Privacy Policy
Last updated August 01, 2022
- Visit our website at www.drum-risk-advisory.com, or any website of ours that links to this privacy notice
- Engage with us in other related ways, including any sales, marketing or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any concerns, please contact us at info@drumrisk.com or info@drum-advisory.com.
1. What personal information do we collect?
1.1. Personal information you disclose to us
In short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services, when you participate in activities on the services, and otherwise when you contact us.
Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the services, the choices you make, and the products and features you use. The personal information we collect may include the following
- names
- e-mail addresses
- mailing addresses
- job titles
- phone numbers
Sensitive information: When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
- Information revealing race or ethnic origin
All personal information that you provide to us must be true, complete, and accurate. You must notify us of any changes to such personal information.
1.2. Information automatically collected
In short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when you visit our services.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and usage data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as system activity, error reports, and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the service used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
In short: We process your information to provide, improve, and administer our services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our services, including:
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our teams and policies, and other similar information.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
In short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal basis we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
- Performance of a contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your conssent, including, for example:
- If collection is clearly in the interest of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased people
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specific to the regulations
In short: We may share information in specific situations described in this section and/or with the following third parties.
Vendors, Consultants, and other third-party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third-parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows: Hubspot, partner companies, service providers, containers and agents.
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API).
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
In short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access and store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
In short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than six years.
When we have no ongoing legitimate business need to process your personal information, we will either delete ar anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
In short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK and Canada), you have certain rights under applicable data protection laws. These may include the right (I) to request access and obtain a copy of your personal information, (II) to request certification or erasure, (III) to restrict the processing of your personal information, and (IV) if applicable, to data portability in certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us via info@drumrisk.com and/or info@drum-advisory.com.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/newsroom/article29/items/612080
If you are located in Switzerland, the contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can make such a request by contacting us via info@drumrisk.com and/or info@drum-advisory.com.
Note: This will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the e-mails we send, or by contacting us using the following details: info@drumrisk.com and/or info@drum-advisory.com.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may e-mail us at info@drumrisk.com and/or info@drum-advisory.com.
In short: We do not respond to DNT browser signals at the moment since there are no universal standards.
Most web browsers and some mobile applications include a DNT feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California civil Code section 1798.83 permits users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addressed of all third parties with which we shared personal information in the preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the e-mail address associated with your account and a statement that you reside in California. We will make sure that the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a ‘resident’ as:
(I) every individual who is in the State of California for other than a temporary or transitory purpose and
(II) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as ‘non-residents’.
What categories of personal information do we collect?
- Identifiers: contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name, gender.
- Personal information categories listed in the California Customer Record Statute: Name, contact information, education, employment, employment history, and financial information.
- Professional or employment-related information: business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us.
We may also collect other personal information outside of these categories or instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels
- Participation in customer surveys or contests
- Facilitation in the delivery of our Services and to respond to your inquiries
How do we use and share your personal information?
DRUM Risk Limited and DRUM advisory Limited collect and share your personal information through:
- Targeting cookies/marketing cookies
- Social media cookies
- Marketing and sales plugin: Hubspot
- Social media plugins: LinkedIn, website. We use social media features, such as a ‘like’ button, and widgets, such as a ‘Share’ or ‘Download’ button, in Our Services or under Case Studies. Such features may process your Internet Protocool (IP) address and track which page you are visiting on our website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform you interact with a widget or button belonging to that social media platform. This information may be recorded to your profile of such social media platform. Social media features and widgets may be hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy notices of the companies that provide them. By clicking on one of these buttons, you agree the use of this plugin and consequently the transfer of personal information to the corresponding social media service. We have no control over the essence and extent of these transmitted data or their additional processing.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for profit entity that processes information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be ‘selling’ of your personal information.
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under ‘When and with whom do we share your personal information?’
Your rights with respect to your personal data
- Right to request deletion of data – request to delete
- Right to be informed – request to know
- Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
To exercise these rights you may contact us by e-mail at info@drumrisk.com and/or info@drum-advisory.com.
In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may e-mail us at info@drumrisk.com and/or info@drum-advisory.com. Alternatively you can contact us via post to:
DRUM Risk Limited / DRUM Advisory Limited
39 Eastcheap
London EC3M 1DT
United Kingdom
Based on the application laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.
This privacy policy was created using Termly’s Privacy Policy Generator.