Privacy Policy

This privacy policy was last updated on May 24, 2018.

Introduction

Adaptics Limited (trading as Drop Kitchen) (“Drop”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you use our platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how Drop collects and processes your personal data through your use of our platform (app or visiting our website), including any data you may provide when you register with us, sign up to our newsletter, purchase a product or service or take part in a competition.
It is important that you read this privacy policy together with any other privacy policy 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 policy supplements the other notices and is not intended to override them.

Controller

Drop is the controller and responsible for your personal data (collectively referred to as “Drop”, “we”, “us” or “our” in this privacy policy).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:
Adaptics Limited
Pablo Marti
Email address: privacy@getdrop.com
Postal address: Drop, The Priory, John St West, Dublin 8, Ireland

Changes to the privacy policy and your duty to inform us of changes

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.

Third party links

Our websites 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 policy of every website you visit.

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 follows:

  • Identity Data includes first name, last name, email, bio and profile image.
  • Contact Data includes billing address, delivery address, business contact number and business contact email address.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and 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 platform.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 
  • Usage Data includes information about how you use our platform, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 policy.

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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 and Financial Data by providing us with your business card, by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • create an account on our platform;
  • subscribe to our service or publications;
  • attend a business conference and distribute a business card displaying your company and / or contact details;
  • 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. We may also receive Technical Data about you if you visit other websites employing our cookies – see our cookie policy below for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data
from analytics providers such as Google, Keen, Mixpanel or Branch based outside the EU; crash reporting tools such as Crashlytics based outside the EU

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.

Contact Data from Helpdesk platforms such as Zendesk based outside the EU.

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 there is a lawful basis that we will rely on to process your personal data:

  • 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.

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 or by clicking on the “Hear from us” button in the app.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
Servers for backend & frontend. Image and video storage. Databases.User email, user IP address, user ID, profile image, user name, user biography informationPerformance of a contract
Log proccessing of backend serversUser IDPerformance of a contract
Transactional emailsUser email, user nameLegitimate interest
SearchUser email, user ID, profile image, user name, user biography informationPerformance of a contract
AnalyticsUser email, user IP address, user ID, profile image, user name, user biography informationConsent
Fulfilment of purchase ordersUser name, user email, user addressPerformance of a contract
User and customer surveysUser emailConsent
Email marketing User email, user nameConsent
Net Promoter Score surveysUser email, user nameConsent
Workflow automationUser email, user nameConsent
Help desk & inbox collaborationUser email, user nameLegitimate interest
Knowledge baseUser email, user nameLegitimate interest
Mobile attribution and deep linkingUser id, ip addressLegitimate interest
Marketing automation and analyticsUser id, user email, user name, ip address, profile image url, profile website, profile bioConsent
Web hosting and CMSIP addressPerformance of a contract
E-CommerceUser email, user name, IP addressLegitimate interest
Crash reportingUser id, user IP addressLegitimate interest
Delivering pre-release builds of the mobile appsUser emailPerformance of a contract

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 and your company/business (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 and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Drop group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into our app and checking or unchecking “Hear from us” to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Drop’s cookies policy below.

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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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 policy.

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.

International transfers

Our Internal Third Parties operate in other jurisdictions outside of the European Economic Area (EEA), including but not limited to the United States of America and many of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

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.
  • 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.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill 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 some circumstances you can ask us to delete your data – see “request erasure” below for further information.

In some circumstances, we may anonymize 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data (further details of each of these are provided below).

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to the processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

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.

Glossary — Lawful basis

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.

Third Parties

Internal Third Parties

Other companies in the Drop group acting as joint controllers or processors and who are based in the United States of America and/or Ireland and provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in United States of America and Ireland who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in United States of America and Ireland who provide consultancy, banking, legal, insurance, and accounting services.
  • Taxation/revenue authorities, regulators and other authorities based in United States of America and Ireland who require reporting of processing activities in certain circumstances, from time to time.

Your legal rights

You have the right 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.

You have the right to make a complaint at any time to the Data Protection Commissioner (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

Cookies Policy

When you interact with Drop through our website, we try to make that experience simple and meaningful. When you visit the website, our web server sends a cookie to your computer. Cookies are small pieces of information which are issued to your computer when you visit a website and which store and sometimes track information about your use of the website. For example, cookies are used to personalize web search engines and to store shopping lists of items a user has selected while browsing through a virtual shopping mall. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for longer.

We use cookies to:

  • remember that you have visited us before; this means we can identify the number of unique visitors we receive. This allows us to make sure we have enough capacity for the number of users that we get;
  • customize elements of the promotional layout and/or content of the pages of the website;
  • collect statistical information about how you use the website (including how long you spend on the website) and where you have come to the website from so that we can improve the website and learn which parts of the website are most popular with visitors; and
  • to speed site navigation and recognize your access rights on the website.

Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note, however, that by blocking or deleting cookies used on the website, you may not be able to take full advantage of the website.

Cookies used by Drop can be largely categorized as follows:

Cookie TypeCookie Purpose
NecessaryThese cookies are essential in order to enable you to move around websites and use the websites’ features, such as accessing secure websites or secure areas of websites. Without these cookies, services you have asked for, such as identifying you as being logged in to the website throughout your visit, cannot be provided.
FunctionalityThese cookies allow the website to remember choices you make (such as your preferred language) and provide enhanced, more personal features.  These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. Other examples include cookies that keep track of your progress when filling online application forms.
PerformanceThese cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous.
Targeting CookiesTargeting cookies remember individual websites you have visited and help Drop to present relevant and targeted online advertising to you.  Targeting cookies may be placed on your machine when you visit the website.  When targeting cookies have been placed on your device, they can be recognised by subsequent websites you visit, and this allows those sites to present targeted Drop and third party advertising to you.  While targeting cookies can track your visits around different websites, the information collected is anonymous.

In addition to cookies, tracking GIFS and web beacons may be set by us or third parties in respect of your use of the website. Web beacons support the delivery of cookies and help determine the number of times a page on the website has been viewed. Tracking GIFS are small image files within the content of the website or the body of our reports so we or third parties can understand which parts of the website are visited and whether particular content is of interest.