Our Privacy Policy

In this Policy the following terms shall have the following meanings:

Account Means an account required to access and use Our Application;

Cookie means a small text file placed on your computer or device by Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and;

Cookie Law means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Our Site is owned and operated by CROWDHANDLER LTD, a limited company registered in England under company number 12677268, whose registered address and main trading address is 97 Icknield Street, Birmingham, England B13 9SR.

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out below, using the methods described. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy, available at https://www.crowdhandler.com/cookies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

• Contact information - e.g. email address, collected when registering an account and/or user onto the system.

• Business information - e.g. address, collected when registering an account and kept up to date via the control panel.

• Profile information - e.g. login details, collected when registering a user account

• Payment information - e.g. credit card details. Collected and stored by our payment provider for subscription billing

• Technical information - e.g. IP address, browser type, version and operating system and language preference. Collected when using a waiting room, accessing the control panel, and/or API.

• Data from third parties - e.g. user profile advertising information collected by third parties and used lawfully in connection with their marketing services.

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following paragraphs describe how we use your personal data, and our lawful bases for doing so:

Consent

• By registering an account and agreeing to our Terms Of Service, you permit to receiving marketing emails regarding the CrowdHandler product. Consent can be withdrawn at any time by using the unsubscribe links attached to all marketing emails.

• By using our Site, you permit to data being used inline with our Cookie Policy. This may include cross-referencing with third party information, e.g. for marketing profiling purposes.

Contract

• Personally identifying business information (e.g. a personally identifiable business email address) may be used in order to fulfil the contract that we enter when you accept the Terms of Service.

• Profile information (e.g. login details) are used in order to fulfil the contract by providing our services.

• Payment information is used in order to fulfil the contract by enabling the continuation of a subscription

Legitimate Interests

• Technical information (e.g. IP address, browser type, version, operating system and language preference) are used in order to provide and ensure a fair waiting-room service, that does not favour individuals who make multiple or fraudulent connections. IP addresses or device fingerprints may be cross-referenced with third-party databases of known fraudulent addresses, however IP addresses will not be linked to individual personal data (i.e. by cross referencing with an ISP database) except where we are required to do so by vital interests (i.e. threat to life situations) or legal obligation.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including FreshDesk, MailChimp, SquareSpace, Google, Twitter and LinkedIn) whose content appears on Our Site or the Application may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• Contact information - e.g. email address, collected when registering an account and/or user onto the system. will be retained until the account and/or user is deleted by the user’s action.

• Business information - e.g. address, collected when registering an account and kept up to date via the control panel. Will be stored for up to six years after the last usage of the account to meet legal obligations.

• Profile information - e.g. login details, collected when registering a user account will be stored until up to one month after the profile is deleted.

• Payment information - e.g. credit card details. Collected and stored by our payment provider for subscription billing. Will be stored until the user explicitly deletes it (in which case deletion will be immediate) or until 30 days after the payment method expires.

• Technical information - e.g. IP address, browser type, version and operating system and language preference. Collected when using a waiting room, accessing the control panel, and/or API. Will be retained for up to 30 days after connecting.

We store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under Data Protection Legislation as follows:

We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguard is applied to such transfers:

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may share your personal data with other companies in our group for contract fulfilment purposes. This includes our holding company and its subsidiaries.

We may sometimes contract with the following third parties to supply certain products and services.

Recipient

Amazon Web Services
Data Processor - Cloud hosting, network and storage services - data processor. No personal data is held here other than email addresses associated with user-logins and IP addresses and agent strings used for maintaining sessions, and network connections and analysing waiting room traffic. Data is held in United States, Virginia.

Stripe
Data Processor - Payment processing - payment details: card details and cardholder. Data is held in United States.

MailChimp
Data Processor - Marketing information. Holds email addresses with associated company and plan information.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site or our Application, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).

You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

You may access certain areas of Our Site without providing any personal data at all. However, to use the Application you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 and our Cookie Policy https://www.crowdhandler.com/cookies.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

Our Site and the Application may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. By using Our Site or the Application you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for advertising re-targeting. In addition, Our Site uses analytics services provided by Google, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how people use Our Site. For more details, please refer to our Cookie Policy at https://www.crowdhandler.com/cookies.

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: support@crowdhandler.com.

Telephone number: +44 29 2168 0805.

Postal Address: 97 Icknield Street, Birmingham B18 6RU, England.

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business or the Application in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site or the Application following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on Oct 26 2020.