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DRAYSON GROUP PRIVACY POLICY

This Privacy Policy sets out the privacy and data protection principles we follow globally regarding any personal data you may provide to us or we may collect and process when you access or use draysontechnologies.com or other websites provided by us (‘Website’ and ‘Websites’) or any service or product provided by us (‘Service’ and ‘Services’) in any way. Please note, this Privacy Policy does not apply to any of our other services which may have separate privacy policies (such as CleanSpace), or any service offered by a third party, which will be subject to the privacy policy of that third party.

By ‘personal data’ we mean any data that personally identifies you, from which you could be identified, or which could identify you in conjunction with other data. We use it interchangeably with the US term ‘personally identifiable information’.

Your use of a Website or Service is your consent to our use of your personal data (and other data you provide to us) in accordance with this policy, including (if you are a resident of the European Economic Area (‘EEA’)) the transfer of your personal data outside the EEA.

We may change this Privacy Policy from time to time and will post any change on the Websites, with a more prominent notice where the change is significant. Your continued use of a Website or Service is your agreement to the updated Privacy Policy.

Who ‘we’ are

We are the ‘Drayson Group’ of companies (together ‘Drayson’), including: Drayson Technologies (Europe) Limited of Grand Union Studios, 332 Ladbroke Grove, London W10 5AD (‘Drayson UK’), Drayson Technologies Inc, of 600 California Street, Floor 11, San Francisco, CA 94108, United States (‘Drayson USA’), Drayson Technologies Mexico, S.A. de C.V. of Varsovia 36, Col. Juarez, Mexico City, ZIP 06600, Mexico (‘Drayson Mexico’) and Drayson Technologies Mexico (Services), S.A. de C.V. of Varsovia 36, Col. Juarez, Mexico City, ZIP 06600 (‘Drayson Mexico (Services)’). ‘We’, ‘us’ and ‘our’ refers to one or more or all of the Drayson Group as the context requires. Each member of the Drayson Group agrees to protect and process personal data related to the Service in accordance with this Privacy Policy and applicable data protection laws. ‘Drayson Technologies’ is a trading name of the Drayson Group.

Data we collect

You may submit and we may collect your personal data when you use a Website or Service or contact us through a Website or a Service. You may provide such personal data to us directly and sometimes we may be given the data by a third party, for example in a ‘refer a friend’ program.

Such personal data could include your name, telephone number and email address and, depending on your query or the Service you are using, other information such as your age range. Using the definitions in EU law, we will be the ‘data controller’ of personal data we collect and use for our own marketing and account management purposes (‘Account Data’) and the ‘data processor’ of personal data collected through your use of a Website or Service, such as data about your device model, operating system or browser, IP address and, if you have enabled tracking for a particular Service, data about your location (‘Service Data’).

When you provide us with personal data about yourself or another person, you are confirming to us that you are authorised to provide us with that information and that any personal data you give us is accurate and up-to-date.

Location Data

Some Websites and Services ask for or need your location to deliver certain benefits or for certain functionality. This will be made clear before collection of location data and if you decide to allow such collection you are consenting to our collection of location data for processing according to this Privacy Policy.

Sensitive Personal Data

‘Sensitive personal data’ is defined under EU law as personal data revealing information such as racial or ethnic origin, political opinions or religious or philosophical beliefs, trade-union membership and data concerning health or sex life. We do not collect or process sensitive personal data for Services such as CleanSpace, the CleanSpace API and Aura. Should we collect or process sensitive personal data in future we will only do so in accordance with applicable law and we will amend this policy to cover such processing.

Using personal data

We may use your personal data for the purposes stated in any data collection notice and in the normal, legitimate, course of our business, including the following required purposes:

  • when you contact us, to respond to your message;
  • when you sign-up to a Service, to confirm that you are eligible to receive that Service;
  • to deliver the Websites and Services including to contact you about your account, to ensure that the Websites and Services are functioning correctly, and to monitor, investigate any bug with, and improve the Websites and Services;
  • to monitor traffic through Websites and Services including to improve your user experience;

And the following ancillary purposes:

  • to inform you about any of our products or services which are similar or connected to the Website or Service that you are using; and
  • inform you about the Drayson Group, our activities and Services.

Sharing data

We shall only share personal data in the limited circumstances below:

  • in order to provide, maintain and otherwise deliver the Websites and Services, we may share the minimum personal data necessary within the Drayson Group and with trusted service providers (who may be outside your jurisdiction, including outside the EEA) for them to deliver the Website or Service, and technical, IT, logistical, marketing, promotional or administrative services and process the data for us in accordance with our instructions, and we shall ensure that the recipient has appropriate security and confidentiality measures in place to protect the personal data;
  • to the extent required or authorized by law including to comply with a legal obligation such as a court order or binding decision of a legally competent authority, to protect or enforce our legal rights, or to protect the health or life of an individual;
  • if we undertake a transaction, or preparations for a transaction, such as a business sale, we may share the personal data to the extent required with the other party to the transaction and only after ensuring that the recipient has appropriate security and confidentiality measures in place to protect the personal data.

Other than for the examples set out above, we shall not share your personal data with other companies or organisations without your prior consent.

Testimonials

If you make a positive, public remark about us, a Website or Service, for example on social media, you agree that we may use that remark as a testimonial.

Non-personal or anonymized data

We may process personal data to create non-personal or anonymized data. By non-personal or anonymised data we mean data that is aggregated or otherwise anonymized, in accordance with applicable law, so that it is no longer personal data. For example, in the CleanSpace Service, we may aggregate geo-located pollution readings from Tags with our AirMap created from other sources, to create a map of air pollution which does not allow for the identification of a living individual from that data. We may use such non-personal or anonymised data, for example, to show trends in air pollution or trends in the use of the CleanSpace Services, or to create a consolidated air pollution map of an area or location, and we may share such non-personal or anonymised data publicly or with third-parties such as publishers and commercial or research partners.

Security

The security of your personal data is of paramount importance to us. We shall use appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access.

Cookies

We may use cookies and similar data collection tools when you visit a Website or use a Service. Such technology allows us to deliver, personalize or otherwise improve your experience of our Websites and Services. Accepting cookies may give us access to information, for example, about your browsing behaviour. Most browsers and devices automatically accept cookies and data collection tools by default but you can usually refuse or selectively accept cookies and data collection tools by adjusting the preferences in your browser or in your device settings. Please see our Cookie Policy for more details.

California Privacy Notice

Please note that our websites do not respond to ‘Do-Not-Track’ signals communicated by your internet browser. As above, please note you can prevent tracking, and collection of location data, through your management of cookies (please see our Cookie Policy) and for mobile Services (for example by the CleanSpace App) by switching the location tracking mode of your phone to ‘off’.

Your rights

You are entitled to know if we are processing any personal data about you and, if we are, with certain limitations, to a copy of that personal data. You can also ask us to limit the use and disclosure of your personal data, ask that we do not use your details to contact you for marketing purposes, ask us to remove or correct inaccurate personal data, or revoke your consent in relation to any processing of your personal data. We’ll ask you to prove your identity when you make such a request. We will respond to your request as soon as reasonably possible and in any event, in accordance with any local legal requirement.

Contact

For any question or request under this policy, please contact us at the addresses above or by email to legal@draysontechnologies.com, marked for the attention of the Data Protection Officer.