- customers and prospective customers and their representatives;
- suppliers and business partners and their representatives.
When interacting with our websites, you also have the ability to link or connect with non-Drafter websites, services, social networks, applications or other features. Enabling these features will lead to other parties than Drafter processing information about you. Drafter does not have any control over these features of other parties. We encourage
3. Who is responsible for your personal information?
4. Which types of personal information do we process and from which sources?
Drafter can process information about you collected online.
- Online information about you originates from your activities on our sites, for example, in relation with your Drafter accounts, or subscription to our newsletters or other notifications.
Information about you that Drafter may collect and process includes:
- name and physical address, email addresses, and telephone numbers;
- demographic attributes, when tied to personal information that identifies you;
- photographs and testimonials;
- transactional data, including products and services ordered, financial details and payment methods;
- company data such as the name, size and location of the company you work for and your role within the company;
- data from surveys and publicly available information, such as social media posts;
- unique IDs such as your mobile device identifier or cookie ID on your browser;
- IP address and information that may be derived from IP address, such as geographic location;
- information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language;
- behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site;
- CEO name linked to the CEO’s company information and activities (for certain Drafter services relating to public company information and activity).
Please note that Drafter does not control the content that you may post to Drafter Communities forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.
5. Why and how do we use your personal information?
We may use personal information for the following purposes:
- to communicate and respond to your requests and inquiries to Drafter;
- to deliver functionality on our sites and for their technical and functional management;
- to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests;
- to engage in transactions with customers, suppliers and business partners and to process orders for Drafter products and services;
- to analyze, develop, improve and optimize the use, function and performance of our sites and products and services;
- to manage the security of our sites, networks and systems;
- to comply with applicable laws and regulations and to operate our business;
We may also use the names of company CEOs to provide select services to Drafter customers which may include publicly-available information regarding names of company CEOs.
These purposes are described below in further detail.
To communicate and respond to your requests and inquiries to Drafter
If you get in touch with us (such as by submitting contact forms on our sites, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third party social networks.
To deliver functionality on our sites and for their technical and functional management
When you choose to register with us (such as to make use of our communities), we need to process the personal information provided by you so that we can create and manage a personal account for you. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account, for example by changing your password for you.
To market our products and services or related products and services and to tailor marketing and sales activities
Drafter may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). Drafter may also use personal information to advertise Drafter’s products and services or related products and services, and also to have our distributors, resellers or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience and our communications to your expressed interests.
We may also process your personal information to post testimonials on our sites, but will first obtain your consent to use your name and testimonial.
To engage in transactions with customers, suppliers and business partners and to process purchases of our products and services
If you place an order for our products and services, or if you provide services to Drafter, our employees, customers or partners as a supplier or business partner, Drafter processes information about you to engage in and administer the relevant transactions (such as by sending invoices and making payments), administer your order, and help you get started and adopt our products and services. If you download products or services from our sites, Drafter uses information about you to confirm certain information about your order (for example, that you did not experience problems in the download process).
To analyze, develop, improve and optimize the use, function and performance of our sites and products and services
We may process personal information in order to analyze, develop, improve and optimize the use, function and performance of our sites and products and services, as well as marketing and sales campaigns. In case the sites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, Drafter may process personal information when moderating these activities.
To manage the security of our sites, networks and systems
We may collect site use data for security and operations management to help keep our sites, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.
To comply with applicable laws and regulations and to operate our business
In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.
To provide select services to Drafter customers which may include publicly-available information regarding names of company CEOs
For some services, we may collect the publicly-available names of CEOs of companies to better understand the status of these companies and help inform our services which relate to providing customers information about other companies.
6. What is our basis for processing information about you?
For personal information collected about you in the EU, our basis for processing is the following:
- In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information.
- In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
- We process personal information for marketing and sales activities based on your consent where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services.
- We rely on our legitimate interest to analyze, develop, improve and optimize our sites, products and services, and to maintain the security of our sites, networks and systems.
- In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.
7. For what period do we retain personal information
Drafter maintains personal information for the following retention periods:
- Information about you we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
- If you have registered for an Drafter account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 18 consecutive months. Drafter retains records of that deletion for 90 days.
- If you have registered for our newsletters your subscription data will be retained for as long as you are subscribed to our distribution lists. Drafter retains records of that deletion for 30 days.
- Contact information such as your email address or phone number collected online on our sites or offline from our interactions with you at Drafter events and conferences, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with Drafter or updated your contact details and preferences in the past 18 months; and (ii) you have not made a deletion request.
- Personal information needed to retain your opt-out preferences is retained for 20 years (or longer as necessary to comply with applicable law).
8. When and how can we share your personal information?
Sharing within Drafter
Drafter officers and employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.
Sharing with third parties
We may share personal information with the following third parties:
- Third-party service providers (for example, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Drafter;
- Drafter distributors or resellers for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising;
- Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
- As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
9. How is your personal information secured?
Drafter has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.
10. What cookies and similar technologies do we use on our sites?
Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Drafter and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.
- Which types of cookie are used by Drafter?
Drafter website uses three types of cookies:
- Required Cookies: These cookies are required to enable core site functionality such as providing secure log-in and are automatically enabled when you use this site.
- Functional Cookies: These cookies enable additional functionality like saving preferences such as allowing social interactions, allowing you to post comments on our site, and analyzing usage for site optimization.
- Advertising Cookies: These cookies collect information to better understand your interests, provide you with interest-based advertising and tailored content across browsers and devices, facilitate measurement and analytics, and improve Drafter products and services.
You can choose whether Drafter site may use Functional and/or Advertising cookies. We will signal participating partners with your choice.
Specific data collection cookies used by Drafter:
|Session Cookies||Required||Authentication, application state, cache|
|Google Tag Manager||Functional||Central controller of cookies|
|Google Optimize||Functional||A/B, multivariate testing, optimizing UI|
|HotJar||Functional||User behavior, testing, optimizing UX, UI|
|Performance monitoring||Functional||Firebase Performance monitoring of UI activities, debugging, optimization|
|Google Analytics||Advertising||User behavior, page views, advertising audience collection|
|Facebook Pixel||Advertising||User behavior, page views, advertising audience collectionn|