021

Drum, Inc. (“Drum,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. Through our mobile applications (the “Apps”), we provide a marketplace where businesses that are seeking an independent sales and/or work force and new sales and/or engagement channels (each a “Business”) can leverage the services of individual professionals (“Referrer(s)”) who can help sell, promote, and market various products and services offered by the Businesses (“Offers”) to third-party customers / potential partners (“Buyer”) (such services, including https://drum.io (the “Site”) and the Apps, are referred to collectively in this Privacy Policy as the “Drum Platform”). Drum utilizes Hyperwallet payment services to deliver payments to you. Such payment services are subject to the Hyperwallet Terms of Service and the Hyperwallet Privacy Policy.

This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.

Before using the Drum Platform or submitting any Personal Data to Drum, please review this Privacy Policy carefully and contact us if you have any questions. By using the Drum Platform, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site, download the Apps, or otherwise use the Drum Platform.

1. PERSONAL DATA WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

Personal Data You Provide: We collect Personal Data when you sign up for the Drum Platform or contact us. The Personal Data collected during these interactions may vary based on what you choose to share with us. If you create an account on behalf of a Business, you will need to provide the Business’ address, a point of contact, email address, password, and Employer Identification Number. You may also provide photographs of the Business. If you use the Drum Platform on behalf of your employer, we collect and process your information as described in the “Personal Data Processed on Behalf of Businesses” section.

If you are a Referrer or Buyer, we will collect your name, email address, username, password, and your contacts (where you consent to us doing so). You can also upload photos that may contain Personal Data through the Drum Platform.

If you are a Referrer, in addition to the information described in the preceding paragraph we will also collect the last four digits of your social security number to allow you to receive payments.

Geolocation Information: Our Apps collect location information using your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g. latitude/longitude) of your mobile device. If you have given our Apps permission to access your location, we may collect your device’s location even if you are not using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the App’s access to your location data.

Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Facebook, Instagram, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Personal Data We Collect From Other Sources: You may use your Facebook or Google credentials to access the Drum Platform. If you do, we will collect the information you make available to us through your Facebook or Google settings such as your name, profile photo, and friend list. If you are a Referrer, we may also receive information from other sources, such as identity verification providers, that we use to supplement and confirm the information we have collected from you directly.

Personal Data Processed on Behalf of Businesses: If you are an employee of a Business, we may receive Personal Data about your use of the Drum Platform on behalf of a Business, such as information related to the Offers you worked on. We process that information pursuant to our Terms of Service and other agreements with Businesses. We have no direct relationship with employees of Businesses. If you are such an employee and would no longer like your data to be used by one of the Businesses that use the Drum Platform or you would like to access, correct or request deletion of your data, please contact the Business that you interact with directly.

Personal Data We Receive Automatically From Your Use of the Drum Platform: When you visit, use and interact with the Drum Platform, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Site or download the Apps, peak hours of visits, which page(s) of the Site or sections of the Apps are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.) when visiting the Site, which browsers people use to access the Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern through the Apps. In particular, the following information is created and automatically logged in our systems:

• Log data: Information that your browser automatically sends whenever you visit the Site (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
• Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
• Device information: Includes name of the device, operating system, and browser you are using when you visit the Site or use one of the Apps. Information collected may depend on the type of device you use and its settings.
• Usage Information: We collect information about how you use our Apps, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

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Cookies: We use cookies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

Email Pixels: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. Click here for more information on how Google uses this data.

Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

2. HOW WE USE PERSONAL DATA

We may use Personal Data for the following purposes:

• To provide the Drum Platform;
• To verify the identities of Referrers;
• To allow you to invite your contacts to the Drum Platform;
• To monitor the effectiveness of our email campaigns;
• To respond to your inquiries, comments, feedback or questions;
• To send administrative information to you, for example, information regarding the Drum Platform, and changes to our terms, conditions, and policies;
• To analyze how you interact with our Drum Platform;
• To maintain and improve the content and functionality of the Drum Platform;
• To develop new products and services;
• To prevent fraud, criminal activity, or misuses of the Drum Platform, and to ensure the security of our IT systems, architecture and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
  

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of the Drum Platform, to improve and add features to the Drum Platform, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of the Drum Platform and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Drum Platform, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Data to contact you to tell you about Offers, products, services, or events we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

3. SHARING AND DISCLOSURE OF PERSONAL DATA

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, email communication software and email newsletter services, advertising and marketing services, payment processors, identity verification services, customer relationship management and customer support services, and web analytics services]. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Drum Platform, or the public, or (v) protect against legal liability.
• Other Users: certain actions you take on the Drum Platform may be visible to other users. For example, if you are a Referrer the Offers you promote will be visible to the Buyers in your network.
  

4. DATA RETENTION

We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

5. UPDATE YOUR INFORMATION

Please log in to your account or contact us if you need to change or correct your Personal Data.

6. CHILDREN

The Drum Platform is not directed to children who are under the age of 13. Drum does not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Drum through the Drum Platform please contact us and we will endeavor to delete that information from our databases.

7. LINKS TO OTHER WEBSITES

The Drum Platform may contain links to other websites not operated or controlled by Drum, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

8. SECURITY

You use the Drum Platform at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Drum Platform or e-mail. Please keep this in mind when disclosing any Personal Data to Drum via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Drum Platform, or third party websites.

9. INTERNATIONAL USERS

By using the Drum Platform, you understand and acknowledge that your Personal Data will be transferred from your location to the facilities and servers of Drum in the United States.

10. YOUR CHOICES

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of the Drum Platform, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.

11. CHANGES TO THE PRIVACY POLICY

The Drum Platform, and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use the Drum Platform or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

12. CONTACT US

If you have any questions about our Privacy Policy or information practices, please visit our Help Center or contact us at privacy@drum.io.

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