Effective: May 25th, 2018
Purpose and who we are
In general, we only collect information that allows us to provide you with our best Service. This includes, for example, simple tasks like allowing other users to see the name and picture you choose to show. It also helps us to keep our Service clear of fraud and spam, and it allows us to get a unique understanding of what additional services may be useful to you, and all other purposes set out in this policy below.
Age requirement (children’s privacy)
To use DROTR you must be at least 16 years old. If you are under 16 years of age, then please do not use or access DROTR or any other our Service at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 16 years of age that has been collected on our Service without verified parental consent upon learning of the existence of such Personally Identifiable Information.
Scope and Consent
Before you start using DROTR, it’s important you understand that by using the Service, you allow us to collect, use, disclose, and retain your personal information and other information but we will never read or listen to the content you are sharing privately. We will only use your information as described in this Policy.
Please note that we rely on legitimate interests as the basis for processing your data in the limited circumstances set out below:
In situations where we obtain your personal data from a source other than you, we process your data on the basis of legitimate interests, until the earlier of (a) the point at which you provide your consent; or (b) the point at which you ask us to stop processing your data on the basis of our legitimate interests;
We may retain your records for our own compliance and verification purposes (including where we are required to do so by law or by legitimate interest of our partners), even after you withdraw your consent to our processing of your data;
We will archive information about your use of our Service, even after you withdraw your consent to our processing of your data. This information will only be used in very limited circumstances, such as for defending legal claims relating to contracts we have with you or a third party and retention for audit purposes relating to commercial contracts; and
We will use information relating to your use of our services for statistical analysis and research purposes, however we delete your name, mobile number and email address from such information before we do so.
Information we collect
First of all, we would like to note that we do not read or listen to the content of your messages and/or calls made privately by means of DROTR and we do not store those messages once they have been delivered to their destination. If for some reason, the message, wasn’t delivered to its destination within up to 3 weeks, it will be deleted from our servers.
We must receive or collect some information to operate, provide, improve, understand, customize, support, and market our Service, including when you install, access, or use our Service. The types of information we receive and collect depend on how you use our Service.
We collect the minimum information required to achieve the purposes set out in this Policy (see below), and you have the ability to limit such collection, as specified below under “Additional Options”:
(i) Personally Identifiable Information provided directly by you: When you use our Service you voluntarily give us personal information (e.g., name, phone number, email, birth date, age, gender, country of living and the desired language for use) and therefore you are not anonymous to us. In addition, providing us with the indicated information you consent and agree that your name and photo (if you choose to provide them) will be visible to other DROTR users.
(ii) Personally Identifiable Information provided directly by third party sites: If you register for or sign in into your DROTR account through your email or social networking sites, you agree to give us with a continued access to all of your personal data listed on such a social network sites (e.g., your email address, birthday, country of residence, your friends list). We can receive certain information about you from social networking sites, depending on your settings on these sites.
(iii) Phone number data: When installing the DROTR application, you will also be asked to allow us access to the address book of your mobile device with the purpose to effect communication between you and your contacts. By doing so, you acknowledge that you have the right to provide us with such information.
(iv) Data on your activity: When using certain part of the Service, we may collect your data with regard to your presence or absence within DROTR network, receiving and viewing by you of messages sent to you by other users (including SMS-messages data routing) as well as information on calls (rooms interlocutors, time and date of calls, duration of calls, missed calls, etc.) received or made by you. With that, information on your presence or absence within DROTR network will be available to other users of DROTR while the information about receiving and viewing by you of messages will be available only to those users who sent the message.
We use the system of encrypting DROTR functions and tools and have limited access to any of your messages and other personal messages, your voice and video calls, information shared by you through your mobile device.
Aimed at improving the Service, except the above data on your activities, we will also collect the information on how you use DROTR’s functions and tools.
(v) Device data: TIW collects data on devices and networks used by the User to connect to DROTR (e.g. IP-address, URLs, operating system and browser software used, Internet Service Provider and the geographic location of his or her point of connectivity, device identifiers, language and regional settings, information about the software installed on your devices).
(vi) Data received from third parties: TIW may obtain data on the User from other persons, i.e. from the Users entitled to provide such data while making calls, sending messages and when they perform other DROTR-related activity; other organizations collaborating with TIW, including but not limited to, improvement, proper work, configuration, maintenance, analysis and advertising the Service.
(vii) Partner sites: If you use services of our partners who provide DROTR-related tools and services, then non-financial information on how you use these sites and/or services, as well as DROTR, can also be collected. To improve the services of DROTR and the sites and / or services of our partners, and to improve the quality of such services, we can share this information with partners (in particular, data on the time spent on the relevant site or application and on the pages viewed). At the same time, any transfer or exchange of information with our partners will be carried out exclusively in accordance with this Policy, as well as in compliance with applicable laws and regulations (including but not limited to GDPR).
How We Use the Information
We aim at constant improvement of our Service and offering you new opportunities. In this regard we can use the information provided by for the following purposes:
(i) Enabling DROTR and services: We use the Personally Identifiable Information provided by you with the aim to (i) register you in the DROTR application and create your DROTR user account; (ii) create your profile and make it visible; (iii) provide support, provide you with information about your user account, and respond to your requests; (iv) provide an individual approach by providing content (for example, information from other services) within the Service, including targeted advertisement of DROTR services and partner services, which we believe may be of most interest to you; (v) indicate which of your contacts is already using DROTR, and and notify you when your contacts become active on the Service; (vi) display the name of the contact from your address book when you receive a call in the DROTR application; and (vii) provide you with access to the Service and provide the requested information, products and services. If you deactivate your account in DROTR, this will result in the immediate deletion of your address book from our servers without the possibility of recovery (more on this below). In all other cases, we store information about your contacts while you use the Application to ensure the functionality of all its functions.
(ii) Technical support and security: We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of DROTR and our services.
(iii) Updates: We use Personally Identifiable Information collected when you sign-up to send you the messages in connection with the Service or news related to it. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
(v) Communications with our Business Partners, Advertising: We may share your Personally Identifiable Information with our business partners so that such partners may share information about their products and services that may be of interest to you where they are legally entitled to do so.
(vi) Disclosure of Information to TIW Group of Companies: We may provide the information we collect about you, including your Personally Identifiable Information, within the TIW group of companies, including our subsidiaries and affiliates for with the aim to provide our Services properly, the proper implementation of our obligations, as well as to comply with the requirements of the law.
(vii) Disclosure to application providers and other third parties: We have the right to disclose your information, including your Personally Identifiable Information, to service providers and other third parties under contract who help us providing you and to other users with our Service on our behalf, or other services provided by third parties through DROTR Services (including but not limited to investigation of fraud and spam activities, site analytics, provision of special partnerships opportunities with our Service - either without identification of users, or using a unique identifier, not tied to the identity of the user). This is necessary to protect the data they receive.
(viii) Disclosure to our Operations and Maintenance Contractors: We use various service providers, vendors and contractors (collectively, "Contractors") to assist us in providing our products and services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Service. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
(x) Disclosure to Acquirers: TIW may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of TIW to which your Personally Identifiable Information relates.
Unless otherwise specified, we retain information as long as it is necessary and relevant for us to achieve the purposes referred to above or to enable us to comply with our legal data protection retention obligations. Upon deactivation of your account or revoking your consent on processing your data, we will minimize the personal data we keep about you only to such data which we are required to keep to comply with laws, or other legal reasons. We may keep activity data on a non-identifiable basis to improve our services. Your posts on public accounts and communities may remain available if you do not delete them.
Confidentiality and Security of Data
Technical, organizational and other measures
TIW endeavor to ensure that the data disclosed by you are as secure as possible. To that end we constantly strive to improve and introduce new number of technical and organizational measures which protect your Personally Identifiable Information from unauthorized or unlawful processing and from unintentional loss, destruction or damage.
TIW aim at minimizing the processing of Personally Identifiable Information. We only process information which is indispensable or information which you provide us with your consent beyond the scope of the necessary processing.
When personal data are transferred to state administration bodies, we use the most suitable and the most secure options offered by the given body.
Exercise of your rights
Right to information
TIW respect the principle of transparency of personal data processing. In accordance with this principle we will provide information to you on the manner in which your personal data are processed.
If you wish to know in general which of your Personally Identifiable Information we process, you may submit your request via email@example.com and specify the Service name via of which the data is processed.
If you wish to find out concrete Personally Identifiable Information which are processed directly for you, you can submit your request via firstname.lastname@example.org and specify which concrete piece of information you require and the Service name, via of which the data is processed. The information to which you are entitled is described in Articles 13 and 14 of the GDPR. If you do not submit specific requirements, your request will be viewed as a general request under the previous paragraph.
We need to point out that if we are not able to verify your identity electronically or if there is reasonable doubt as to your identity, we may ask you to submit proof of identity at the office of TIW. Only in this way we can rule out the possibility that your Personally Identifiable Information are disclosed to a person who only pretends to be you.
Your request will be handled in as short time as possible. But keep in mind that often this is a very complicated process which may take several weeks.
Right to Accessing, Reviewing, and Rectification Your Personally Identifiable Information
As a registered member, you can access, review and change your Personally Identifiable Information and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the App and visiting your user account. Please be sure to update your personal information promptly if it changes or becomes inaccurate.
If you reside or are located in the EEA, you have the right to request that we:
If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via email@example.com.
In certain cases we cannot rectify your Personally Identifiable Information. This includes cases when your incorrect or outdated personal data are contained in documents which we have to archive by law.
Withdrawal of consent to personal data processing and right to be forgotten
If TIW process your Personally Identifiable Information on the basis of your consent with such processing, you can stop their further processing at any time. You only have to withdraw your consent to such processing.
You can also exercise your right to be forgotten. In such case TIW will destroy all your Personally Identifiable Information that we process. Exception is cases when the processing is performed on the basis of a statutory obligation or for a legitimate interest of TIW. Also in this case TIW may demand your identification before destroying the Personally Identifiable Information.
You may manage your communication, therefore, you may block any of your contacts you selected, so such users would not be able to contact you through DROTR. You may also skip your photo, as well as use other advanced settings that are available in the application. You may also set the permissions for the application on your device, for example, access to the list of contacts, etc.
From time to time, we can send you messages about the activities and operation of our Service (for example, changes in policies, technical issues, etc.). We may also send notifications about our or third parties offers, which in our opinion may be of interest to you. If you do not want to receive such notifications, you can unsubscribe them in the system settings or by writing to us at firstname.lastname@example.org.
Cookies and Tracking Technologies
Questions, Suggestions and Complaints
If you have any privacy-related questions, suggestions, unresolved problems, or complaints you may contact us via email@example.com.
If you reside or are located in the EEA, our Data Protection Officer and Privacy Team may assist with all queries regarding our processing of Personally Identifiable Information at firstname.lastname@example.org.
If you reside or are located in the EEA, you may also make a complaint to our supervisory body for data protection matters (namely the Czech Office for Personal Data Protection) or seek a remedy through local courts if you believe that your rights have been breached.
California Privacy Rights
Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).
To obtain this information, please send an email message to email@example.com with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
International Privacy Practices
DROTR Service is primarily operated and managed on servers located and operated within the Germany. In order to provide our products and services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including to Germany. Accordingly, if you reside or are located outside of Germany, your Personally Identifiable Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.
Updating personal data protection principles
TIW keep the personal data protection principles up-to-date and in compliance with applicable legal regulations. For this reason they may be changed from time to time. We ask all our users to pay due attention to these principles.
Representative in the EU
To comply with all its obligations arising under the GDPR TIW appoints as of 25 of May 2018 the Representative, who represents TIW in the EU with regard of data processing (Representative). The Representative’s task is to monitor compliance with the GDPR and in cooperation with the TIW’s employees the Representative is your contact in EU for your enquiries, comments, complaints and claims regarding personal data protection.
Representative contact data:
Technology Improves the World s.r.o.
Stodůlky, Nárožní 2787 / 7a, PSČ 158 00, Prague-5, Czech Republic
Enquiries, comments, complaints and claims relating to the protection of personal data may also be submitted via firstname.lastname@example.org.
In the event you read this policy in any language other than English, you agree that in the event of any discrepancies, the English version shall prevail.