In this Privacy Policy (“Policy”), we describe how Creative Bot, Inc. d/b/a Drop (“Drop”, or "we", "us", "our") collects, uses, and discloses information about natural persons, including visitors to our website https://usedrop.io (the “Site”) and users of our services (“you” or “your”) (collectively ,the “Services”).
By visiting the Site or using any of our Services, you acknowledge and agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Drop Terms of Service are incorporated by reference into this Policy.
Please read this Privacy Policy carefully to understand how we handle your Personal Information.
We provide our customers (e-commerce brands) with technical solutions to interact with their audiences. For example, our customers may deploy a virtual assistant ('chatbot') or provide an Instagram Direct Messages service offering to enable 1-to-1 conversations at scale with their subscribers on our customer’s digital service offerings. Our customers may choose to integrate additional third-party solutions that allow their audiences to purchase and pay for our customer’s products and services. We also provide our customers with professional services and dedicated client strategists.
To the extent Creative Bot, Inc. d/b/a Drop processes Personal Information on behalf of organizations (“Clients”) that want to engage with individual consumers (“Client Consumers”) through the Service, Creative Bot, Inc. d/b/a Drop acts a data processor or service provider on behalf of these Clients. Our processing of Client Consumers’ Personal Information is described in this Privacy Policy and is governed by Creative Bot, Inc. d/b/a Drop's agreements with those Clients.
Client Consumers who wish to exercise any privacy rights in connection with their Personal Information that has been submitted to us by a Client should inquire with the Client directly. Because we only process Client Consumers’ data upon instruction from that Client, Client Consumers who make a request directly to us should provide to us the name of the Client who submitted their Personal Information to us. If we are able to verify the Client, we will refer the request to that Client and support them as needed in responding to the request within a reasonable timeframe.
Personal Information We Collect from Clients’ Representatives and other Website Visitors.
We collect the following categories of Personal Information for our own business purposes, as set out below:
- Identifiers, including your first and last name, email address, and phone number;
Preferences for receiving communications about our services and publications, and details about how you engage with our marketing communications;
- Information you provide when you interact with content on our Website;
- Information you provide in connection with requests to contact us or requests for customer service; andInformation you provide in connection with your participation in a contest, sweepstakes, research study, or email survey.
Personal Information about Client Consumers that Clients Provide to Us.
Clients may provide us with information about Client Consumers through the Service or offline for inclusion in the Service. Such information may include Client Consumers’ name, email address, and telephone number. Our Clients are responsible for providing notice and obtaining appropriate consents necessary for us to process this Personal Information.
Personal Information We Automatically Collect.
Like most online services, we may automatically receive and store certain Personal Information about individuals who interact with our Service through their browser or device. As discussed further below, we and our service providers may use a variety of technologies, including cookies, to assist in collecting this information.
• Device Information. We collect technical information associated with the device(s) you use to access our Service, including information related to your browser and operating system, IP address (the Internet address of your computer), unique device identifiers, and other information such as your device type.
• Usage Information. We collect a variety of information to better understand how individuals use our Service. This may include the webpage that you were visiting before accessing our Service, the pages or features of our Service you use, how much time you spend there, date and time of use, and information about your usage preferences.
• Transaction Information. We also collect information to help us verify transactions completed using our Service. This may include the names and email addresses of parties to a transaction, subject line, history of actions that individuals take on a transaction (e.g., reviewing and approving transactions, providing payment method details), and authentication methods.
Personal Information We Collect from Social Media and Other Content Platforms.
When individuals “like” or “follow” us on Facebook, Instagram, X, LinkedIn, or other social media sites, we may collect some Personal Information including your name, e-mail address, and any comments or content you post that is relevant to us. We also collect your Personal Information if you sign up for one of our promotions or submit information to us through social media sites.
Personal Information We Collect from Others.
We may also receive Personal Information from service providers, advertisers, business partners, data companies and other third parties. We may combine this information with other information we receive through the Service.
We use Personal Information for the following business and operational purposes:
• Account Administration. To enter into or perform a contract with our Clients and Website visitors, we use Personal Information for account administration, information verification, payment collection and invoicing and accounting.
• Service Provision. To perform our contract with our Clients and Website visitors, we use Personal Information to provide, manage, support, and improve our Service.
• Communications and Customer Support. To perform our contract with Clients and Website visitors, or where it is in our legitimate business interests, we use Personal Information to respond to requests or other communications we receive by email, phone or otherwise, and to provide more effective and efficient customer service.
• Fraud Protection and Security. It is in our legitimate business interests to use Personal Information to conduct internal business operations to keep our Service safe and secure, such as auditing, detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity and resolving crashes.
• Analytics and Aggregation. It is in our legitimate business interests to monitor use of the Service, analyze trends, and carry out research and development. We may aggregate or anonymize Personal Information in a form that does not allow individuals to be personally identified and use the resulting information for statistical analysis regarding use of the Service, such as to better understand our customer base, or for other purposes.
• Marketing. It is in our legitimate business interests to contact Clients and Website visitors regarding Creative Bot, Inc. d/b/a Drop and third-party products, services, surveys, research studies, promotions, special events, and other subjects that we think may be of interest to them (in accordance with any privacy preferences they have expressed to us). Where legally required, we will only send marketing communications with prior consent.
• Personalization. It is in our legitimate business interests to use Personal Information to customize content, preferences, and advertising on the Service and across the Internet.
• Compliance and Legal Reasons. We may use Personal Information to enforce and comply with our terms and policies, to comply with our legal obligations such as applicable laws, regulations, and other legal processes and procedures, or where it is in our legitimate interests to establish, exercise or defend our legal rights.
To collect the information in the “Personal Information We Automatically Collect” section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. We use these technologies to offer a more personalized experience by understanding and remembering Website visitors’ particular browsing preferences.
• A web server log is a file where website activity is stored.
• A cookie is a small text file that is placed on your computer or mobile device when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Service you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
• Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or emails that are designed to: (i) collect usage information like ad impressions or clicks and email open rates; (ii) measure popularity of the Service and associated advertising; and (iii) access user cookies.
As we adopt additional technologies, we may also gather information through other methods and technologies.Please note that you can change your settings to notify you when certain cookies are being set or updated, or to block certain cookies altogether.
Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website.
Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Service and that Creative Bot, Inc. d/b/a Drop does not control the choices that are available through above third-party offerings.
For detailed information about our cookie policy, please visit this page.
Analytics. We may use third-party analytics services (such as Google Analytics) on our Service to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to Website visitors. To prevent Google Analytics from using Personal Information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
Interest-Based Advertising. When you visit our Website, Creative Bot, Inc. d/b/a Drop may use the information collected from you in order to display advertising to you on other websites, such as Facebook or Google, about products, services, and related features that we think may be of interest to you to improve and personalize your use of the Service. This type of advertising is called retargeting. These ads may be personalized based on various factors such as the features you are using, demographic and geographic data, and other information that we collect about you. This advertising may be based on your current activity or your activity over time and may be tailored to your interests.
In order to provide this interest-based advertising, we may use third-party service providers who, on our behalf, may place cookies or other tracking technologies, such as cookies and SDKs on your computer browser, mobile phone applications, or other devices to collect information about your use of the Service in order to provide interest-based advertising to you both on the Website and on other websites.
We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device by non-affiliated third parties. As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based advertising to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each non-affiliated third party, not us.
If you are interested in more information about interest-based advertising and how you can generally control cookies and other tracking technologies from being put on your device to deliver such advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link, or TrustArc’s Advertising Choices Page. To opt out of the display of interest-based advertising from Google, please visit the Google Ads Settings page. Facebook also offers settings that may control what information Facebook uses about you or your device activity for advertising purposes. For more information, you will need to log in to Facebook via the Sign In link and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app).
Please note that to the extent advertising technology is integrated into the Website, Website visitors may still receive advertising even if you opt-out as described above. In that case, the advertising will just not be based on your interests.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.
Analytics
Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site and Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site and ServicWe use automated technologies, such as Google Analytics, which involves the use of several different cookies, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site’s performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout
Do-Not-Track
Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.
We may disclose Personal Information to the following parties:
• Service Providers. We may disclose Personal Information to vendors who provide services to us, such as analytics, payments processing, web site management, information technology, security and other similar services.
• Advertising Partners. We may disclose Personal Information pertaining to Clients and Website visitors to third-party advertising companies, including for the interest-based advertising purposes described above.
• Our Clients. We may disclose Client Consumers’ Personal Information to the Client with which that Client Consumer engages.
• Related Entities. We may disclose Personal Information to our affiliates (entities that control or are under the control of Creative Bot, Inc. d/b/a Drop) for business purposes. We will require these entities to comply with the terms of this Privacy Policy with regard to their use of Personal Information.
• State, Federal, and Foreign Courts and Regulatory and Government Authorities. We may disclose Personal Information as we believe to be necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce our Terms of Use; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.
• Prospective Purchasers, Assignees and other Parties Involved in Corporate Transactions. We reserve the right to transfer Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, diligence, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
• Other Third Parties as Authorized by You. We may also disclose Personal Information when you have authorized us to do so or at your direction.
From time to time, we may share aggregate or de-identified information about use of the Service and individuals. We may disclose such aggregate or de-identified information to any third party, including advertisers, promotional partners, and sponsors.
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
We will maintain your personal information only for as long as is it is necessary for a purpose identified in this Policy or by applicable law. In particular, we may store your personal information for specified periods of time where we are required to do so in accordance with legal, regulatory, tax, accounting requirements. We may also retain your personal information so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Certain laws provide for rights for individuals relating to the use of their personal information. These rights will only be available to you if a relevant law applies to our use of your personal information, or if we, in our absolute discretion, choose to extend any such right to you. Other than where permitted by law, we do not charge for your exercise of these rights but in certain cases may require further proof of your identity. Where you are entitled to a right, we will respond to your request within the timeframe set out by law, or where we provide answers on a voluntary basis within a reasonable timeframe.
Please note that we only respond directly to you in cases where we are the controller of your personal information. As explained in the section "About Creative Bot, Inc. d/b/a Drop" above, if you are using a digital service which incorporates our Services, the relevant controller will be our customer, and not us.
Drop is headquartered in the United States of America. The personal information we collect from you may be transferred to, stored at or processed in countries other than your country of residence, including the United States or outside the European Economic Area, which may not provide equivalent levels of data protection as your home jurisdiction.
If your personal information is subject to a restricted international transfer (including through our use of third party service providers) we will take steps to ensure that it receives an adequate level of protection. Safeguards may also include adequacy decisions by the EU Commission or putting in place standard contractual clauses as approved by the European Commission or other appropriate transfer mechanisms.
You may have the right to access, rectify (correct), or delete your personal information held by us. You may also have the right to ask for an overview or copy of your personal information or to request that certain of your personal information be exported to another provider where technically feasible. On some of our Sites and Services, you may access, rectify, or delete your personal information by making the change directly on your account page. You may also make these requests by sending an email to support@usedrop.io.
Please note that there are some limitations to these rights. For example, we will not be able to delete your personal information if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your personal information may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information. If we cannot fulfill your request we will inform you about why we cannot comply with your request.
The Service may contain links to third-party services (e.g., social media sites like Facebook and X) and third-party plug-ins (e.g., the Facebook “like” button and the X “follow” button). These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators. If you choose to use these sites or features, you may disclose your Personal Information not just to those third parties, but also to their users and the public more generally depending on how their services function. Creative Bot, Inc. d/b/a Drop does not control these third parties and is not responsible for the content or data practices of such third-party websites or services. Any information you provide to third parties on their websites or services is covered under their privacy and data collection policies, and is not covered by this Privacy Policy. We urge you to review the privacy and security policies of these third parties before interacting with their services.
In general, when we operate as a Service Provider, we will handle requests to know or requests to delete on behalf of our Business customer as they require under our agreement, which allows us to comply with the CCPA by acting on their behalf according to their instructions or by responding to a consumer that the request cannot be acting upon because the request has been sent to a Service Provider.
In general, under the CCPA, Businesses must notify and provide California residents with the following rights with respect to their personal information:
Do-not-sell (opt-out)
to opt-out of the sale of their personal information.
Right of deletion
to request deletion of their personal information collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
Right to know
with respect to the personal information collected in the prior 12 months, disclose the following (up to twice per year and subject to certain exemptions):
categories of personal information collected;
categories of sources of personal information;
categories of personal information disclosed or shared with a third party for a business purpose;
categories of third parties to whom their personal information was sold and for each the specific categories of personal information sold;
the business or commercial purposes for collecting or selling personal information;
copy of the specific pieces of personal information collected about them.
Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.
As a Service Provider under the CCPA, we process or maintain personal information on behalf of our Business customers that provide the personal information to us in compliance with written contracts that we enter into with our Business customers directly. In accordance with the CCPA, we use and disclose personal information we receive from our Business customers as necessary to provide the Services to our Business customers, to retain or employ another Service Provider where that Service Provider meets the requirements of a Service Provider under the CCPA, for our internal use to build and improve the quality of our Services as permitted under the CCPA, to detect security incidents or protect against fraudulent or illegal activity and for the purposes enumerated under CCPA Civil Code section 1798.145(a)(1) through (a)(4) or as otherwise required by the CCPA.
This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
California residents may submit CCPA requests by contacting our Business customers directly or by emailing us at: support@usedrop.io. When you submit a request to know or a request to delete, we, if and as requested by our Business customers, will take steps to verify your request by matching the information provided by you with the information we and/or our Business customers have in our or their records. In some cases, additional information may be requested in order to verify your request or where necessary to process your request. If we and/or our Business customers are unable to adequately verify a request, we and/or our Business customers will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting our Business customers directly or emailing us at support@usedrop.io. Authorized agents will be required to provide proof of their authorization, and our Business customers and/or we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
For more information about our privacy practices, please see the Contact Us section below.
If a privacy complaint or dispute relating to Personal Data received by Creative Bot Inc d/b/a Drop in reliance on the Data Privacy Framework (or any of its predecessors) cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/
If a complaint or dispute cannot be resolved through our internal process, we have also agreed to cooperate with the EU and UK data protection authorities and the Swiss Federal Data Protection and Information Commissioner and to participate in the dispute resolution procedures of the panel established by such data protection authorities.
If your dispute or complaint related to your Personal Data that we received in reliance on the Data Privacy Framework cannot be resolved by us, nor through the dispute resolution mechanism mentioned above, you may have the right to require that we enter into binding arbitration with you under the Data Privacy Framework “Recourse, Enforcement and Liability” Principle and Annex I of the Data Privacy Framework.
Drop is committed to enhancing data protection and privacy for our users. We are currently in the process of obtaining Data Privacy Framework certification. This certification underscores our dedication to maintaining high standards of data security and compliance, reflecting our ongoing commitment to safeguarding user information and enhancing trust in our services.
To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
We respect your right to make choices about the ways we collect, use, and disclose your Personal Information.
Legal Rights. Depending on the laws of their local jurisdiction,
Clients’ representatives and Website visitors may have certain rights and choices with respect to their Personal Information. Client Consumers who wish to exercise any rights in connection with their Personal Information that has been submitted to us by a Client should inquire with the Client directly.Clients’ representatives and Website visitors may be able to ask us to:
• provide access to and/or a copy of certain Personal Information we hold about you;
• prevent the processing of your Personal Information for direct-marketing purposes (including any direct marketing processing based on profiling);
• update or rectify Personal Information which is out of date or incorrect;
• delete certain Personal Information which we are holding about you;
• oppose, cancel, or restrict the way that we process and disclose certain of your Personal Information;transfer your Personal Information to a third-party provider of services;
• revoke your consent for the processing of your Personal Information;
• optout out of sharing your Personal Information for interest-based advertising. You can limit online tracking as described in the “Online Analytics and Interest-Based Marketing” section or by clicking the “Cookie Notice” link on the footer of our website. We do not sell Personal Information.We will consider all requests and provide our response within the time period required by applicable law. Please note that certain Personal Information may be exempt from such requests in some circumstances, which may include if we need to keep processing your Personal Information for our legitimate interests, to comply with a legal obligation, or if you are a resident of a country or state that does not provide the rights you have requested.
We may request that you provide us with information necessary to verify your identity before responding to your request as required or permitted by applicable law. Depending on your jurisdiction, you may be entitled to empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws.
If you consider that we have processed Personal Information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with a competent data protection authority. If you choose to exercise any of these rights, you will not be discriminated against or receive discriminatory treatment.
Marketing Communications. Client representatives and Website visitors may instruct us not to contact them by email, postal mail, or phone regarding products, services, and promotions that might appeal to their interests by following the unsubscribe instructions provided in the promotional email or by contacting us directly at the email address listed below. Individuals who opt out may continue to receive services-related and other non-marketing emails.
Client Consumers who would like to opt-out of receiving instagram Direct Message from our Clients using our Service need to exercise their rights with our Clients by, for example, unsubscribing from Client emails or by responding to Client text messages with any of the following replies: STOP. If you opt-out of receiving instagram direct messages from one of our Clients, you may continue to receive instagram direct messages from any other Clients’ instagram direct messages campaigns you have joined until you separately unsubscribe from those campaigns.
We may send periodic promotional messages to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email, or by contacting support@usedrop.io. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you non-promotional emails about your account or any services you have requested or received from us.
This Policy is current as of the Last Updated date set out above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please email us at support@usedrop.io or write to us at Creative Bot, Inc. d/b/a Drop, 1156 W 26th Street, San Pedro, CA90731.
