Welcome to Drammers Club!

 Drammers LLC and its affiliates (collectively “Drammers Club”, “we” and “us”) respect your privacy. 

 This Global Privacy Policy describes the types of personal data we collect through our payments products and services (“Services”) and via our online presence, which include our main website at drammers.com (our “Site”).  This policy also describes how we use personal data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Site, and you should consider the privacy practices of those third-parties carefully.

1. Overview 

Drammers Club obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our Site, a user of one or more of our Services (“Customer, “User” or “Drammers Club User”). 

2. Personal Data We Collect

a. Personal Data that we collect about you. Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Site and Services will be apparent from the context in which you provide the data. In particular:

• When you register for a Drammers Club account we collect your full name, email address, and account log-in credentials.

• When you respond to Drammers Club emails we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Drammers Club. If you contact us by phone as a Drammers Club User, we may collect additional information in order to verify your identity.

• If you are a Customer, when you make payments or conduct transactions through our Site, we will receive your transaction information. Depending on how any third-party services integrated with our Site function, we may receive this information directly from you, or from such third parties. The information that we collect may include payment method information, purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information.  When you make a transaction, we may also receive your name, email, billing or shipping address and in some cases your transaction history to authenticate you.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that we collect automatically on our Site. Our Site uses cookies and other technologies to function effectively. These technologies record information about your use of our Site, including:

• Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Site you are visiting; 

• Usage data, such as time spent on the Site, pages visited, links clicked, and the pages that led or referred you to our Site.

 We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We may use Google Analytics on our Site to help us analyze Your use of our Site and diagnose technical issues.

3. How We Use Personal Data 

a. Our products and services. We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to provide payment-related services to our Users. 

b. Marketing and events-related communications. We may send you email marketing communications about Drammers Club products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. 

c. Advertising. We do not use, share, rent or sell the Personal Data of our Customers for interest-based advertising. We do not sell or rent the Personal Data of our Customers or our Site visitors.

4. How We Disclose Personal Data. 

Drammers Club does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

a. Drammers Club. We share Personal Data for internal administration purposes.

b. Service providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
c. Business partners. We share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are payment method providers (such as credit card networks).

d. Third party service providers.  We share Personal Data with Users as necessary with third party service providers to maintain a User account and provide the Services.  The use of Personal Data by an authorized third party is subject to the third party’s privacy policy.

e. Corporate transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but only in the manner set out in this Privacy Policy unless you agree otherwise. 

f. Compliance and harm prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Drammers Club, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

5. Your Rights and Choices.

You have choices regarding our use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.

b. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your Drammers Club account or by contacting us.

c. Your data protection rights. Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:

• The right to request confirmation of whether Drammers Club processes Personal Data relating to you, and if so, to request a copy of that Personal Data;

• The right to request that Drammers Club rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;

• The right to request that Drammers Club erase your Personal Data in certain circumstances provided by law;

• The right to request that Drammers Club restrict the use of your Personal Data in certain circumstances, such as while Drammers Club considers another request that you have submitted (including a request that Drammers Club make an update to your Personal Data); and

• The right to request that we export to another company, where technically feasible, your Personal Data that we hold in order to provide Services to you.

Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.

d. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Drammers Club as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.

 For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request. If you are a Customer of a third party services that is integrated within Drammers.com, please direct your requests directly to such third party servcice. 

6. Security and Retention. 

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services directly or indirectly to you, even if you close your Drammers Club account or complete a transaction with a Drammers Club User, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

7. International Data Transfers.

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

 If you are located in the European Economic Area (“EEA”), the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US. Drammers Club Inc. is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework and adheres to the Privacy Shield Principles in connection with personal data transfers from the EEA, the UK and Switzerland.  

8. Use by Minors. 

The Services are not directed to individuals under the age of twenty-one (21), and we request that they not provide Personal Data through the Services.

9. Updates To this Privacy Policy and Notifications.

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Drammers Club Dashboard, email address and/or the physical address listed in your Drammers Club account.

10. Links To Other Websites. 

The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website. 

11. Jurisdiction-specific Provisions.

• Australian residents. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Privacy Policy, you may wish to contact the Office of the Australian Information Commissioner.

• If you are a resident of the EEA and believe we process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK and the UK is no longer a Member State of the EU, you may direct your questions or concerns to the UK Information Commissioner’s Office.

• Mexican residents. Mexican residents may exercise data protection rights to access, correction, deletion, opposition or revocation under applicable law. You may be provided with further information about the steps to exercise your privacy rights, including identity verification, timing, the way to get in touch with the organization responding to your request for further communications about your request, and how your request may be honored.

• United States - California residents. This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).

a. How We Collect, Use, and Disclose your Personal Information. The “Personal Data We Collect” section above describes the personal information we may have collected over the last 12 months, including the categories of sources of that information. We collect this information for the purposes described in the “How We Use Personal Data” section. We share this information as described in the “How We Disclose Personal Data” section above.  Drammers Club uses cookies, including advertising cookies, as described above.

b. Your CCPA Rights and Choices. As a California consumer and subject to certain limitations under the CCPA, you have choices regarding our use and disclosure of your personal information:

• Exercising the right to know. You may request, up to twice in a 12-month period, the following information about the personal information we have collected about you during the past 12 months:

  • the categories and specific pieces of personal information we have collected about you;

  • the categories of sources from which we collected the personal information;

  • the business or commercial purpose for which we collected the personal information;

  • the categories of third parties with whom we shared the personal information; and

  • the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

• Exercising the right to delete. You may request that we delete the personal information we have collected from you, subject to certain limitations under applicable law.

• Exercising the right to opt-out from a sale. You may request to opt out of any “sale” of your personal information that may take place. As described above, we do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors.

• Non-discrimination. The CCPA provides that you may not be discriminated against for exercising these rights.

To submit a request to exercise any of the rights described above, you may contact us.  We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required. 

12. Contact Us 

If You have any questions or complaints about this Privacy Policy, please contact us electronically or send physical mail to:

Drammers Club
250 Mercer Street C512

New York NY 10012 USA
Attention: Drammers Club Legal