October 13, 2022
This privacy notice for
7621396 CANADA INC.
(doing business as Dracme)
( " Dracme
," "we," "us," or "our"
), describes how and why we might collect, store, use, and/or
share ( "process" ) your information
when you use our services ( "Services" ), such as when you:
Visit our website
at https://www.dracme.com , or any website of ours that links to this privacy notice
Engage with us in other related ways, including any sales,
marketing, or events
Questions or concerns?Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with
Dracme and the Services, the choices you make,
and the products and features you use. Click
to learn more.
Do we process any sensitive personal information?
We do not process sensitive
Do we receive any information from third parties?
We do not receive any information
from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.
In what situations and with which
parties do we share personal information? We may share information in specific situations and with specific third parties. Click
to learn more.
How do we keep your information safe? We have
organizational and technical processes and
procedures in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be
guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Click
to learn more.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available
, or by contacting us. We will
consider and act upon any request in accordance with applicable data
Want to learn more about what
Dracme does with any information we collect? Click
to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you
express an interest in obtaining information about us or our
products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
We do not process sensitive
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by
. You may find their privacy notice link(s) here:
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related,
diagnostic, usage, and performance information our servers
automatically collect when you access or use our Services
and which we record in log files. Depending on how you interact
with us, this log data may include your IP address, device
information, browser type, and settings and information about
your activity in the Services
(such as the date/time stamps associated with
your usage, pages and files viewed, searches, and other
actions you take such as which features you use), device
event information (such as system activity, error
reports (sometimes called
"crash dumps" ), and hardware settings).
Device Data. We collect device data such as information
about your computer, phone, tablet, or other device you use
to access the Services. Depending on the device used, this
device data may include information such as your IP address
(or proxy server), device and application identification
numbers, location, browser type, hardware model, Internet
service provider and/or mobile carrier, operating system,
and system configuration information.
Location Data. We collect location data such as
information about your device's location, which can be either
precise or imprecise. How much information we collect depends
on the type and settings of the device you use to access
the Services. For example, we may use GPS and other technologies
to collect geolocation data that tells us your current location
(based on your IP address). You can opt out of allowing us
to collect this information either by refusing access to
the information or by disabling your Location setting on
your device. However, if you choose to opt out, you may not
be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short:We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
To deliver and facilitate delivery of services to the user.
We may process your information to provide you with the
To respond to user inquiries/offer support to users.
We may process your information to respond to your
inquiries and solve any potential issues you might have with the
fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
To request feedback.We may process your
information when necessary to request feedback and to contact
you about your use of our Services.
To send you marketing and promotional communications.
We may process the personal information you send to us
for our marketing purposes, if this is in accordance with your
marketing preferences. You can opt out of our marketing emails at
any time. For more information, see
" WHAT ARE YOUR PRIVACY RIGHTS? " below).
To deliver targeted advertising to you.We may
process your information to develop and display
personalized content and advertising tailored to your interests, location, and more.
To evaluate and improve our Services, products, marketing, and
your experience. We may process your information when we believe it is necessary to
identify usage trends, determine the effectiveness of our promotional
campaigns, and to evaluate and improve our Services, products, marketing,
and your experience.
To determine the effectiveness of our marketing and promotional
campaigns. We may process your information to better understand how to provide
marketing and promotional campaigns that are most relevant to you.
To comply with our legal obligations. We may process
your information to comply with our legal obligations, respond to legal
requests, and exercise, establish, or defend our legal rights.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short:We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e.
, legal basis) to do so under
applicable law, like with your consent, to comply with laws, to provide
you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e.
, express consent) to use your
personal information for a specific purpose, or in situations where your
permission can be inferred (i.e. , implied consent).
You can withdraw your consent at any time. Click
to learn more.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is
necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating
with next of kin
If we have reasonable grounds to believe an individual has been,
is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would
compromise the availability or the accuracy of the information and
the collection is reasonable for purposes related to investigating a
breach of an agreement or a contravention of the laws of Canada or a
If disclosure is required to comply with a subpoena, warrant, court
order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their
employment, business, or profession and the collection is consistent
with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary
If the information is publicly available and is specified by the
In Short: We may share information in specific situations described in this section and/or with the following
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (
"third parties" ) who perform services
for us or on our behalf and require access to such information to do
that work. The third parties we may share personal
information with are as follows:
- Advertising, Direct Marketing, and Lead Generation
- Communicate and Chat with Users
- Invoice and Billing
- Retargeting Platforms
- Social Media Sharing and Advertising
- Web and Mobile Analytics
also may need to share your
personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share
your information with certain Google Maps Platform APIs (e.g.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short:We keep your information for as long as necessary to
fulfill the purposes outlined in
this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or
anonymize such information, or, if
this is not possible (for example, because your personal information
has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until
deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short:We aim to protect your personal information through a system of
organizational and technical security
We have implemented appropriate and reasonable technical and
organizational security measures designed
to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee
that hackers, cybercriminals, or other unauthorized third parties will not
be able to defeat our security and improperly collect, access, steal,
or modify your information. Although we will do our best to protect
your personal information, transmission of personal information to
and from our Services is at your own risk. You should only access the
Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at
9. WHAT ARE YOUR PRIVACY RIGHTS?
In some regions, such as Canada , you
have rights that allow you greater access to and control over
your personal information.
You may review, change, or terminate your account at any
In some regions (like
Canada ), you
have certain rights under applicable data protection laws. These
may include the right (i) to request access and obtain a copy of
your personal information, (ii) to request rectification or
erasure; (iii) to restrict the processing of your personal
information; and (iv) if applicable, to data portability. In
certain circumstances, you may also have the right to object to
the processing of your personal information. You can make such a
request by contacting us by using the contact details provided in
the section "
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html .
Withdrawing your consent: If we are relying on your consent to process your personal information,
which may be express and/or implied
consent depending on the applicable law, you have the right to withdraw
your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the section
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
" below .
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor,
when applicable law allows, will it affect the processing of your personal information conducted
in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by
clicking on the unsubscribe link in
the emails that we send, or by contacting us using the details
provided in the section "
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
" below. You will then be removed
from the marketing lists. However, we may still communicate with you
— for example, to send you service-related messages that are necessary
for the administration and use of your account, to respond to service
requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/ .
If you have questions or comments about your privacy rights, you may email us at
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (
feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities
monitored and collected. At this stage no uniform technology
standard for recognizing and implementing DNT signals
has been finalized . As such, we do not
currently respond to DNT browser signals or any other mechanism
that automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted that we must
follow in the future, we will inform you about that practice in a
revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short:Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the
"Shine The Light" law, permits our users
who are California residents to request and obtain from us, once a
year and free of charge, information about categories of personal information
(if any) we disclosed to third parties for direct marketing purposes
and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If
you are a California resident and would like to make such a request,
please submit your request in writing to us using the contact information
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g.
, backups, etc.).
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short:Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated
"Revised" date and
the updated version will be effective as soon as it is accessible. If
we make material changes to this privacy notice, we may notify you either
by prominently posting a notice of such changes or by directly sending
you a notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
email us at firstname.lastname@example.org
or by post to:
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?