LAST UPDATED: APRIL 24, 2015

This Policy explains how CrowdTwist and its subsidiaries and affiliated companies (“CrowdTwist” or “We”) collect and use personal information on behalf of its business partners (“Partners”) that use our loyalty and data solutions (“Solutions”). Personal information we collect on behalf of our Partners are ultimately governed by their own privacy policies, and we do not control or direct, nor are we responsible for our Partner’s practices with respect to that information. This privacy policy (“Policy”) does not cover the information collected on www.crowdtwist.com.

CrowdTwist complies with the U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union. Information regarding the U.S. – EU Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework can be found at: http://export.gov/safeharbor.

We self-certify compliance with:

 

INFORMATION COLLECTED

As directed by our Partners, we may receive and collect personal information in connection with our Solutions on their behalf. For example, we may receive and collect name, email address, postal address, phone number, payment information, demographics and other information. We may also help our Partners collect data from other sources (for example, information derived from social networking sites used to sign in to our Partners sites and online services and demographics information from third party data providers) and combine that with personal information we received and collect for our Partners.

Some information is automatically collected through our Solutions. For example, we may collect the following: IP address, browser type and language, referring website addresses, date/time of visits, page view data, visitor activities and actions on Partners’ websites and online services, browser history, Internet service provider, referring/exit pages, date/time stamp, geolocation (city, country, and zip code), click data, types of advertisements viewed, and information about visitor’s computer or device including make, model, operating system type and version, and data connection type. We also collect information about usage and activity of our Solutions.

Cookies. We may automatically collect information using “cookies.” Cookies are small data files stored on your computer or device by a website. Among other things, cookies help us improve the Solutions and your experience on behalf of our Partners. We use cookies to see which areas and features are popular and to count visits to our Partner’s websites and websites we host and track for our Partners.

Web Beacons. We may collect information using Web beacons. Web beacons are electronic images that may be used in connection with our Solutions, including in emails we send on behalf of Partners. We use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon

USE OF INFORMATION WE COLLECT

We use personal information collected through our Solutions for the purpose of providing services to our Partners and improving our Partner Solutions. The following are just a few examples of ways we may use personal information on behalf of our Partners, to:

 

  • operate and improve their and our internal operations, systems, products, and services;
  • understand preferences, needs, and interests of our Partner’s customers;
  • process and deliver contest entries and rewards;
  • provide and deliver products and services;
  • send information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
  • communicate about contests, promotions, rewards, upcoming events, and other news about products and services offered by and through our Partners;
  • link or combine information with data we get from third parties, to help our Partner’s further understand their customers; and 
  • protect, investigate, and deter against fraudulent, unauthorized, or illegal activity on behalf of all of our Partners.

We may store and process personal information in the United States and other countries directed by our Partners that may have data protection laws different than your home country. We do not own or control the data that we process on behalf of our Partners, but will adhere to and be guided by the privacy principles of the safe harbor framework. Our Partners may use personal information for other purposes other than listed above and may store and process your personal information in other locations, please visit their respective privacy policies to understand their practices.

 

DISCLOSURE OF PERSONAL INFORMATION

We do not disclose personal information with third parties other than as allowed and directed by our Partners, which may include, for example, allowing our subcontractors to access and use personal information to help us provide services to our Partners and transferring personal information in connection with a merger, acquisition, or divestiture to another company assuming providing services on behalf of our Partners. We will work with subcontractors that also adhere to the safe harbor principles or enter into appropriate contracts with them to ensure data meets privacy principles of safe harbor.

SECURITY OF PERSONAL INFORMATION

We take reasonable steps to help protect personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We may also take additional steps to safeguard personal information as directed by our Partners.

INFORMATION CHOICE AND ACCESS

We facilitate requests relating to choice and access of personal information in the manner directed by our Partners. Requests relating to choices such as marketing opt-outs, and deletion, update, or access of data, should be directed to our Partners through the mechanisms they provide or which we provide on their behalf through the Solutions or through the contact information in their respective privacy policies. If you need help contacting a Partner, please contact us at info@crowdtwist.com and provide the name of the Program you are inquiring about.

DISPUTE RESOLUTION

If you are not completely satisfied with our resolution of your data privacy concern then you may contact our dispute resolution provider, Direct Marketing Association (DMA) for assistance in resolving your complaint. DMA may be reached at:

DMA Safe Harbor Program
Direct Marketing Association
1615 L Street, NW – Suite 1100
Washington, DC 20036
safeharbor@the-dma.org
http://thedma.org/consumer-guide/

CHANGES TO THIS POLICY

 

We may change this Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date above.

QUESTIONS

 

For questions about this Policy, please contact us at info@crowdtwist.com. For questions regarding use of personal information by our Partners, please contact them directly.