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This Privacy Policy applies when you interact with us through bromos.app, our mobile apps, and/or through any other feature or service owned or controlled by Dromos App Corp., ("Bromos", "we", or "us") that posts, links to, or references this Privacy Policy (collectively, the "Service(s)"). This Privacy Policy informs you of our practices regarding the collection, use, and disclosure of personal information we receive from users of our Services. By accessing or using the Services, you consent to our Privacy Policy and our collection, use, and disclosure of your information as described in this policy, our Terms of Use, and any additional policies and terms you may agree to in connection with the Services.
We and our third-party service providers and business partners may collect information from you directly and/or automatically when you visit the Site or use the Services. We and our third-party service providers may also collect information about you from third parties. Some of this information may be considered "personal information" or "personal data" under applicable laws (collectively, "personal information"). We consider information that identifies you as a specific, identified individual (such as your name, phone number, and email address) to be personal information. We also, where required by applicable law, consider additional types of identifying data, like IP addresses and cookie identifiers, to be personal information.
We may, in accordance with applicable law, take your personal information and de-identify or pseudonymize it to make it non-personally identifiable, either by combining it with information about other individuals and/or by hashing the information or otherwise removing characteristics that make the information personally identifiable. We maintain and use de-identified or pseudonymized data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified, or pseudonymized information, as non-personal to the fullest extent allowed by applicable law.
We may collect the following categories of personal information from or about you:
Identifiers and Contact Information. This category includes names, addresses, telephone numbers, mobile numbers, email addresses, signatures, account names, dates of birth, bank account information, and other similar contact information and identifiers.
Commercial Information. This category includes, without limitation, products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or Other Electronic Network Activity Information. This category includes, without limitation, browsing history, search history, or a consumer's interactions with a website, application, or advertisement.
Geolocation Data. This category includes, without limitation, location information collected when using our Services.
Sensitive Personal Information/Sensitive Personal Data. This category includes:
NOTE: Please do not provide us "sensitive personal information" or "sensitive personal data", as those terms are defined under applicable privacy laws, unless we directly request that you do so. If you feel, after careful consideration, that it is necessary to provide us certain sensitive personal information or data, please provide us the minimum amount of such information or data that is necessary.
We may ask you to provide certain personal information when you use the Services. This information may include contact information (such as your name and email), account information (such as your email address and, if you choose to log in through Google or Apple, the associated user ID and email address), transaction information (such as your billing address and mailing address), or user content you choose to upload (such as photos, task lists, journal notes, and health information). Note that all payments are handled by our third-party payment providers who may collect relevant information in order to complete your transaction (such as your payment card, billing address, and phone number).
Our current providers are Stripe. We encourage you to review their respective privacy policies for additional information regarding their privacy practices.
We may also ask you to provide the contact information of another individual, such as when you invite another user to the Services. By providing us this information, you represent to us that you do so with the consent of the individual to whom it relates. We will only use this information for the specific reason for which it was provided.
We and third-party companies and business partners may use a variety of technologies, including, without limitation, cookies, pixels, embedded scripts, and session events (collectively, "cookies") that automatically or passively collect certain information whenever you visit our Site, use our Services, or otherwise interact with us or our content ("Usage Information"). Usage Information may include the hardware model, browser, and operating system you are using, the URL or advertisement that referred you to the Site you are visiting or Service you are using, all of the areas within the Site that you visit or Services that you use, your time zone, non-precise location information, and mobile network (if applicable), among other information. In addition, we automatically collect your IP address or other unique identifier ("Device Identifier") for any computer, mobile phone or other device you use to access our Services. In some cases, we may directly collect location information through your device. You may be able to turn off the collection of location information through the settings on your device. Usage Information is generally non-identifying, but if Bromos associates it with you as a specific and identifiable person, Bromos treats it as personal information.
Types of Cookies
The Site uses essential, functional, and performance cookies to function and perform as designed; analytics cookies to understand how you use the Site, improve its functionality, and other related purposes; and advertising cookies to help us with our advertising and marketing activities. We and our third-party partners and service providers may collect and track information about your online activities over time and across different websites, applications, and devices.
We use Google Analytics, a service which uses cookies to collect and analyze data about the use of the Services and report on activities and trends. This service may also collect data about the use of other websites, apps, and online services. You can learn about Google's practices, and opt out of them, by downloading the Google Analytics opt-out browser add-on.
You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a site. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work.
IMPORTANT: BY USING THE SITE, YOU CONSENT TO THE PROCESSING OF ANY PERSONAL INFORMATION FOR THE PURPOSES AND FUNCTIONS DESCRIBED ABOVE.
"Do Not Track" is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user's computer, we are unable to respond to Do Not Track requests.
We do not collect your precise location. However, please note that we may still be able to collect or infer your approximate location through other information we collect, such as IP address. In addition, some mobile service providers may also provide us or our third-party service providers with information regarding the non-precise physical location of the device you use to access our Services.
We may receive information about you from third parties. For example, you may have the opportunity to log in through or otherwise connect your Apple and Google accounts. Additionally, when you interact with us through social media, you will be choosing to share information about your interactions with Bromos with that social media service.
We collect categories of personal information including Contact Information, User Account Information, Demographic Information, Device ID/Interaction Information, Transaction Information, Information about your Interests and Preferences, and Photo/Video Data and Other User Generated Content. We collect this information for purposes including: providing you the Service; advertising activities and marketing messages; personalization; administrative purposes; internal business purposes; security; legal compliance; business transitions; and other purposes as disclosed at the time of collection. We may disclose this information to categories of third parties including analytics partners, social media platforms, business partners, order fulfillment vendors (such as payment processors), technology systems service providers, security vendors, communications service providers, customer service providers, government agencies and law enforcement, and other service providers we engage. With the exception of Contact Information and Device ID/Interaction Information, which may be sold/shared with Analytics Partners for targeted advertising, the remaining categories are not sold or shared for targeted advertising.
We may use non-personal information for any purpose, including for research and marketing purposes. We also use information that we collect, including personal information and Usage Information, as disclosed in this Privacy Policy and as follows:
We may also use your personal information for any other purpose disclosed to you at the time of collection, with your consent (where required by applicable law), or permitted by applicable law.
Our service providers may collect information on our behalf and at our direction, in order to provide Services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these Services to us and for other purposes permitted by applicable law.
Our Service Providers include, without limitation:
We may offer sweepstakes, contests, or other promotions (collectively, "Promotion(s)") that may require registration. By participating in a Promotion, you agree to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to co-promotion partners, third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion's terms or official rules.
Bromos maintains commercially reasonable administrative, physical, and technical safeguards that are designed to secure your personal information; however, no data transmission over the Internet, wireless transmission, or electronic storage of data can be guaranteed to be 100% secure. Bromos cannot ensure or warrant the security of any data we collect. You use the Services and provide us your data at your own risk.
We retain your personal information for as long as necessary to provide you Services and in accordance with our data retention schedule. We may retain your personal information for longer if it is necessary to comply with our legal or reporting obligations, resolve disputes, enforce contracts, or address other legitimate business needs, or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors, such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use, or disclosure; the purposes for which we collect or process your personal information; and applicable legal requirements.
The Service is intended for users 18 years or older; you are not permitted to access or use the Service if you are younger than 18. We do not knowingly collect personal information from children under the age of 18 through the Service. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us at jorge@dromos.io, and we will delete that information from our databases.
Bromos is based in the United States. Please be aware that information we collect will be transferred to and processed in the United States and other countries. Bromos makes no representation that this Privacy Policy or the practices described in it comply with the laws of any other jurisdiction. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions for which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to laws in those jurisdictions.
Edit Your Information: On the website, you can update the information in your user profile at any time by going to the user icon in the upper right, selecting the "Profile" option, then clicking "Edit Profile". You can update your username and email address by going to the user icon in the upper right and selecting the "Settings" option. If you are using the mobile app, you can update your user profile, username, and email by tapping the Settings gear in the menu and then selecting the "My Account" option.
Reset Your Account: You can fully delete or reset your account by selecting the user icon in the upper right, selecting the "Settings", and then looking under "General Settings". You can fully delete or reset your account on the mobile apps by tapping the Settings gear in the menu and then selecting the "My Account" submenu. Please note that in order to fully delete all data associated with your account, you will need to email us at jorge@dromos.io. Note that we may be required to retain certain data about you to comply with applicable laws.
Newsletter: You may also sign-up to receive our email newsletter. If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in emails we send to you, or by contacting us. Please note that we reserve the right to send you certain communications relating to your account or use of the Services, such as administrative and services announcements. These transactional account messages may be unaffected if you choose to opt out from marketing emails.
Push Notifications: With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can elect to stop receiving those messages by changing the notification settings in the app or on your mobile device.
Other Privacy Rights: Certain jurisdictions provide additional rights. Please see the "Jurisdiction-Specific Rights" section below for more information.
To the extent permitted by applicable law, we reserve the right to change or modify this Privacy Policy at our discretion at any time. We will notify you of any material changes by posting the changed or modified Privacy Policy on our Services. We may also provide notice to you in other ways, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Services after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will, to the fullest extent permitted by applicable law, constitute your consent to those changes. However, we will provide notice and obtain your consent (opt-in or opt-out) if required by law. We encourage you to regularly review this Privacy Policy for the latest information on our privacy practices.
This section applies only to California, Nebraska, and Texas residents. It supplements and amends the information contained in the Policy with respect to such individuals. The other provisions of the Policy continue to apply, except as modified in this section.
Shine the Light [California residents only]. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties' direct marketing purposes. Such requests must be submitted to us in accordance with the instructions in the Contact Us section of this Policy. Please mention when contacting us that you are making a "California Shine the Light" inquiry. Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than in accordance with the instructions specified in this paragraph.
Eraser Law [California residents only]. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California law permits you to request and obtain removal of content or information you have publicly posted. You may submit your request using the contact information at the end of this Policy. Please be aware that such request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
You may have certain rights related to your personal information, subject to certain exceptions (including, as applicable and without limitation, safety, security, and protecting the rights of other users). Specifically:
Submitting Data Subject Rights Requests. To submit a data subject rights request, please email us at jorge@dromos.io. We reserve the right to only respond to verifiable requests. To verify your identity, we may ask you to verify personal information we already have on file for you. You may authorize another person to act on your behalf with respect to your rights under this section. We reserve the right to deny requests from persons claiming to be authorized agents that do not submit sufficient proof of their authorization.
Our Response. You may have the right, subject to applicable law, to submit up to two (2) requests per year free of charge. We will endeavor to respond to verifiable requests within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by email.
Appeal of Our Response. In the event you believe we have erroneously denied your request, in full or in part, you may, within 60 days of receipt of that denial, submit an appeal to jorge@dromos.io. Within 60 days of receipt of your appeal, we will advise you in writing of any action we have taken, or refrained from taking, in response to your appeal, along with an explanation.
Nevada residents may opt out of the sale of certain "covered information" collected by operators of websites or online services. We currently do not sell covered information, as "sale" is defined by such law, and do not have plans to do so. In accordance with Nevada law, you may submit to us a verified request instructing us not to sell your covered information by sending an email to jorge@dromos.io.
If you are a resident of the United Kingdom (UK), European Economic Area (EEA), or of Switzerland, the following information applies.
Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon your use of our Services. We process personal information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide the Services; (3) compliance with our legal obligations; and (4) as necessary for our legitimate interests in providing the Service where those interests do not override your fundamental rights and freedoms related to data privacy such as for: preventing fraud; ensuring network and information security; supporting internal administration; improving and developing the Services; and conducting data analytics analyses to review and better understand consumer interaction.
Right to lodge a complaint: Users that reside in the UK, EEA, or Switzerland have the right to seek information and assistance or lodge a complaint about our data collection and processing actions with the supervisory authority where they reside. Contact details for data protection authorities are available here. UK: https://ico.org.uk/ EEA: https://edpb.europa.eu/about-edpb/board/members_en Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.
Your rights as a UK/EEA/Switzerland resident also include: withdrawing consent at any time; access to personal information we collected; correction of inaccurate or incomplete information; erasure of data we have collected from you; portability of your personal information; restriction of processing in certain circumstances; and objection to our processing where it is based on legitimate interests, direct marketing, or scientific/historical research and statistics. We must verify your identity for everyone's protection, so we may require you to provide us with verification information prior to accessing any records containing personal information about you. We will use the information you provide for verification only for the purpose of verification.
If you have any questions or concerns about this Privacy Policy, please contact us at jorge@dromos.io with "Privacy Policy" in the subject line.