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LEGAL RESOURCES
AT DRIFT

Drift Terms of Service
API Terms of Service
Privacy Policy
Acceptable Use Policy
GDPR


PRIVACY POLICY

Effective Date: August 13, 2021

Drift.com, Inc. (“us”, “we”, or “our”) operates the https://www.drift.com,
http://app.drift.com, and http://dev.drift.com website and the Drift mobile
application (collectively, the “Services”). This page informs you of our
policies and practices regarding the collection, use and disclosure of
information which personally identifies you (“Personal Information”) when you
use our Services. We will not use or share your information with anyone except
as described in this privacy policy (the “Privacy Policy”). We use your Personal
Information for providing and improving the Services. By using the Services, you
agree to the collection and use of your Personal Information in accordance with
this Privacy Policy.

Information Collection and Use; Personal Information

We may ask you to provide us, or third parties may provide us, with certain
Personal Information that can be used to contact or identify you. Personal
Information may include, but is not limited to, your name, postal address, email
address, and employer. We collect Personal Information for the purpose of
providing the Services, identifying and communicating with you about the
Services, responding to your requests/inquiries, servicing your purchase orders,
improving our Services, and communicating with you about our Services,
discounts, and promotions.

How Long We Keep Your Personal Information

How long we keep information we collect about you depends on the type of
information, as described in further detail below. After such time, we will
either delete or anonymize your information or, if this is not possible (for
example, because the information has been stored in backup archives), then we
will securely store your information and isolate it from any further use until
deletion is possible.

Account Information

We retain your account information for as long as your account is active and a
reasonable period thereafter in case you decide to re-activate the Services. We
also retain your information as necessary to comply with our legal obligations,
to resolve disputes, to enforce our agreements, and to continue to develop and
improve our Services. Where we retain information for Service improvement and
development, it will be anonymized and used to uncover collective insights about
the use of our Services, not to specifically analyze personal characteristics
about you.

Managed Accounts

If the Services are made available to you through an organization (e.g., your
employer), we retain your information as long as required by your employer under
our agreement with your employer as required by the administrator of your
account. If your account is deactivated, your information and conversations you
may have had and actions you may have taken on the Services will remain in order
to allow your team members to make full use of the Services.

Marketing Information

If you have elected to receive marketing emails from us, we retain information
about your marketing preferences for a reasonable period of time from the date
you last expressed interest in our Services. Every marketing email we send will
provide you with the option to opt out of receiving future emails.

Accessing and Correcting Your Personal Information

We acknowledge individuals’ rights to access their personal information. You may
access, update, correct or have removed from our systems and records the
Personal Information you provided to us by emailing a request to
privacy@drift.com or contacting us by telephone or postal mail as further
specified in the How to Contact Us clause of this Privacy Policy. To protect
your privacy and security, we will also take reasonable steps to verify your
identity before updating or removing your information.

Information Collected Directly from You

We collect information about you when you provide it to us and automatically
when you use the Services.

Log Data

We collect information that your browser sends whenever you visit our website or
use our Services (“Log Data”). This Log Data may include information such as
your computer’s Internet Protocol (“IP”) address, browser type, browser version,
the pages of our Services that you visit, the time and date of your visit, the
time spent on those pages and other statistics. In addition, we use third party
services such as Google Analytics that collect, monitor and analyze this type of
information in order to increase our Services’ functionality. These third-party
service providers have their own privacy policies addressing how they use such
information. When you access the Services by or through a mobile device, we
collect certain information automatically, including the type of mobile device
you use, your mobile device’s unique device ID, the IP address of your mobile
device, your mobile operating system, the type of mobile Internet browser you
use, and your general location information as described further below.

Location Information

We use and store information about your general location. We use this
information to provide features of our Services and to improve and customize our
Services.

Cookies

Cookies are files with a small amount of data, which may include an anonymous
unique identifier. Cookies are sent to your browser from a web site and
transferred to your device. We use cookies to collect information in order to
improve our Services. You can instruct your browser to refuse all cookies or to
indicate when a cookie is being sent. The “Help” feature on most browsers
provide information on how to accept cookies, disable cookies or to notify you
when receiving a new cookie. If you do not accept cookies, you may not be able
to use some features of our Services and we recommend that you leave them turned
on.

Do Not Track Disclosure

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set
in your web browser to inform websites that you do not want to be tracked. You
can enable or disable Do Not Track by visiting the “Preferences” or “Settings”
page of your web browser.

Information Collected from Other Sources

We will enrich your Personal Information with additional Personal Information
received from publicly accessible sources. We may also receive your information
from services you integrate with Drift, from other users of Drift, or from our
partners.

Integrations

You may enhance the Services by enabling Drift integrations with third-party
products. If you provide third-party account credentials to us, you understand
some content and/or information in those accounts (“Third Party Account
Information”) will be transmitted into your account with us, and that Third
Party Account Information transmitted to our Services is covered by this Privacy
Policy. Further, Drift software may request permissions to take actions on your
behalf using your third-party account credentials. For example, if you choose to
integrate Drift Services with your Google Mail inbox, Drift software will
request authority to read incoming messages and send emails on your behalf.

Other Users of the Services

Other users of our Services may provide information about you when they use the
Services. For example, we receive your email address from other Service users
when they provide it in order to invite you to the Services.

Partners

We work with partners who may market, sell, or support our Services. These
partners may provide us your Personal Information so that we can contact you. We
also may receive your Personal Information from advertising, market research, or
data enrichment partners with whom we engage to identify prospective customers.

Google User Data

Notwithstanding anything else in this Privacy Policy, if you provide the Drift
Application with access to the following types of your Google data, the
Application’s use of that data will be subject to these additional restrictions:

The Application will only use access to read, write, modify or control Gmail
message bodies (including attachments), metadata, headers, and settings to
provide a web email client that allows users to compose, send, read, and process
emails and will not transfer this Gmail data to others unless doing so is
necessary to provide and improve these features, comply with applicable law, or
as part of a merger, acquisition or sale of assets.

The Application will not use this Gmail data for serving advertisements.

The Application will not allow humans to read this data unless we have your
affirmative agreement for specific messages, doing so is necessary for security
purposes such as investigating abuse, to comply with applicable law, or for the
App’s internal operations and even only when the data have been aggregated and
anonymized.

Drift’s use and transfer to any other app of information received from Google
Accounts will adhere to Google API Services User Data Policy, including the
Limited Use requirements.

Service Providers who may Receive Your Personal Information

We may employ third-party companies and individuals (our “agents”) to facilitate
our Services, to provide the Services on our behalf, to perform complementary
services and/or to assist us in analyzing how our Services are used. Examples
may include storing data, delivering messages, processing credit card payments,
analyzing data, providing marketing assistance, managing our agreements with
you, supplementing the information you provide us in order to provide you with
better service, and providing customer service. We do not transfer data to
non-agent third parties. These third parties have access to your Personal
Information only to perform specific tasks on our behalf and are under written
obligation not to disclose or use your Personal Information for any purpose
other than those disclosed in this Privacy Policy.

Notwithstanding such legal and contractual obligations between us and such
service providers, we remain potentially liable for any misuse of your Personal
Information. We will only disclose Personal Information when we are required to
do so in response to a lawful request by public authorities, including to meet
national security or law enforcement requirements.

Communications; Your Options

We may use your Personal Information to contact you with newsletters, marketing
or promotional materials and other information that may be of interest to you.
You may opt out of receiving any, or all, of these communications from us by
following the unsubscribe link or instructions provided in any email we send, or
by emailing privacy@drift.com.

Security of Personal Information

The security of your Personal Information is important to us, and we strive to
implement and maintain reasonable, commercially acceptable security procedures
and practices appropriate to the nature of the information we store, in order to
protect it from unauthorized access, destruction, use, modification, or
disclosure. However, please be aware that no method of transmission over the
internet, or method of electronic storage is 100% secure and we are unable to
guarantee the absolute security of the Personal Information we have collected
from you.

International Transfer of Personal Information

Your Personal Information may be transferred to — and maintained on — computers
located outside of your state, province, country or other governmental
jurisdiction where the data protection laws may differ from those in your
jurisdiction. If you are located outside the United States and choose to provide
Personal Information to us, please note that we transfer Personal Information to
the United States.

Links To Other Sites

Our Services may contain links to other web sites or online locations that are
not operated or controlled by us. If you click on a third-party link, you will
be directed to that third party’s site. We strongly advise you to review the
privacy policy of every site or location you visit. We have no control over, and
assume no responsibility for the content, privacy policies or practices of any
third-party sites or services.

Children’s Privacy

Only persons who are age 18 or older have permission to access our Services. Our
Services are not intended to be used by anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from children
under 13. If you are a parent or guardian and you learn that your Children have
provided us with Personal Information, please contact us. If we become aware
that we have collected Personal Information from a child under age 13 without
verification of parental consent, we take steps to remove that information from
our servers.

For EU Users and UK Users

This section applies only to Users located in the European Union and the United
Kingdom.

Contact Information for the Data Controller

This paragraph pertains only to individuals for whom Drift is a “controller”
within the meaning of Regulation (EU) 2016/679 of the German Parliament and of
the Council of 27 April 2016 (“GDPR”):

Controller of your Personal Information:

Drift.com, Inc.
222 Berkeley Street, Suite 600
Boston, MA 02116
Phone: +1 855-266-1567
Email: privacy@drift.com

Representative in the EU:
Lionheart Squared Ltd
2 Pembroke House Upper Pembroke St 28-32,
Dublin DO2 EK84 Ireland
drift@lionheartsquared.eu
Representative in the UK:
Lionheart Squared Ltd
17 Glasshouse Studios
Fryern Court Road
Fordingbridge, Hampshire
SP6 1QX United Kingdom
drift@lionheartsquared.uk
Data Protection Officer:
Mike Parent
Data Protection Officer, Senior Tech Lead
222 Berkeley Street, Suite 600
Boston, MA 02116
DPO@drift.com

 

Legal Bases for Processing EU and UK Users’ Personal Information

We only process your information when we have the legal basis to do so. That is,
we will only process your Personal Information when:

 * We need it to provide you the Services;
 * You give us consent for a specific purpose; or
 * It satisfies Drift’s legitimate interests (which are not overridden by your
   data protection interests), such as for improving, marketing, and promoting
   the Services and protecting our legal rights;
 * We need to process your data to comply with our legal obligations.

Transfer of EU and UK Users’ Personal Information Outside the EU and the UK

We may transfer your Personal Information to Drift-affiliated entities in third
parties in the United States or other countries that may not have equivalent
privacy and data protection laws to the country in which you reside. When we
transfer Personal Information of customers in the European Economic Area, the
United Kingdom, or Switzerland to any such country, we make use of European
Commission-approved standard contractual data protection clauses.

EU and UK Users’ Rights to Control Personal Information

You have control over your Personal Information. Below are the rights you have
and the steps you can take to exercise them. Please note that your rights may be
limited in certain cases: for example, if fulfilling your request would reveal
information about another person, or if you ask to delete information which we
or your employer are permitted by law or have compelling legitimate interests to
keep, and it may take time for us to investigate your request. If you believe
that we are not respecting your rights with regard to your Personal Information,
you may lodge a complaint with your local supervisory authority or by contacting
our EU or UK Representative.

Right to Access

You have a right to request a copy of the Personal Information that Drift holds.
To request this information, please email us at privacy@drift.com.

Right to Rectification

If you believe that any Personal Information that Drift holds is incorrect, you
have the right to correct that information. You can change your Drift account
information on the “Settings” page, and if you have any further concerns
regarding the accuracy of your information, please email us at
privacy@drift.com.

Right to Erasure, Restriction, or Objection to Processing

If you believe we do not have the right to process your information or you
object to our processing for a particular purpose, or if you want us to erase
your Personal Information altogether, please email us at privacy@drift.com.

Right to Withdraw Consent

If you gave us consent to process your Personal Information for a particular
purpose, you have the right to withdraw that consent by emailing us at
privacy@drift.com. Your withdrawal of consent does not affect the lawfulness of
our processing of your Personal Information prior to the withdrawal.

Data Portability

You have the right to obtain the Personal Information that you have directly
submitted to Drift in a format you can transfer to another service provider. If
you want to exercise this right, please email us at privacy@drift.com.

CCPA Privacy Statement

This Statement applies solely to residents of California or individuals whose
information has been collected in California. Drift has adopted and included
this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).
Any terms used in this Statement that are defined in the CCPA have the same
meaning given therein.

INFORMATION WE COLLECT

In the past twelve (12) months, Drift has collected from individuals, and may
have shared or sold (as defined in the CCPA), certain categories of Personal
Information (as defined in the CCPA) as follows:

# Category Collected? Disclosed? 1 Identifiers.
Name, alias, postal address, unique personal identifier, online identifier,
Internet Protocol (IP) address, email address, account name, social security
number, driver’s license number, passport number, or other similar identifiers
YES YES 2 Personal information categories under the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver’s license or
state identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card number, debit
card number, or any other financial information, medical information, or health
insurance information. Some personal information included in this category may
overlap with other categories. YES
Only name, signature, address, telephone, employment. YES 3 Protected
classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression, pregnancy
or childbirth and related medical conditions), sexual orientation, veteran or
military status, genetic information (including familial genetic information).
NO NO 4 Commercial information.
Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies. NO NO 5
Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying
information, such as, fingerprints, faceprints, and voiceprints, iris or retina
scans, keystroke, gait, or other physical patterns, and sleep, health, or
exercise data. NO NO 6 Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a
website, application, or advertisement. YES
In website only YES 7 Geolocation data.
Physical location or movements. YES
No movements YES 8 Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information. YES
In video YES 9 Professional or employment-related information.
Current or past employment history or performance evaluations. YES YES 10
Education Information under California Family Educational Rights and Privacy Act
(20 U.S.C. section 1232g, 34 C.F.R. Part 99)
Information that is not “publicly available personally identifiable information”
as defined in the California Family Educational Rights and Privacy Act (20
U.S.C. section 1232g, 34 C.F.R. Part 99). Includes education records directly
related to a student maintained by an educational institution or party acting on
its behalf, like grades, transcripts, class lists and student schedules,
identification codes, financial information, or disciplinary records. YES YES 11
Inferences
Conclusions that could be used to create a profile reflecting an individual’s
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, aptitude. NO NO

Under the CCPA, Personal information does not include:

 * Publicly available information from government records;
 * Personal Information that has been de-identified or aggregated such that it
   cannot be used to identify an individual;
 * Information excluded from the CCPA’s scope, like: (a) health or medical
   information covered by the Health Insurance Portability and Accountability
   Act of 1996 (HIPAA) and the California Confidentiality of Medical Information
   Act (CMIA) or clinical trial data; and (b) personal information covered by
   certain sector-specific privacy laws, including the Fair Credit Reporting Act
   (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information
   Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994. Please
   note that Drift does not collect any such sensitive personal information.

Drift obtains the categories of personal information listed above from the
following categories of sources:

 * Directly and indirectly from Drift’s site visitors and activity on the Drift
   website (www.drift.com). Examples: from site visitors, by interacting with
   the Drift chat bot and providing information to the chatbot; by cookies from
   the Drift or Customer website; and by event registration forms or pages
 * Directly from Drift’s Customers or their agents. Examples: the information
   that our clients provide to us related to the services or products that Drift
   provides them (such as contact or profile or user profile information).
 * Directly and Indirectly from third-parties, such as partners or
   collaborators, that interact with Drift in connection with Drift marketing
   activities and the services we perform. Examples: leads and sales activities
   from partners, leads from co-marketing campaigns; event registration; or lead
   generation.

USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of
the following business purposes: (i) to provide you with information, products
or services that you request from Drift; (ii) to provide you with email alerts,
event registrations and other notices concerning our products or services,
events or news; (iii) to seek feedback on the Drift products, services or your
experience with Drift, a Drift event, a Drift publication or the Drift website;
(iv) to carry out our obligations and enforce our rights arising from any
contracts entered into between us, including renewals, professional services,
billing, collections or other notices; (v) to improve our website or
interactions with you; (vi) for Drift product or service development; (vii) as
necessary or appropriate to protect the rights, property or safety of Drift,
Drift customers and other third parties; (viii) to respond to law enforcement
requests and as required by applicable law, order, or regulation; or (ix) as may
be described to you when collecting your personal information or as otherwise
set forth in the CCPA. We will not collect additional categories of personal
information or use the personal information we collected for materially
different, unrelated, or incompatible purposes without reasonable notice.

SHARING PERSONAL INFORMATION

We may disclose your personal information for a business purpose to the third
parties, including service providers (as defined under the CCPA), our affiliates
(to the extent applicable), and third parties to whom you or your agents
authorize us to disclose your personal information in connection with the Drift
products and services we provide you. When we disclose personal information for
a business purpose, we enter a contract that describes the purpose and requires
the recipient to not use it for any purpose except performance of the contract
and, if confidential, maintain its confidentiality. In the preceding twelve (12)
months, Drift has disclosed the categories of Personal Information for a
business purpose as provided in the table above.

SELLING INFORMATION

Drift does not sell any Personal Information or any other data collected or
created by its customers in their use of the Drift platform, services,
application or otherwise.

Drift may sell your Personal Information only to the extent that Drift has
collected your personal information for its own purposes (not by, in or through
the provision of its Services to a Drift Customer). In the preceding twelve (12)
months, Drift may have sold, as defined in the CCPA, the following categories of
data: Identifiers (#1); Personal information categories under the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)) (#2); Geolocation data
(#7); and Professional or employment-related information (#9).

FOR AVOIDANCE OF DOUBT, DRIFT DOES NOT SELL THE INFORMATION THAT ITS CUSTOMERS
OR USERS COLLECT, GENERATE OR STORE THROUGH THEIR USE OF THE DRIFT PLATFORM
AND/OR SERVICES. DRIFT DOES NOT USE OR PROCESS SUCH INFORMATION FOR ITS OWN
PURPOSES. ANY PROCESSING OR SHARING OF PERSONAL INFORMATION COLLECTED BY OR
BELONGING TO CUSTOMER IS FOR THE PURPOSE OF PERFORMING THE SERVICES ONLY. SUCH
INFORMATION IS AT ALL TIMES THE PROPERTY OF THE CUSTOMER AND DRIFT DOES NOT SELL
IT.

YOUR RIGHTS AND CHOICES

The CCPA provides individuals residing in California or whose Personal
Information was collected in California with specific rights regarding their
Personal information. The below describes your rights and how you may exercise
them.

Access to Specific Information and Data Portability Rights

You have the right to request that Drift disclose certain information to you
about our collection and use of your Personal Information over the past twelve
(12) months. Once Drift receives and confirms your verifiable information access
request, Drift must disclose to you: (i) the categories of Personal Information
we collected about you; (ii) the categories of sources for the Personal
Information we collected about you; (iii) our business or commercial purpose for
collecting or, if applicable, selling that Personal Information; (iv) the
categories of third parties with whom we share that Personal Information; (v)
the specific data points or pieces of Personal Information we collected about
you. If we disclosed for a business purpose or sold your Personal Information,
Drift must also provide separate lists that: (x) identify the personal
information categories that were sold to each category of recipient in
connection with sales of your Personal Information; and (y) identify the
personal information categories that were provided to each category of recipient
in connection with business purposes disclosures of your Personal Information..

Deletion Request Rights

You have the right to request that Drift delete any of your Personal Information
that we collected from you and/or retained. Unless subject to a certain limited
exception, once Drift receives and confirms your verifiable data deletion
request, we will delete (and direct our service providers to delete) your
personal information from our records. Drift will notify you promptly if it
determines it must deny your deletion request and will provide reasons why
retention of your information is necessary to Drift and permissible under the
CCPA in such case.

Do Not Sell Opt-Out Rights

You have the right to opt-out of any sales, as defined by the CCPA, of Personal
Information by Drift. You must request that Drift not sell any information you
provide to Drift as an individual, either upon the provision of Personal
Information to Drift or any time thereafter. Once Drift receives and confirms
your request, Drift will refrain from selling your Personal Information.

EXERCISING YOUR RIGHTS

To exercise your access, data portability, and deletion or do not sell opt-out
rights described above, you may submit a verifiable consumer request by any of
the following means:

CCPA Requests Information Access and Data Deletion:
https://preferences.drift.com/privacy Do Not Sell My Personal Information:
https://preferences.drift.com/dont_sell By Email: privacy@drift.com By Phone:
855-266-1567

You may only make a verifiable consumer request for access or data portability
up to two times within a 12-month period. You may make a verifiable do not sell
opt-out request at any time. Any such request must: (i) provide sufficient
information that allows Drift to reasonably verify that you are the person about
whom we collected personal information or an authorized representative thereof;
and (ii) describe your request with sufficient detail such that we may
understand, evaluate, and respond to it. Drift cannot respond to your request or
provide you with personal information if we cannot verify your identity or
authority to make the request and confirm the personal information relates to
you. Making a verifiable consumer request does not require you to create an
account with Drift. Drift will only use personal information provided in a
verifiable consumer request to verify the requestor’s identity or authority to
make the request. Only you or a person registered with the California Secretary
of State that you authorize to act on your behalf may make a verifiable consumer
request related to your Personal Information. You may also make a verifiable
consumer request on behalf of your minor child.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its
receipt. If we require more time (up to 90 days), we will inform you in writing
of the extension period and the reason for it. Drift will deliver any required
or requested responses or other communications in writing to you by email. Any
disclosures we provide will only cover the 12-month period preceding the
verifiable consumer request’s receipt. If applicable, the response we provide
will also explain any reasons we cannot comply with a request. For data
portability requests, Drift will provide your personal information in a format
that is readily usable and transferable. Drift does not charge a fee to process
or respond to your verifiable consumer request unless such requests become
excessive, repetitive, or manifestly unfounded or as otherwise permitted by the
CCPA. If we determine that a request warrants charging a fee, we will notify you
and provide you with a cost estimate before completing your request.

NON-DISCRIMINATION

We will not discriminate against you or any other individual for exercising any
of your CCPA rights. Unless and only to the extent permitted by the CCPA, Drift
will not (i) deny you goods or services; (ii) charge you different prices or
rates for goods or services; (iii) provide you a different level or quality of
goods or services; or (iv) suggest that you may receive a different price or
rate for goods or services or a different level or quality of goods or services.

Changes to This Privacy Policy

We reserve the right to update or change our Privacy Policy at any time and you
should check this Privacy Policy periodically. Your continued use of the
Services after we post any modifications to the Privacy Policy on this page will
constitute your acknowledgment of the modifications and your consent to abide
and be bound by the modified Privacy Policy. If we make any material changes to
this Privacy Policy, we will notify you either through the email address you
have provided us, or by placing a prominent notice on our website.

How to Contact Us

If you have any questions or concerns about this Privacy Policy, please contact
us at:privacy@drift.com 222 Berkeley Street, 6th Floor, Boston, MA 02116,
855-266-1567

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