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Privacy Policy

Last updated 17th November 2023

Drive Inc.

Introduction

Drive Inc respects the privacy of its customers, suppliers and partners. We have therefore formulated and implemented a policy on complete transparency regarding the processing of personal data, its purpose(s) and the possibilities to exercise your legal rights in the best possible way. For employees, we have formulated a separate privacy policy, available upon employment and upon request. Not Applicable

Definitions

Party responsible for processing personal data: Drive Inc; with registered address at 17 Percy Place, in Ireland; company registration number 652277 and Data Protection Officer Lyndon Leggate who can be reached at lleggate@driveinc.ie (the “Controller”).
Data Protection Authority: The Data Protection Authority of Ireland.
Data Protection laws:
- For European citizens or residents, the EU GDPR 2018; the EU e-privacy directive 2002 (soon to be replaced by the EU e-privacy regulation);
- For UK citizens or residents, the UK GDPR 2020 and the UK Data Protection Act 2018
- and the national laws of the countries where we operate.

Collection of data

Your personal data will be collected by Drive Inc. and its data processors.
Personal data means any information relating to an identified or identifiable natural person (‘data subject’).
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The types of personal data we may process:

Business process	Type	Data subject	Legal basis
Website	Financial, Identification, Location	Customers, Employees, Suppliers	Consent
Email	Business data, Contracts, Date of Birth, Educational and Employment History, Financial, Identification, Location, Software, Tools, and Applications, Technical data (e.g. source code)	Contractors, Customers, Employees, Partners, Suppliers	Legitimate interest
Storage and exchange of documents	Not applicable	Not applicable	Legitimate interest
Delivery of goods and services	Identification	Contractors	Performance of a contract
Financial and business administration	Business data, Contracts, Date of Birth, Educational and Employment History, Financial, Identification, Location, Software, Tools, and Applications, Technical data (e.g. source code)	Contractors, Customers, Employees, Partners, Suppliers	Legitimate interest
Marketing	Business data, Identification, Location, Software, Tools, and Applications, Technical data (e.g. source code)	Customers, Employees, Suppliers	Consent

Purposes

Drive Inc. processes personal data for one or more of the following purposes:

Customer, employee, contractor, partner or supplier management
Business and financial administration
Direct marketing
Delivery of goods or services
Work planning

How we collect, store or otherwise process your data:

The following business processes describe how we may collect, store or otherwise process the types of personal information set out in the table above:

Collection of cookies, subscription to newsletter or filling out the contact form on the website(s);
Analyse trends and profiles, for our legitimate interest to aim to enhance, modify, personalise and improve our services and communications for the benefit of our customers;
Process and respond to support requests, enquiries and complaints received from you through use of business email;
Provide services and products requested and/or purchased by you and to communicate with you about such services and/or products. We do this as necessary in order to carry out a contract with you and in accordance with our legitimate interest to operate a business;
Carry out administrative activities such as invoicing and collecting payments either locally on devices or using cloud-services;
Store and exchange personal information contained in documents through email and cloud-services;
Marketing and customer acquisition through email or using cloud-services.

Sharing data with third parties

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your Personal Data outside Ireland. If we do, you can expect a similar degree of protection in respect of your Personal Data.

We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.

We share your personal data with the following enterprise third parties. We also share your data with SME third parties, details of which are available upon request. You will be notified when we have engaged with a new third party recipient of your personal data.

Zoho

Function	Password management
Business process	Administration, Software, Tools, and Applications
Data categories	Identification
Data subjects	Contractors, Employees, Suppliers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

AWS

Function	Website Hosting
Business process	Production of content, Software, Tools, and Applications, Storage of Digital Documents, Website
Data categories	Financial, Identification
Data subjects	Customers, Employees
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Github

Function	Other Software Suite
Business process	Administration, Software, Tools, and Applications
Data categories	Identification
Data subjects	Contractors, Employees
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Heroku

Function	Website Hosting
Business process	Website
Data categories	Identification, Location
Data subjects	Customers, Suppliers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Google Analytics

Function	Marketing Tool
Business process	Administration, Marketing, Software, Tools, and Applications
Data categories	Software, Tools, and Applications, Technical data (e.g. source code)
Data subjects	Customers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Mailchimp

Function	Marketing Tool
Business process	Administration, Email, Marketing
Data categories	Identification, Location
Data subjects	Customers, Suppliers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Sendgrid

Function	Email Provider
Business process	Email
Data categories	Identification
Data subjects	Customers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Stripe

Function	Payment Processing
Business process	Administration, Software, Tools, and Applications
Data categories	Date of Birth, Financial, Identification, Location
Data subjects	Customers, Suppliers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Microsoft Office 365

Function	Document Storage Service, Email Provider, Office, Other Software Suite, User Management/Authentication
Business process	Administration, Email, Production of content, Software, Tools, and Applications, Storage of Digital Documents
Data categories	Financial, Business data, Technical data (e.g. source code), Software, Tools, and Applications, Date of Birth, Identification, Contracts, Location, Educational and Employment History
Data subjects	Contractors, Employees, Partners, Suppliers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Hubspot

Function	CRM
Business process	Administration, Email, Marketing
Data categories	Business data, Identification, Location
Data subjects	Customers, Employees
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

International data transfers

The third parties we have engaged for the abovementioned business process may transfer your personal information to outside of your jurisdiction. Drive Inc’s third party processors take all necessary measures to ensure the confidentiality, availability and integrity of personal data and to comply with the GDPR with regards to international data transfers. The international nature of its compliance certifications, as well as far-reaching technical security measures (including but not limited to encryption of the personal data, making the data illegible to an unauthorised recipient) are sufficient to ensure that the data subjects continue to benefit from the fundamental rights they are entitled to under the GDPR.

Where Drive Inc transfers data to third countries, it relies on the following legal grounds for international data transfers:

An Adequacy Decision in accordance with article 45 of the GDPR
In the absence of an Adequacy Decision, appropriate safeguards in the form of Standard Contractual Clauses or Binding Corporate Rules.

In the event that Drive Inc is reliant on Standard Contractual Clauses for the legality of its international data transfer, it ensures that the Processor or Subprocessor takes supplementary security measures to safeguard the international data transfer with one or more of the following measures:

Encryption;
Anonymisation;
Pseudonymisation.

Storage and protection of data

Your data is protected by Drive Inc and its processors in pursuance to all legal requirements set by the relevant data processing laws. Drive Inc has taken technical and organizational security measures to protect your data and requires its data processors to meet the same requirements. Drive Inc has signed processing agreements with its processors to ensure an adequate level of data protection.

The following security measures are taken by Drive Inc to protect your personal data in the course of the listed business processes:

Organisational security measures

Staff

Drive Inc staff members are required to conduct themselves in a manner consistent with Drive Inc’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. All staff members undergo appropriate background checks prior to hiring and sign a confidentiality agreement outlining their responsibility in protecting customer data.

We continuously train staff members on best security practices, including how to identify social hacks, phishing scams, and hackers.

Access controls

Drive Inc maintains your data privacy by allowing only authorized individuals access to information when it is critical to complete tasks for you. Drive Inc staff members will not process customer data without authorization.

Data hosting

As a rule, data is hosted within countries and areas that provide a substantially similar level of protection as data subjects have under the GDPR. To ensure this, we rely on Adequacy Decisions as a legal basis for our international data transfers. In exceptional circumstances, where data is transferred to a country or area not subject to an Adequacy Decision, we rely on Standard Contractual Clauses with the recipient and take supplementary security measures to secure this data transfer, such as anonymisation.

Physical security

The data centres on which personal data is hosted are secured and monitored 24/7 and physical access to facilities is strictly limited to select staff.

Technical security measures

All devices which are used to access personal data for which we are responsible are secured with antivirus software, firewalls, encryption and access management. We regularly update operating systems and software to ensure vulnerabilities cannot be exploited.

We carry out regular vulnerability scanning of our website and have engaged credentialed external auditors to verify the adequacy of our security and privacy measures.

Your rights regarding information

Each data subject has the right to information on and access to, and rectification, erasure and restriction of processing of their personal data, as well as the right to object to the processing and the right to data portability.You also have the right to request that you are not made subject to decision making based solely on automated processes, including profiling, if these decisions would have a significant effect on you.

You can exercise these rights by contacting us at the following email address: hello@driveinc.ie. If we have any doubts as to your identity, we may request you to provide us with proof of identification, such as through sending us a copy of your valid ID. Ensure that you write “Data Request” in the subject line of your email.

Within one month of the submitted request, you will receive an answer from us. We will not charge you for submitting your request unless the request is manifestly unfounded or otherwise unreasonable in its nature. Depending on the complexity and the number of the requests this period may be extended to two months.

Marketing

You may receive commercial offers from Drive Inc. If you do not wish to receive them (anymore), please send us an email to the following address: hello@driveinc.ie and ensure that you write “Data Opt-Out” in the subject line of your email.
Your personal data will not be used by our partners for commercial purposes.
If you encounter any personal data from other data subjects while visiting our website, you are to refrain from collection, any unauthorized use or any other act that constitutes an infringement of the privacy of the data subject(s) in question. The collector is not responsible in these circumstances.

Data retention

The collected data are used and retained for the duration determined by law. You may, at any time, request your data to be deleted from any Drive Inc account, system or other data processing medium in accordance with the process described above.

Applicable law

These conditions are governed by the laws and regulations of the country where we are headquartered. The court in the district where we are headquartered has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.

Children's Data

We do not knowingly process children's data, unless specifically stated in this Privacy Policy. If you have concerns about or knowledge of a child using our services, products, websites or apps without parental consent, please contact our DPO via lleggate@driveinc.ie to ensure we can take appropriate action as soon as possible.

Contact

For questions about this privacy policy, product information or information about the website itself, please contact: hello@driveinc.ie.

International data transfers

AWS

Third party headquarter address	410 Terry Ave. North, Seattle, WA, 98109-5210, United States of America
The primary location of processing is the United States of America.	Personal data collected by AWS may be stored and processed in any country where AWS or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see AWS’s Privacy Policy	https://aws.amazon.com/privacy/

Github

Third party headquarter address	88 Colin P. Kelly Jr. Street, San Francisco, CA 94107, United States of America
The primary location of processing is the United States of America.	Personal data collected by Github may be stored and processed in any country where Github or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Github’s Privacy Policy	https://docs.github.com/en/github/site-policy/github- privacy-statement

Heroku

Third party headquarter address	Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, United States of America
The primary location of processing is the United States of America.	Personal data collected by Heroku may be stored and processed in any country where Heroku or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Heroku’s Privacy Policy	https://www.salesforce.com/company/privacy/full_privacy/

Google Analytics

Third party headquarter address	1601 Amphitheatre Parkway, Mountain View, CA 94043, United States of America
The primary location of processing is the United States of America.	Personal data collected by Google Analytics may be stored and processed in any country where Google Analytics or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Google Analytics’s Privacy Policy	www.google.com/policies/privacy/partners/

Mailchimp

Third party headquarter address	675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, United States of America
The primary location of processing is the United States of America.	Personal data collected by Mailchimp may be stored and processed in any country where Mailchimp or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Mailchimp’s Privacy Policy	https://www.intuit.com/privacy/statement/

Sendgrid

Third party headquarter address	1801 California St #500, Denver, United States of America
The primary location of processing is the United States of America.	Personal data collected by Sendgrid may be stored and processed in any country where Sendgrid or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Sendgrid’s Privacy Policy	https://www.twilio.com/legal/privacy

Stripe

Third party headquarter address	510 Townsend Street San Francisco, CA 94103, United States of America
The primary location of processing is the United States of America.	Personal data collected by Stripe may be stored and processed in any country where Stripe or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Stripe’s Privacy Policy	ttps://stripe.com/en-gb-nl/privacy

Microsoft Office 365

Third party headquarter address	1 Microsoft Way, Redmond, WA 98052-6399, United States of America
The primary location of processing is the United States of America.	Personal data collected by Microsoft Office 365 may be stored and processed in any country where Microsoft Office 365 or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Microsoft Office 365’s Privacy Policy	https://privacy.microsoft.com/en-ca/privacystatement

Hubspot

Third party headquarter address	2 Canal Park, Cambridge, MA 02141, United States of America
The primary location of processing is the United States of America.	Personal data collected by Hubspot may be stored and processed in any country where Hubspot or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and United States of America
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible
For more information, see Hubspot’s Privacy Policy	https://legal.hubspot.com/privacy-policy

PAVE

Country where data is processed or sent to	Canada
Safeguards (art. 45 GDPR)	Adequacy decision exists between European Union and Canada
Additional safeguards	Encryption, Anonymisation where possible, Pseudonymisation where possible

Privacy Policy

Drive Inc.

Introduction

Definitions

Collection of data

The types of personal data we may process:

Purposes

How we collect, store or otherwise process your data:

Sharing data with third parties

Zoho

AWS

Github

Heroku

Google Analytics

Mailchimp

Sendgrid

Stripe

Microsoft Office 365

Hubspot

International data transfers

Storage and protection of data

Organisational security measures

Staff

Access controls

Data hosting

Physical security

Technical security measures

Your rights regarding information

Marketing

Data retention

Applicable law

Children's Data

Contact

International data transfers

AWS

Github

Heroku

Google Analytics

Mailchimp

Sendgrid

Stripe

Microsoft Office 365

Hubspot

PAVE

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