Privacy Policy

Privacy Statement effective as of June 28, 2022.

Special Note for EU Users: If you are in the European Union (EU) or European Economic Area (EEA), this General Privacy Policy does not apply to you. Instead, you must use the EU User Privacy Policy.

Special Note for California Residents: The Additional Terms for California Residents available here also apply to you.

Please read this privacy statement carefully. By accessing or using the sites, platform, and/or services, you agree to be bound by the terms described herein and all terms incorporated by reference. Please do not use the website and/or platform if you disagree with all terms.

1. Context and Purpose

   1. Draup recognizes the importance of maintaining your privacy. We value your privacy and appreciate your trust in us. In this Privacy Statement, references to “you”, “your” or “user” shall mean the end user accessing the www.draup.com and/or its affiliated websites, (the “Sites”) and/or any mobile application, platform, application programming interfaces, and/or other services offered by Draup, Inc. (collectively the “Services”), and its contents. References to “we”, “us” and “our” shall mean Draup, its franchisor, affiliates, and partners
   2. This statement describes how we collect, use, protect, and disclose information and data that you provide through our Sites and Services. By visiting and/or using our website/platform, you expressly consent to our use and disclosure of your information in accordance with this Privacy Statement. This statement also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information.
   3. This statement applies to all users of the Sites and Services, whether you are a candidate/lead who is listed in our people database (“Candidate”) or an HR manager or sales representative or recruiter looking for prospective hires on behalf of your company (“Business User”)
   4. The Draup Platform is the property of Draup Inc.
   5. By using the platform/services or by otherwise providing us with your information, you will be deemed to have read, understood and agreed to the practices and policies outlined in this privacy statement and agree to be bound by this privacy statement. You hereby consent to our collection, use, sharing and/or disclosure of your information as described in this privacy statement. We reserve the right to change, modify, add or delete portions of the terms of this privacy statement, at our sole discretion, at any time. If you do not agree with this privacy statement at any time, please do not use any of the services/platform or provide us with any of your information. If you use the services/platform on behalf of someone else or an entity, you represent that you are authorized by such individual or entity to (i) accept this privacy statement on such individual’s or entity’s behalf, and (ii) consent on behalf of such individual or entity to our collection, use and disclosure of such individual’s or entity’s information as described in this privacy statement.

2. Personal Information We Collect

   Personal information means and includes all information that can be linked to a specific individual or to identify any individual, such as name, age, address, mailing address, telephone number, email ID, information about your mobile phone and any details that may have been voluntarily provided by the user in connection with availing any of the services on the website and/or mobile application.

   We collect the following categories and types of “Personal Information” concerning Candidates:

   • Contact Information: We may collect your name, email addresses, phone number and/or mobile phone number;
   • Professional or employment-related information: work history, job title, skills, years of experience and education information;
   • Demographic information: billing address, location (street, city, state, pin code, country);
   • Photos: your professional social network picture;

   Additionally, if you visit our Sites or use our Services, including if you are Business User, we collect the following additional categories of Personal Information:

   
   Other Identifiers: We may collect IP address; account name, company name, billing address, and approximate location, etc. about you or any other information provided by you during the use of our website/platform. We may collect such information as a part of a survey as well;

   Internet or other electronic activity: we may collect information about your browsing and click history, including the functions you use and searches you perform using the services; IP address and the browser name with version you are using. We may look at what site you came from, duration of time spent on our sites or services, pages accessed or what website you visit when you leave us. We may also collect information on the type of computer you are using, or the version of the operating system your computer or device is running.

   Information you post: We collect information you post in a public space on the website/platform including your chat history including that created by our chat bot.

   Information from other sources: We also may periodically obtain information about you from other sources. The collection of such information will be in accordance with applicable privacy laws. We may combine this information with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored marketing campaigns to provide products, subscriptions and services that may be of interest to you.

3. We collect information in different ways

   We collect Personal Information from the following sources:

   • For Candidates who appear in our people insights database, we collect information about you from third parties. We collect your Personal Information from your public profiles (such as professional social network sites and social media sites where you have publicly posted information), other public websites and web platforms, from data brokers or other data vendors, and from our business customers.
   • If you are a Business User or a visitor of our Sites, we collect additional information directly from you. We collect contact information, professional and employment information directly from you when we set up your account, or when you fill out a form on our website, such as to sign up for an event or to receive our newsletter or other marketing communications or from authorized personnel in your company when you are registered on our website/platform. We also collect and store the chat history with the chatbots.
   • If you are a Business User or a visitor of our Sites, we also collect information from you passively. We use tracking tools like Google Analytics, Google Webmaster, logfiles, browser cookies and web beacons for collecting information about your usage of our website/platform. Using these tools, we analyze web page flow, measure promotional effectiveness, track your usage on our website/platform and promote trust and safety. Additionally, you may encounter “cookies” or other similar devices on certain pages of the website/platform that are placed by third parties. We do not control the use of cookies by third parties.
   • If you are a Business User or a visitor of our Sites, we also collect information about you from message boards and/or from customer service communication you have with us. If you choose to post messages on our message boards, chat sessions or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
   • If you are a Business User, we also collect information through correspondence. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the website/platform, we may collect such information into a file specific to you.
   • If you are a Business User, we also collect social media and single sign-on information. Our Web sites and platforms may use social media features, such as the Twitter, LinkedIn and Facebook. These features may collect relevant information and may give an option to share comments/activities with your social media network.
     We may combine information collected from our different Sites and Services.

4. Use of your Personal Information

   If you are a Candidate, we use your Personal Information for the following purposes:

   • To Provide People Insights Services: We use Personal Information of Candidates to help make great matches between them and prospective employees/vendors. When our business customers search for people with certain titles and talents, they can contact Candidates who match their searches, so the Candidates may learn more about the new opportunities. Those opportunities may be a better fit for their professional interests or simply more exciting to them.

   If you are a Business User or a visitor to our Sites, we use your Personal Information for the following additional purposes:

   • Transactional Purposes: We use your contact information, other identifiers, and professional and employment information to provide you with the Sites and Services, including to open and maintain a user account for you and provide Services to you, and send you alerts and communicate with you about your registration or account. We use your billing address to determine your tax liability if you make a purchase of the Services through the Sites.
   • Analytical Purposes: We use your other identifiers, and internet activity and browsing history to analyze, research and better understand how users access and use our Site and Services to understand site trends and customer interests, both on an aggregated and individualized basis, to maintain, support, and improve our Site and Services, to respond to user preferences, and for research and analytical purposes. We may combine information we get from you with information about you we get from third parties.
   • Marketing and Promotional Purposes: We use your Personal Information to:
     • To keep you informed of Draup programs, products and other services we think may be of interest to you;
     • To allow business customers and Business Users to contact you about opportunities and interact with you through Draup events; and
     • Provide you with other information from and about our Company, including personalized marketing communications.
   • Maintenance and Improvement of the Sites and Services: We use your contact information, other identifiers and internet activity and browsing history to:
     • Handle your customer services requests;
     • 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;
     • Help us diagnose technical and service problems and administer our stores, websites and apps.
   • Security and Fraud Prevention: We use Personal Information to protect the Sites and Services, our Company, and others and to prevent fraud, theft and misconduct.

   We will not use your Personal Information we collected for materially different, unrelated, or incompatible purposes other than the purposes indicated above without providing you notice.

5. Third-Party Sharing

   Service Providers

   We share Personal Information with our authorized service providers that perform certain services on our behalf (“Service Providers”). We may contract with other Service Providers to provide certain services, such as hosting and maintenance of our databases and Sites, data storage and management, our online registration process, payment processors, transactional message processors, 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 Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us. Some Service Providers may be located outside of USA.

   Our Business Customers and Business Users

   If you are a Candidate, we may share your Personal Information, including your contact information, professional and employment-related information, demographic information, photos and inferences drawn from the foregoing categories, with our business customers and Business Users for their purposes. Specifically, we share this information with our customers to help them find Candidates who may meet their business needs, and to help them contact and engage with Candidates regarding opportunities that fit those Candidates’ interests and professional backgrounds.
    

   Advertising Partners

   We may allow social media, third-party advertisers and service providers to collect internet and other electronic activity data when you visit the Sites and Services. These companies include LinkedIn, Facebook and digital advertising networks. These companies collect information to help us analyze the performance of our advertising, and they may also track your activity across different websites and over time to provide advertising based on your interests. These third parties typically use cookies to collect internet and other electronic activity data. Please see our Cookie Settings for further information about these third parties and the cookies they may use.

   Our Affiliates and in Corporate Transactions

   We may share Personal Information with businesses controlling, controlled by, or under common control with Draup. Additionally, if Draup 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 Information in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.

   Compliance with Laws and Law Enforcement

   We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information 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). Or, we may also share information when we are investigating potential fraud.

   Customer Data Input or Uploaded by Business Users

   As part of utilizing our Services, our Business Users may provide us with information about Candidates or prospective buyers. Business Users may also provide us with credentials to third-party sites or services in order to synchronize certain emails or other information with our Services, and may provide us with other information (collectively any such personal information we collect in these ways is “Business Customer Data”). We treat Business Customer Data as confidential and do not use it for any purposes other than delivering the Services to the customer or Business User who provided the Business Customer Data. We do not share or disclose Business Customer Data with any parties other than the customer or Business User who provided it.

   Other ways

   • We may share information with any successor to all or part of our business. For example, if part of our business is sold, we may provide our customer list as part of that transaction.
   • Unless provided for in this Privacy Statement, Draup does not share, sell, rent, or trade personally identifiable information with third parties for their promotional purposes. We may share information collected with other companies that work on our behalf.
   • We may share your information for reasons not described in this policy. We will inform you before we do this.

6. Cookies and Automated Data Collection Technologies

   • 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 to help deliver the content of our Sites, for authentication purposes (to keep track of the fact that you have logged in) and to analyze use of and improve the Sites and Services. We also use cookies and similar technologies to personalize content and our advertising, and to provide social media features. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent.
   • The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies and how to disable existing cookies. However, certain features of the Sites or Services may not work if you delete or disable cookies. We may combine information from cookies or other identifiers with Personal Information that you have provided to us. Please see our Cookie Settings for further information about the cookies we use.

7. Response to Do-Not-Track Signals

   The Sites do not respond to web browser “do not track” signals.

8. Be Careful When You Share Information with Others

   Please be aware that if you share information on any public area of the Sites or Services or through our events, that information may be accessed by others, who may copy that information and make it public in other settings. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.

9. Third Party Websites

   If you click on one of the links to third party websites, you may be taken to websites we do not control. 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 and this Privacy Statement does not apply to the privacy practices of those 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. We encourage you to read the privacy policies of other websites carefully.

10. Children’s Safety and Privacy

    Our website/platform contains business-related content and is specifically aimed at and designed for use by adults. We do not knowingly solicit or collect personal information from individuals under the age of 18 years. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records. California users under the age of 18 may request the removal of their content or information publicly posted on the Sites or Services by emailing us at privacy@draup.com. Please note that some of the user content that appears on our Sites or Services is stored and controlled by third-party providers; thus, complete and comprehensive removal of the content may not be possible. Draup strongly encourages parents and guardians to supervise the online activities of their minor children.

11. International Transfers of Personal Information

    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.

12. Candidate Access Right and Your Right to Opt Out of Our People Insights Database

    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). We respect your control over your personal information and, upon request, we will confirm whether we hold or are processing information that we have collected or gathered about you. If we have collected your personal information, we will provide you with a copy of that information. You may also amend or update inaccurate or incomplete personal information, request deletion of your personal information, or request that we no longer use it. Under certain circumstances we will not be able to fulfill your request, such as when it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort. In any event, we will respond to your request within a reasonable timeframe and provide you an explanation of our course of action. To make a request, please use our self-service portal, email us at privacy@draup.com using the email subject line “Opt-Out,” or by calling our Consumer Support Hotline: +1 844 42-DRAUP or +1 844 423-7287.

    Our People Database helps our business customers Business Users find people to fill their business objectives including hiring and sales needs. To do this, we gather and index Personal Information of Candidates/Leads from the sources described above so it can be searched by our business customers and Business Users. 

    To opt out or exercise other rights described above, you will need to verify your identity by providing us with your first and last name and an email address that we have on file for you and we will remove your information from our system. We will 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 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 our business customers, Business Users or other users of our services.

13. Security and Data Retention

    We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information with encryption in transit and at rest. 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 Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.

    Draup makes information accessible to its employees and data processors only on a need-to-know basis. All employees and data processors, who have access to, and are associated with the processing of personal information, are obliged to respect its confidentiality.

    We will retain your Personal Information only for as long as it is necessary for the purposes set out in this Privacy Policy. Those purposes include needing to perform a service for you, complying with applicable laws or regulations, resolving legal disputes, or if it is necessary to pursue Draup’s legitimate interest that is not overridden by your personal rights and freedoms.

14. Email Opt-Out

    You can opt out of receiving our marketing emails and other communications from us by emailing us at privacy@draup.com. It may take about ten days to process your request. You are able to opt out of receiving marketing emails from us; however, you cannot opt out of receiving all messages from us, such as transactional messages emails through email and SMS about the services/status of your account with us. If you have questions or concerns regarding this Privacy Policy, please email us at privacy@draup.com.

15. Accurate or Complete Information

    If you are a Business User –

    • You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our website or platform or by contacting us through privacy@draup.com. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Draup has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Draup may, at its sole discretion, discontinue the provision of the services to you.
    • If you wish to terminate your account or if you request that we no longer use your information to provide you with the services, you may contact us at privacy@draup.com. We will retain your information for as long as your account with us is active and as required to provide you with the services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. Please note that your withdrawal of consent, or cancellation of account may result in Draup being unable to provide you with its services or to terminate any existing relationship you may have with Draup.

16. Protecting Access Information

    You are responsible for maintaining the confidentiality of your account, access information and password. You shall be responsible for all uses of your own account and password, whether or not authorized by you. You shall immediately notify Draup at privacy@draup.com of any actual or suspected unauthorized use of your account or password.

17. Privacy Questions

    Should you have questions about this Privacy Statement or Draup’s information collection, use and disclosure practices, you may contact us at privacy@draup.com. We will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information.

18. Jurisdiction

    If you choose to visit and use the website/platform, your visit, use and any dispute over the privacy is subject to this Privacy Statement. Any disputes arising out of this Privacy Statement and the website/platform shall be governed by the laws of State of Texas, USA.

19. Privacy Policy Changes

    We may change this Privacy Policy from time to time. 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 “Revised” date shown in the revised Privacy Policy. By continuing to use the Sites or Services, you are consenting to the revised Privacy Policy. We encourage you to check our website/platform periodically for updates.

20. Contact Us

    If you have any questions regarding this Privacy Statement or the information practices of Draup’s Web sites, Platforms and Services should be directed to Draup by sending an email to privacy@draup.com or by mailing us at: Draup Inc 21 Waterway Ave, Suite 300 The Woodlands, TX 77380 USA

PLEASE PRINT A COPY OF THIS PRIVACY POLICY FOR YOUR RECORD AND PLEASE CHECK THE SITES FREQUENTLY FOR ANY CHANGES.

If you are a California resident, you have certain rights under California law, including the California Consumer Privacy Act (“CCPA”). These additional terms supplement the information in our General Privacy Policy, and are intended for California residents only.

If you are not a California resident, these additional terms do not apply to you. Instead please review our General Privacy Policy or EU User Privacy Policy, which may apply to you. However, these additional terms may not cover all aspects of our business practice. You can reference our General Privacy Policy for any information that you may not be able to find here.

A.    Draup’s Role under CCPA

Draup as a Business in California

Under CCPA framework, Draup is defined as a Business as to activities of collecting, sharing, and determining the means of processing California consumer information for Commercial Purposes. Draup may collect Personal Information to provide Services to our customers including the customers’ end users. Personal Information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Commercial Purpose means to advance our commercial or economic interests.

Draup as a Service Provider in California

Under CCPA framework, in certain scenarios, Draup may be considered as a Service Provider who processes Personal Information on behalf of a Business, Draup’s customer. Draup’s customer may disclose your Personal Information to Draup for a Business Purpose pursuant to a written contract between Draup and Draup’s customer. Business Purpose means the use of Personal Information for the Business’s or Service Provider’s operational purposes, including auditing, detecting security incidents, debugging, short-term/transient use, performing customer services, internal research, and maintaining / improving/ upgrading / enhancing services.

B. Personal Information We Collected for the Preceding 12 Months:

Specifically, Draup collected Personal Information differently based on your role as a non-user or a user:

• Categories of Non-user Personal Information Collected: real name, alias, phone number, email, approximate location (city/metro area), job title, skills, education, work history, professional social network profile picture, professional social network link, and inferences draw from the aforementioned information.

• Categories of User Personal Information Collected: real name, alias, address, phone number, mobile phone number, email, payment information, company name, computer/web browser/IP address information from cookies, web beacons and other identifiers, and other specific information you choose to provide us with or that you choose to include in your account.

C. Personal Information We Sold for the Preceding 12 Months

If you are a Candidate, we share the Non-user Personal Information described above with our customers, through Draup’s paid services, so that they may reach out to you for opportunities and offering that you may have interest in, and which may better fit to your professional background. 

D. Personal Information We Disclosed for Business Purposes for the Preceding 12 Months

If you are a Business User, your information provided in your user account is confidential to Draup, and we neither sell your Personal Information nor share your Personal Information with third parties, except that your Personal Information may be shared with your company’s Admin and other users who have the authority to view your Personal Information in order to provide Services to the customer of ours with whom you are employed.

E. California Consumers’ Rights under CCPA

CCPA provides California consumers’ rights to control how their Personal Information is collected and shared by businesses. “California consumer” means a natural person who is a California resident as defined in 18 CCR §17014. 

As a California consumer, you have the following rights regarding how Draup processes your Personal Information:

• Right to Notice: Provides you the right to request Draup disclose the categories of Personal Information to be collected and the purposes for which the categories of Personal Information will be used.

• Right to Access: Provides you the right to access your Personal Information free of charge, not more than twice within a year, upon Draup’s verification of your identity. You can request Draup to disclose categories of Personal Information collected, sold or disclosed; categories of sources of where the information was collected; Business or Commercial Purposes of collecting or selling the information; categories of third parties to whom the information was disclosed or sold; and specific piece of information collected by Draup. 

• Right to Delete Information: Provides you the right to request Draup delete your Personal Information that Draup collected, upon a verifiable request, unless such Personal information was collected for the purpose of completing a transaction involving you; detecting security related incidents or illegal activities; debugging or fixing errors; protecting other consumers’ rights or other rights protected by law; preventing criminal offenses; engaging in scientific, historical or statistical reach in the public interest; internal uses that are reasonably aligned with your expectation; or compliance with a legal obligation.  

• Right to Equal Services and Prices: Provides you the right not to be discriminated against for exercising your rights under CCPA. Examples of discrimination include: denying goods or services to you, charging you different prices or rates for goods or services, providing you with a different level or quality of goods or services, or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

• Right to Opt-out: Provides you the right to request to opt-out and delete your personal information collected by Draup.

F. Response Timing and Format

You may contact us at the methods set out in Section 11 above to exercise your rights as a California consumer. We endeavor to respond to a verifiable consumer request within 45 days of our receipt. If we need to request additional information from you to verify your identity, we will use that information solely for purposes of verification. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to your email address linked to your account. If you do not have an account with us, we will deliver our written response by email in our record or an alternative way at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. Notwithstanding the foregoing, we have no obligation to respond to you if your Personal Information was collected for a single, one-time transaction, if such information is not sold or retained by Draup.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We have no obligation to provide you with responses more than two times in a 12-month period. 

PLEASE PRINT A COPY OF THESE ADDITIONAL TERMS FOR YOUR RECORD AND PLEASE CHECK THE SITE FREQUENTLY FOR ANY CHANGES.