Privacy Policy

Personal information you disclose to us In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Passwords are processed through OPAQUE; Droccy receives an authentication record rather than the plaintext password.

usernames

user ids / uuids

Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission: Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's microphone, storage, camera, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Link Preview Data. When you send a supported HTTP or HTTPS link, the sender application may transiently submit that URL to Droccy so our server can request limited public metadata such as the page title, description, author, and thumbnail. We do not separately store or cache the submitted URL or retrieved metadata; sanitized preview metadata is encrypted on the sender's device as part of the message.

Space Data. To operate an invite-only Space, we process Space membership, owner/admin/member roles, custom role names, icons, colors, gradients and assignments, custom emoji names and converted 32 by 32 PNG images, category and channel ordering, text or voice channel type, optional custom Space profile pictures and header images, account and remembered-device identifiers, timestamps, read and mention state, presence, voice-room participation, public MLS GroupInfo, commit and epoch records, public device-leaf credentials and signing keys, and encrypted payload sizes. Space images, custom role definitions, and custom emoji images are restricted to authenticated members but are not MLS-encrypted. Space names, category and channel names, topics, messages, reaction content, private MLS device state, and history archives are stored as ciphertext.

Space History Choices. Space history defaults to content sent from the time a member joins. If a Space owner enables full history, encrypted retained epoch keys may allow current members and future invitees to decrypt earlier channel content. Disabling full history affects future joins only; keys already delivered to a member or device cannot be technically revoked.

Space Invites. The authorization token is received by the service and stored only as a digest. A separate 256-bit fragment secret remains after the # character in the invite URL, is not sent in HTTP requests, and must not enter Droccy server plaintext, query strings, analytics, or logs. The service stores an opaque encrypted invite envelope.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including: To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.

To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

Account creation and authentication. We use usernames, UUIDs, OPAQUE authentication records, and related account information to create accounts, verify login attempts, maintain user sessions, and allow users to access the platform. The server does not receive the plaintext password.

Providing the service. We use personal information to operate the website, mobile app, desktop app, and related services, including saving user settings, identifying accounts, and making core platform features work.

User-to-user communications. We use account identifiers, encrypted message records, membership and delivery metadata, WebRTC signaling, and voice participation data to enable direct messages, groups, Space text channels, calls, and Space voice rooms. Message and reaction content is end-to-end encrypted, while the operational metadata described in this Notice remains visible to Droccy.

Rich-link previews. We transiently process a sender-submitted URL to retrieve public page metadata before the preview is encrypted into the message. The destination website or its metadata provider can observe Droccy's server request. Preview thumbnails load from the image host without a referrer, and that host can observe the recipient's network address.

Security and abuse prevention. We use personal information to protect accounts, detect misuse, prevent spam, block unauthorized access, enforce our terms, and keep the platform secure.

Support and administrative messages. We use personal information to respond to user questions, provide support, send important service notices, and communicate about account, security, or policy-related updates.

Security, abuse prevention, and account protection. Reason: We use limited personal information, such as UUIDs, usernames, and OPAQUE authentication records, where necessary to identify user accounts, authenticate users, protect accounts, prevent unauthorized access, detect misuse, enforce our Terms, and keep the platform secure.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our products and services so we can improve user experience

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next of kin

If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations: Business Transfers. We may share or transfer your information 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.

Other Users. Droccy Spaces are private and invite-only, with no public discovery directory. Members of a Space can see the configured account identity, role, presence, and voice participation of other Space members and can receive content shared in channels. Participants who receive decrypted content can copy, record, or share it outside Droccy, so end-to-end encryption does not control what an authorized recipient does after decryption.

In Short: We are not responsible for the safety of any information that you share with third parties that we may link to or who advertise on our Services, but are not affiliated with, our Services.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We keep account and service information only for the periods needed for the purposes described here, unless a longer period is required or permitted by law. After account deletion, we permanently reserve the random account UUID to prevent identity reuse. When surviving encrypted group or Space history requires it, we may also retain the deleted account's public encryption/signing identity and public MLS leaf tombstones needed to validate surviving ciphertext. These records contain no password, private key, nickname, metadata key, content key, or message plaintext.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

Space content uses OpenMLS through a pinned Rust/WebAssembly wrapper, together with client-side metadata, content-key, and history-archive encryption. This design does not hide operational metadata listed in this Notice and does not make compromised endpoints or authorized recipients trustworthy. Space support remains disabled by default until its production security, independent-review, and rollout gates are completed.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at mailo@mailodatacenter.com.

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority (https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm) or UK data protection authority (https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/).

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home.html).

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.Account Information If you would at any time like to review or change the information in your account or terminate your account, you can: Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at mailo@mailodatacenter.com.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.Categories of Personal Information We Collect The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT? "

CategoryExamplesCollectedA. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

YES

B. Personal information as defined in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information

NO

C. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data

NO

D. Commercial information Transaction information, purchase history, financial details, and payment information

NO

E. Biometric information Fingerprints and voiceprints

NO

F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

NO

G. Geolocation data Device location

NO

H. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities

YES

I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

NO

J. Education Information Student records and directory information

NO

K. Inferences drawn from collected personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics

NO

L. Sensitive personal Information

NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for: Category A - For the account lifetime, except that the random UUID remains reserved after deletion to prevent identity impersonation and limited public-key history may remain while surviving encrypted group grants depend on it.

Category H - Files selected for sharing may include audio, visual, or electronic data. File payloads are encrypted on the sender device and transferred directly to the recipient over WebRTC. Droccy does not receive or store the file payload.

Sources of Personal Information Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT? "How We Use and Share Personal Information Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION? "

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? "

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers. Your Rights You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include: Right to know whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request the deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to non-discrimination for exercising your rights

Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights: Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)

Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)

Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights To exercise these rights, you can contact us by visiting https://droccy.com/settings/account/data-request, by emailing us at mailo@mailodatacenter.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. Request Verification Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.Appeals Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at mailo@mailodatacenter.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.California "Shine The Light" Law California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE? "

We collect only limited account information needed to operate the service, such as a UUID, an optional username, and password authentication records that do not reveal your password to the server. We do not require users to provide a real name, phone number, mailing address, or payment information unless this is clearly requested in the service.

By default, users may be identified by a UUID. Users may choose to set a custom username, which may be visible to other users when they interact through the platform.

Passwords are stored only as secure hashes and are not stored in plain text. We do not disclose passwords or password hashes in response to data access requests for security reasons.

File payloads are transferred directly between participating devices over WebRTC and are not stored by Droccy.

Peer-to-peer files may contain personal information depending on what a user chooses to share. Users are responsible for ensuring that they have the right to share those files or other content.

When users interact with each other, other users may see limited account information, such as a username, display name, or UUID. Other users cannot see passwords or private account security information.

Within a Space, every member may see the Space's member identities, roles, configured presence, and voice-room participation. Droccy does not offer private Space channels or per-channel permission overrides in the initial Space release.

Users may request access to, correction of, or deletion of their personal information through https://droccy.com/settings/account/data-request. Export format version 7 includes account and active-session metadata, relationships, DM/group records, Space memberships, built-in and custom roles, custom emojis, encrypted Space descriptions and Space/category/channel metadata, accessible channel ciphertext and read state, public MLS delivery and commitment records, and only the requesting account's opaque device state and history archives. It excludes passwords, OPAQUE records, bearer tokens, TOTP seeds, rate-limit records, Space invite authorization tokens, invite fragment secrets, invite envelopes, and another member's private MLS state.

Because peer-to-peer file payloads are not stored by Droccy, we cannot access, recover, or provide copies of transferred files.

Our service may include third-party GIF selector or advertising features, including services provided by Klipy. It may also contact a linked website or its metadata provider when a sender requests a rich-link preview. These third parties may process network and request information according to their own privacy policies and technologies. Droccy suppresses referrer information when recipient devices load preview thumbnails.

We do not sell users' personal information. If this changes in the future, we will update this Privacy Policy and provide any choices required by applicable law.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at mailo@mailodatacenter.com or contact us by post at:

Droccy

Netherlands

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please visit: https://droccy.com/settings/account/data-request.