Our Privacy Policy

1. Introduction

1.1 Important information and who we are

Welcome to Drovi Limited's Privacy and Data Protection Policy (“Privacy Policy”).

At Drovi Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• And any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

Drovi Limited is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to contact@drovi.app or by post to 71-75 Shelton Street, Manchester, WC2H 9JQ, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors' responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR;
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperat e, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. Legal Basis for Data Collection

2.1 Types of data / Privacy policy scope

“Personal Data” 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 below:

• **Profile/Identity Data:** This is data relating to your first name, last name, gender, date of birth.
• **Contact Data:** This is data relating to your phone number, addresses, email addresses, phone numbers.
• **Marketing and Communications Data:** This is your preferences in receiving marketing information and other information from us.
• **Billing Data:** This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
• **Financial Data:** These are your banking details e.g. your account number and sort code.
• **Technical Data:** This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• **Customer Support Data:** This includes feedback and survey responses.
• **Usage Data:** information about how you use our website, products and services.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• **Consent:** Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or 'opt in' to a service.
• **Contractual Obligations:** We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• **Legal Compliance:** We're required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• **Legitimate Interest:** We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

3. How We Use Your Personal Data

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

3.2 Marketing and content updates

You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 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.

4. Your Rights and How You Are Protected By Us

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

• **Right to be informed**
• **Right of access**
• **Right to rectification**
• **Right to erasure**
• **Right to object**
• **Right to restrict processing**
• **Right to data portability**

If you wish to make a request under any of these rights, please contact us atcontact@drovi.app.

4.2 Your control over Drovi Limited's use of your Personal Data

You may delete your account at any time – this will remove your account page from our systems and our related software. We guarantee this will delete all stored data.

4.3 How Drovi Limited protects customers' Personal Data

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including All user data is stored encrypted in the database.

5. Your Data and Third Parties

We may share Personal Data with interested parties in the event that Drovi Limited anticipates a change in control or the acquisition of all or part of our business or assets.

6. How Long We Retain Your Data

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for.

7. Age Limit for Our Users

You must not use Drovi Limited unless you are aged 18 or older. This website is not intended for children and we do not knowingly collect data relating to children.

8. International Transfer of Data

Your information may be stored and processed in the US or other countries or jurisdictions outside the US where Drovi Limited has facilities.

9. Notification of Changes and Acceptance of Policy

We keep our Privacy Policy under review and will place any updates here. This version is dated 8 March 2024.

10. Interpretation

All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate.