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Privacy Policy of the Dromni Platform

Home  /  Privacy Policy of the Dromni Platform

This Privacy Policy is incorporated into the Dromni Terms of Use and Conditions (available at www.dromni.eu/legal) (“TOUC”).  This also includes the Privacy Policy of the website (available at www.dromni.eu/privacy-policy) .Any terms used, but not defined, in this Privacy Policy have the meanings set forth in the TOUC.

1. General

This Policy describes how we process your personal data at Dromni.

It applies to your use of:

  • all Dromni services as a user (e. g. Dromniverse). This includes use of these services under our free or paid options (each a “Service Option”); and
  • all Dromni services as a creator (e. g. DromniScan App).
  • all Dromni services which include a link to this Privacy Policy.

From now on, we’ll collectively call these the “Dromni Platform”.

From time to time, we may develop new or offer additional services. They’ll also be subject to this Policy, unless stated otherwise when we introduce them.

2. Your personal data rights and controls

Privacy laws, including the General Data Protection Regulation (“GDPR”), give rights to individuals over their personal data.

Your rights are:

  • Access. Be informed of the personal data we process about you and to request access to it.
  • Rectification. Request that we amend or update your personal data where it’s inaccurate or incomplete
  • Erasure. Request that we delete certain of your personal data
  • Restriction. Request that we temporarily or permanently stop processing all or some of your personal data
  • Object. Object to us processing your personal data at any time, on grounds relating to your particular situation Object to your personal data being processed for direct marketing purposes
  • Data portability. Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service
  • Not be subject to automated decision-making. Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect

You can contact Dromni directly to exercise your rights at any time (see Section 11 ‘How to contact us’). You also have the right to contact the local data protection authority about any questions or concerns.

3. Personal data we collect about you

Collected data when you sign up for the Dromni Platform or when you update your account:

CategoryDescription
User DataPersonal data that we need to create your Dromni account and enables you to use the Dromni Platform. The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third party services to sign in. This may include your: We receive some of this data from you e.g. from the sign up form or account page. We also collect some of this data from your device e.g. country
Street Address DataWe may ask for your street address for tax administration reasons.

Collected data when you use the Dromni Platform:

CategoryDescription
Usage Data  Personal data collected about you when you’re accessing and/or using the Platform. There are a few types of information this includes, detailed in the following sections.

Information about how you use Dromni Services, as example:
– Your actions with the Dromni Platform (including date and time), such as:
search queriescontent streaming history, browsing history, account settings, interactions with other Dromni users, your use of third party devices and applications in connection with the Dromni Platform.

– Inferences (i.e., our understanding) of your interests and preferences based on your usage of the Dromni Platform.

– Content you post to any part of the Dromni Platform, such as volumetric content, text, titles, communications, and other types of content.  

Your technical data, as example:
– Online identifiers such as IP addressesInformation about the devices you use such as:
device IDs, network connection type (e.g. wifi, 4G, LTE, Bluetooth), provider, network and device performance, language, information enabling digital rights management, operating system, Dromniverse application version

– Information (such as the device name, device identifiers, brand and version) which enables us to improve the quality of recordings  

Your device sensor data, as example:
– Camera properties and configurations
– Volumetric content data which implies
– Device orientation, position and location
– Camera sensor data
– Recorded audio  

Your general (non-precise) location:
– This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency). We need this to meet geographic requirements in our agreements with the owners of content on the Dromni Platform, and to deliver content and advertising that’s relevant to you.

Additional data you may choose to give us

CategoryDescription
Payment and Purchase DataIf you make any purchases from Dromni, we will need to process your payment data. The exact personal data collected will vary depending on the payment method, but will include information such as:
Contests, Surveys, and Sweepstakes DataWhen you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstake, we collect the personal data you provide.

Collected from other (‘third party’) sources

Third PartiesDescription
Third party applications, services and devicesIf you connect your Dromni account to a third party application, service and/or devices, we may collect certain information from them to make the integration possible. These third party apps, services or devices may include: social mediadevices including:
– mobile phones and tablets
– games consolesVR headsets
– computers
– services or platforms  
We’ll ask your permission before we collect your information from certain third parties.
Payment partnersIf you choose to pay Dromni by invoice, we may get data from our payment partners. This allows us to:
– send you invoices
– process your payment
– give you what you’ve purchased
Advertising and marketing partnersWe may get data about you from certain advertising or marketing partners. This may include:
– cookie id
– mobile device id
– email address
– inferences (i.e., our understanding) of your interests and preferences

This allows us to deliver more relevant ads and marketing.

4. Our purpose for using your personal data

The table below sets out:

  • our purpose for processing your personal data
  • our legal justifications (each called a “legal basis”) under data protection law, for each purpose
  • categories of personal data which we use for each purpose (see more about these categories in Section 3 ‘Personal data we collect about you’)

Here is a general explanation of each “legal basis” to help you understand the table:

  • Performance of a Contract: When it’s necessary for Dromni (or a third party) to process your personal data to:
    • comply with obligations under a contract with you, e.g. Dromni’s obligations under the Terms of Use to provide the Dromni Platform to you
    • or verify information before a new contract with you begins.
  • Legitimate interest: When Dromni (or a third party) has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other Dromni users. For example, using your Usage Data to improve the Dromni Platform for all users. Contact us if you want to understand a specific justification.
  • Consent: When Dromni asks you to actively indicate your agreement to Dromni’s use of your personal data for a certain purpose(s).
  • Compliance with Legal Obligations: When Dromni must process your personal data to comply with a law.
Purpose for processing your dataLegal basis that permits the purposeCategories of personal data used for the purpose
To provide the personalized Dromni Platform.Performance of a Contract
Legitimate Interest
Consent
User Data
Usage Data
Payment and Purchase Data
Street Address Data
To understand, diagnose, troubleshoot, and fix issues with the Dromni Platform.Performance of a Contract
Legitimate Interest
User Data
Usage Data
To evaluate and develop new features, technologies, and improvements to the Dromni Platform.Legitimate Interest
Consent
User Data
Usage Data
To process the data to improve the visualization and shared experiencesPerformance of a Contract
Legitimate Interest
Consent
User Data
Usage Data
For marketing, promotion, and advertising purposes.Legitimate Interest
Consent  
User Data
Usage Data
Contests, Surveys and Sweepstakes Data
To comply with legal obligations and law enforcement requests.Compliance with legal obligations
Legitimate interest
User Data
Usage Data
Payment and Purchase Data
Street Address Data
Contests, Surveys and Sweepstakes Data
To: fulfill contractual obligations with third parties, for example our agreements with owners of content on the Dromni Platform, andtake appropriate action with reports of intellectual property infringement and inappropriate content.  Legitimate interestUser Data
Usage Data
Payment and Purchase Data
To establish, exercise, or defend legal claims.Legitimate interestUser Data
Usage Data
Payment and Purchase Data
Street Address Data
Contests, Surveys and Sweepstakes Data
To conduct business planning, reporting, and forecasting.      Legitimate InterestUser Data
Usage Data
Payment and Purchase Data
To process your payment.Performance of a Contract
Compliance with legal obligations
User Data
Payment and Purchase Data
To detect and prevent fraud, including fraudulent payments and fraudulent use of the Dromni Platform.Performance of a Contract
Compliance with legal obligations
Legitimate Interest
User Data
Usage Data
Payment and Purchase Data
Street Address Data
To conduct research, contests, surveys, and sweepstakes.Performance of a Contract
Legitimate Interest
Consent  
User Data
Usage Data
Contests, Surveys and Sweepstakes Data

5. Sharing your personal data

This section sets out the categories of recipients of the personal data collected or generated through your use of the Dromni Platform.

The following personal data will always be publicly available on the Dromni Platform:

  • Your profile name
  • Your profile photo
  • Who you follow on the Dromni Platform
  • Who follows you on the Dromni Platform (you can remove followers)

We will only share the following personal data with those outlined in the table below:

  • where sharing of particular personal data is needed for the use of a Dromni Platform feature, or a third party application, service or device, which you have chosen to use; or
  • if you otherwise grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Dromni Platform or by giving your consent
Categories of recipientsReason for sharing
Third party applications, services and devices you connect to your Dromni AccountTo connect your Dromni account, and/or allow you to use the Dromni Platform in connection with third party applications, services or devices. Examples of such third party applications, services and devices include: social media, mobile devices, desktop applications and devices, VR headsets and game consoles.
Dromni Discord CommunityTo enable you to use the Dromni Discord Community service. When you register for an account on the Dromni Discord Community, we’ll ask you to create a specific profile name. This will be publicly displayed to anyone who uses the Dromni Discord Community. We’ll also display any questions or comments you post.
Other Dromni usersTo share content and information about your use of the Dromni Platform with other Dromni users, including your ‘Followers’.  

Information we may share

Categories of recipientsReason for sharing
Service providersSo they can provide their services to Dromni. These service providers may include those we hire to:
– give customer support
– operate the technical infrastructure we need to provide the Dromni Platform
– assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA)
– help market Dromni’s (and our partners’) products, services, events and promotions
Payment processorsSo they can process your payments, and for anti-fraud purposes.  
Advertising partnersSo our ad partners can help us deliver more relevant advertising to you on the Dromni Platform. For example, our ad partners help us facilitate tailored advertising: This is when we use third party information to tailor ads to be more relevant to you (also known as interest based advertising).
An example of a tailored ad is when an ad partner has information suggesting you like cars, which could enable us to show you ads about cars.
You can control tailored advertising in your account privacy settings under “Tailored Ads”.
If you are “opted out” of Tailored Ads, you may still get advertising on ad-supported services (such as podcasts or the Free Service Option) based on your registration information and ads based on the content you are streaming on our Services. For example, if you are streaming a cooking podcast, you may hear an ad for a food processor or if you are streaming a workout playlist, you may hear an ad for sports clothing.  
Marketing PartnersTo promote Dromni with our partners. We share some personal data with these partners where necessary to: enable you to participate in Dromni promotions, including trials or other bundled offersto promote Dromni in media and advertising published on other online serviceshelp us and our partners to measure the effectiveness of Dromni promotions   Examples of partners include:
– marketing or sponsorship partners
– websites and mobile apps who sell us advertising space on their services
– device, app and mobile partners who also offer Dromni promotions  

Our partners may also combine the personal data we share with them with other data they collect about you (e.g. your use of their services). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you.  
Other partner sharingWe may share personal data with partners to help us understand and improve the performance of our products and partnerships.
Academic researchers    For activities such as statistical analysis and academic study, but only in a pseudonymised format. Pseudonymised data is where your data is identified by a code rather than your name or other information that directly identifies you.
Law enforcement and other authoritiesWhen we believe in good faith it’s necessary for us to do so, for example: to comply with a legal obligationto respond to a valid legal process (such as a search warrant, court order, or subpoena)for our own or a third party’s justifiable interest, relating to:
– national security
– law enforcement
– litigation (a court case)
– criminal investigation
– protecting someone’s safety
– preventing death or imminent bodily harm.  
Purchasers of our businessWhere we sell or negotiate to sell our business to a buyer or possible buyer. In this situation, Dromni will continue to ensure your personal data is kept confidential. We’ll give you notice before your personal data is transferred to the buyer or a different privacy policy starts to apply.

6. Data retention and deletion

Retention

We keep your personal data only as long as necessary to provide you with the Dromni Platform and for Dromni’s legitimate and essential business purposes, such as:

  • maintaining the performance of the Dromni Platform
  • making data-driven business decisions about new features and offerings
  • complying with our legal obligations
  • resolving disputes

Deletion

If you close or request that we close your account, we’ll delete or anonymise your personal data so it no longer identifies you, unless we’re required to keep something or we still need to use it for a legally justifiable reason.

Here are some examples of situations where we’re legally allowed or required to keep some of your personal data:

  • if there’s an unresolved issue relating to your account, such as an outstanding credit or unresolved claim or dispute
  • for our legal, tax, audit and accounting obligations
  • for our legitimate business interests such as fraud prevention or to maintain security.

7. Transfer to other countries

When carrying out the activities described in this Policy, Dromni shares your personal data internationally with subcontractors and partners. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.

Whenever we transfer personal data internationally, we use tools to:

  • make sure the data transfer complies with applicable law
  • help to give your data the same level of protection as it has in the EU

We do this using a variety of protections, as appropriate for each data transfer. For example, we use:

  • Standard Contractual Clauses (or an alternative legal tool) to require the third party to protect your data and to provide you with EU-level rights and protections
  • technical protections, such as encryption and pseudonymisation
  • policies and processes to challenge disproportionate or unlawful government authority requests

You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.

8. Keeping your personal data safe

We’re committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.

We have implemented various safeguards including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.

To protect your user account, we encourage you to:

  • use a strong password that is unique to your Dromni account
  • never share your password with anyone
  • limit access to your computer, smartphone and other devices using the Dromni Platform
  • log out once you have finished using the Dromni Platform on a shared device

You can log out of Dromni using the “Sign out” function on your account page.

If other individuals have access to your Dromni account (for example if you’ve given them permission to use your account on a shared device), then they can access personal data, controls and the Dromni Platform available in your account.

It’s your responsibility to only provide individuals with permission to use your account where you’re comfortable sharing this personal data with them. Anyone else’s use of your Dromni account may impact your personalised recommendations and be included in your data download.

9. Children

The Dromni Platform has a minimum “Age Limit” in each country. The Dromni Platform is not directed to children whose age:

  • is under the age of 13 years
  • or, makes it illegal to process their personal data
  • or, requires parental consent to process their personal data

We do not knowingly collect personal data from children under the applicable Age Limit. If you’re under the Age Limit, please do not use the Dromni Platform, and do not provide any personal data to us.

If you’re a parent of a child under the Age Limit and become aware that your child has provided personal data to Dromni, please contact us.

If we learn that we’ve collected the personal data of a child under the applicable Age Limit, we’ll take reasonable steps to delete the personal data. This may require us to delete the Dromni account for that child.

When using a shared device on the main Dromni Platform, you should be cautious about playing or recommending any content to individuals under 18 years old which could be inappropriate for them.

10. Changes to this policy

We may occasionally make changes to this Policy.

When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Dromni Platform or send you an email or device notification.

11. How to contact us

For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:

    Email contact@dromni.eu

    Write to us at:

Dromni GmbH,
Am Blütenring 48,
80939 München,
Germany