EU User Privacy Policy

Special Note for Users who are not in the EU or EEA: If you are in the US, or any country outside the European Union (EU) and European Economic Area (EEA), this EU User Privacy Policy does not apply to you. Instead, please review our General Privacy Policy.

When we use the term “EU data”, “EU user”, “EU data subject”, we refer to data, users, and data subjects from both EU and EEA.

Your information privacy is extremely important to us. We have prepared this EU User Privacy Policy to explain how we collect, use, protect, and disclose your information and data if you are in the EU or EEA (an “EU data subject”), including when EU users use the www.draup.com websites (the “Sites”) and any mobile application, application programming interfaces, and other services offered by Draup, Inc. (collectively the “Services”). This EU User Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Data (defined below). This Privacy Policy applies to all EU users of the S
ites and Services. The Sites and Services are provided by Draup, Inc. dba Draup ( “Draup” “we” “our” or “us”).

1. Information We Collect and Draup’s Role under General Data Protection Regulation (“GDPR”)

   1. Draup as Data Controller

      Draup may collect Personal Data about you as explained in this section. Personal Data is information relating to you as an identified or identifiable person. For this section, under the GDPR framework, Draup is the data controller as to the Personal Data we collect about you.

      Personal Information Collected through Our Sites or Services

      We may collect Personal Data when you use our Sites or Services. In order to register your Draup account and use the Services, you provide information that personally identifies you, such as your name, address, phone number, mobile phone number, email, transient payment information, company name, and other personally identifiable information that you choose to provide us with or that you choose to include in your account. You may be asked to provide us with Personal Data when you register with the Sites or use any of our Services, when you communicate with us, and at other times.

      Our People Insights Service

      The People Insights is a people searching and engaging service that we offer to users through the Draup Site (the name “People Insights” is subject to change from time to time at our discretion). Our People Insights allows our users to search for and find people who are the right fit for their business (recruiting/sales) needs. It also helps individuals who are listed in our People Insights to find new opportunities. Our People Insights collect user information through deep search technology continuously collects information from public websites to integrate into our system. Draup also collects information from third parties who legally sell or provide data they collected and are authorized to share. Through these sources we collect Personal Data, including names, email addresses, phone numbers, city or region, educational background, career background, social profile picture, social profile links, and job skills.

      In the event that we cannot disclose to our users certain personal information we obtained based on a legitimate interests basis, which will be discussed below, we may process and index this data in pseudonymized professional profiles so that the information can be searched by our users for business engagement purposes without directly identifying the individuals of the professional profiles. By pseudonymized, we mean that if we collect Personal Data about you, the professional profile we create is not directly linked to your name, contact information or other information that could directly identify you, although we have the ability to make that link. Furthermore, we will seek your consent before we disclose your identifying information to anyone by sending an email to you on behalf of our registered users who want to contact you regarding opportunities that may be good fit to you. If you provide your consent, we will link your identifying information to your pseudonymized profile and share your identifying information with the user. If you do not consent, we will delete your information, including your pseudonymized profile.

      In addition, we recognize that you may not wish to have your data appear in our People Insights (even in a pseudonymized form), and we will honor your request to opt out. To opt out, please provide your name and email address via this link and we will remove your information from our system, or follow up with you if we need further information in order to honor your request.

      Please note, we may need to retain certain data about you in order to ensure that we can continue to honor your request to opt out. We will maintain the minimum amount of information necessary for this purpose, and will not share this information with any business users of our services.

      Usage Data and Site Activity

      We automatically collect the following information about your device and your use of our Sites or Services through cookies, web beacons, and other technologies: the functions you use and searches you perform using the Services, browser agent name and version, web pages you view, links you click, your IP address, the length of time you visit our Sites and or use our Services, and the referring URL, or the webpage that led you to our Sites ( “Usage Data”). We use this information to monitor and improve the Sites and Services, enhance your online experience and to enable us to provide you with an easier and more personalized experience and level of service. We may combine Usage Data with Personal Data that you have provided to us.

      Cookies and Anonymous Identifiers

      We use cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other anonymous identifiers for authentication purposes (to keep track of the fact that you have logged in) and to analyze the use of and improve the Sites and Services. Please see our Cookie Settings for further information about the cookies we use.

   2. Draup as Data Processor

      Information You Input or Upload while Utilizing Our Services

      As a part of utilizing our Services you may input or upload information about potential job candidates or prospective buyer to help you find desired person using Draup’s technology. You may also provide us with your credentials to third-party sites or services in order to synchronize certain emails or other information with our Services. All of this information is collectively “Customer Data.” Draup is a data processor as to Customer Data. Draup will only process Customer Data according to your instructions and to deliver the Services to you. We treat Customer Data as confidential and will not share it other Draup users. Draup will not integrate such data into Draup’s People Insights.

2. Our Purposes and Legal Basis for Processing

   1. As explained in more detail below, we may process your Personal Data:
   2. (i) under GDPR Article 6(1)(b), where such processing is necessary to deliver the Services you have requested;
   3. (ii) under GDPR Article 6(1)(a), where we seek your consent for the processing; and
   4. (iii) under GDPR Article 6(1)(f), where it is necessary for our legitimate interests, or the legitimate interests of a third party, and those legitimate interests are not overridden by your rights and freedoms.

   We process the Personal Data you provide to us if such processing is necessary to deliver the Services you have requested. Thus, we process your Personal Data to establish and maintain your account, to provide you notices and other communications relating to the Services, to provide you customer support, and to otherwise provide the Services to you.

   1. Our legitimate interests, and the legitimate interests of others, include:
   2. (i) the interests of sales executives and recruiters to be able to reach out to individuals who are interested in the relevant opportunities;
   3. (ii) the interests of individuals in learning about offerings that are the best fit for their needs and interests; and
   4. (iii) our interests helping make great matches for potential recruiters and sales executives. These legitimate interests provided are our basis for searching for and collecting public information and creating pseudonymized professional profiles based on that information. As explained above, by pseudonymized, we mean that the profiles we create are not directly linked to any individual’s name, contact information or other information that could directly identify an individual, although we have the ability to make that link, and individuals may opt out at any time.

   In a rare situation where we believe we cannot rely on legitimate interests or your prior consent to disclose your data we collected from public websites, we may pseudonymize your profile and seek your consent before we link your identifying information to your pseudonymized profile, or disclose your identifying information to anyone else. We will send an email to you on behalf of our registered users who want to contact you regarding opportunities that may be a good fit for your interests and background, and only after you consent, will we link you to your identifying information to your profile and share your identifying information. If you do not consent, we will ultimately delete your information.

   We may also process your Personal Data based on our legitimate interests, or the legitimate interests of others in the following circumstances:

   1. (i) To seek your consent for sharing your personally identifiable information with others;
   2. (ii) To comply with laws and regulations that apply to Draup;
   3. (iii) In the case of information you provide as a user of our Services:
      1. (a) to administer our business and improve the service quality;
      2. (b) to improve user experience and our customer relationships;
      3. (c) to communicate with you about the Services or other services we offer that might be of interest to you;
      4. (d) to protect our Service and users from threats such as fraud or security threats; and
   4. (iv) To facilitate necessary business transactions such as mergers or acquisitions.

3. When We May Share and Disclose Information

   We allow our registered users to search and view people profile information relying on our legitimate interests and consent obtained as mentioned above. In addition, if your profile is pseudonymized, once you have consented to share your data, we will link your identifying information to your pseudonymous profile information and permit our registered users to view your identifying information.

   From time to time, we may utilize other businesses whom we believe are trustworthy and who have confirmed that their privacy practices are consistent with ours ( “Service Providers”). We may contract with other Service Providers to provide certain services, such as hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Data from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Data for any use other than as specified by us.

   Draup uses Amazon Web Services (AWS) as a Service Provider to host the Sites and Services and store Personal Data and Customer Data. Your information is not disclosed to AWS, but is transferred through, and resides on, computers owned by AWS. AWS is ISO/IEC 27018 certified and has a system of controls in place that specifically address the privacy protection of Draup’s content.

   We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose personal data and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our organization or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.

   We may share Personal Data and Usage Data with businesses controlling, controlled by, or under common control with our Company. If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Data and Usage Data in connection with such transaction. You will have the opportunity to opt out of any such transfer if it will result in the handling of your Personal Data in a way that differs materially from this Privacy Policy.

   We will not disclose Personal Data to third parties for direct marketing purposes, without your consent. We may disclose to third parties certain Usage Data regarding the Sites and Services. However, in such cases, your Usage Data is aggregated with the Usage Data of others and does not identify you individually.

4. Cross-border Transfers and Safeguards

   We host and operate the websites and platforms in the United States and, depending on your country of residence, the submission of personal information to our website may involve the transfer of personal information to the United States. In addition, we may transfer personal information to our subsidiaries or affiliated companies and service providers and/or third-party agents in various other countries for certain processing operations. You should be aware that privacy laws in these countries may not adequately provide protections equivalent to those in your country of residence.

5. How Long We Process and Store Information

   If you use our Services, we will store your information until you choose to close and delete your account. If you do not use our Services, we will store your information for as long as we have a legal basis on which to do so, or until you instruct us to delete your information. At any time, you can also opt out from our People Insights.

6. Managing Your Personal Account Data

   You can review, correct, update, delete, or change most of your Personal Information used to establish your account by using your account settings. You can also opt out of receiving marketing emails and other communications from us by contacting privacy@draup.com. However, you cannot opt out of receiving all emails from us, such as messages about the status of your account with us. If you have questions or concerns regarding this Privacy Policy, please email us at privacy@draup.com.

7. Your Right to Opt Out of Our People Insights

   As explained above, our goal is to help make great matches, and our service could help you find exciting opportunities. However, if you do not wish to have your data appear in our People Insights (even in a pseudonymized form), we will honor your request to opt out. To opt out, please provide your name and email address via this link and we will remove your information from our system, or follow up with you if we need further information in order to honor your request. We may need to retain certain data about you to ensure that we can continue to honor your request to opt out. We will maintain the minimum amount of information necessary for this purpose, and will not share this information with other users of our services.

8. Your Rights Regarding Your Personal Data under the GDPR

   You have the following rights with respect to your Personal Data. When exercising any of the rights listed below, in order to process your request, we may need to verify your identity for your security. In such cases we will need you to respond with proof of your identity before you can exercise these rights.

   1. The right to access information we hold on you:

      At any point you can contact us to request access to and be provided with information on the processing of your personal information. Once we have received your request, we will respond within one month. There are no fees or charges for the first request, but additional requests for the same data may be subject to an administrative fee.

   2. The right to correct and update the information we hold on you:

      If the data we hold on you is out of date, incomplete or incorrect, you can inform us and your data will be updated.

   3. The right to have your information erased:

      If you would not like us to use your data, you can request that we erase your data. In particular, you have the right to opt out of our People Insights Service as explained above in Section 7.

   4. The right to object to processing of your data:

      You have the right to request that we stop processing your data for direct marketing or for processing based on our legitimate interests. Furthermore, you have the right to opt out of our People Index and Search Service as explained above in Section 7.

   5. The right to data portability:

      1. You have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format, or to have us transfer your data to another controller if the legal basis for our processing of your personal data is:
      2. (i) consent; or
      3. (ii) that the processing is necessary for the provision of services to you or to take steps at your request to provide you services, and such processing is carried out by automated means.

   6. The right to withdraw your consent to the processing at any time where the legal basis for our processing is your consent:

      In particular, even if you have consented to have your identity disclosed or your data included in our People Insights, you have the right to withdraw your consent at any time. Please see Section 7.

   7. The right to restrict processing of your data:

      1. You have the right to restrict the processing of your data in certain circumstances including:
      2. (i) if you contest its accuracy;
      3. (ii) if the processing is unlawful and you oppose the erasure; or
      4. (iii) if it is no longer needed for the purposes for which it was collected, but you require it for the defense of a legal claim.

   8. The right to lodge a complaint:

      Have the right to lodge a complaint with the supervisory authority in the Member State where you have your habitual residence, place of work, or where an alleged infringement of the GDPR has taken place.

9. Be Careful When You Share Information with Others

   Please be aware that whenever you share information on any public area of the Sites or Services, that information may be accessed by other users in your organization. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

10. Security

    We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Sites or Services, we cannot and do not guarantee the security of any information you transmit on or through the Sites or Services, and you do so at your own risk.

11. Links

    Our Sites and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.

12. Children’s Privacy

    The Sites and Services are intended for EU users who are 18 years old or older. We do not knowingly collect Personal Data from children under the age of 18. If we become aware that we have inadvertently received Personal Data from a child under the age of 18, we will delete such information from our records.

13. Updates or Changes in Processing

    If we wish to use your Personal Data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Wherever and whenever necessary, we will seek your prior consent to the new processing.

    In other circumstances, if we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Sites. Those changes will go into effect on the “Last Updated” date shown in the revised Privacy Policy. By continuing to use the Sites or Services, you are consenting to the revised Privacy Policy.

14. Contact Information

    If you have any questions or feedback, or want to report a violation regarding the EU User Privacy Policy, you may email us at privacy@draup.com or contact us by mail addressed to:

    Attn: Legal Dept.
    Draup, Inc.
    21 Waterway Ave, Suite 300
    The Woodlands, TX 77380 USA

In order to exercise your right regarding your Personal Data including right to access, correction (rectification), erasure, restriction of processing, objection to processing, and portability, you can contact our Data Protection Officer at privacy@draup.com.

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOUR RECORD.