Drumsandkeys, INC

​Last updated: February 2022

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

We reserve the right, at our sole discretion, to change, modify, add, or remove portions of these General Terms of Use at any time.

Types of Data Collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; Cookies; email address; first name; last name; country; password; profile picture. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and Place of Processing the Data

Methods of processing: The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.​

Legal basis of processing: The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to U.S data protection law;

  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

  • processing is necessary for compliance with a legal obligation to which the Owner is subject;

  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place: The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the United States or to any international organization governed by public international law or set up by two or more countries, such as the U.S , and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time: Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The Purposes of Processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Tag Management, Analytics, Managing contacts and sending messages, Contacting the User, Remarketing and behavioral targeting, Handling payments, Traffic optimization and distribution, SPAM protection, Displaying content from external platforms, Hosting and backend infrastructure, Infrastructure monitoring, Registration and authentication and Access to third-party accounts. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook Permissions Asked by This Application

This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc. For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy. The permissions asked are the following:

Basic information: By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Email: Provides access to the User's primary email address.

Detailed Information on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts: This type of service allows this Application to access Data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by the User.​​

Facebook account access (Facebook, Inc.): This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc. Permissions asked: Email. Place of processing: United States – Privacy Policy.

Analytics: The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Ireland Limited): Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data processed: Cookies; Usage Data. Place of processing: Ireland – Privacy PolicyOpt Out.

Google Ads conversion tracking (Google Ireland Limited): Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Application.

Personal Data processed: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.): Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy.

Contacting the User. Mailing list or newsletter (this Application): By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase. Personal Data processed: country; email address; first name; last name.

Displaying content from external platforms: This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Wistia widget (Wistia, Inc.): Wistia is a video content visualization service provided by Wistia, Inc. that allows this Application to incorporate content of this kind on its pages. Personal Data processed: Cookies; Usage Data. Place of processing: United States –Privacy Policy.

Handling payments: Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Inc): Stripe is a payment service provided by Stripe Inc. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

PayPal (PayPal Inc): PayPal is a payment service provided by PayPal Inc. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Hosting and backend infrastructure: This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Heroku (Salesforce.com, inc.): Heroku is a hosting service provided by Salesforce.com, inc. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: European Union – Privacy Policy.

Amazon Web Services (AWS) (Amazon Web Services, Inc.): Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc. Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Filestack (Filestack): Filestack is a hosting service provided by Filestack. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

GitHub Pages (GitHub Inc.): GitHub Pages is a hosting service provided by GitHub, Inc. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Infrastructure monitoring: This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

New Relic (New Relic): New Relic is a monitoring service provided by New Relic Inc. The way New Relic is integrated means that it filters all traffic of this Application, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on this Application to be collected. Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Logentries (RevelOps, Inc.): Logentries is a monitoring service provided by RevelOps, Inc. Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Managing contacts and sending messages: This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailchimp (The Rocket Science Group INC): Mailchimp is an email address management and message sending service provided by The Rocket Science Group INC. Personal Data processed: country; email address; first name; last name; Usage Data. Place of processing: United States – Privacy Policy.

Mandrill (The Rocket Science Group INC): Mandrill is an email address management and message sending service provided by The Rocket Science Group, INC. Personal Data processed: email address. Place of processing: United States – Privacy Policy.

Registration and authentication: By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Facebook Authentication (Facebook, Inc.): Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Direct registration (this Application): The User registers by filling out the registration form and providing the Personal Data directly to this Application. Personal Data processed: country; email address; first name; last name; password; profile picture.

Remarketing and behavioral targeting: This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User. This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page. Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Google Ads Remarketing (Google Ireland Limited): Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings. Personal Data processed: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy – Opt Out.

Facebook Remarketing (Facebook, Inc.): Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network. Personal Data processed: Cookies; Usage Data. Place of processing: United States – Privacy Policy – Opt Out.

SPAM protection: This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA (Google Ireland Limited): Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited. The use of reCAPTCHA is subject to the Google privacy policy and terms of use. Personal Data processed: Cookies; Usage Data. Place of processing: Ireland – Privacy Policy.

Tag Management: This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google Ireland Limited): Google Tag Manager is a tag management service provided by Google Ireland Limited. Personal Data processed: Usage Data. Place of processing: Ireland – Privacy Policy.

Traffic optimization and distribution: This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.): Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected. Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service. Place of processing: United States – Privacy Policy.

Further Information About Personal Data

The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.

Selling goods and services online: The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery. The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

The Rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.

  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.

  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.

  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing: Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights: Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Application uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional Information About Data Collection and Processing

Legal action: The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data: In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance: For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy: More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled: This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy: The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references. Personal Data (or Data): Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data: Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User: The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject: The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor): The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner): The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application: The means by which the Personal Data of the User is collected and processed.

Service: The service provided by this Application as described in the relative terms (if available) and on this site/application.

Cookie: Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker: Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information: This privacy statement has been prepared based on provisions of multiple legislations, including Personally Identifiable Information (US privacy law and information security) and (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.

Contact Us: Apologies for the length of this document. If you have any questions or concerns about our “Privacy Policy/Terms and Conditions”, you may contact us at: Online@drumsandkeys.com