DThis Privacy Policy describes how Drafter Inc. (“Drafter”, “we”, “us” or “our”) processes personal information that we collect through our website (www.drafterinc.com) and any other digital and online properties or services that link to this Privacy Policy, and our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the “Service”).
Our websites, products, and services are designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.
This Privacy Policy does not apply to information that we process on behalf of our business customers while providing services to them. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of our business customer, please direct your concerns to the business customer with which you have a relationship.
NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).
Table of Contents
Personal information we collect
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, subscription fulfillment, customer support, online chat functionality, email delivery, marketing, consumer research and website/data analytics).
Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers to power certain aspects of the Services. To learn more about how those providers processes your information, please refer to their privacy policies.
Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above. This may include certain social networks where we use their ad services to display ads to our customers, or other people like them, on social media.
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account on the third-party service.
Sponsor partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financing of Drafter, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Drafter or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Your Profile data and User-generated content may be visible to other users of the Service and the public. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Once you publish content, it may be copied and stored on third party systems where you might not have the ability to have it deleted.
Your choices
Training data. As set out in the “How We Use Personal Information” section, we may use information collected in the Services to train or improve our AI models and for other machine learning purposes. This helps improve the Service and create new products and features. If you would like to opt out of our processing of your personal information, please contact us at
Shine the Light law opt-out. Under California’s Shine the Light law (California Civil Code Section 1798.83), we give you the right to opt-out of our disclosure of your personal information (as defined by this law) to third parties for their direct marketing purposes. You may send us requests to peter@drafterinc.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.
Retention period for personal information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information. Additionally, you should take care to keep your username and password private, as sharing that information could jeopardize the confidentiality of your content in the Service.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the information provided below about the transfer of personal information outside of Europe.
Children and teens
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.
How to contact us
If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.
Notice to European users
Where this Notice to European users applies. The information provided in this “Notice to European users” section applies to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy), as well as individuals who reside in jurisdictions with laws similar to European data protection laws that apply to your use of the Service and require the following disclosures, in each case solely to the extent required by local law. References to “Europe,” “Europeans,” and “GDPR” should be construed to include these additional jurisdictions, populations, and similar data protection laws.
Controller. Drafter Inc. is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called UK GDPR (as and where applicable, the “GDPR”)). See the “How to contact us” section above for our contact details.
Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information that identifies or can reasonably identify a natural person.
Our legal bases for processing. In respect of each of the purposes for which we use your personal information, applicable law requires us to ensure that we have a “legal basis” for that use.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see “How we use your personal information.”
Purpose
Categories of personal information involved
Legal basis
Service delivery and operations
Service personalization
Research and development
Direct marketing
Interest-based advertising
Service improvement and analytics
Compliance and protection
To create aggregated, de-identified and/or anonymized data
Data sharing in the context of corporate events
Further uses
No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. Where required to do so by law, we will notify you if this is the case at the time.
No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, information related to sex life or sexual orientation, trade union membership, or information pertaining to criminal convictions) when you communicate with us, such as IT or customer support communications. If you provide any sensitive information to the Service, you consent to our processing and use of such sensitive information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive information, you must not submit such sensitive information through our Services.
No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling that produces legal or similarly significant effects.
Exercising these rights. You may submit these requests by email to peter@drafterinc.com. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your right to lodge a complaint with your supervisory authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
Data processing outside of Europe or your home country
We are a U.S.-headquartered business and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.
It is important to note that that the U.S. is not the subject of an “adequacy decision” under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.
Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at peter@drafterinc.com.
