Globaldrum and GLOBALDRUM Limited ("We") are committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our mobile social platform and associated products (the Services) you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is GLOBALDRUM Limited of 84 Brook Street London W1K 5EH.

Our nominated representative for the purpose of the Act is Data Manager.

Information we may collect from you:

We may collect and process the following data about you:

• Your mobile phone number. We will never disclose your mobile phone number to any third parties other than as necessary for the provision of the services to you.
• Information you give us. You may choose to give us further information about you in the course of using the Services, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you use the Services, search for a product, place an order through the mobile social platform, participate in discussion boards or other social media functions, enter a competition, promotion or survey, and when you report a problem.
• Information we collect about you. With regard to your use of the Services we may automatically collect the following information:
• • technical information, including the Internet protocol (IP) address used to connect your device to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our mobile social platform (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Cookies Our Services uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you use the Services and also allows us to improve our mobile social platform. Dependent on your method of accessing the Services, the following cookies will be used for the purposes set out below:

Web	Cookie name	Duration	Purpose	Retained information
ASP.net cookies	cookiesShow	1 month	Acceptance of Cookie Policy.	Acceptance/Rejection
ASP.net cookies	phoneno	1 month	User request to remember phone number.	Phone number
ASP.net cookies	PIN	1 month	User request to remember PIN.	PIN
ASP.net cookies	IntroDontShowMe	1 month	User request not to repeat help facility.	User preference.
ASP.net cookies	IntroUserId	1 month	User request not wish to view an Introduction.	Unique Id number

Android	Name	Duration	Purpose	Retained information
File System	remember_me	Until cancelled by user	User request to remember phone number and PIN.	Phone number & PIN.
File System	phone_no	Until cancelled by user	User request to remember phone number.	Phone number
File System	pin	Until cancelled by user	User request to remember PIN.	PIN
File System	got_it_pref	Until a new user signs in on same device	User request not wish to view an Introduction.	User preference.

iPhone	Name	Duration	Purpose	Retained information
File System	dontShowUser	Until cancelled by user	User request to remember phone number.	Phone number
File System	dontPin	Until cancelled by user	User request to remember PIN.	PIN
File System	Helpshow	Until a new user signs in on same device	User request not wish to view an Introduction.	User preference.

Uses made of the information We use information held about you in the following ways:

• Information you give to us. We will use this information:
• • to authenticate you and enable your use of the Services
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the Services that you request from us;
  • to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
  • to notify you about changes to our service;
  • to ensure that content from our Services is presented in the most effective manner for you and for your computer.
• Information we collect about you. We will use this information:
• • to administer the Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our Services to ensure that content is presented in the most effective manner for you and for your user experience;
  • to allow you to participate in interactive features of the Services, when you choose to do so;
  • as part of our efforts to keep our Services safe and secure; and
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information We may share your information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may disclose information we hold to analytics and search engine providers that assist us in the improvement and optimisation of our Services. We may disclose your information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of GLOBALDRUM, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. GLOBALDRUM will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a PIN which enables you to access certain elements of the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our mobile social platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Your rights You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at data@global-drum.com. Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to data@global-drum.com or using the support facility within the App.