At Drawbridge (“Drawbridge,” “we,” “us,” “our” or the “Firm”), your privacy is important to us. This Privacy Policy describes our privacy practices and provides information on the type of personal data we process, our processing methods, and processing purposes. This Privacy Policy governs the personal data we collect for Drawbridge business purposes, whether it is from our clients, our website, or other resources, as fully described in this Privacy Policy.
For the purposes of this Privacy Policy:
Drawbridge complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, and Switzerland transferred to the United States pursuant to Privacy Shield.
Drawbridge has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
With respect to personal data received or transferred pursuant to the EU-US and/or Swiss-US Privacy Shield Frameworks, Drawbridge is subject to the regulatory enforcement powers of the Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to privacy@drawbridgeco.com. If requested to remove data, we will respond within a reasonable time frame.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@drawbridgeco.com
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Drawbridge’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Drawbridge remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles unless Drawbridge proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Drawbridge commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom, and Swiss individuals with Privacy Shield inquiries or complaints should first contact Drawbridge at:
Drawbridge
3300 PGA Boulevard | Suite 570
Palm Beach Gardens, FL 33410
(561) 593-1600
privacy@drawbridgeco.com or filling out the contact us form located at Contact Us Drawbridge has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Drawbridge may collect the following categories of personal data:
Drawbridge only collects personal data from you or about you that is reasonably necessary for us to provide the applicable products or services you have engaged us for, to contact you for the purposes of carrying out our contractual obligations, to establish a business relationship with you, to send your marketing communications in accordance with your communication preferences, for a legitimate business interest, or to comply with our legal or regulatory obligations.
Where consent is required, Drawbridge will request your consent to process your personal data. You are free to withdraw your consent at any time by contacting privacy@drawbridgeco.com
Drawbridge may collect personal data from the following sources:
Drawbridge has reasonable technical, administrative, and physical security measures in place to protect your personal data. If you have reason to believe that our security measures or your interactions with us are no longer secure (e.g., you feel that the security of an account you have with us may have been compromised), please contact us immediately at (561) 593-1600 or privacy@drawbridgeco.com.
Drawbridge retains your personal data as necessary to fulfill our services, for the purposes outlined in this Privacy Policy, in accordance with Drawbridge’s retention policies, and as required or permitted by law.
To the extent permitted by law and subject to any contractual limitations on sharing personal data (as set forth in the relevant agreement for products or services), we may share your personal data with our affiliates, subsidiaries, and business partners for the purposes described in this Privacy Policy. We may also share your personal data in the following circumstances:
Drawbridge may share your personal data with other third parties as directed by you or subject to your consent. Under no circumstances does Drawbridge sell, trade, or rent your personal data.
You may choose to receive or not receive marketing communications from Drawbridge by:
We will try to comply with your request as soon as reasonably practicable as required by law. Please note that we may need to retain certain information for record keeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by law. In addition, please note that even if you opt-out of receiving marketing communications, we may need to send you service-related communications. If you have questions regarding your communication preferences or our marketing activities, please contact us at privacy@drawbridgeco.com
You may have the following set of rights with respect to your personal data:
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en
Please note that the above-mentioned rights may not be applicable to you in certain cases and are subject to conditions as specified under the applicable law. Drawbridge may require you to verify your identity if you elect to exercise your rights, and we will try our best to comply with your request as soon as reasonably practicable, but no later than the time frame required by law.
For more information regarding your rights or to exercise your rights, please contact us at privacy@drawbridgeco.com
Our website may use cookies and similar technologies to improve the performance of our website, help address technical issues, and allow you to engage in our social media offerings. Our website may also collect non-personal data either directly or through a third-party service (e.g. Google Analytics).
“Cookies” are automatically collected pieces of data that identify you as a unique user, facilitate your ongoing access to and use of this website, and helps diagnose server problems. If you prefer to disable cookies on this website, we suggest consulting the Help section of your browser.
Drawbridge does not engage in decision-making based on the automated processing of your personal data, including profiling, which produces legal effects concerning an individual or similarly significantly affects an individual.
This Privacy Policy does not apply to the websites of our service providers, subcontractors, or any other third parties, even if their websites are linked to our website. We have no control over third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our website. We encourage you to read the privacy policies located on each third party’s website.
Drawbridge takes children’s privacy seriously. We do not knowingly collect personal data from minors (children under 13 years of age, or any other age defined under applicable law). If we become aware that a minor is attempting to or has submitted personal data via our website, we will notify the user that we may not accept his or her personal data. We will then remove any such person from our records.
Except as limited by law, Drawbridge reserves the right to makes changes to this Privacy Policy. If we materially change our personal data processing activities, we will revise this Privacy Policy to reflect such changes. We encourage you to periodically review this Privacy Policy in order to stay informed of how we are using and protecting your personal data.
If you have any questions, comments, or complaints about our Privacy Policy or privacy practices, please contact us at:
Drawbridge
3300 PGA Boulevard | Suite 570
Palm Beach Gardens, FL 33410
(561) 593-1600
privacy@drawbridgeco.com
