Last updated:  May, 2013

Drumbi, Inc. (“Drumbi”) owns or has rights to the Drumbi application available at various websites.  Drumbi is dedicated to building and maintaining goodwill with our customers and we are committed to implementing measures designed to protect the privacy of those using our services.  Moreover, we see it as our responsibility to help set an example and establish high standards for privacy on the Internet.

Although Drumbi respects the privacy of all those who visit our website and use our online services, we do collect information from our members and visitors.  This Privacy Policy governs your interaction with the Drumbi website and application, and your registration for and use of the Drumbi’s application and other services provided by Drumbi.  Except as set forth within this Privacy Policy and our Terms of Service and other published guidelines, we do not release personally identifiable information about out members and visitors without their permission.

Please note that Drumbi reviews its privacy practices from time to time, and that those practices are, therefore, subject to change.  We ask that you bookmark and periodically review this page to ensure continuing familiarity with the most current version of our Privacy Policy.To contact Drumbi about privacy issues, to report a violation of our Privacy Policy or to raise any other issue, please e-mail us at [email protected].

1.         The Information We Gather.  Drumbi gathers two types of information about users:

            (a)        Non-personally identifiable information: When visitors come to our web site or use the Drumbi application, we collect and aggregate information indicating, among other things, which pages of the website were visited, the order in which they were visited and which hyperlinks were “clicked.”  Collecting such information involves the logging of the IP addresses, operating system and browser software used by each visitor.  Although such information is not personally identifiable, we can determine from an IP address a visitor’s Internet Service Provider and the geographic location of his or her point of connectivity.

We also use “cookies” — that is, small text files placed on a user’s computer hard drive — to help us determine the type of content and sites to which a visitor to the Drumbi site or application links, the length of time each visitor spends at any particular area of the Drumbi site or app and the Drumbi services visitors choose to use.  Cookies also tell us which advertising a visitor has seen.  Essentially, cookies are a visitor’s identification card for the Drumbi computers, or servers, that placed them there. Cookies are only read by the server that placed them, and are unable to execute any code or virus.  Cookies allow Drumbi to serve you better and more efficiently, and to personalize your experience at Drumbi’s web site.  Nevertheless, you should be able to control how and whether cookies will be accepted by your web browser.  For more information on how to do so, please refer to the documentation accompanying your browser.

When you access the Drumbi site or application, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Drumbi may present links in a format that enables us to keep track of whether these links have been followed.  We use this information to improve the quality of our technology, customized content and advertising.

Additionally, Drumbi collects information from its mobile phone users (who have installed the Drumbi application or a business application which utilizes Drumbi technology) in a similar manner to optimize your experience using the mobile application. Beyond mobile phone numbers, we collect mobile screen resolution, device make and manufacturer, as well as the device’s unique identifier (in the iPhone’s case, a UDID). 

            (b)        Personally identifiable information: In certain areas of the Drumbi website or application – for example, when registering to become an Drumbi member – we require that you provide us with personally identifiable information (including, for example, first name, surname, street address, email address, telephone number and, when applicable, credit card information). 

When you send email or other communications to Drumbi, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.

Drumbi may make available third party applications through its services.  The information collected by Drumbi when you enable a gadget or other application is processed under this Privacy Policy.Information collected by the application or gadget provider is governed by their privacy policies.

We do not knowingly collect personally identifiable information from children (defined herein as minors younger than eighteen years of age) without obtaining parental consent.  Before registering for membership with Drumbi, we ask that children have their parents read our Privacy Policy.  Before and during the registration process, we encourage children to include a parent or guardian in the process.

2.         How We Use (and Do Not Use) the Information We Gather.  Please take some time to familiarize yourself with the different ways Drumbi uses the information that it gathers.  Keep in mind that, while Drumbi encourages all third parties involved – including but not limited to its affiliates and advertisers – to adhere to our policies regarding the privacy of our visitors and members and to otherwise handle personal information in a responsible manner, we cannot and do not assume any responsibility for any actions or omissions of third parties, including the manner in which they use information received either from Drumbi or independently.  Nevertheless, in the event that you encounter any third party associated with, or who claims association with, Drumbi who you feel is improperly collecting or using information about you, please contact [email protected]; we will be happy to forward your message to the third party.

            (a)        Non-personally identifiable information: Drumbi uses non-personally identifiable information in aggregate form to build higher quality, more useful online and mobile services by performing statistical analyses of the collective characteristics and behavior of our members and visitors, and by measuring demographics and interests regarding specific areas of the Drumbi web site.  We provide statistical information based on this data to advertisers, affiliates and other current and potential business partners.  We also use the aggregate data to inform these third parties as to the number of people who have seen and clicked on links to their web sites.

The Drumbi website and applications contains links to other Internet websites, including co-branded or other affiliated sites which may or may not be owned or operated by Drumbi.  Unless otherwise explicitly stated, we are not responsible for the privacy practices or the content of such websites, including such sites’ use of any information (such as IP number, browser type or operating system) collected when visitors to the Drumbi website and application click through links to those sites.  Even though such information might not identify you personally, we strongly encourage you to become familiar with the privacy practices of those sites.

            (b)        Personally identifiable information:   In certain instances requiring user registration, Drumbi provides notice to potential Drumbi registrants that personally identifiable information will be collected during the registration process.Such notice is provided simultaneously with your Drumbi registration; moreover, this Privacy Policy itself serves as notice that such information is collected under those circumstances.Although you may not “opt out” of the registration process if you wish to become a Drumbi member, you may choose to “opt out” of receiving promotional materials from Drumbi and/or its affiliates, advertisers or other business partners.  If you do not “opt out” of receiving such promotional materials, Drumbi reserves the right to release any personally identifiable registration information regarding you to third parties who provide goods or services that we believe may be of interest to you.  We will not release your credit card information to third parties unless necessary to complete a transaction between you and such a third party.  If you decide that you would like to discontinue receiving promotional information from such third parties, please contact those third parties directly, or contact Drumbi at [email protected].

Drumbi limits its own e-mail solicitations to those customers who have not “opted out” of receiving such communications.  The solicitations are limited in that they, among other things, will clearly indicate the originator of the e-mail and provide the customer with a method of “opting out” of receiving future communications of a similar nature.

In addition, Drumbi sometimes uses individual data to “target” advertising — to decide which advertisements and sponsor messages to show to which members.

Finally, Drumbi may use individual members’ data to “pre-populate” forms which are displayed for the purpose of collecting individual data by Drumbi and/or its sponsors.  In no case does pre-populating a form automatically transfer any data to any advertiser or third party.  Only if the member voluntarily requests that such data be transferred will any transfer take place — for example, if/when a member clicks a “submit form” button or other button.

We reserve the right to release information contained within our access logs concerning any visitor or member when that visitor or member is in violation of our Terms of Use or other published guidelines, or partakes (or is reasonably suspected of partaking) in any illegal activity, even without a subpoena, warrant or other court order, and to release such information in response to court and governmental orders, civil subpoenas, discovery requests and as otherwise required by law.  We cooperate with law enforcement agencies in identifying those who may be using our servers or services for illegal activities. We also reserve the right to report any suspected illegal activity to law enforcement individuals or entities for investigation or prosecution.

3.         Third Party Sites. This Privacy Policy applies to Drumbi services only. We do not exercise control over the sites displayed as search results, or links from other sites.  These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

4.         Data Security. .  Drumbi takes appropriate security measures to protect any personally identifiable information it stores against unauthorized access to or unauthorized alteration, disclosure or destruction.  We periodically review our security measures for data collection, storage and processing practices, as well as physical security measures to guard against unauthorized access to systems where we store personally identifiable information.

Drumbi restricts access to personal information to Drumbi employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

5.         Changing or Deleting Personal Information; Business Transfers.  If you would like to have your personally identifiable information removed from Drumbi’s database, please contact us at [email protected], and we will use reasonable efforts to comply with your request.  Keep in mind, however, that there will be residual information that will remain within Drumbi databases, access logs and other records, which may or may not contain such personally identifiable information. The residual information will not be used for commercial purposes; however, Drumbi reserves the right, from time to time, to recontact former customers or users of Drumbi.

In addition, we may sell or transfer assets or portions of our business as we continue to improve our product and service offerings.  In such transactions, user or visitor information (whether non-personally identifiable or personally identifiable) may constitute one of the transferred business assets.

6.         Questions.  Questions regarding this Privacy Policy should be directed to Drumbi at [email protected] or, if by U.S. mail, at 9541 Technology Drive, Irvine, CA, 92618, Attn: Shervin Talieh.