Privacy Policy

This Privacy Policy discloses the privacy practices for this site, The Drive owned and operated websites and mobile apps on which it appears, our email newsletters and other applications owned and operated by The Drive, including offline and online subscriptions and other product offerings (collectively referred to as the “Services”), and to any other services that display this Privacy Policy. Your privacy is important to us. To better protect your privacy, we provide this Privacy Policy explaining our information practices and the choices you can make about the way your information is collected and used by The Drive and its subsidiaries.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Web Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Web Site Terms and Conditions.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

1. Who are we and what do we do?

The Web Site and our Services are operated by The Drive (“we”, “us” or “our”). We are the data controller responsible for your personal information.

2. The information we collect and how do we use it?

Through the Services, you can, among other activities, order publications and products; engage in various activities like entering contests or sweepstakes, playing games, taking quizzes, voting in polls or otherwise expressing an opinion; subscribe to one of our services, such as newsletters; or participate in one of our online forums or communities.

We collect the information, including any personally identifiable information, that you provide to us in the course of using the Services. The types of information that may be collected through these Services include, but are not limited to: name, address, gender, e-mail address, telephone number, fax number and credit or debit card information.

We may also collect information about your personal or professional interests and your use of, or opinions about, various products, programs and services. For instance, we may ask you to identify your job or industry to qualify you for free business magazines.

Through some features of the Services and through certain promotions, you can submit information about other people. For example, you might submit a person’s name, mailing and/or e-mail address to send a gift or electronic greeting card. The types of personally identifiable information that may be collected about other people at these pages include: recipient’s name, address, e-mail address and telephone number.

We, our partners, advertisers, advertising networks or other third party service providers, as explained further in the “Collection of Information by Third-Parties” section below, may also collect certain non-personally identifiable information when you visit our web pages, open our emails, use our applications, or otherwise use the Services, including such information as the type of browser and operating system you are using, your IP address, your device identifiers, your Internet or wireless service provider, location-based information , and the content and advertisements you have interacted with, viewed, or accessed. This data may be combined and linked with data from other sources.

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Web Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other clients and users of the Web Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law. In particular, we use your personal information for the following purposes:

Fulfillment of products and services.

We collect and maintain personal information that you voluntarily submit to us during your use of the Web Site and/or our Services. We use the contact and payment details you have provided to us so that we can fulfil the supply of products and services you have ordered from our Web Site. This includes your purchase of products, your attendance at events hosted by us or our third party partners, personal shopping appointments, alterations to products and customizations to products, such as engraving and monogramming, processing of returns and refunds and tax free rebates. In particular, and without limitation, we may use the information collected under this Privacy Policy in the following ways:

    • We may use the information you provide about yourself or others to fulfill requests for our publications, products or services, to respond to inquiries about offerings and to offer other products, programs or services that may be of interest.
    • We may combine information we receive with outside records and share such information with third parties for use on our behalf to enhance our ability to market to you those products or services that may be of interest to you.
    • We may disclose personally identifiable information that we receive from you and from third party sources to third parties whose practices are not covered by this privacy statement (e.g., other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that want to market products or services to you.
    • When you request a magazine, service, or other product, we will forward the information you give us to the publisher or provider to the extent necessary to fulfill your request. They may contact you with special offers of possible interest.
    • We sometimes use this information to communicate with you, such as to notify you when you have won one of our contests or sweepstakes, when we make changes to subscriber agreements, to fulfill a request by you for an online newsletter, or to contact you about your account.
    • If you choose to submit content (e.g., a “letter to our editors” or an online review), we may publish your name, screen name and other information you have provided to us. You hereby consent to this.
    • The information we collect in connection with our online forums and communities is used to provide an interactive experience. We use this information to facilitate participation in these online forums and communities and, from time to time, to offer you products, programs, or services.
    • We sometimes use the non-personally identifiable information that we collect to improve the design and content of our publications and websites, and to enable us to customize your Internet experience. We also may use this information to analyze site usage, as well as to offer you products, programs, or services.
    • We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.
    • Agents and contractors of The Drive that have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for The Drive
    • We may transfer your personally identifiable information to other The Drive offices for internal management and administrative purposes on our behalf. Your personal data will be transferred to other The Drive offices where necessary for the performance or conclusion of our contractual obligations to you or for your benefit. To the extent not prohibited under applicable law, transfers and disclosures of personally identifiable information may also be made where necessary for the establishment, exercise, or defense of legal claims, to protect the rights and property of The Drive , our agents, customers, and others, including to enforce our agreements, policies, and terms of use; or to protect the personal safety of any person.
    • Please note that if The Drive or any of its subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger of, consolidation, sale or divestiture of assets, the relevant customer database, including personally identifiable information we may possess about you, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.

Who do we share your personal information with for this purpose?
We may share your personal information with the following categories of third parties:

    • To verify card payments and process refunds – credit card companies and other payment providers;
    • To deliver products and process returns – delivery and courier companies;
    • Events – any applicable third party hosting the event; ticketing companies such as Eventbrite;

What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you. 

Client service enquiries.

Our Web Site uses various user interfaces to allow you to request information about our products and services: these include printed and electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?
We do not share your personal information for this purpose.

What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.

Your feedback about our products and services.

From time to we will contact you to invite you to provide feedback about our products and services in the form of online, postal or in-store surveys. We use this information to help us improve the quality of service provided by our staff and in our stores. We also use your feedback to monitor the quality of our products and services and to assist with the selection of future product and service lines.

Who do we share your personal information with for these purposes?
We do not share your personal information for this purpose.

What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.

Customer insight and analysis.

We analyze your contact details with other personal information that we observe about you from your interactions with our Web Site, our email communications to you and/or with our products and services in our stores, such as the products and services you have purchased or viewed.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Web Site, or from your mobile. This includes the following:

    • an IP address to monitor Web Site traffic and volume;
    • a session ID to track usage statistics on our Web Site;
    • information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences. 

Cookie policy.

Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

This information is used to create profiles and insights about your shopping habits and the shopping habits of our other customers. Where we have your consent to do so, we will also use your location data for customer insight purposes.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Web Site and our Services. This allows us to learn what pages of our Web Site are most attractive to our visitors, which parts of our Web Site are the most interesting and what kind of offers our registered users like to see.

We also use this information to help us with the selection of future product and service lines, store and websites design and to remember your shopping preferences.

We also use this information for marketing purposes (see the marketing section below for further details).

Who do we share your personal information with for these purposes?
We may share your personal information with a variety of third party service providers to assist us with customer insight analytics. These providers include those described in our cookie policy.

What is our legal basis?
Where your personal information is completely anonymized, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so.

Marketing communications.

We carry out the following marketing activities using your personal information:

    • Postal marketing.

We use information that we observe about you from your interactions with our Web Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your address details, to send you marketing communications by post.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you, including the post office.

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized information may be subject to other laws where your consent is required. Please see our cookie policy for further details.

Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

We will only use your location data where we have your consent to do so.

    • Email marketing.

We use information that we observe about you from your interactions with our Web Site, our email communications to you and/or with our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you.

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.

    • Online personalized advertising.

We use information that we observe about you from your interactions with our Web Site, our email communications to you and/or with our products [and services in our stores] (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized online advertising.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party service providers who assist us with our online personalized advertising campaigns. These providers are described in our cookie policy.

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

    • Social media remarketing.

We use information that we observe about you from your interactions with our Web Site, our email communications to you and/or with our products and services in our stores (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services.

We do this using Facebook Customer Audiences and/or Google Customer Match respectively [others?]. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party service providers with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match services respectively. 

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only engage in social media remarketing where you have consented to us [using your email address] [sharing your email address in an encrypted format with Facebook and/or Google respectively] for marketing purposes.

    • Social media insight.

Where you are a registered user of Facebook, or of a Google service, we will use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:

      • information that we observe about you from your interactions with our Web Site, our email communications to you and/or with our products and services in our stores (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and
      • the information Facebook and/or Google hold about you.

We do this using Facebook Lookalike Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have elected to make on such services.

Who do we share your personal information with for these purposes?

We share your email address with third party service providers who assist us with social media remarketing campaigns.

Your encrypted email address is also shared by us or our third party marketing consultancies with Facebook and/or Google under the terms of their Facebook Customer Audiences and/or Google Customer Match respectively.

What is our legal basis?

Where your personal information is completely anonymized, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymized personal information may be subject to other laws where your consent is required. Please see our cookie policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

    • to comply with our legal obligations;
    • to enforce our legal rights;
    • protect rights of third parties; and
    • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets. 

Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Where we share your sensitive personal information, we shall obtain your consent to do so.

    • Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

3. How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail or post using the contact details set out in this Privacy

4. Your California Privacy Rights: Notice to California Customers

California’s “Shine the Light” law

California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. (Note: The Drive sites do not recognize the “do not track signals” that some browsers may employ.) As discussed above, if you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes offline, please contact us as described in the “How to Contact Us” section below.

California Do Not Track Disclosures

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org. At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy.

5. Collection of Information by Third Parties

Some of our Services contain links to third party sites and services whose privacy practices may be different than ours. We also allow you to connect with other third party sites and services. Please remember that when you use a link to go from our Web Site to another website or you request a service from a third party, this Privacy Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.

We sometimes may offer contests, sweepstakes, promotions, editorial features, or other activities or offerings that are sponsored or co-sponsored by or presented with identified third parties. By virtue of your participation in such activities or offerings, your IP address and the personally identifiable information that you voluntarily submit may be provided to both The Drive site and the third parties. The Drive has no control over the third parties’ use of this information.

We may use third parties to present or serve advertisements, including online behavioral advertisements, that you may see on the Services and to conduct research about the advertisements-or the Services themselves. Additionally, third parties may place and use tracking mechanisms, e.g., tracking pixels, in the emails we may send to you. This Privacy Policy does not cover any use of information that such third parties may have collected from you (e.g., type of browser, operating system, domain name, day and time of visit, page(s) visited) or the methods used by the third-parties to collect that information (e.g., cookies, web beacons and clear gifs).

Note regarding Market Research/Ratings: Our Services may also feature Nielsen’s proprietary measurement software which may contribute to market research, like Nielsen’s TV Ratings. To learn more about this information, please click here. Nielsen’s software may collect your choices with regards to it.

6. Cookies and other Tracking Technologies

We may place “cookies” on your computer or device. Cookies are small text files that we place in your computer or device to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personal information unless you choose to provide this information to us by, for example, registering with one of our Services. Once you choose to provide us with personal information, this information may be linked to the data stored in the cookie. A cookie assigns a unique numerical identifier to your Web browser or device, and may enable us to recognize you as the same user who has used our Services, and relate your use of the Services to other information about you, such as your usage information and personal information.

We use cookies (and Local Shared Objects, HTML5, cache cookies, web beacons, or clear gifs, all described further below) to understand usage of the Services and to improve our content and offerings and to deliver advertisements that you might be interested in. For example, we may use cookies to personalize your experience on our Services (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, to enable shopping carts, or to tailor content or product and service offerings).

Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. However, you may find that some parts of the site will not function properly if you have refused cookies or similar tracking technologies and you should be aware that disabling cookies or similar tracking technologies might prevent you from accessing some of our content. However, your viewing of editorial content may be hampered. If you wish to block cookies, go to http://www.allaboutcookies.org/ to find out how, or check your browser’s instructions.

Some of the tracking technologies we may use include:

  • Local Shared Objects: Local shared objects, such as .Flash cookies,. also may be stored on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, see http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
  • HTML 5: HTML5, the language some Web sites are coded in, may be used to store information on your computer or device about your Service usage activities. This information may be retrieved by us to help us manage our Services, such as by giving us information about how our Services are being used by our visitors, how they can be improved, and to customize them for our users.
  • Cache Cookies: Cache cookies, such as eTags, may be used to identify your computer or device as the same computer or device that visited a Service or Services in the past.
  • Web Beacons: Our websites may also use small pieces of code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image called a single-pixel or clear GIF. Web beacons can recognize certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies that conform to our cookie policy above.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you, and relate your Service usage information to other information about you, including your personal information. We may match information collected from you through different means or at different times, including both personal information and Service usage information, and use such information along with offline and online information obtained from other sources (including third parties) such as demographic information and updated contact information (where that information has been lawfully disclosed to us) for the purposes of learning more about you so we can provide you with relevant content.

7. Our Commitment to Security

We have put in place appropriate administrative, technical, and physical safeguards to help prevent unauthorized access, maintain data security and correctly use the information we collect.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorized access;
  • improper use or disclosure;
  • unauthorized modification; and
  • unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

No system can be completely secure, however, and we do not guarantee that unauthorized disclosures and access will not happen. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.

8. Accessing, Correcting, and Deleting Your Personal Information

We will take reasonable steps to accurately record the personal information that you provide to us and any subsequent updates. You have the following rights in relation to the personal information we hold about you:

  • Your right of access.
    If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
  • Your right to rectification.
    If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to erasure.
    You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to restrict processing.
    You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
  • Your right to data portability.
    With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
  • Your right to object.
    You can ask us to stop processing your personal information, and we will do so, if we are:
    • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
    • processing your personal information for direct marketing.
  • Your rights in relation to automated decision-making and profiling.
    You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
  • Your right to withdraw consent.
    If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
  • Your right to lodge a complaint with the supervisory authority.
    If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113

9. Retention of Personal Information

We will retain your personal information while you have an account with us and thereafter for as long as we need it for purposes not prohibited by applicable laws. Thereafter, we will either delete your personal information or de-identify it so that it is anonymous and not attributed to your identity.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.

Your rights to request that we delete your personal information are set forth in the “Accessing, Correcting, and Deleting Your Personal Information” section above.

10. Special Note for Parents

The site you are visiting is not intended for use by children. Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18. It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by e-mail or post using the contact details set out in this Privacy Policy.

11. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

12. How to contact us?

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:

The Drive
1 Pier 76, 408 12th Avenue,
New York, New York. 10018
Attention: Privacy Policy Officer

This Privacy Policy was revised February 14, 2019.