Privacy Policy

Privacy Policy

Effective Date: 1/1/2022

The materials on the Drumroom software (“Drumroom”) and the Drumroom website are provided by Drumroom, Inc. (hereinafter “us” or “we”). The Drumroom website at https://www.drumroom.io (including all content under the “drumroom.io” and “drumroom.net” domain names) are owned by us and is referred to herein as the “website.” The website, Drumroom, and the associated products, services, data, information, updates, and materials that we provide are referred herein and in the Terms as the “services.” This notice (“Privacy Policy”) is part of and supplements our Terms of Service (the “Terms”). This Privacy Policy explains our online information collection and use practices, and the choices you can make about the way we use such information. It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information. REMEMBER – IF YOU ACCESS OR USE THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. AS WE UPDATE OR EXPAND OUR SERVICES, WE MAY CHANGE THIS PRIVACY POLICY UPON NOTICE TO YOU IF WE HAVE YOUR EMAIL ADDRESS. HOWEVER, PLEASE REVIEW IT FROM TIME TO TIME.

  1. 1. Important Notices

    1. 1.1 EU Privacy Rights. For users that are citizens of the European Union (“EU”), this Privacy Policy is subject to the provisions of the General Data Protection Regulation (“GDPR”) and other applicable privacy laws. In such case, we are a data “Controller” and you are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.” We will take commercially reasonable steps to maintain compliance with GDPR requirements. Your Personal Data may identify you as a person, and thus is often referred to as Personally Identifiable Information (“PII””).

1.2 California Privacy Rights. The California Consumer Privacy Act (“CCPA”) of 2018 enhances privacy rights and consumer protection for residents of California. Under the CCPA, California residents have the rights to: 1) know what Personal Data are being collected about them; 2) know whether their Personal Data are sold or disclosed, and to whom; 3) say ‘no’ to the sale of their Personal Data; 4) access their Personal Data; and 5) not be discriminated against for exercising their privacy rights under the CCPA. California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their PII to third parties. To make such a request, please contact us as indicated in the “Contact” section at the bottom of this Privacy Policy. Please include enough detail for us to locate your account; at a minimum, your or your child’s name, email address and username, if any. We will attempt to verify your identity and provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted via methods other than the ones posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

  1. 2. Information Collection

We may collect information from you through the services, and we are responsible for the protection of your information that we collect from you. When you use Drumroom, we will not collect any PII about you unless you choose to provide such information to us.

2.1 Requested Information. On various pages of the services, we may request specific PII about you to register you for an account, add you to our email list, facilitate your payments for services or subscriptions, or fulfill your requests for information. You may choose not to provide your PII, but then you might not be able to take advantage of some of the features of our services. We only collect basic Personal Data from you that does not include any special types of information (e.g., biometric or health-related). The types of Personal Data we collect and save include:

  • Contact and account information such as account user’s name, the account creator’s email address, physical billing address

  • Financial information such as name, credit card number, CVV code, date of expiration;

  • Information you provide such as feedback, comments, or other messages; and

  • Device information such as the mobile phone provider associated with the device you are using to access the website or services, the type of device and its operating system, calls and messages placed through the website or services, how pages or features of the services are used, and similar analytics about use of the website or services.

2.2 Financial Information. All personal financial information required to complete your purchase will be securely collected for purposes of processing payments and completing transactions. In some cases, we may securely provide this personal financial information to a third-party vendor who provides us with payment processing services.

2.3 Information Retained. The services retain and store documents created or edited, and saved during use of Drumroom. We collect this solely to make it available to you as a benefit of your account. We do not share this information with any third parties, except in the circumstances described in the Disclosure and Sharing section, below.

2.4 Tracking and Aggregated Information. We may automatically and through third-party tracking services (e.g., Google Analytics) gather certain non-PII about your use of our services and store it in log files. This information may include browser type, operating system, date/time stamps, and related data. We use this information, which does not identify individual users, solely to improve the quality of our products and services. Out of respect for your privacy, we do not link this automatically-collected data to PII.

  1. 3. Information Use

3.1 Use of Personal Data. We use the Personal Data you provide for the purposes for which you have submitted it, including:

  • Creating and Maintaining Your User Account. We use your PII to create and maintain an account for Drumroom for you to allow you to purchase and use the services.

  • Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to respond to your inquiries and to fulfill your requests for information.

  • Communicating With You About Our Services. We may use your PII to send you marketing information about new or updated services, and other items that may be of interest to you.

  • Improving Our Services. We may use your information to make our services more stable and user-friendly, to analyze service issues, and to develop new marketing programs relating to the services.

  • Sending Administrative Emails. We may use your PII to send you emails to: (a) confirm your account and other provided PII, (b) process transactions that you make using our services, (c) provide you with information regarding the services, or (d) inform you of changes to this Privacy Policy, our Terms, or any other policies.

3.2 Use of Anonymous Data. We may use anonymous information that we collect to improve the design and content of our website, and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze how our website is used, analyze industry trends, as well as to offer you programs or services.

4. Disclosure and Sharing

4.1 Sharing Policy. In general, we will not share your Personal Data except: (a) for the purposes for which you provided it; (b) with your consent; (c) as may be required by law (e.g., in response to a court order or subpoena, or in response to a law enforcement agency request); (d) as we think necessary to protect our organization or others from injury (e.g., when we believe that someone is causing, or is about to cause, injury or interference with the rights or property of another); or (e) on a confidential basis with persons or organizations with whom we contract to carry out internal site operations or as necessary to render the services.

4.2 Although it is not our practice to sell your Personal Data, the CCPA further restricts us from selling your Personal Data if you click the “Do Not Sell My Personal Information” link on the website.

4.3 Successor in Interest. We may transfer your Personal Data to our successor-in-interest in the event of an acquisition, sale, merger, or bankruptcy. In the event we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, any PII we have on record will likely be among the interests transferred. The transferred PII will remain subject to the provisions of this Privacy Policy, as it is updated from time to time.

5. Access and Control of Account Creator’s Personal Data

5.1 Access and Control After registering for an account for you, or your child, you may log-in to the account and edit your Personal Data in your profile [if not available, should be added]. For instructions on how you can further access your Personal Data that we have collected, or how to correct errors in such information, please contact us as indicated in the “Contact” section at the bottom of this Privacy Policy. We will promptly stop using your information and remove it from our servers and databases at any time upon your request. To protect your privacy and security, we will take reasonable steps to help verify your identity prior to granting access, making corrections, or removing your information.

5.2 EU Citizens If you are an EU citizen and believe that we have misused your Personal Data, you have the right to contact the European Data Protection Supervisor (“EDPS”) to ask the EDPS for advice on how to exercise your rights or to ask the EDPS to investigate a complaint. For more information, see EDPS Complaints.

5.3 Access to Login Information. Should you forget your account login information, you may request that we send it to the email address associated with your account. To prevent unauthorized disclosure of and access to your account, you should always keep your account information secure.

6. Children and Young People’s Personal Information

6.1 Required Information. We will not request additional Personal Information from an account creator or account user after the initial account creation stage unless reasonably necessary to respond to a service or information request by the account creator, or there is an issue with payment under the billing policies defined in the Terms.

6.2 Compliance with COPPA. Drumroom, Inc.’s services are intended to comply with COPPA. If you reside in the United States, we encourage you to visit for more information about COPPA and children’s privacy. If we become aware that we have collected COPPA-restricted Personal Information from any child other than as permitted under law, we will dispose of the information, or otherwise treat it in accordance with COPPA and other applicable laws and regulations. If you, as the child’s parent or guardian, believe that your child under thirteen years of age (13) provided us with Personal Information, as defined by COPPA, without COPPA’s required consent, please contact us as indicated in the “Contact” section at the bottom of this Privacy Policy.

Should a child under sixteen years of age (16) post content or information on the services, the user can request that the content or information be removed from public display. This removal can be done by contacting us as indicated in the “Contact” section at the bottom of this Privacy Policy, making such a request, and stating that they personally posted the content or information and where the information is posted. We will make reasonable, good faith efforts to either anonymize the information or remove the content.

6.3 Maintaining Child’s Personal Information You are responsible for maintaining the information that you submit to us. You may review, correct, update, or remove a child’s Personal Information as outlined prior in section 5.1. If you edit or request deletion of any Personal Data, information may persist internally for Drumroom, Inc.’s administrative purposes as permitted or required by applicable law.

6.4 Interaction with Other Users. We have made efforts to design Drumroom to limit your child’s interaction with other users. Users with a “teacher” profile (the “Teacher”) may send a pairing request to users with a “student” profile (aka your child). There is no interaction between users unless a pairing request has been approved. Once you have authorized a pairing between your child and the Teacher, the Teacher may send text and drumbeat transcriptions to your child, and your child may send drumbeat transcriptions to the Teacher. Please supervise your child’s use of Drumroom and the website and teach them about protecting themselves and their Personal Information online.

7. Notification Options

7.1 Notifications and Alerts. If you choose to create a Drumroom account and/or purchase the services, we will send you a welcome email confirming the creation of a Drumroom account that includes information about your subscription plan and your account. We will also notify you via email upon any changes to this privacy policy, or changes to your account.

7.2 Notification Opt-In. We offer you the ability to opt-in to receive notifications about new or upcoming products or services, and promotional materials and offers from us as well as from our subsidiaries, marketing partners, advertisers, and other third parties. We may offer these notifications via email. Out of respect for your privacy, you may opt-out of receiving these notifications as instructed in each email.

7.3 Email Notification Opt-Out. If you no longer wish to receive email notifications, you may opt-out of receiving them as instructed in each email. Be advised that you may not opt-out of receiving administrative email notifications from us related to technical support or customer service requests, billing and subscription issues, or changes to the services’ Terms or Privacy Policy.

7.4 Browser Notification Opt-Out. If you no longer wish to receive browser notifications, you may opt-out of receiving them by using the instructions at the following links:

8. Cookies and Other Network Technologies

8.1 Cookies. To enhance your online experience with us, our services may presently or in the future use “cookies.” A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use session ID cookies to make it easier for you to use the services. A Session ID cookie expires when you close your browser. You are free to decline to accept cookies, but by doing so, you may not be able to take full advantage of all our services. We do not link the information we store in cookies to any PII you may submit while using our services.

8.2 Clickstreams. As you use the Internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to the website. We may use clickstream data of our website as a form of non-PII to determine how much time visitors spend on each page of our website, how visitors navigate through the website, and how we may tailor our website to better meet our visitor’s needs. We will only use this information to improve our website.

8.3 Do Not Track. Many modern web browsers give you the option to send a “Do Not Track” signal to the websites you visit, indicating that you do not wish to be tracked. Currently, the website and services respond to “Do Not Track” signals.

8.4 Advertising. Drumroom, Inc. may use third party advertising servers, advertising network providers, or advertisers (collectively “Ad Providers”). We are very selective of the Ad Providers we work with and only intend to authorize Ad Providers that (i) do not use Drumroom or the website to associate tracking cookies with our users, or (ii) target online behavioral advertising to our users while using the website or Drumroom. Third party advertising services will not have access to the Personal Data we collect from you. Drumroom, Inc. makes good faith efforts to monitor its Ad Providers for continued compliance with the above practices and is legally entitled to terminate its relationship with any Ad Provider should the provider change its approach to Personal Information, and/or provide targeted advertising in a manner inconsistent with these restrictions. We make efforts to keep all advertisements appropriate, in our opinion, to our audience. Further, we may offer parents options to limit ads, such as ad blocking.

Drumroom may use unique identifiers such as cookies, web beacons, or similar technologies to gather user data and may allow others to do so in connection with the Website. Specifically, Drumroom allows the use of cookies for ad campaign analytics and frequency capping, and for segregating Website users from profiling for online behavioral advertising purposes. Drumroom may also use web beacons to track the effectiveness of a particular advertising campaign. Third party use of cookies and web beacons are subject to their own privacy policies.

8.5 User Behavior Tracking. We may track the pages, links, and functions our users visit within our services, to determine what services are most popular. We may also collect user data to track the areas of the services where users most frequently move the mouse or click. These tracking activities make it possible to monitor and analyze web traffic and evaluate user behavior to customize our services.

9. Information Security and Storage

9.1 Security. After receiving your Personal Data, we will store it on our website systems for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access maintain data security, and correctly use the information we collect. Unfortunately, no data transmission or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.

9.2 Server Location. If you are visiting the website or using Drumroom from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our web servers and internal systems located within the USA. By accessing or using the services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the USA, where you may not have the same rights and protections as you do under local law.

9.3 Storage. We store Personal Data for as long as reasonably required for its purpose or for any additional period required by law (if any). Account information is deleted when you or when we delete your account. We may store information longer for legitimate business reasons (for example, Personal Data may remain in backups for a reasonable period of time), or as legally required.

10. Changes to this Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future we plan to use your Personal Information in a way that differs from this Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a change to our Privacy Policy, we will email the updated Privacy Policy to the email address that you have provided to us. Your continued use of the services following our notice of changes to this Privacy Policy means you accept such changes.

11. Contact Us

If you have any questions or concerns about these Terms, the website, or Drumroom, please click here to contact us or call us at (978) 462 – 1100 ext. 301.