Welcome to the Dropit for America Inc, Dropit Shopping Limited’s and DBAG Shopping Limited’s (known individually or collectively as “Dropit”) privacy notice.
Dropit respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or otherwise provide data to us offline in the course of our dealings with you and tell you about your privacy rights and how the law protects you.
Important information and who we are:
Purpose of this privacy notice
The Dropit Service, App, POS device and website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Dropit Shopping Limited and DBAG Shopping Limited is the controller and responsible for your personal data (collectively referred to as “Dropit”, "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Dropit Shopping Limited and DBAG Shopping Limited
Email address: firstname.lastname@example.org
Postal address: 5th floor, 205 Regent Street, W1B 4HB, London, United Kingdom
Telephone number: +44 20 3105 1677
Dropit for America Inc Email address: email@example.com
Postal address: 400 S. 4th Street, Suite 500, Las Vegas, Nevada 89101 USA
Telephone number: +1-855-372-7700
Depending on your jurisdiction and where you use the Dropit Services, you have the right to make a complaint at any time to make a complaint to any relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before this so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in December 2020 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
1. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details. This type of personal data is currently collected and stored by a third party.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences, your Contact Data as relevant to provide you with marketing information in accordance with any preferences or as provided in accordance with the law.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Dropit services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
2. How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Marketing Data and Financial Data by filling in forms or by corresponding with us by post, phone, email, via the App or otherwise. This includes personal data you provide when you:
▪ apply for our or services;
▪ create an account on our App, POS device, website or with us directly;
▪ subscribe to our service or publications;
▪ request marketing to be sent to you;
▪ enter a competition, promotion or survey; or
▪ give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
▪ Technical Data from the parties such analytics providers Google, based outside the EU;
▪ Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.
3. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Where you have consented to our use of your personal data for specific purposes;
Consent means you have expressly given us consent to process your personal data for specific purposes such as to process your data for marketing purposes or supply you with third party direct marketing communications to you via email or text message. You have the right to withdraw consent you have given at any time, however, where you do this in respect of processing information to provide our services to you we will no longer be able to fulfil this.
We strive to provide you with choices regarding certain personal data uses, particularly relating to marketing and advertising. We do not sell your personal data.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Dropit group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by sending us a message via in-app live chat, calling us by phone or sending us an email or by clicking ‘Unsubscribe’ in our emails.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes outlined in paragraph 3 above.
Internal Third Parties as set out in the Schedule.
External Third Parties as set out in the Schedule.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
We share your personal data within the Dropit group of companies. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries. If there is no adequacy decision in place from theEuropean Commission with a third country then we will take all steps to ensure that such a transfer of your personal data is done with appropriate protection in place, using the Standard Contractual Clauses where necessary. Please be advised that if you are an EU citizen using our services post 31.12.2020 your data will be transferred to the UK and such transfers are subject to the Data Protection Act 2018, which ratified GDPR in the UK and also to the SCCs as set out in the Guest Terms and Conditions.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them provided we have put in place adequate measures to provide your Personal Data with the same level of protection required by GDPR or the Data Protection Act 2018.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In accordance with certain laws to which the Dropit group of companies is subject, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and audit purposes.
In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Under the California Consumer Privacy Act 2018 (CCPA) we are obliged to declare whether we sell or share your personal data. We do not sell or share your personal data. However you may still specifically opt out of the sale of your personal data by clicking on the attached link: Do not sell my personal data.
You have the right at any time to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Internal Third Parties
Other companies in the Dropit group of companies acting as joint controllers or processors and who are based EEA, USA and Israel and provide IT, Research and Development and system administration services and undertake leadership reporting.
External Third Parties
The parties with whom we may share your data will vary depending (for example courier providers) depending on where you use the Dropit Services, and we will not share your data with any party that does not need to receive it in order to effect delivery of the Services
Service providers acting as processors based in Israel, USA and the EEA who provide IT, system administration and delivery services:
AppsFlyer Ltd. - https://www.appsflyer.com/product/gdpr
Intercom, Inc. and Intercom R&D Unlimited Company - https://www.intercom.com/security
Stripe, Inc. - https://support.stripe.com/questions/stripe-and-european-data-transfers
Google Inc. (Google Cloud and Google Analytics) - https://cloud.google.com/security/gdpr/, https://policies.google.com/privacy?hl=en
Kit Log Limited trading as PaperTrail- https://blog.papertrail.io/questions-about-gdpr/#.WumDztNuZQI
MongoDB, Inc. - https://www.mongodb.com/cloud/compliance/gdpr
OneSignal - https://onesignal.com/blog/product-policy-updates-for-gdpr/
Mailjet SAS – https://www.mailjet.com/security-privacy/
Apple Inc. - https://www.apple.com/legal/privacy/en-ww/governance/
Mixpanel, Inc. - https://help.mixpanel.com/hc/en-us/articles/360000345423-GDPR-Compliance
Microsoft Corporation - https://www.microsoft.com/en-us/TrustCenter/Privacy/gdpr/default.aspx
Facebook, Inc. and Facebook Ireland Ltd. - https://www.facebook.com/business/news/facebooks-commitment-to-data-protection-and-privacy-in-compliance-with-the-gdpr
84codes AB trading as CloudAMQP - https://www.cloudamqp.com/gdpr.html
Royal Mail Group Limited - https://www.parcelforce.com/privacy
Revisecatch trading as eCourier - http://www.ecourier.co.uk/privacy/
Gophr Limited - https://uk.gophr.com/privacy-policy
Dropoff, Inc - https://www.dropoff.com/privacy/
Direct Response Ltd - http://drltd.com/privacy-policy/
Other external third parties:
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based EEA, Israel and USA who provide consultancy, banking, legal, insurance and accounting services.
Relevant national regulators and other authorities acting as processors or joint controllers based in jurisdictions where Dropit operates or has a presence who require reporting of processing activities in certain circumstances