1. Scope of This Privacy Notice
“Personal Data” refers to information that identifies you as an individual or relates to an identifiable individual. This Privacy Notice explains how we collect, use, and process Personal Data in connection with the Services outlined below.
This Notice applies to Personal Data collected through the following channels (collectively, the “Services”):
- Websites operated by us that link to this Privacy Notice (“Websites”);
- Software applications, platforms, and technologies provided by us for use on computers and mobile devices (“Apps”);
- Our social media pages that reference this Privacy Notice (“Social Media Pages”);
- Email messages and other communications sent by us that include a link to this Privacy Notice;
- Interactions with our customer service teams or communications initiated by you;
- Visits to our facilities or our visits to your offices;
- Other online and offline business engagements, including discussions of potential transactions, participation in programs or activities, and data shared at industry events, conferences, seminars, trade shows, or other networking and marketing functions hosted by us.
2. Exclusions
This Privacy Notice does not apply to:
- Personal Data processed for recruitment, hiring, or onboarding purposes. Such data is governed by our separate Recruitment Privacy Statement.
- Personal Data processed in connection with cloud applications or technology services provided under a separate agreement between DRAAS Command and your organization. For such services, please refer to our Enterprise Services Documentation.
3. Collection and Use of Personal Data
We collect Personal Data through our Services and other authorized sources. Certain Personal Data is necessary for us to deliver the Services you request. If you choose not to provide required information, we may be unable to fulfill those Services.
If you provide Personal Data about another individual, you confirm that you have the authority to do so and authorize us to process that Personal Data in accordance with this Privacy Notice.
4. Personal Data You Provide to Us
4.1 Categories of Personal Data
Name & Contact Details
First and last name, title, prefix, email address, telephone number, postal address, date of birth, gender, country of residence.
Business Contact Details
Company name, business email, business telephone number, business address, country of operations.
Account Information
Username, password, authentication credentials, and internal identifiers.
Billing Information
Payment card details, bank account information, billing address.
Preferences
Language settings, areas of interest, user preferences, submitted feedback.
Marketing Data
Newsletter preferences, promotional content preferences, survey responses.
Relationship History
Communications, inquiries, complaints, claims, and correspondence history.
Transaction Information
Contract details, purchase histories, billing records, subscription usage.
Due Diligence Information
Credit verification, compliance screening, sanctions assessments.
Visitor & Event Information
Dietary restrictions, travel details, accommodation data, event credentials.
User Photographs & Videos
Images, videos, and content submitted while using our Services.
Phone Call Recordings
Audio recordings of calls with support or service teams.
User Content
Chat messages, blog posts, webcam sessions, and other shared account data.
Interaction Data
Technical and device data, configuration settings, logs, IP address, diagnostics.
Learning History
Training program participation, progress tracking, and feedback.
5. Personal Data Collected Automatically or from Other Sources
Social Media Information
Profile images, identifiers, and other public profile attributes.
Event Photographs & Videos
Images or recordings captured at events hosted or attended by us.
CCTV & Site Security Data
Visual footage recorded at DRAAS Command facilities.
Device Information
Device identifiers, browser type, usage patterns, and cookie data (see Cookie Policy).
6. Security
We implement reasonable organizational, technical, and administrative safeguards to protect Personal Data. No method of transmission or storage is completely secure. If you believe your interaction with us may no longer be secure, please notify us immediately using the contact information provided under “Contacting Us.”
7. Third-Party Disclosures and Processing Purposes
We may share Personal Data with affiliates, service providers, and other authorized entities for the following purposes:
7.1 Operational and Service Delivery
- Enabling core functionality
- Website and application hosting
- Account and credential management
- Payment processing and billing
- Order fulfillment and returns
- Communication delivery
- Customer service and support
- Event and conference facilitation
- Relationship management
7.2 Technology and Infrastructure
- IT system maintenance and improvements
- Supporting web and mobile platforms
- Monitoring diagnostics and performance
- Product and service innovation
7.3 Marketing and Personalization
- Managing newsletters and promotional content
- Personalizing user experience
- Advertising and social campaigns
- Facilitating social interactions
7.4 Analytics and Data Management
- Aggregating/anonymizing Personal Data
- Usage and performance analytics
- Learning program support
7.5 Legal, Compliance, and Risk Management
- Fraud prevention and security
- Regulatory compliance
- Response to law enforcement requests
- Audit, investigation, and whistleblower processes
- Health and safety obligations
7.6 Affiliates and Strategic Transactions
- Sharing data with corporate affiliates
- Mergers, acquisitions, reorganizations, or asset transfers
- User notifications in accordance with applicable law
8. Legal and Regulatory Disclosures
We may disclose Personal Data when required or permitted by law, including:
- Court orders and civil proceedings
- Criminal investigations
- Consumer protection regulations
- Corporate and tax compliance
- Engagement with data protection authorities
- Internal investigations and whistleblower laws
- Health and safety reporting
- Protection of rights, property, or safety
9. Sensitive Personal Data
Unless explicitly requested, please do not submit sensitive Personal Data, including:
- Social security numbers
- Racial or ethnic origin
- Political, religious, or philosophical beliefs
- Health or medical data
- Biometric or genetic data
- Criminal history
- Trade union membership
10. Cookies
10.1 Overview
We use various technologies to collect and store information, including cookies, local storage
(such as browser web storage or application data caches), databases, and server logs
(collectively, for purposes of this section, “cookies”). Cookies are small bits of data cached
or stored on your computer or mobile device based on your Internet activity. We may use cookies
to improve the Services and provide features tailored to your needs.
This section describes how we use cookies and how you can manage cookies that are not required
to operate our sites and mobile applications.
10.2 Types of Cookies We Use
Essential Cookies
These cookies are necessary for the Services to function and enable you to move around and use
essential features. Without these cookies, the Services may not perform properly, and certain
features may not be available.
Examples include:
- Determining when you are signed in;
- Detecting when your account is inactive;
- Supporting troubleshooting and security functions.
Analytics Cookies
Analytics cookies help us understand how many visitors access our Services, how often they
visit, and how users interact with specific pages.
These cookies allow us to gather information such as pages visited and repeat usage but
do not identify you personally (for example, we cannot determine your
name or address from analytics cookies).
10.3 Managing Cookies
Depending on your browser or device, you may be able to:
- Modify cookie settings;
- Delete existing cookies;
- Block or restrict certain types of cookies;
- Receive alerts when cookies are being placed.
Please note that disabling essential cookies may affect the functionality of the Services.
11. Updates to This Privacy Notice
The “Last Updated” date above reflects the most recent revision. Changes will take effect upon publication of the revised Privacy Notice on our Services.
