LAST UPDATED: January 28, 2019
This Privacy Notice (“Notice”) explains how CrowdTwist, Inc and its subsidiaries and affiliated companies (“CrowdTwist” or “we”) collect and use information that can be used to individually identify a person (“Personal Data”) obtained when you make contact with us, use our website at www.crowdtwist.com (the “Site”) or as otherwise detailed below (“Your Data”).
CrowdTwist is committed to protecting your Personal Data and your privacy. We endeavor to ensure that any Personal Data we collect about you will be held and processed strictly in accordance with applicable data protection legislation. If you are resident in the EU (or a country that has adopted a local law to implement or adopt the GDPR) (“EU Residents”), this will include the European General Data Protection Regulation (“GDPR”) or the applicable local law implementing or adopting the GDPR (“Applicable Local Laws”). Please see the section “Additional Information for EU Residents” below, for further information.
This Notice also does not apply to the practices of third parties who we do not own or control, including but not limited to any third party websites, services or applications (each a “Third Party Service”) that you elect to access through the Site or to individuals who we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.
We collect Personal Data about you when you provide such information directly to us, when we obtain it from third parties sources that provide contact information for marketing purposes, or when Personal Data about you is automatically collected in connection with your use of or access to our Site.
Information Collected Directly From Individuals
We collect Personal Data from you in the following ways:
1. When you request additional information about CrowdTwist’s products or services;
2. When you access certain resources made available through our Site (such as a whitepaper).
3. When you submit information to us through our “Contact Us” form;
4. When you register to attend a seminar;
5. When you participate in an online forum, blog, or a voluntary survey;
6. When you ask to be included in an email or other mailing list;
7. When you submit an entry for promotions offered by CrowdTwist directly to you;
8. When you submit your Personal Data to CrowdTwist for any other reason.
We collect the following Personal Data directly from you:
First and last name
Telephone phone number
If you voluntarily provide additional Personal Data to us, we will also collect and hold that data in accordance with this Privacy Notice.
Information Collected from Third Party Sources
We use third party sales promotion and market research companies to obtain Personal Data relating to people we believe may be interested in our Partner Solutions. A list of the third party sources we use is available on request. The information we collect may include your name, business address, job title, company name and business contact details.
Information Collected Automatically Through our Site
Some information is automatically collected when you use or access our Site. For example, we collect information such as the following when a user visits our Site:
Browser type and language
Referring website addresses
Date/time of visits
Page view data
Internet service provider
Device information, such as make, model, operating system type and version
Data connection type
We also collect statistical information about how users use our Site. Some of this information is derived from Personal Data, but it is not used in a way that can be tied back to you or your account.
Like many websites and mobile application operators, we (directly and through our third party service providers) collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Site. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting or using our Site whereas “persistent cookies” are stored on your device for a period of time after you leave our Site. We use persistent cookies to store your preferences so that they are available for your next visit, and to keep a more accurate account of how often you visit our Site and how your use of our Site varies over time. For more information on cookies, including how to control your cookie settings and preferences, visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/and http://www.allaboutcookies.org/.
You may opt-out from receiving targeted advertisements at any time. Please see the NAI website opt-out page here: http://www.networkadvertising.org/choices/ for further information on how to do this.
Our Site use the following cookies:
Essential Cookies: Essential cookies are required for providing you features or services that you have requested. For example, certain cookies enable you to log into secure areas of our website. Disabling these cookies will make certain features and services unavailable.
Functional Cookies: Functional cookies are used to record your choices and settings regarding our Site, maintain your preferences over time, and recognize you when you return to our Site. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies: Performance/analytical cookies allow us to understand how visitors use our Site such as by collecting information about the number of visitors, what pages visitors view, and how long visitors are viewing pages.
Targeting/Advertising Cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to display our advertisements to you when you visit certain other webpages. We may also share this information with third parties for this purpose.
We collect information using Web beacons. Web beacons are electronic images that can be used in connection with our Site, 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 process Your Data for the following purposes:
1. To provide the product or service you have requested – when you request information from us, register for our emails or to attend a seminar, we use the Personal Data you have provided to us in order to respond to your request and provide the information you request. The legal basis for us processing your Personal Data in this way is that it is necessary for the purposes of our legitimate interest of increasing our customer base or providing the service you have requested.
2. To keep you apprised of the latest service offers or other information about us – when you submit Personal Data to us, we add you to our mailing lists so that we can send you marketing materials about us which we believe may be of interest to you. The legal basis for us processing your Personal Data in this way is your consent, which we request at the time you submit Your Data to us. You can opt out of receiving marketing communications at any time using the unsubscribe button in the email. For EU Residents, please see the “Additional Information for EU Residents” below, for further information on how you can withdraw your consent.
3. Operating and improving our internal operations, systems, products, and services and understanding preferences, needs, and interests of our users – we use the information collected through our cookies and web beacons, as well as any feedback you may give us, to help us improve our Site. The legal basis for us processing your Personal Data in this way is that it is necessary for the purposes of our legitimate interest of improving our business.
4. To provide targeted adverts to you online – we use some of the information collected through our cookies and directly from you to display our adverts to you on certain website. The legal basis for us processing your Personal Data in this way is that it is necessary for the purpose of our legitimate interest of marketing our services.
DISCLOSURE OF PERSONAL DATA
We only share Your Data with our carefully selected vendors, third party service providers and agents where it is necessary for the purposes described in this Notice.
These parties include:
Marketing partners– in relation to our marketing activities, we use the following service providers:
a CRM software solution provider to store some of our Personal Data;
a sales automation platform to send marketing communications; and
an online advertising service provider to provide targeted advertising.
Web Analytics service providers – we share Your Data with service providers such as Google Analytics for web analysis purposes.
We will only provide these companies with the information they need to deliver the service we have requested, and they are prohibited from using that information for any other purpose.
We may also share Personal Data when we believe it is necessary to:
Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
Maintain the security of our products and services
We may also share Personal Data with third parties when you give us consent to do so.
We share aggregate or de-identified information with our partners, service providers and other persons with whom we conduct business.
If we choose to buy or sell assets, we may share and/or transfer Personal Data in connection with the evaluation of and entry into such transactions. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers can occur, and that any acquirer of us or our assets can continue to use your Personal Data as set forth in this policy.
We retain Personal Data about you for the period necessary to fulfil the purposes outlined in this Notice. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
SECURITY OF PERSONAL DATA
We take reasonable steps to help protect Personal Data in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction.
PERSONAL DATA OF CHILDREN
We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at email@example.com.
California Privacy Rights
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request using the contact details provided under the “Contact Us” section below.
CHANGES TO THISPOLICY
We may change this Notice from time to time. If we make any changes to this Notice, we will change the “Last Updated” date above. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of our Site, and you are still responsible for reading and understanding them. If you continue to use our Site after any changes to the Notice have been posted, that means you agree to all of the changes.
For questions or comments about this Notice, your Personal Data or our data practices generally, please contact us by email: firstname.lastname@example.org or by mail at: 110 E 23rd St, New York, NY 10010.
You can also contact us through our Data Protection Officer, Calligo, by sending an email to Calligo.CrowdTwistdpo@calligo.cloud.
ADDITIONAL INFORMATION FOR EU RESIDENTS
YOUR PRIVACY RIGHTS
Under the GDPR or Applicable Local Laws, you have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email email@example.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. If we are not the controller of the Personal Data subject to your request, we will need to refer you to the controller party.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Site.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about CrowdTwist’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Your Choices and Opt-Outs
You can opt out of receiving marketing emails from us at any time. You can opt out of our marketing emails by clicking the ‘unsubscribe’ link at the bottom of our marketing messages.
Also, all opt out requests can be made by emailing us at firstname.lastname@example.org. Please note that it may take up to 3 days to remove you contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make a request.
TRANSFERS OF PERSONAL DATA
CrowdTwist is based in the United States and the Site is hosted and operated in the United States (“U.S.”). All of the Personal Data we collect is, therefore, processed in the Unites States. If you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Site or providing your Personal Data to us, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to CrowdTwist in the U.S. and will be hosted on U.S. servers, and you authorize CrowdTwist to store and process your Personal Data in the U.S. CrowdTwist has liability in cases of onward transfers to third parties.
We also use service providers who are located outside the EEA, in countries which are not considered by the European Commission to have an adequate level of data protection in its domestic legislation. Where we transfer your Personal Data to these service providers, we ensure that we have appropriate safeguards in place in accordance with Article 44 of the GDPR, such as certification to the EU-US Privacy Shield.
CrowdTwist complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Economic Area and Switzerland to the United States. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
Please contact us at email@example.com with any questions or concerns relating to our Privacy Shield Certification. If you do not receive timely acknowledgment of your Privacy Shield-related complaint from us, or if we have not resolved your complaint, you may also resolve a Privacy Shield-related complaint through DMA, an alternative dispute resolution provider located in the United States. You can visit https://thedma.org/resources/consumerresources/privacyshield-consumers/ for more information or to file a complaint, at no cost to you. Under certain conditions, you may also be entitled to invoke binding arbitration for complaints not resolved by other means. Additionally, CrowdTwist is subject to the investigatory and enforcement powers of the Federal Trade Commission.
We have appointed Calligo to be our EU representative for the purposes of the GDPR. Please ensure that any correspondence you send to us in relation to your Personal Data is copied to Calligo.