LAST UPDATED: July 17, 2025

SWI-DE, LLC d/b/a Drew Estate (“Company,” “our,” “we,” or “Drew Estate”) respects your privacy and is committed to protecting it as set forth in this Privacy Policy (“Policy”). This Policy describes our practices in connection with personal information and other information that we collect through:

• Websites owned, published, or operated by us (the “Websites”);
• Our social media pages, including those available on Facebook, Instagram, and Discord (collectively, our “Social Media Pages”);
• Email messages or other communications with you; and
• Any other online or offline business interactions you have with us.

Collectively, we refer to the Websites, Social Media Pages, emails, communications, and online and offline business interactions as the “Services.”

“Personal information” means any information that identifies or reasonably could be linked to a particular person or household. It includes things like email addresses, phone numbers, mailing addresses, payment card information, account numbers, and government-issued identification numbers. These are just examples and there are many other types of information that would be considered personal information.

By using our Services, you signify your agreement to the collection, use, storage, treatment, and disclosure of your personal information in accordance with this Policy. If you do not agree with this Policy, do not use our Services.

1. Notice of Monitoring Chat Functionality
2. Information We Collect From You and How We Use It
3. How Your Personal Information Is Shared
4. De-Identified Information
5. Cookie Policy
6. Video Privacy
7. Data Security
8. Retention Period
9. Third Party Services (Including Social Media)
10. Age Verification 21/Children’s Privacy
11. Your Choices Regarding Marketing Emails
12. Privacy Rights
13. Additional Information for California Residents
14. International Customers
15. Changes to This Policy
16. Contact Information
17. California Personal Information Chart

We may enable chat functionality on our website. Please note that if you use the chat function on our website, all information you send and receive will be recorded.  If you do not wish for us to record this information, please do not use the chat function on our website. By using the chat function, you consent to our monitoring all communications.

a. Personal Information You Disclose To Us
From time to time, we collect certain Personal Information directly from you, when engaging with the Services, such as when you sign up for a newsletter or, register an account, attend one of our events, from social media platforms or otherwise or when you correspond with us either online or offline.

This information is collected for a number of purposes, as described in more detail below.

Perform Services:

• Visit Website, Account Creation, Access to Features, Logon Process. We use Personal Information you provide when you visit the Websites, to create an account with us, or to let you have access to certain features or areas of the Services, including: your first and last name, email address, mailing address, phone number, profile picture, social media account ID, date of birth or age (and driver’s license under certain circumstances to verify age), general location information, and similar security information used for authentication and account access. Without providing your Personal Information, you cannot create an account with us or access certain features or areas of the Services. We process your personal information based on our legitimate interest in providing our products and services, or performance of a contract. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.
• Communicate with You. To provide you with order confirmations and order updates, manage and maintain our business relationship with you, provide you with store locations, provide services according to our contractual agreement with you, assist you with any of our services or that of our partners, give you notices about your Drew Diplomat Program account status and subscription (including expiration and renewal notices), or to facilitate social sharing functionality that you choose to use, provide customer service, or otherwise communicate with you via email or by phone regarding your account, purchases, or service requests. We may also use this information to send you system-generated communications relating to products or services you have purchased. We may collect your name, product information, email, billing address, phone number, financial information, purchase or service history, communications preferences, and other information relevant to your products or inquiries. We process your personal information based on our legitimate interest in providing our products and services, or performance of a contract. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.
• Processing Order and Payments. When you place an order through our website, such as tickets to an event, you provide information required to complete your transaction, which may include your name, phone number, shipping address, billing address, email address, date of birth or age (and driver’s license under certain circumstances to verify age), redacted or truncated payment card data, purchase or service history, and delivery information and status. We process your personal information based on our need to fulfill our contract obligations and on our legitimate interests in processing orders and payments for products and services. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.
• Event Registration. You may provide us with your name and contact information when you register or purchase tickets for one of our events, and we may take photos at events that include you. We may use this information for tracking registrations and confirming attendance. We process your personal information based on our legitimate interests. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Otherwise, processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• Sweepstakes, Contests, or other Promotions. We may offer you the opportunity to participate in a sweepstakes, contest or other promotions. You may provide us with your name, phone number, address, email address, date of birth or age (and driver’s license under certain circumstances to verify age), and social security number (for winners only). We process your personal information based on our need to fulfill our contract obligations and on our legitimate interests. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Some of these sweepstakes, contests or other promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.

Improve or Develop Products or Services:

• Customer Service. We may collect your Personal Information from you when you contact us for customer services support or questions. Specifically, we may collect your name, email address, phone number, address, purchase or service history, recording of a call, billing or account information, and limited payment card information, depending on the nature of your customer service inquiry and the requests you are making. Processing is necessary for the performance of the contract with you. Otherwise, processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal.
• Customer Satisfaction Surveys. We may ask you to complete surveys to tell us about your experiences with us. If you choose to fill out a survey, we may collect your name, email address, phone number, and the information you provide to us in your survey responses. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.

Market and Promote Services:

• Marketing. We or our third-party marketing partners may use your Personal Information for our marketing purposes, depending on your marketing preferences. These communications may include information about our products, services, or features. The Personal Information collected for these purposes include your name, email address, and zip code. You can opt out of our marketing emails at any time. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Otherwise, processing is based on your consent.

b. Personal Information We Collect Automatically

We may collect the following Personal Information from your device or browser for the following purposes:

Improve or Develop our Products or Services:

• Improving the Websites. We may use your Personal Information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the websites, products, services, and your experience, including: device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the websites and other technical information. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.

Market and Promote Services:

• Advertising and Behavioral Profiling. We collect information about your interaction with our Services, your advertising preferences and your communications with us. This is information we receive from your devices (including mobile devices) you use when you access our Services. This information could include the following: Device ID or unique identifier, device type, ID for advertising and a unique device token, preferences, purchase / service history, cookie IDs, your computer or device’s operating system and browser type, device identifiers, usage details, IP address, geolocation, tracking data on behavior across websites, and postal or country code. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Otherwise, processing is based on your consent.
• Advertising Analytics. For advertising analytics, we may collect computer and connection information such as usage details, statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing activity, precise geolocation, history and your web log information. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Otherwise, processing is based on your consent.
• Website Analytics & Marketing. When you visit and use our Websites, we collect information automatically from your devices to evaluate and improve our website performance, as well as for marketing purposes. This includes your IP address, cookie IDs, device identifiers, geolocation, information about how you use our Website, preferences and trends, and purchase and service history. Our Websites may also collect certain analytics information, including your history of viewing and interacting with our YouTube channel, which we use to deliver targeted advertising and to analyze our Websites, products, and Services. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Otherwise, processing is based on your consent.

Prevent and Detect Harm or Abuse:

• Protection. We may use your Personal Information as part of our efforts to keep the Services safe and secure and to protect others from harm or abuse, including: device and usage information, such as your IP address, browser and device characteristics, your computer or device’s operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Services and other technical information. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.

Please refer to our Cookie Policy below for more information on how we use cookies.

c. Data Collected From Other Sources

We may use third party service providers to help us with our day-to-day business activities. Where we use third parties, they may share Personal Information about you with us.

Perform Services:

• To Send System Generated Communications To You. We may use third parties to send you administrative information about products or services you have purchased. We may receive Personal Information about you from the third party, including name and email address. Processing is necessary for the performance of the contract with you, or the processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.
• To Fulfill and Manage Your Orders. All payment data is stored by our third-party payment provider when we fulfill and manage your orders for services, subscriptions, and payments. When you make a purchase, our third-party payment provider may share transaction information, such as your name, email address, billing address, transaction ID, time, amount, and payment type. Processing is necessary for the performance of the contract with you, or the processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. For more information on how your Personal Information is processed by our third-party payment provider, please review their relevant privacy policies:
  • Stripe
• To Verify Your Age. We utilize a third-party age verification service to confirm you are of legal age to purchase or access any of our products or services. Our third-party age verification provider may share transaction information, such as your name, email address, and transaction ID. Processing is necessary for the performance of the contract with you, or the processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Our age verification provider acts as an independent controller over your Personal Information when you conduct a transaction with them. For more information on how your Personal Information is processed by our third-party age verification provider, please review their privacy policy:
  • AgeChecker.Net

Market and Promote Services:

• Marketing and Promotions. On occasion we might collect Personal Information from third parties such as from tradeshow marketing and advertising partners, and partnerships with third parties who help to administer promotions, giveaways or sweepstakes. This information is usually limited to name, email address, address, and birthdate. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Otherwise, processing is based on your consent.
• To Deliver Targeted Advertising To You. We may use your Personal Information to develop and display content and advertising (and work with third parties who do so) tailored to your interests or location and to measure its effectiveness, including: marketing leads and search results and links, including paid listings (such as sponsored links). We also receive analytics information from certain sites, including your history of viewing and interacting with our YouTube channel, which we use to deliver targeted advertising and to analyze our Websites, products, and Services. The processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests. Otherwise, processing is based on your consent.
• Communicating Via Social Media. When you communicate with us or otherwise engage with us through the use of Social Media, such as Facebook, Instagram, X (formerly Twitter), or Discord, we may receive information related to your engagement with us via social media. Generally, we may receive information such as name, social media handle, and other information about your profile which you may have made public. On the social media channels we engage with, we reserve the right, but are not obligated to monitor our Discord server and have access to all information publicly posted on the server. If you connect your social media account to your Services account, you will share certain Personal Information from your social media account with us, for example, your name, email address, date of birth, list of social media contacts, and any other information that may be or you make accessible to us. Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. If you interact with us via social media, the information we collect via your participation is subject to the terms of this Privacy Policy and our Terms of Use, as well as the Privacy Policy and Terms of Use for any of those social media sites / platforms.

d. Other Purposes for Which We May Use the Personal Information We Collect

We may use any Personal Information we collect as described above for the following business purposes:

• To Develop Our Websites, Products and Services. We may use your Personal Information to further develop or improve our existing websites, products and services, or to develop new products and services.
• To Protect The Websites, Us, and Others. We may use your Personal Information as part of our efforts to keep the Websites safe and secure (for example, for fraud monitoring and prevention) and to protect others from harm or abuse.
• To Enforce Our Terms, Conditions, and Policies. We may use your Personal Information to ensure you and others are complying with our terms, conditions and policies, including providing your information to law enforcement if we believe it is appropriate to do so and using your information in connection with legal proceedings brought by us or against us.
• To Respond to Legal Requests and Comply with Applicable Law. If we receive a subpoena, discovery request, or other legal request, we may need to review and evaluate your Personal Information and potentially provide your Personal Information in response to the request. We may also need to use your Personal Information as needed to comply with applicable laws and regulations.
• For Other Business Purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve the websites, products, services, and your experience.

We use Personal Information for these purposes to comply with a legal obligation to which we are subject. Otherwise, the processing is based on our legitimate interest. When we rely on our legitimate interest, we will always assess whether your interests or fundamental rights and freedoms do not outweigh our interests.

We may share your personal information in certain circumstances as set forth below:

• With our affiliates for the purposes described in this Privacy Policy;
• With our third-party service providers, to facilitate services they provide us. These can include providers of services such as age verification, website hosting, data analysis, payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits (including special promotions), email delivery, auditing, and other services;
• With our event services provider.  Our third-party event service provider acts as independent controller over your Personal Information when you use their platform to register or interact with one of our events. For more information on how your Personal Information is processed by our third-party event service provider, please review their relevant privacy policies:
  • Eventbrite
• On our website, with your permission (for example, photos taken at events);
• With third party sponsors of sweepstakes, contests, and similar promotions;
• With third parties that you elect to disclose Personal Information:
  • Through User Contributions.  You may provide information to be published or displayed (“Posted”) on public areas of websites or social media pages (“User Contributions”) you access through your Services. Your User Contributions are Posted and transmitted to others at your own risk. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons;
  • When you interact with us via social media, we will receive and share information with social media platforms, including but not limited to Discord;
  • Through your social sharing activity.  When you connect your Services account to your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy;
  • By interacting with us via social media or public websites, or Posting or Sharing User Contributions, you consent to Drew Estate re-posting, re-sharing, or otherwise using or sharing any User Contributions you choose to publish, display, or otherwise share with us.

• With law enforcement; government agencies or regulators; courts; parties to legal proceedings in which a subpoena or legal request has been propounded to which such information would be responsive. In those circumstances we will make reasonable efforts to disclose only that information that is relevant to the reason for disclosure and to protect the privacy of such information to the extent reasonably possible; and
• In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

We may also disclose your personal information to other third parties not described above with your consent.

We may de-identify (also referred to as “anonymize”) and aggregate information for our business purposes, including but not limited to, improving the products and features of its services, maintaining the security and integrity of its systems, for analytics, and other legitimate business purposes. “De-identified Information” means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular individual. De-identified Information includes anonymized data and is no longer “personal information” under applicable data protection laws. Where we process De-identified Information, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. We may disclose De-identified Information to third parties who commit themselves to maintaining the De-identified Information in anonymized form and not attempt to re-identify the data for any business purpose.

This section describes how the Websites use cookies and similar technologies to collect and store information when you visit the websites. Like many companies, the websites use certain technologies – cookies, web beacons, clear GIFs, tracking pixels, and similar technologies (collectively, “cookies”) – to collect information when you interact with the websites and email communications.  You can find more information about the cookies we use by clicking “Customize” on the cookie banner or by clicking the cookie icon in the bottom left corner of the website.  

How Do Cookies Work?

To understand how tracking technologies work, it is helpful to describe the types of technologies we use and what they are used for:

• Cookies – a “cookie” is a small text file that websites send to your computer, device, or other internet-connected tool you are using that contains data used by the website for its business purposes.
• Web Beacons – a “web beacon” or “pixel” is a tag used on a web browser or HTML email that records your activities when viewing the web page or email where it is placed.

Cookies are classified by their purpose:

• Essential – These cookies are required for the website to function. You cannot disable these.
• Personalization – Allow the website to remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personal features. For example, a website may provide you with local weather reports or traffic news by storing data about your general location.
• Analytics – Help us understand how the websites perform, how visitors interact with the websites, and whether there may be technical issues.
• Targeted Advertising – Used to deliver advertising that is more relevant to you and your interests. May be also used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns.

The Websites use first party cookies and third-party cookies. The difference between first party cookies and third-party cookies relate to the control of the party who serves the tracking technology. First party cookies are cookies that are specific to the website that created them. Their use enables us to operate an efficient service and to track the patterns of behavior of visitors to the website. Third-party cookies, on the other hand, are placed on your device or served by a third-party (i.e., not by us). While we may allow third parties to access the websites to place these cookies on users’ devices, we do not retain control over the information supplied by the cookies, nor do we retain access to that data. This information is controlled wholly by that third-party in accordance with their respective privacy policy. To learn more about the tracking technologies delivered on the websites, please visit our Consent Preferences Center and select the drop-down arrow next to each category’s heading.

How Do We Use Cookies

We use cookies consistent with this Policy. For example, a cookie may be used to determine your preferred language, maintain the security of our website and your account, measure website analytics, measure the effectiveness of our advertising and promotional communications, and gain information for marketing and advertising purposes, including by identifying the website from which a person was referred to the websites and to track other websites visited by an individual.

Information gathered through usage of a cookie is not linked to any direct personal identifiers (e.g., your name or e-mail address), unless you become a customer of ours (under certain circumstances). Once you submit personal information on our websites (e.g., by signing up to receive information from us) we may link such personal information with data associated with your visit(s) to the websites.

Third-Party Analytics. Our websites use third-party web analytics services that use cookies to help the websites analyze how users use the websites. The information that is collected about your use of the website will be de-identified or pseudonymized by the third-party analytics provider (Google Analytics) for the purpose of evaluating your use of the sites, compiling reports on website activity and providing other services relating to website activity and internet usage. This service may also collect information regarding the use of other websites, apps and online resources.  Information collected by us through use of third-party analytics includes: website interaction; number of visitors; where they visit the website; and the pages visited.

Disabling, Deleting, or Opting-Out of Cookies

If you do not want to have cookies placed on your device. You may refuse the use of cookies by selecting the appropriate setting in our Consent Preferences Center.

In addition, many of them offer ways to opt out, and most web browsers allow at least some control of most cookies, as well as JavaScript through browser settings. You may refuse the use of cookies by selecting the appropriate settings on your browser to decline cookies. You may also delete existing cookies through your browser. Please visit the following websites to learn more (depending on the browser you use):

• Firefox, Microsoft Edge, Internet Explorer, Google Chrome and Safari.

Please note, if you disable cookies, you may not be able to use the full functionality of our websites. In particular, you may have limited access to some areas or be transitioned to a different experience.

Please remember, some features of our websites may not function properly unless cookies and JavaScript are enabled, and some areas of our websites may not function at all.

You may choose to delete cookies placed on your device and to block new third-party cookies from being placed by using your internet browser’s privacy and security settings. In addition, you may opt out of our sharing your personal information for targeted advertising purposes by clicking “Customize” on the cookie banner or by clicking the cookie icon in the bottom left corner of the website.

Do-Not Track Features (U.S. Residents only)

Many web browsers and some mobile operating systems and mobile applications include a “do-not-track” feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing do-not-track signals has been finalized and, as such, we do not currently respond to do not track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We will update this Policy if that changes in the future.

Some pages of the Websites include videos hosted on Vimeo and YouTube. If you enable this setting, the video sharing platform may collect information about your viewing for analytics and advertising purposes. If you don’t enable this setting, the pages will include external links instead.

We have implemented appropriate organizational, technical, and administrative measures to protect the security of personal information within our organization.  While we endeavor to protect the security and integrity of personal information, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by unauthorized persons.

If you have an account with us, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.

Unfortunately, no transmission of information via the internet and mobile platforms and no storage of information is completely secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Information” section below. 

We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as business records, tax, accounting or other legal requirements). In determining data retention periods, we take into consideration the applicable law, contractual obligations, and your expectations.

When there is an indication of potential legal claims or liability, the retention period will be extended accordingly.

When we have no ongoing legitimate business need to process your Personal Information, i.e., when we no longer have a legal basis in accordance with applicable law, we will either delete or anonymize it and we will make such determination based on applicable laws. When the processing of Personal Information is based on your consent, the data will be stored for as long as there is valid consent for the processing.

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any personal information. If you follow a link to any third-party site, any information you provide that site will be governed by its own terms of use and privacy policy and not this Policy.

We are not responsible for the privacy or security of any information you provide to a third-party website, or the information practices used by any third-party site, including links to any third-party site from the websites. We make no representations, express or implied, concerning the accuracy, privacy, safety, security or the information practices of any third-party site. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.  We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third-party website. We encourage you to carefully review any terms, conditions and policies of such third-party sites before providing any information on or through them.

The Services are not intended for, directed at, nor marketed to, individuals under 21 years of age. If we learn we have collected or received Personal Information from anyone under the age of 21, we will keep the information containing the results of the age verification and will delete any other information. If you believe we might have any information from or about someone under 21, please contact the Company at [email protected].

If you do not want us to use your e-mail address or contact information to receive marketing related emails from us on a going-forward basis, you can opt-out by communicating via email such request to [email protected] or by following the opt-out instructions at the bottom of any Company emails you receive. We will try to comply with your request as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

Some privacy laws require that we disclose the privacy rights that you may have regarding your Personal Information. We have defined the various rights below.

For all Personal Information that we collect about you, you may have the following rights or choices that we will accommodate where your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data. You may also designate an authorized agent to make a request on your behalf.

• Right to access — The right for a consumer to access from a business/data controller the information or categories of information collected about a consumer, the information or categories of information shared with third parties, or the specific third parties or categories of third parties to which the information was shared; or, some combination of similar information.
• Right to correct — The right for a consumer to request that incorrect or outdated personal information be corrected but not deleted.
• Right to delete — The right for a consumer to request deletion of personal information about the consumer under certain conditions.
• Right to opt out of certain processing — The right for a consumer to restrict a business’s ability to process personal information about the consumer.
• Right to portability — The right for a consumer to request personal information about the consumer be disclosed in a common file format.
• Right to opt-out of sales — The right for a consumer to opt out of the sale of personal information about the consumer to third parties.
• Right to opt in for sensitive data processing — The right for a consumer to opt in before a business can process their sensitive data.
• Right against automated decision making — A prohibition against a business making decisions about a consumer based solely on an automated process without human input.
• Right to appeal — where a controller declines to take action regarding a consumer’s request to exercise any privacy right, the controller must allow the consumer to appeal the decision and provide instructions on how they may request an appeal.

In addition, a business may not treat a consumer who exercises a consumer right differently than a consumer who does not exercise a right.

Making a Request

If at any time you wish to make a privacy request, such as if your Personal Information should ever change, you wish to change your preferences, or to delete any Personal Information that you provided to us, please contact us at https://drewestate.com/privacypolicy/individual-request-form/ or (866) 440-3644. We are not responsible for any losses that could arise from any inaccurate, deficient, or incomplete Personal Information that you provide us.

Verifying Your Identity

For security reasons, we may need to request specific information from you to help us confirm your identity, before we correct, update or delete any personal information you provide us.

Once the request has been received, you may be asked to provide additional personal information for verification purposes, including your full name, email address, or telephone number. For requests involving specific pieces of information, we may also require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. In some instances, we may decline to honor your request where the law or right you are invoking does not apply or where an exception applies.

Authorized Agents

You may have the right to designate someone else make privacy requests for you under the data protection laws. Authorized agents must provide us with valid written authorization, that the third-party agent has the authority to act on behalf of the individual whom they are making the request, which must include the agent’s name, email address, and phone number.  The authorized agent must follow the instructions provided in this section to make a request. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request. We reserve the right to verify the validity of any third-party request to exercise privacy rights on behalf of our customers to the fullest extent permitted under applicable data protection law.

Appealing our Decision

If you disagree with a decision we make regarding your request to exercise a privacy right as described in this policy, you may contact us using the Contact Information section below. Please refer to the prior request and include the reason for your appeal in your request.

This section supplements the terms of the Policy and applies only to persons who are California residents.

California law requires us to tell you about the “legal categories” of personal information we have collected or received, disclosed, shared or sold, the sources of personal information, and categories of third parties to whom we have disclosed or sold personal information in the past twelve (12) months. To make this easy to understand, we have summarized this information in the Personal Information Privacy Chart included at the end of this Policy.

California “Shine the Light”

California residents also have the additional rights regarding disclosure of your personal information to third parties for their own direct marketing purposes. We do not share “personal information” as defined by California’s “Shine the Light” law with non-affiliate third parties for their direct marketing purposes. If you are a California resident, and have questions about these practices, or would like to make a request, you may contact us using the methods in the “Contact Us” section below. Requests must include “California Marketing Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mailing address. 

Drew Estate is a U.S. based corporation with its operations and services headquartered in the United States. As such, customers who visit us outside of the U.S. acknowledge and consent to their personal information being transferred to the United States.

We may update this Policy from time to time.  The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is accessible.  In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you, or by posting a notice of the changes on our website prior to the changes becoming effective.

The collection, use, and disclosure of your personal information by us will be governed by the version of this Policy in effect at that time. New versions of this Policy will be posted on this page of our website. We encourage you to check the Policy from time to time. Your continued use of the websites will signify that you consent to the collection, use, and disclosure of your personal information in accordance with the changed policy.

If you have questions or comments about this Policy and/or our privacy practices as they relate to the Services, contact us at [email protected]. If you contact us by email, you should be aware that email transmissions might not be secure. Information you send by email could be viewed in transit by a third-party. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during transmission.

This section summarizes how we process Personal Information in accordance with California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”). The terms used in this section shall have the same meanings as given to them under the CCPA.

In the last 12 months, we have collected or received, shared or sold the following categories of Personal Information: