Privacy Policy

FEBRUARY 2023

The website and mobile app operated under the brand name – “DRIP” is owned and operated by DRIP OTC UAB (“us”, “we” or “Company”) a corporation organized and existing under the laws of Lithuania, with its head office located at Vilnius, Lvivo g. srt 105A, Vilnius, Lithuania.

We respect the privacy of our users (“each”, “you”, or “User”) who access, download, install or register to our mobile application (the “Application”), our website https://drip.org/ and software applications (either existing or available in the future) and our digital decentralized blockchain bank or any other online services we provide (collectively: the “Platform”) whether as a guest or a registered user. We are committed to protecting the privacy of our Users.

The Company has prepared this Privacy Policy to outline our practices with respect to collecting, using and disclosing your information when you use the Platform. We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using the Platform, you agree to the terms of this Privacy Policy and your continued use of the Platform constitutes your ongoing agreement to the Privacy Policy.

This Policy constitutes a legal agreement between you, as the User of the Platform, and us, as the owner of the Platform. By voluntarily providing us or allowing us to access the personal information, you are consenting to our use of it in accordance with this Policy. By merely visiting/accessing the Platform, you expressly consent to the Company’s use and disclosure of your personal information in accordance with this Privacy Policy. This Policy does not apply to Third-Party platforms that are connected via links to the platform. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, PLEASE DO NOT PROCEED FURTHER TO USE/ ACCESS THIS PLATFORM. Also, in the absence of your acceptance of the Policy by you, we will not be able to provide the services to you.

The Privacy Policy is a part of the Terms of Service and is incorporated herein by reference. This Policy shall operate in accordance with Lithuania's Personal Data Protection Law and the EU General Data Protection Regulation.

In this Privacy Policy you will read about, among other things:

  • INFORMATION WE COLLECT

  • COOKIES AND ANALYTICS

  • HOW WE USE THE INFORMATION

  • WITH WHOM WE SHARE THE INFORMATION AND FOR WHAT PURPOSE

  • THIRD-PARTY COLLECTION OF INFORMATION

  • FOR HOW LONG DO WE RETAIN THE INFORMATION

  • HOW WE PROTECT YOUR INFORMATION

  • ADVERTISEMENTS

  • CORPORATE TRANSACTION

  • MINORS

  • ADVERTISING ID AND ADVERTISING IDENTIFIER

  • SEVERABILITY AND EXCLUSION

  • UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

  • PDPL AND GDPR COMPLIANCE

  • HOW TO CONTACT US

INFORMATION WE COLLECT

We may collect two types of data and information from our Users.

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Platform (“Non-personal Information”). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information that is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website’s domain name from which you linked to the Platform, etc.), in order to enhance the functionality of the Platform. We may also collect information about your activity on the Platform (e.g., pages viewed, online browsing, clicks, actions, timestamps, etc.).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify the company/institution and its members (“Personal Information”). Such information may include:

  • Account Information: When you sign-up and register to the Platform, you will be asked to provide us with certain details about the company/institution and its members. You may register to the Platform directly through the Application or our website (if applicable).

  • Registering through the Application or our website (if applicable): When you register to the Platform through the Application or our website, we may collect from you the information required for our compliance with regulatory Know Your Customer (“KYC”)/Know Your Business (“KYB”) requirements and any other information you agreed to share with us.

  • Voluntarily Information: We may collect information that you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email, or share additional information about yourself through your use of the Platform. We may also collect the feedback, suggestions, complaints and reports that you send to us. Please note that we may also collect complaints about you from other Users, which may include your Personal Information.

  • Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) as well as other information which relates to your activity through the Platform.

For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

COOKIES AND GOOGLE ANALYTICS

We may use cookies and other technologies or methods of web and mobile analysis (e.g., pixels, Mixpanel, Google Analytics, etc.) to gather, store, and track certain information related to your access to and activity through the Platform, including when you visit our website. A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Platform quicker, easier and smoother. Our website may use the following types of cookies:

  • Session Cookies which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.

  • Persistent Cookies which are saved on your device for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to identify who you are for repeated visits (for instance, to allow us to store your preferences for the next sign-in).

  • Third-Party Cookies which are set by other online services that run content on the page you view on your browser (for example, by third-party advertising companies who monitor and analyze our website access).

You may remove the cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Platform may not operate properly and your online experience may be limited. We also use a tool called Google Analytics to collect information about your use of the Platform. Google Analytics collects information such as how often users access the Platform, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Platform. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.

HOW WE USE THE INFORMATION

We use and share Personal Information in the manners described in this Privacy Policy. In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:

  • To set up your account and to provide the Platform.

  • To identify and authenticate your access to the Platform.

  • To authenticate your identity for the purpose of compliance with regulatory Know Your Customer requirements.

  • To send you relevant push notifications, which are based on different activities offered by the Platform.

  • To communicate with you and to keep you informed of our latest updates and newsletters.

  • To market our website, products, and the Platform.

  • To serve you personalized advertisements when you use the Platform.

  • To perform research or to conduct analytics in order to improve and customize the Platform to your needs and interests.

  • To support and troubleshoot the Platform and to respond to your queries.

  • To investigate and resolve disputes in connection with your use of the Platform.

  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Platform; and

  • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

WITH WHOM WE SHARE THE INFORMATION AND FOR WHAT PURPOSE

We do not rent, sell, or share your Personal Information with third parties except as described in this Privacy Policy. We may share Personal Information with the following recipients:

  • our subsidiaries;

  • affiliated companies;

  • subcontractors and other third-party service providers;

  • auditors or advisers of our business processes; and

  • any potential purchasers or investors in the company.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our recipients for any of the following purposes:

  • storing or processing Personal Information on our behalf (e.g., cloud computing service providers);

  • processing such information to assist us with our business operations;

  • performing research, technical diagnostics, personalization and analytics.

We may also disclose Personal Information or any information you submitted via the Platform if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to:

  • comply with any applicable law, regulation, legal process or governmental request;

  • enforce our policies, including investigations of potential violations thereof;

  • investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;

  • to establish or exercise our rights to defend against legal claims;

  • prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party;

  • for the purpose of collaborating with law enforcement agencies; and

  • in case we find it necessary in order to enforce intellectual property or other legal rights.

THIRD-PARTY COLLECTION OF INFORMATION

Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Platform (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or for the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

FOR HOW LONG WE RETAIN THE INFORMATION

We respect your privacy rights and therefore you may contact us at any time and request:

  • to access, close, change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); or

  • that we will cease any further use of your Personal Information (for example, you may ask that we will stop using or sharing your Personal Information with third-parties) or that we shall remove your Personal Information (subject to any other legal obligation that may require us to keep the information).

Please note that unless you instruct us otherwise, we retain the information we collect for as long as needed to provide the Platform and to comply with our legal obligations, resolve disputes and enforce our agreements. We may rectify, replenish, or remove incomplete or inaccurate information, at any time and at our own discretion. If you wish to raise a complaint about how we have handled your Personal Information, please contact us directly at hello@drip.org.

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.

HOW WE PROTECT YOUR INFORMATION

We take great care in implementing and maintaining the security of the Platform and your information. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Platform, and we make no warranty, express, implied or otherwise, that we will prevent such access. If you feel that your privacy was not treated in accordance with our policy, or if any person attempted to abuse the Platform or acted in an inappropriate manner, please contact us directly at hello@drip.org.

ADVERTISEMENTS

We may use third-party advertising technology to serve advertisements when you use the Platform. This technology uses your information with regard to your use of the Platform to serve advertisements to you (e.g., by placing third-party cookies on your web browser). We may also use our third parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retarget our Users. You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

CORPORATE TRANSACTION

We may share information, including Personal Information, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

ADVERTISING ID AND ADVERTISING IDENTIFIER

The Google Advertising ID is an anonymous identifier, provided by the Google Play Platform. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. We may also use Apple’s Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for the purpose of advertising. By downloading the Application or using the Platform you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have an Advertising ID or Advertising Identifier respectively, we will use other identifiers.

SEVERABILITY AND EXCLUSION

We have taken every effort to ensure that this Policy adheres with the applicable laws. The invalidity or unenforceability of any part of this Policy shall not prejudice or affect the validity or enforceability of the remainder of this Policy. This Policy does not apply to any information other than the information collected by the Company through the Platform. This Policy shall be inapplicable to any unsolicited information You provide Us through this Platform or through any other means or through public channels. This includes, but is not limited to, information posted in any public areas of the Platform. All unsolicited information shall be deemed to be non-confidential and the Company shall be free to use and/ or disclose such unsolicited information without any limitations.

UPDATES OR AMENDMENTS TO THE PRIVACY POLICY

We may revise this Privacy Policy from time to time, at our sole discretion, and the most current version will always be posted on our website or Application (as reflected in the “Last Revised” heading). In the event of a material change to the Privacy Policy, we will notify you through the Platform or via email, or you may be notified within the Application. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Platform, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

PDPL AND GDPR COMPLIANCE

The Company is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the PDPL and the GDPR.

We are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for PDPL and GDPR compliance have been summarized and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and on-going compliance. Please refer to our “PDPL AND GDPR COMPLIANCE STATEMENT” for the same.

HOW TO CONTACT US

If you have any general questions regarding the Platform or the information that we collect about you and how we use it, please contact us at hello@drip.org.