1.1 The use Drawy makes of the information collected through the Services varies depending on whether you are:
1.1.1 a Drawy customer (“Customer”),i.e. any person having directly concluded an agreement with Drawy for the provisions of the Services, and this for the benefit of the Customer and its Users;
1.1.2 a Drawy user (“User”), meaning an end-user of the Services under the subscription by the Customer; or
1.1.3 a mere visitor of our Website, without registering our subscribing to the Services (“Visitor”),which may include Customers as well as prospective customers.
PART A – CUSTOMERS
2. INFORMATION WE COLLECT FROM CUSTOMERS
2.1 We collect Customer Information directly from our Customers (e.g. through their use of the Customer Portal, as defined in the Drawy Terms and Conditions),. We will collect:
When a Customer sends us an email asking a question, or signs up to our email newsletters, we will collect the Information that the Customer submits to us. We will also collect other Information that Customers choose to provide to us.
3. HOW WE USE CUSTOMER INFORMATION
3.1 We use Customer Information for the following purposes:
3.1.1 Providing our Service: We will use your personal data as this is necessary for the conclusion of our contract and/or for the performance of our contractual obligations.
3.1.2 Communicating with you or others: We will use your personal data as this is necessary for the conclusion of our contract and/or for the performance of our contractual obligations
3.1.3 Marketing and advertising: We may send you marketing and advertising-materials, based on the legitimate interest we have in promoting and improving our services and managing our customer relations. If you would wish to stop receiving such communications and unsubscribe, please let us know via firstname.lastname@example.org.
4. HOW WE DISCLOSE CUSTOMER INFORMATION
4.1 We may disclose Customer Information as follows:
4.1.1 Drawy affiliates. We may disclose Customer Information to any future affiliates, parent companies, or subsidiaries to support our legitimate interests in our corporate, financial and HR-management, while ensuring that the processing of your personal data is proportionate and that it respects your privacy rights.
4.1.2 Our service providers. We may disclose Customer Information to online payment provider Stripe only for payments. This disclosure is necessary for the provision of our services and for the performance of our contract with Stripe.
4.1.3 Customers. We may disclose Customer Information to other Customers (for instance: when buying a design in the marketplace.) to support our legitimate interests that we have as a business in providing products and services to other Customers, while ensuring that the processing of your personal data is proportionate and that it respects your privacy rights.
5. YOUR RIGHTS IN RELATION TO THE INFORMATION YOU PROVIDE US WITH
5.1 Customers may verify, correct, or update the Information they have provided us with by updating the Information in their account, or by emailing us at email@example.com. Customers may also request the deactivation of their account by emailing us at firstname.lastname@example.org.
5.2 We may send periodic promotional or informational emails to Customers who have opted in to receive these. Customers may at any moment opt out of such communications by following the optout instructions contained in the email. Please note that it may take up to 3 business days for us to process opt-out requests. If Customers opt out of receiving emails about recommendations or other information we think may interest them, we may still send them emails about their account or any Services they have requested or received from us.
PART B – USERS
6. INFORMATION WE COLLECT FROM USERS
6.1 We collect User the following Information directly from Users:
6.2 We also collect User Information automatically through a User’s use of or interaction with our Services and this by means of tracking technologies which allow to individualize a User. This Information may include, without limitation, information about a User’s operating system, the webpages or our Website accessed by Users, the link that led a User to a Customers’ website, the dates and times a User accesses webpages and content of the Website, event information (e.g., system crashes),and general location information (e.g., city and state). We also collect User IP addresses.
7. HOW WE USE USER INFORMATION
7.1 We use User Information for the following purposes:
7.1.1 Providing our Services. To provide our Services to Users and our Customers, including but not limited to our Service consisting of proving date and time of access to Website content by Users. The use of your personal data is therefore necessary for the conclusion of our contract and/or for the performance of our contractual obligations.
8. HOW WE DISCLOSE USER INFORMATION
8.1 We may disclose User Information as follows:
8.1.1 Drawy affiliates. We may disclose User Information to any future affiliates, parent companies, or subsidiaries to support our legitimate interests in our corporate, financial and HR-management, while ensuring that the processing of your personal data is proportionate and that it respects your privacy rights.
8.1.2 To our service providers. We may disclose User Information to vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, customer relationship management, email marketing, surveys, credit card processing, data hosting, or fraud detection) on our behalf. Such disclosure will only take place insofar it is required for the provision of the Service and will be based on the necessity for the performance of our contractual obligations.
8.1.3 Customers. We may disclose User Information to Customers to comply with our contractual obligations of Service delivery as described in our agreement.
PART C – VISITORS
9. INFORMATION WE COLLECT FROM VISITORS
9.1 We collect Visitor Information directly from you or from third parties who collect Visitor Information. We may combine all of the Information we collect from various sources.
9.2 Information we collect directly from you. We may collect Visitor Information directly from you. For example, when you send us an email asking a question, or submit a form on our Website to receive marketing materials or email newsletters, we will collect the Information that you submit to us.
9.3 Information we collect from third parties. We may collect Visitor Information about you from third parties that collect information automatically through your use of the Site, such as web analytics companies. Such information may include, without limitation, information about your operating system, settings and system configurations, device model, device ID and other unique device identifiers, mobile related information, the webpages you access within our Website, the website that led you to our Website, the website to which you go after leaving our Website, the dates and times you access our Website, event information (e.g., system crashes) and web log data. These third parties may also collect your IP address however we do not collect these IP addresses.
10. HOW WE USE VISITOR INFORMATION
10.1 We use your Visitor Information for the following purposes:
10.1.1 Providing our Service. To provide and manage our Website and Services. We will use your personal data as this is necessary for the conclusion of our contract and/or for the performance of our contractual obligations.
10.1.2 Communicating with you or others. We will use your personal data to communicate with you, including via email, about our Services and to respond to your inquiries or complaints. This processing is based on the legitimate interest we have in in promoting and improving our services and managing our (prospective) customer relations
10.1.3 Marketing and advertising. We may send you marketing and advertising-materials, based on your consent. This consent stems from the fact that you have entered your email in the subscribe-box at the bottom of our Website. If you would wish to stop receiving such communications and unsubscribe, please let us know via email@example.com.
11. HOW WE DISCLOSE VISITOR INFORMATION
11.1 We may disclose Visitor Information as follows:
11.1.1 Drawy affiliates. We may disclose Visitor Information to any future affiliates, parent companies, or subsidiaries to support our legitimate interests in our corporate, financial and HR-management, while ensuring that the processing of your personal data is proportionate and that it respects your privacy rights;
PART D – GENERAL PROVISIONS APPLICABLE TO CUSTOMERS, USERS AND VISITORS
12. HOW WE USE YOUR INFORMATION
12.1 The Information we collect from Customers, Users and Visitors are used for the purposes as respectively set forth in the sections above, as well as for the following purposes:
12.1.1 Analyzing use of our Services. To better understand how Customers, Users, Visitors access and use our Website and Services, both on an aggregated and individualized basis, to respond to Customers’, Users’, and Visitors’ desires and preferences, and for other research, analytical, and statistical purposes. The processing of your personal data for this purpose is based on the legitimate interest we have in acquiring business intelligence in order to improve our services
12.1.2 Legal compliance. We may also process and/or disclose Information in order to comply with a legal obligation, regulations, a judicial proceeding, subpoena, court order, or other legal process (e.g. requests from law enforcement or other governmental entities)
12.1.4 Business transfers. We reserve the right to disclose and/or transfer Information to another entity if we are acquired by or merged with another company, if we sell or transfer a business unit or assets to another company, as part of a bankruptcy proceeding, or as part of any other similar business transfer.
13. DISCLOSING YOUR INFORMATION
13.2 Aggregate and de-identified Information. We may disclose aggregate or de-identified information about users for marketing, advertising, research, or other purposes.
14. KEEPING YOUR INFORMATION
14.1 In principle, we store your data as long as it is required to deliver our Services and as long as we have a legitimate interest in retaining it for an extended period of time (for instance, after fully executing a contract, we may still have a legitimate interest towards the use of your data for marketing purposes). We shall not delete personal data (i) which we need for the execution of pending commitments: or (ii) which we need to enforce our own rights and claims, as well as (iii) personal data included in documents that we must store for a legally mandatory longer period of time (e.g. during prescription periods). During such mandatory preservation term, the processing of such data will be restricted, even without your request.
15. YOUR RIGHTS IN RELATION TO THE INFORMATION YOU PROVIDE US WITH
15.1 Subject to applicable law, you may have some or all of the following rights in respect of your personal data. You can exercise these rights by submitting your request to firstname.lastname@example.org. You will need to include your personal details as well as some means of verifying your identity (e.g. copy of identity card or driving licence). Please note that we may reject requests that are excessive or a misuse of the relevant right.
15.1.1. Access right & data portability. You may have the right to obtain confirmation of whether Drawy processes personal data in relation to you and, if so, gain access to a copy thereof. For certain kinds of data, you may also have a right to data portability.
15.1.2. Data accuracy: right of rectification and right to erasure. You may have the possibility to rectify or obtain the erasure of your personal data, provided that the applicable legal requirements are met. The right to erasure is subject to various exceptions, notably as regards personal data whose processing is necessary to support litigation or for compliance with statutory retention requirements. Customers may verify, correct, or update the Information they have provided us with by updating the Information in their account
15.1.3. Limits to processing: right to restriction, right to object & consent withdrawal. In addition, you may have the right to object to the processing of personal data based on Drawy’s legitimate interests (see above) and to otherwise obtain the restriction of certain forms of processing in specific circumstances. In particular, in relation to the processing of personal data for direct marketing purposes, you may have the right to object at any time thereto (see below). Where any processing is based on consent (including transfers of personal data outside of the European Economic Area), you may have the right to withdraw such consent at any time (without this affecting the processing prior to the consent withdrawal).
15.1.4. Right to lodge a complaintwith the supervisory authorities. You may have the right to lodge a complaint with the supervisory authority, in particular the data protection authority that is competent for your place of residence or the lead supervisory authority for Drawy, namely the Belgian Data Protection Authority: www.dataprotectionauthority.be.
15.2 We may send periodic promotional or informational emails to Customers or Visitors who have opted in to receive these. They may at any moment opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 3 business days for us to process opt-out requests. If Customers opt out of receiving emails about recommendations or other information we think may interest them, we may still send them emails about their account or any Services they have requested or received from us.
15.3 Furthermore, if we invoke a legitimate interest for any of the abovementioned processing activities, this processing is based on a balancing test between your and our interests. For more information, see below for our contact details
15.4 Customers may request the deactivation of their account by emailing us at email@example.com.
16.1 We value the security of your Information, including but not limited to the Personal data collected via the Website or Services. We have taken steps to help protect the Information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, destruction and any other form of unauthorized processing. Please be aware, however, that no data security measures can guarantee 100% security. We also refer to our security provisions as set out in the Terms and Conditions.
17. IMPORTANT NOTICE IN RELATION TO TRANSFERRING DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
17.1 We may transfer your Information outside the country in which it is collected, including to a country that may not offer the same level of protection for Personal data as the country in which you reside.
17.2 In the event of transfer of personal data to a country outside of the European Economic Area, we systematically ensure the application of an adequate level of protection of such personal data by approved means (e.g. selecting “Privacy Shield”-certified processors or putting in place standard contractual clauses on the processing of personal data, in accordance with the EU Commission model clauses). You can request more information about such measures (including copies where relevant) by getting in touch with us through the contact details below.
18. COOKIES AND OTHER TRACKING MECHANISMS
19. THIRD-PARTY LINKS
20. CONTACT US
20.1 If you have questions about the privacy aspects of our Website or Services, please contact us at: firstname.lastname@example.org
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