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This Privacy Policy is incorporated into the Dromni Terms of Use and Conditions (available at www.dromni.eu/legal) (“TOUC”). This also includes the Privacy Policy of the website (available at www.dromni.eu/privacy-policy) .Any terms used, but not defined, in this Privacy Policy have the meanings set forth in the TOUC.
This Policy describes how we process your personal data at Dromni.
It applies to your use of:
From now on, we’ll collectively call these the “Dromni Platform”.
From time to time, we may develop new or offer additional services. They’ll also be subject to this Policy, unless stated otherwise when we introduce them.
Privacy laws, including the General Data Protection Regulation (“GDPR”), give rights to individuals over their personal data.
Your rights are:
You can contact Dromni directly to exercise your rights at any time (see Section 11 ‘How to contact us’). You also have the right to contact the local data protection authority about any questions or concerns.
Collected data when you sign up for the Dromni Platform or when you update your account:
| Category | Description |
| User Data | Personal data that we need to create your Dromni account and enables you to use the Dromni Platform. The type of data collected depends on the type of Service Option you have, how you create your account, the country you are in, and if you use third party services to sign in. This may include your: We receive some of this data from you e.g. from the sign up form or account page. We also collect some of this data from your device e.g. country |
| Street Address Data | We may ask for your street address for tax administration reasons. |
Collected data when you use the Dromni Platform:
| Category | Description |
| Usage Data | Personal data collected about you when you’re accessing and/or using the Platform. There are a few types of information this includes, detailed in the following sections. Information about how you use Dromni Services, as example: – Your actions with the Dromni Platform (including date and time), such as: search queriescontent streaming history, browsing history, account settings, interactions with other Dromni users, your use of third party devices and applications in connection with the Dromni Platform. – Inferences (i.e., our understanding) of your interests and preferences based on your usage of the Dromni Platform. – Content you post to any part of the Dromni Platform, such as volumetric content, text, titles, communications, and other types of content. Your technical data, as example: – Online identifiers such as IP addressesInformation about the devices you use such as: device IDs, network connection type (e.g. wifi, 4G, LTE, Bluetooth), provider, network and device performance, language, information enabling digital rights management, operating system, Dromniverse application version – Information (such as the device name, device identifiers, brand and version) which enables us to improve the quality of recordings Your device sensor data, as example: – Camera properties and configurations – Volumetric content data which implies – Device orientation, position and location – Camera sensor data – Recorded audio Your general (non-precise) location: – This may be understood from technical data (e.g. your IP address, language setting of your device, or payment currency). We need this to meet geographic requirements in our agreements with the owners of content on the Dromni Platform, and to deliver content and advertising that’s relevant to you. |
Additional data you may choose to give us
| Category | Description |
| Payment and Purchase Data | If you make any purchases from Dromni, we will need to process your payment data. The exact personal data collected will vary depending on the payment method, but will include information such as: |
| Contests, Surveys, and Sweepstakes Data | When you complete any forms, respond to a survey or questionnaire, or take part in a contest or sweepstake, we collect the personal data you provide. |
Collected from other (‘third party’) sources
| Third Parties | Description |
| Third party applications, services and devices | If you connect your Dromni account to a third party application, service and/or devices, we may collect certain information from them to make the integration possible. These third party apps, services or devices may include: social mediadevices including: – mobile phones and tablets – games consolesVR headsets – computers – services or platforms We’ll ask your permission before we collect your information from certain third parties. |
| Payment partners | If you choose to pay Dromni by invoice, we may get data from our payment partners. This allows us to: – send you invoices – process your payment – give you what you’ve purchased |
| Advertising and marketing partners | We may get data about you from certain advertising or marketing partners. This may include: – cookie id – mobile device id – email address – inferences (i.e., our understanding) of your interests and preferences This allows us to deliver more relevant ads and marketing. |
The table below sets out:
Here is a general explanation of each “legal basis” to help you understand the table:
| Purpose for processing your data | Legal basis that permits the purpose | Categories of personal data used for the purpose |
| To provide the personalized Dromni Platform. | Performance of a Contract Legitimate Interest Consent | User Data Usage Data Payment and Purchase Data Street Address Data |
| To understand, diagnose, troubleshoot, and fix issues with the Dromni Platform. | Performance of a Contract Legitimate Interest | User Data Usage Data |
| To evaluate and develop new features, technologies, and improvements to the Dromni Platform. | Legitimate Interest Consent | User Data Usage Data |
| To process the data to improve the visualization and shared experiences | Performance of a Contract Legitimate Interest Consent | User Data Usage Data |
| For marketing, promotion, and advertising purposes. | Legitimate Interest Consent | User Data Usage Data Contests, Surveys and Sweepstakes Data |
| To comply with legal obligations and law enforcement requests. | Compliance with legal obligations Legitimate interest | User Data Usage Data Payment and Purchase Data Street Address Data Contests, Surveys and Sweepstakes Data |
| To: fulfill contractual obligations with third parties, for example our agreements with owners of content on the Dromni Platform, andtake appropriate action with reports of intellectual property infringement and inappropriate content. | Legitimate interest | User Data Usage Data Payment and Purchase Data |
| To establish, exercise, or defend legal claims. | Legitimate interest | User Data Usage Data Payment and Purchase Data Street Address Data Contests, Surveys and Sweepstakes Data |
| To conduct business planning, reporting, and forecasting. | Legitimate Interest | User Data Usage Data Payment and Purchase Data |
| To process your payment. | Performance of a Contract Compliance with legal obligations | User Data Payment and Purchase Data |
| To detect and prevent fraud, including fraudulent payments and fraudulent use of the Dromni Platform. | Performance of a Contract Compliance with legal obligations Legitimate Interest | User Data Usage Data Payment and Purchase Data Street Address Data |
| To conduct research, contests, surveys, and sweepstakes. | Performance of a Contract Legitimate Interest Consent | User Data Usage Data Contests, Surveys and Sweepstakes Data |
This section sets out the categories of recipients of the personal data collected or generated through your use of the Dromni Platform.
The following personal data will always be publicly available on the Dromni Platform:
We will only share the following personal data with those outlined in the table below:
| Categories of recipients | Reason for sharing |
| Third party applications, services and devices you connect to your Dromni Account | To connect your Dromni account, and/or allow you to use the Dromni Platform in connection with third party applications, services or devices. Examples of such third party applications, services and devices include: social media, mobile devices, desktop applications and devices, VR headsets and game consoles. |
| Dromni Discord Community | To enable you to use the Dromni Discord Community service. When you register for an account on the Dromni Discord Community, we’ll ask you to create a specific profile name. This will be publicly displayed to anyone who uses the Dromni Discord Community. We’ll also display any questions or comments you post. |
| Other Dromni users | To share content and information about your use of the Dromni Platform with other Dromni users, including your ‘Followers’. |
Information we may share
| Categories of recipients | Reason for sharing |
| Service providers | So they can provide their services to Dromni. These service providers may include those we hire to: – give customer support – operate the technical infrastructure we need to provide the Dromni Platform – assist in protecting and securing our systems and services (e.g. Google’s reCAPTCHA) – help market Dromni’s (and our partners’) products, services, events and promotions |
| Payment processors | So they can process your payments, and for anti-fraud purposes. |
| Advertising partners | So our ad partners can help us deliver more relevant advertising to you on the Dromni Platform. For example, our ad partners help us facilitate tailored advertising: This is when we use third party information to tailor ads to be more relevant to you (also known as interest based advertising). An example of a tailored ad is when an ad partner has information suggesting you like cars, which could enable us to show you ads about cars. You can control tailored advertising in your account privacy settings under “Tailored Ads”. If you are “opted out” of Tailored Ads, you may still get advertising on ad-supported services (such as podcasts or the Free Service Option) based on your registration information and ads based on the content you are streaming on our Services. For example, if you are streaming a cooking podcast, you may hear an ad for a food processor or if you are streaming a workout playlist, you may hear an ad for sports clothing. |
| Marketing Partners | To promote Dromni with our partners. We share some personal data with these partners where necessary to: enable you to participate in Dromni promotions, including trials or other bundled offersto promote Dromni in media and advertising published on other online serviceshelp us and our partners to measure the effectiveness of Dromni promotions Examples of partners include: – marketing or sponsorship partners – websites and mobile apps who sell us advertising space on their services – device, app and mobile partners who also offer Dromni promotions Our partners may also combine the personal data we share with them with other data they collect about you (e.g. your use of their services). We and our partners may use this information to present you with offers, promotions, or other marketing activities that we believe will be relevant to you. |
| Other partner sharing | We may share personal data with partners to help us understand and improve the performance of our products and partnerships. |
| Academic researchers | For activities such as statistical analysis and academic study, but only in a pseudonymised format. Pseudonymised data is where your data is identified by a code rather than your name or other information that directly identifies you. |
| Law enforcement and other authorities | When we believe in good faith it’s necessary for us to do so, for example: to comply with a legal obligationto respond to a valid legal process (such as a search warrant, court order, or subpoena)for our own or a third party’s justifiable interest, relating to: – national security – law enforcement – litigation (a court case) – criminal investigation – protecting someone’s safety – preventing death or imminent bodily harm. |
| Purchasers of our business | Where we sell or negotiate to sell our business to a buyer or possible buyer. In this situation, Dromni will continue to ensure your personal data is kept confidential. We’ll give you notice before your personal data is transferred to the buyer or a different privacy policy starts to apply. |
Retention
We keep your personal data only as long as necessary to provide you with the Dromni Platform and for Dromni’s legitimate and essential business purposes, such as:
Deletion
If you close or request that we close your account, we’ll delete or anonymise your personal data so it no longer identifies you, unless we’re required to keep something or we still need to use it for a legally justifiable reason.
Here are some examples of situations where we’re legally allowed or required to keep some of your personal data:
When carrying out the activities described in this Policy, Dromni shares your personal data internationally with subcontractors and partners. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.
Whenever we transfer personal data internationally, we use tools to:
We do this using a variety of protections, as appropriate for each data transfer. For example, we use:
You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal data.
We’re committed to protecting our users’ personal data. We implement appropriate technical and organisational measures to help protect the security of your personal data. However, be aware that no system is ever completely secure.
We have implemented various safeguards including pseudonymisation, encryption, access, and retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems.
To protect your user account, we encourage you to:
You can log out of Dromni using the “Sign out” function on your account page.
If other individuals have access to your Dromni account (for example if you’ve given them permission to use your account on a shared device), then they can access personal data, controls and the Dromni Platform available in your account.
It’s your responsibility to only provide individuals with permission to use your account where you’re comfortable sharing this personal data with them. Anyone else’s use of your Dromni account may impact your personalised recommendations and be included in your data download.
The Dromni Platform has a minimum “Age Limit” in each country. The Dromni Platform is not directed to children whose age:
We do not knowingly collect personal data from children under the applicable Age Limit. If you’re under the Age Limit, please do not use the Dromni Platform, and do not provide any personal data to us.
If you’re a parent of a child under the Age Limit and become aware that your child has provided personal data to Dromni, please contact us.
If we learn that we’ve collected the personal data of a child under the applicable Age Limit, we’ll take reasonable steps to delete the personal data. This may require us to delete the Dromni account for that child.
When using a shared device on the main Dromni Platform, you should be cautious about playing or recommending any content to individuals under 18 years old which could be inappropriate for them.
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the Dromni Platform or send you an email or device notification.
For any questions or concerns about this Policy, contact our Data Protection Officer any one of these ways:
Email contact@dromni.eu
Write to us at:
Dromni GmbH,
Am Blütenring 48,
80939 München,
Germany
Dromni GmbH
Am Blütenring 48
80939 München
HRB 269578
Contact Person: Maximilian Prexl
Phone: +49 (0)15679 140100
E-Mail: contact@dromni.eu
Website: www.dromni.eu
As a service provider, we are responsible for our own content on these pages in accordance with general legislation pursuant to Section 7 (1) of the German Telemedia Act (TMG). According to §§ 8 to 10 TMG, however, we are not obligated as a service provider to monitor transmitted or stored third-party information or to investigate circumstances that indicate illegal activity.
Obligations to remove or block the use of information under the general laws remain unaffected. However, liability in this regard is only possible from the point in time at which a concrete infringement of the law becomes known. If we become aware of such infringements, we will remove this content immediately.
Our offer contains links to external websites of third parties, on whose contents we have no influence. Therefore, we cannot assume any liability for these external contents. The respective provider or operator of the pages is always responsible for the content of the linked pages. The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not recognizable at the time of linking.
However, a permanent control of the contents of the linked pages is not reasonable without concrete evidence of a violation of the law. If we become aware of any infringements, we will remove such links immediately.
The content and works created by the site operators on these pages are subject to German copyright law. The reproduction, editing, distribution and any kind of exploitation outside the limits of copyright require the written consent of the respective author or creator. Downloads and copies of this site are only permitted for private, non-commercial use. Insofar as the content on this site was not created by the operator, the copyrights of third parties are respected. In particular, third-party content is identified as such. Should you nevertheless become aware of a copyright infringement, please inform us accordingly. If we become aware of any infringements, we will remove such content immediately.