Effective Date: October 21, 2024
This policy explains what information we collect when you use DrunkLab Group (hereinafter DrunkLab) websites (based at dl.ge, drunklab.com, drunklabstore.com, hamcom.ge, drunklab.ae and its sub-domains *.dl.ge, *.drunklab.com, *.drunklabstore.com, *.hamcom.ge, *.drunklab.ae), services, products, and content (“Services”). It also has information about how we store, use, transfer, and delete that information.
Information We Collect & How We Use It
DrunkLab doesn’t make money from ads. We don’t collect data in order to advertise to you. The tracking we do at DrunkLab is to make our product work as fine as possible. To give you the best possible experience using DrunkLab, we collect information from your interactions with our Services. Some of this information you actively provide to us (such as your email address, which we use to track your account or communicate with you). We collect other information based on actions you take while using DrunkLab, such as what pages you visit (including how many times for a given page and for how long) and your usage of product features (button clicks, etc.). This information includes records of those interactions, your Internet Protocol address, information about your device (such as the type of the device or the browser), and referral information (how you navigated to a particular page).
We use this information to:
- provide, test, improve, promote, and personalize the Services;
- prevent spam and other forms of abuse;
- generate and aggregate non-identifying information about how people use the Services.
When you create your DrunkLab account, and authenticate with a third-party service (like Twitter, Facebook, Apple, or Google) we may collect, store, and periodically update information associated with that third-party account, such as your lists of friends or followers. Without your express permission, we never publish anything through your third-party accounts.
Information Disclosure
DrunkLab won’t transfer information about you to third parties to provide or facilitate third-party advertising to you. We won’t sell information about you to a third party.
We may transfer your account information to third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonymization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) when we have a good faith belief that doing so will help prevent imminent harm to an individual.
Suppose we are going to share your information in response to a legal process. In that case, we’ll give you notice so you can challenge it (for example by seeking court intervention) unless we’re prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our services that we believe are improper.
Public Data
Search engines may index your DrunkLab user profile page, public interactions, and post pages, such that people may find these pages when searching against your name on services like Google, Yandex, or Bing. Users may also share links to your content on social media platforms such as Facebook or Twitter.
Data Storage
DrunkLab uses third-party vendors and hosting partners, such as Amazon, OVH, Digital Ocean, and Hetzner, for hardware, software, networking, storage, and related technology we need to run DrunkLab. By using the Services, you authorize DrunkLab to transfer, store, and use your information in Germany, France, Poland, Netherlands, Finland, and any other country where we operate.
Third-Party Embeds
Some of the content that you see displayed on DrunkLab is not hosted by DrunkLab. These “embeds” are hosted by a third party and embedded in a DrunkLab page, so that it appears to be part of that page. For example, YouTube videos, Imgur or Giphy gifs, Twitter tweets, or some images. These “embeds” send data to the hosted site just as if you were visiting that site directly (for example, when you load a DrunkLab blog post page with a YouTube video embedded in it, that video appears because of a pointer to files hosted by YouTube, and in turn, YouTube receives data about your activity, such as your IP address and how much of the video you watch).
DrunkLab doesn’t control what data third parties collect in cases like this, or what they ultimately do with it. So, third-party embeds on DrunkLab are not covered by this Privacy Policy. They are covered by the privacy policy of the third-party service (when you watch a YouTube video embedded in a DrunkLab blog post, the use of data about your interactions with the video would be covered by YouTube’s privacy policy).
Please be careful when you see embedded forms on DrunkLab asking for your email address or any other personal information. Make sure you understand who you are submitting your information to and what they say they plan to do with it. We suggest that you do not submit your email address or other personal information to any third party through an embedded form.
When posting on DrunkLab, you may not embed a form that allows the submission of personal information by users. You must link to an offsite page that allows such submissions by users, and the appearance of that page must be distinct enough from DrunkLab to ensure it does not confuse users over to whom they are submitting personal information. Failure to do so may lead DrunkLab to disable the post or take other action to limit or disable your account.
Tracking & Cookies
We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences (such as default language), evaluate email effectiveness, allow our paywall and meter to function, and personalize content and other services. Without cookies, our metered paywall would not work, so they are necessary for DrunkLab’s basic functionality.
DrunkLab saves data about the URLs you visit on DrunkLab, but we do not otherwise track your visits or activities off DrunkLab Services. We track your interactions within the DrunkLab Services (which encompasses dl.ge, drunklab.com, drunklabstore.com, and custom domains hosted by DrunkLab).
Some third-party services that we use to provide the Service, such as Intercom, and Google Analytics, may place their own cookies in your browser. This Privacy Policy covers the use of cookies by DrunkLab only and not the use of cookies by third parties.
Modifying or Deleting Your Personal Information
If you have a DrunkLab account and have any trouble modifying or deleting account details, please contact us via email: [email protected] or through online support.
To protect information from accidental or malicious destruction, we may maintain residual copies for a brief time period (generally several weeks). But, if you delete your account, your information and content will be unrecoverable after that time. DrunkLab may preserve and maintain copies of your information beyond this time period when required to do so by law.
Data Security
We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.
Email from DrunkLab
Sometimes we’ll send you emails about your account, service changes, or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account).
When you interact with an email sent from DrunkLab (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction.
We won’t email you to ask for your password or other account information. If you receive such an email, please forward it to us at [email protected] so we can investigate.
SMS and Other Messaging Services Events From DrunkLab
By confirming your phone number or messaging service (WhatsApp, Viber, Telegram) contact with OTP, you agree to receive OTP codes and other DrunkLab service information messages.
You can disconnect or change your contact at any time in your profile section.
DrunkLab will never send SMS and other messages to you without your confirmation.
Changes to This Policy
DrunkLab may periodically update this Policy. We’ll notify you about significant changes to it. The latest version of the policy will always be here https://dl.ge/privacy-policy/.
Questions
We welcome feedback about this policy at [email protected].
Data Protection Statement for European Union Users
Description of Processing Activity
DrunkLab collects and stores personal information about its users to customize their experience and enable personalized distribution of content. It shares minimal data with its service providers.
Purposes of Processing
- Provide, test, promote, and improve the Services;
- Gather usage statistics of services;
- Provide customized reading experience;
- Publish and distribute user-generated content;
- Prevent spam, fraud, and other abuse of services.
Legal Bases
Where DrunkLab collects and stores personal data about non-users mentioned in user-generated content, it does so under the jurisdiction of contract obligations to users who use the Services to publish content on websites hosted by DrunkLab. In such cases, users authoring such user-generated content containing personal data of third parties are responsible for that content. DrunkLab will consider related complaints in compliance with the General Data Protection Regulation’s rights of the data subject, as well as rights of expression and access to information.
Public Nature of Personal Data
Logged-in users may choose to interact publicly with the Services in the form of clapping for a post, sharing links on connected social media accounts or writing original posts. Where such personal data may reveal special category protected data, it is processed on the basis that it is manifestly made public by the user. Additional information on the potential consequences of such processing can be found below. If you do not agree to this public usage, do not create an account or use these features of the Services.
Search engines may index your DrunkLab user profile page, public interactions (such as claps or highlights), and post pages. Users may also share links to your content on social media platforms such as Facebook or Twitter.
Categories of Personal Data Collected
Logged out users:
- IP address;
- Browser information.
Logged in users:
- Username;
- Display name;
- Avatar image;
- Email address (non-public);
- Mobile phone number (non-public);
- Session activity (security);
- Billing address;
- Shipping address (optional);
- Linked social media accounts (optional);
- IP address;
- Browser information;
- Network interactions (recommends, follows, etc.);
- Posts, responses, or series published by user.
Categories of Recipients
DrunkLab shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:
- Hosting, Storage, & Other Infrastructure;
- Security;
- Analytics;
- Communication & Support;
- Payment Processors.
Use of Algorithms to Personalize User Experience
DrunkLab collects and stores personal data about its users to customize their reading experience by displaying content tailored to the preferences and interests indicated by the users (including through their reading history and Service interactions). This does not constitute automated decision-making as that phrase is used in the GDPR because it does not produce any legal effects or similarly significant effects for users. DrunkLab also moderates content for the purposes of fighting and preventing spam, fraud, and other forms of abuse, and may rely on algorithms as part of doing so.
Potential Consequences of Processing
By creating and using an account on DrunkLab, users may make certain personal data about themselves public and accessible to others on their profile and through network interactions. This may in some cases constitute special category protected data which is considered manifestly made public by the user.
Users are free to use their real name and information, or a pseudonym of their choosing, for their account. Users may also choose to use the service without posting data or engaging in network interactions. However, if you do not agree with and accept the risks of such usage, you may not use the Services.
Cross-border Transfers
DrunkLab is hosted in the EU. By using the Services, you authorize DrunkLab to transfer, store, and use your information in the EU and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.
Retention
DrunkLab retains personal data associated with your account for the lifetime of your account. If you would like to delete your personal information, you can delete your account at any time. Deleted account profile pages will yield an error 404 “file not found” page, immediately upon initiating deletion, and will become unrecoverable in our system after a period of fourteen days. It may take several additional days for your personal data to be de-indexed from search engines, depending on those search engines’ practices, over which DrunkLab may have limited or no control.
To delete your payment or billing information, you will need to do so with your payment provider, as DrunkLab only has minimal secure access to those records as needed to provide the Services.
Inactive Account Delete
DrunkLab LLC respects your privacy and is committed to protecting your personal data. Per this commitment, we have implemented a policy for the deletion of inactive accounts.
An account is deemed ‘inactive’ if there are no login actions either on the DrunkLab site or in the Mochester 4 App for a continuous period of three (3) years. If the account remains inactive for such a period, DrunkLab LLC will automatically delete this account and all associated personal data.
Please note that any funds remaining in the account wallet at the time of deletion will be withdrawn. DrunkLab LLC is not responsible for the management of these funds after account deletion.
We strongly encourage all users to maintain activity within their accounts to avoid automatic deletion and to manage their wallet funds appropriately. Users will receive a notification 60 days prior to the deletion due to inactivity to provide the last chance to keep the account active.
Contact Information
If you have any questions about this Privacy Policy, you can contact us at [email protected].
California Consumer Privacy Act Disclosures
Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information,” as described in the CCPA).
This section provides additional privacy disclosures and informs you of key additional rights as a California resident:
Right to Know Request
Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:
- Categories of and specific pieces of personal information we have collected about you.
- Categories of sources from which we collect personal information.
- Purposes for collecting, using, or selling personal information.
- Categories of third parties with which we share personal information.
- Categories of personal information disclosed about you for a business purpose.
- If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.
To make a verifiable request for information about the personal information we have collected about you, please email us at [email protected].
Right to Delete Request
Under the CCPA, you also have a right to request that we delete personal information, subject to certain exceptions. To delete all personal information linked to your DrunkLab account please email us at [email protected], be ready to identify your Right to manage the account.
General Requests under CCPA
If you do not have a DrunkLab account, we will not have enough information about you to verify your Right to Know and Right to Delete requests since we do not keep sufficient information to reidentify and link you to DrunkLab data. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.
Requests made through Agents
You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your Rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
Disclosures of Personal Information for a Business Purpose
DrunkLab may disclose certain data from the following categories of personal information to the categories of recipients listed above in the ‘Categories of Recipients’ for one or more business purposes:
Logged in users:
- Username;
- Display name;
- Avatar image;
- Email address (non-public);
- Mobile phone number (non-public);
- Billing Address;
- Shipping address (optional).
Members:
- Billing information and history.
Partner authors:
- Bank account for payments;
- Business information, if applicable.
No Sale of Personal Information
Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. Since DrunkLab doesn’t make money from ads, we don’t collect data to facilitate nor enable third parties to advertise to you. At this time and pending final regulations and guidance interpreting the CCPA, we don’t believe any of our data practices constitute a “sale” under the CCPA.
Other Special Privacy Options
All credit/debit cards details and personally identifiable information will NOT be stored, sold, shared, rented or leased to any third parties.
Contact Us
You may contact us by emailing us at [email protected].
