Privacy Policy

Last updated Jul 21, 2022

Drive Inc.

Document Control

This document has been created by Naq Cyber and has been provided to Drive Inc. as part of their subscription to the Naq Cyber service. The contents of this document are strictly controlled by Naq Cyber to ensure accuracy and conformance to laws and regulations.

This document was prepared by Naq Cyber with the information provided to Naq Cyber by Drive Inc. at the time of production. It is the responsibility of Drive Inc. to ensure its accuracy and the implementation of this document into the organisation as a whole and each relevant business process. Drive Inc. trades as Sweep, Tradebid, and Nevo, and this policy pertains to processing activities carried out by each of those entities separately or as a whole. Where possible, this privacy policy will distinguish between the different entities.

Version History

Date	Version	Reason for change	Author
22/03/2022	1.0.0	Initial release	Naq

Privacy policy

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.

This privacy policy pertains to processing by Drive Inc. (trading as: Sweep; Tradebid and Nevo) by means other than through the use of cookies. We have formulated a separate cookie policy, which can be found on our websites:

Definitions

Party responsible for processing personal data: Drive Inc. with registered address at 17 Percy Place, Dublin, Ireland.
Data Protection Authority: The Data Protection Commission 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);
and/or the national laws of Ireland.

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:

Sweep

Identification information

Your full name
Your address and postcode
Your job title
Your company name
Your company address
Your business email
Your phone number

User information

Your IP address
Browser type
Operating system
Access times; and
Referring website addresses

TradeBid

Identification information

Your full name
Your address and postcode
Your job title
Your company name
Your company address
Your business email
Your phone number

Nevo

Identification information

Your full name
Your address and postcode
Your job title
Your company name
Your company address
Your business email
Your phone number

Purposes

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

To provide products and services that you have requested
To ensure that the content on our Website and web app is presented in the most effective manner for you and your computer
To enable you to use the interactive features of our Website and web app
To provide news and updates on our services
To develop and improve our products and services
For our internal record keeping
To contact you to answer any queries you may have
To contact you for market research or marketing purposes where you have given us permission to do so

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 and filling out the contact form on the website(s);
Logging into and using Sweep, Tradebid and Nevo;
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 and other entities in the group. 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 and the wider European Economic Area. 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.

Microsoft Office 365

What it's used for	Email provider, Document storage service, Office software
Part of the business process	Email, Digital storage of documents, Software tools and applications
Types of information shared	Identification, Financial, Date of birth, Location, Contracts, Business data, Technical data, Employment and educational history
Who the information is about	Employees, Contractors, Suppliers, Partners
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 minimised and regularly deleted according to national retention periods.
International data transfer?	Yes, Microsoft 365 retains the right to store and transfer data in and to the USA. This is based on Standard Contractual Clauses.

Mailchimp

What it's used for	Emailing for marketing purposes
Part of the business process	Marketing
Types of information shared	Identification
Who the information is about	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 minimised and regularly deleted according to national retention periods.
International data transfer?	Yes, Mailchimp retains the right to store and transfer data in and to the USA. This is based on Standard Contractual Clauses.

Sendgrid

What it's used for	Emailing for marketing purposes
Part of the business process	Marketing
Types of information shared	Identification
Who the information is about	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 minimised and regularly deleted according to national retention periods.
International data transfer?	Yes, Sendgrid retains the right to store and transfer data in and to the USA. This is based on Standard Contractual Clauses.

Stripe

What it's used for	Payment processing
Part of the business process	Administration
Types of information shared	Identification, Financial, Date of Birth, Location
Who the information is about	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 minimised and regularly deleted according to national retention periods.
International data transfer?	Yes, Stripe retains the right to store and transfer data in and to the USA. This is based on Standard Contractual Clauses.

Zoho

What it's used for	Password management
Part of the business process	Administration
Types of information shared	Identification
Who the information is about	Employees, Contractors, 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 minimised and regularly deleted according to national retention periods.
International data transfer?	Yes, Zoho retains the right to store and transfer data in and to the USA. This is based on Standard Contractual Clauses.

AWS

What it's used for	Website hosting
Part of the business process	Website
Types of information shared	Identification, Financial, Date of Birth, Location
Who the information is about	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 minimised and regularly deleted according to national retention periods.
International data transfer?	No

Github

What it's used for	Source Code Depository
Part of the business process	Administration
Types of information shared	Identification
Who the information is about	Employees, Contractors
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 minimised and regularly deleted according to national retention periods.
International data transfer?	Yes, Github retains the right to store and transfer data in and to the USA. This is based on Standard Contractual Clauses.

Heroku

What it's used for	Website hosting
Part of the business process	Website
Types of information shared	Identification, Location
Who the information is about	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 minimised and regularly deleted according to national retention periods.
International data transfer?	No

Google Analytics

What it's used for	Analytics
Part of the business process	Marketing
Types of information shared	Technical data
Who the information is about	Customers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention ofunauthorised 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 minimised and regularly deleted according to national retention periods.
International data transfer?	Yes, Google retains the right to store and transfer data in and to the USA. This is based on Standard Contractual Clauses.

Safeguards for international data transfers

Drive Inc. (trading as: Sweep; Tradebid and Nevo)’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.

Drive Inc. (trading as: Sweep; Tradebid and Nevo) relies on processing agreements with these sub-processors that include the model clauses (or “Standard Contractual Clauses”) which have been tested on the adequacy of its protection with regards to the specific sub-processing activities carried out in this particular subprocessing relationship.

Additional security measures are taken to safeguard the international data transfers:

Encryption;
Anonymisation;
Pseudonymisation where possible.

Where Pseudonymisation is used by this third-party processor, they ensure that the personal data can no longer be attributed to a specific data subject without the use of additional information.
This additional information is kept separately; and
Technical and organisational measures are taken to ensure that the personal data cannot be attributed to identifiable persons (encryption; database and data separation; access controls; and logging).

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 organisational 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.’s staff members are required to conduct themselves in a manner consistent with 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 authorised 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 the EEA, but it is possible that we might transfer personal data to countries outside of this area. We ensure that we comply with the GDPR when sending data overseas by relying on data processing agreements containing standard contractual clauses with our sub processors or by taking additional 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 his personal data, as well as the right to object to the processing and the right to data portability.

You can exercise these rights by contacting us at the following email address: hello@driveinc.ie. Each request must be accompanied by a copy of a valid ID, on which you put your signature and state the address where we can contact you. 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. (trading as: Sweep; Tradebid and Nevo). 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 unauthorised 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. (trading as: Sweep; Tradebid and Nevo) account, system or other data processing medium in accordance with the process described above.

Applicable law

These conditions are governed by the laws of England and Wales. The court in the district where the collector has its place of business has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.