Privacy Policy

Effective Date: September 10,2021

This Privacy Policy (“Policy”) describes how Drumroll Health Inc. (“Drumroll Health,”we,”“our,” “us”) collects, processes, uses, and discloses certain information obtained through your use of our website(the “Site”), which is available at https://www.drumroll.health/, as well as the features made available to you through the Site, such as our surveys (collectively, the “Services”).

Information WeCollect and Maintain About You. We collect information from you directly when you provide it to us through the Services. We further automatically collect certain information about you and your smartphone or other device when you use, access, or interact with our Services.

Personal information provided by Suite Members. If you create an account through the Drumroll Health Suite (and are a “Suite Member”), we will collect personal information related to creating your account and offering you our Services. The categories of information we may collect from you include:
- Full name
- Email address
- Password (that you create)
- Information about your company, such as company name, and your title within the company
- Information about your potential survey participants, such as their email address
- Information about any surveys you create (including the survey questions, the response rate, and metadata related to the survey responses)

Other personal information collected through the Site. You may navigate the Site without submitting any personal information. However,if you use certain features on the Site, such as the “Contact Us” feature, we will collect any personal information associated with your inquiry, such as your name, company name, email address, phone number, and any other information that you choose to share with us.

Server logs. Server logs automatically record information and details about your online interactions with us. For example, server logs may record information about your visit to our Site on a particular time and day and collect information such as your device ID or IP address. Cookies.We also use cookies on the Site. Cookies are small files that are stored on your mobile device through the Site. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your device’s operating system, your device ID, IP address, and your general geographic location.

Pixel tags. A pixel tag (also known as a web beacon, clear GIF, pixel, or tag) is an image or a small string of code that may be placed in an advertisement or email. It allows companies to set or read cookies or transfer information to their servers when you load a webpage or interact with online content. For example, we or our service providers may use pixel tags to determine whether you have interacted with a specific part of our Services, viewed a particular advertisement, or opened a specific email.

Third-party plugins. Our Site may include plugins from other companies, including social media companies (e.g., the Facebook “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.

Third-party online tracking. We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set pixels through the Site. This information may be used for a variety of purposes, including analytics, as discussed below (see the section entitled “With Whom and Why We Share YourInformation”).

Aggregated or deidentified information.  We may also share aggregated or deidentified information about users of the Services, such as by publishing a report ontrends in the usage of the Services. Such aggregated or deidentified information will not identify you personally.

How We Use andProcess Your InformationWe use the information that we collect for a variety of purposes. Our legal bases for processing your personal information are: 1) our legitimate interest in running and maintaining our business; 2) performance and fulfillment of our contracts; 3) your consent; and 4) compliance with our legal obligations. In many instances, more than one of these legal bases apply to the processing of your personal information.The purposes for which we use your information include to:  
●      Provide you with our Services;
●      Respond to your questions or requests concerning the Services;
●      Fulfill the terms of any agreement you have with us;
●      Fulfill your requests for our Services or otherwise complete a transaction that you initiate;
●      Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails;
●      Improve our artificial intelligence and machine learning;
●      Deliver confirmations, account information, notifications, and similar operational communications;
●      Improve your user experience and the quality of our products and Services;
●      Comply with legal and/or regulatory requirements;
●      Aggregate and deidentify information;
●      Benchmark results for our customers;
●      Serve advertisements;
●      Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services;
●      Create new products and Services; and
●      Manage our business.

With Whom and Why We Share Your Information
We share your information with third parties for a variety of purposes, as described below.

Third-party service providers. Drumroll Health uses third-party service providers that perform Services on our behalf, including web-hosting companies, and mailing vendors. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.We may also share your information with third parties when necessary to fulfill your requests for Services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or ourpartners; or to manage our business.

Analytics.  We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting.These third parties may use pixels or server logs, and they may set and access deviceIDs and IP addresses from your device.

Legal purposes.  We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
●      To comply with applicable law or a court order, subpoena, or other legal process;
●      To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
●      To establish, protect, or exercise our legal rights or defend against legal claims; or  
●      To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.  

Your Choices
If you wish to access, correct, or delete the personal information we have on file, you may contact us at hello@drumroll.health.  If you wish to opt-out of marketing emails you receive from us, you may do so by following the instructions in those emails or by contacting us at hello@drumroll.health.  

California ResidentsIf you are a resident of the state of California, please review our California Privacy Notice for additional protections that may apply to you.

International Users If you are a resident of the EU, UK, or another jurisdiction with an applicable privacy law, you may have certain rights available to you.These rights may include:
·     The right to be informed about our data collection practices;
·     The right to access and rectify your data;
·     The right to erase or delete your data;
·     The right to data portability;
·     The right to restrict and object to the processing of your data (including for direct marketing purposes);
·     The right to opt out of the sale of your information;
·     The right to opt-out of marketing emails and text messages;
·     The right to limit our use of any automated decision-making processes;
·     The right to lodge a complaint to your local data protection authority; and
·     The right to withdraw consent (to the extent applicable). To exercise any of the rights listed above, please contact us via email at hello@drumroll.health.  We will respond to your request as soon as reasonably possible but in no longer than 30 days.

External Links The Site may contain links to third-party websites. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them.If you decide to access any of the third-party sites listed on our website, you do so at your own risk.

Data Security We employ physical, technical, and administrative procedures to safeguard the personal information we collect both online and offline.However, no website or platform is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.

Data RetentionWe retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it.  When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.

International UsersThe information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. We may also subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. However, we comply with all applicable laws regarding international data transfers.By using the Services or by providing any information to us, you expressly consent to such transfer and processing.

Children Content on the Services is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.

Changes to thisPolicy We may make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Services, so you should review this page periodically.

How to Contact Us Should you have any questions or concerns about this Policy, you can contact us at by email at hello@drumroll.health.