(Last updated 29 July 2020)
THIS POLICY APPLIES TO OUR SERVICES AND ONLINE TOOLS, INCLUDING THE WEBSITE AND SERVICES, AND OTHER (COLLECTIVELY “THE WEBSITE AND SERVICES”), AS WELL AS OTHER INTERACTION (E.G. USER CONVERSATIONS, USER SURVEYS AND INTERVIEWS ETC.) YOU MAY HAVE WITH US.
“Personal data” means any information that enables us to identify you or the beneficiary of your transaction with us, directly or indirectly, such as name, email, address, telephone number, any form of identification number or one or more factors specific to your or your beneficiary’s identity.
We are committed to complying with applicable data protection laws and will ensure that personal data is:
According to the personal information protection and electronic documents act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to Crumble is considered personal information it is possible to relate it back to you through your name, address, e-mail address, telephone number and any other information that can identify you. If information cannot be related to an identifiable individual it is considered anonymous information (such as laboratory results identified by alpha-numeric identifier instead of individual’s name). Whenever possible, Crumble works with anonymous information. This privacy statement does not apply to anonymous information.
Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g. demographic information or web site visitations). Crumble may collect non-personal information through any of the methods discussed above as well as automatically through use of industry standard technologies described further below.
The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011; Cookies is a small text file placed on your computer by this Website and services when you visit certain parts of the Website and services and/or when you use certain features of the Website and services. Details of the cookies used by this Website and services are set out in the (Cookies policy page);
While you are able to visit the Crumble site and remain anonymous, Crumble or its third party service providers may still collect non-personal information about your use of the Crumble materials (e.g. Your internet browser, operating system, ip address, connection speed, and the domain name of your internet service provider). Such information may be gathered by the following methods:
You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.
For purposes of the General Data Protection Regulation (GDPR), Crumble is the "data controller". We will retain any Data you submit for a minimum of 12 months or the length of our services. Unless we are obliged or permitted by law to do so, and subject to any third party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group.
All personal Data is stored securely in accordance with the principles of the General Data Protection Regulation. For more details on security see the clause below (Data Security). Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website and services. Specifically, Data may be used by us for the following reasons:
We may use algorithms and other automated means to implement any of the above.
The Sites may provide you the opportunity to participate and post content publicly in forums, through interactive features and through other communication functionality ("Community Forums"). You may choose, through such features or otherwise, to submit or post photographs, videos, questions, comments, suggestions or other content, (collectively, "User Content").
We share data with third parties as follows:
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and devices. DNT is a way for users to inform website and services and services that they do not want certain information about their webpage visits collected over time and across website and services or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
As noted above, you may limit advertising tracking using advertising identifiers through your browser privacy settings. The online advertising industry also provides website and services from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or www.youronlinechoices.eu and www.aboutads.info/choices.
We retain your data for as long as you have an account. When you close an account, we will delete your personal information. We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it. If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.
Legal Bases for Processing your Information:
For individuals who are located in the European Economic Area, United Kingdom or Switzerland (collectively “EEA Residents”) at the time their personal data is collected, we rely on legal bases for processing your information under Article 6 of the EU General Data Protection Regulation (“GDPR”). We generally only process your data where we are legally required to, where the processing is necessary to perform any contracts we entered with you (or to take steps at your request prior to entering into a contract with you), for our legitimate interests to operate our business or to protect Crumble application and website and services or your, property, rights, or safety, or where we have obtained your consent to do so. Below is a list of the purposes described in our policy with the corresponding legal bases for processing.
We enable you to make numerous choices about your data:
Crumble complies with both the Children’s Online Privacy Protection Act of 1998 (COPPA) and, with regard to EU data subjects, with GDPR. We do not knowingly request to collect personal information required for Crumble services from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, Crumble will prevent user from registering for an account, also Crumble retains the right to close such account and or not allow such users to continue using Crumble Service. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.
To facilitate our global operations, Crumble may transfer, store, and process your information within our family of companies, partners, and service providers based throughout the world. We contractually obligate recipients of your personal information to agree to at least the same level of privacy safeguards as required under applicable data protection laws. By communicating electronically with Crumble, you acknowledge and agree to your personal information being processed in this way. If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please submit your request via any of Crumble provided CONTACT US mediums.
If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services
Crumble takes appropriate security measures to protect against unauthorized access, alteration, disclosure or destruction of personal information. These include, but are not limited to, internal reviews of: (a) Crumble’ data collection; (b) storage and processing practices; (c) electronic security measures; and (d) physical security measures to guard against unauthorized access to systems where Crumble stores personal information. All Crumble employees, contractors and agents who access personal information are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution or unauthorized use or disclosure of personal information.
The Crumble contents may contain links to third parties who may collect personal information and non-personal information directly from you. Additionally, Crumble may use third parties to provide components of the Crumble contents. In either case, such third parties may have separate privacy policies and data collection practices, independent of Crumble. Crumble: (a) has no responsibility or liability for these independent policies or actions; (b) is not responsible for the privacy practices or the content of such site; and (c) does not make any warranties or representations about the contents, products or services offered on such App or the security of any information you provide to them
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, Crumble do not monitor or take any action with respect to these signals or other mechanisms.
By creating an account, you consent to receive commercial emails from us. This includes newsletters and offers. Users from certain countries may have the ability to opt out or opt in at the time of account creation. All users may decline to receive commercial messages in their account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).
We are committed to maintaining the security of your personal data and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We employ modern and secure techniques to protect our systems from intrusion by unauthorized individuals, and we regularly upgrade our security as better methods become available. Our data centers and those of our partners utilize modern physical security measures to prevent unauthorized access to the facility. In addition, all personal data is stored in a secure location behind firewalls and other sophisticated security systems with limited (need-to-know) administrative access. All our employees who have access to, or are associated with, the processing of personal data are contractually obligated to respect the confidentiality of your data and abide by the privacy standards we have established. Please be aware that no security measures are perfect or impenetrable. Therefore, although we use industry standard practices to protect your privacy, we cannot (and do not) guarantee the absolute security of personal data.
This applies only to natural persons residing in the European economic area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Crumble’ policy to comply with the EU'S general data protection regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the United Kingdom (or other countries) based upon the following legal frameworks:
We enable exercise of these rights primarily through our services (which we reserve the right to modify). We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us. If you have a request, complaint or inquiry, please contact our data protection officer at the address listed below. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.
If you are an EU resident and Crumble is processing, and/or transmitting your personal data, then you - as an “EU data subject” – benefit from the following rights and privileges under the General Data Protection Regulation (GDPR):
Right of Access: you have the right to obtain from us, as controllers, confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the following personal data and information:
Right to Rectification: you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerned, provided during registration by him or her. Taking into account the purposes of the processing, the user have the right to have request his incomplete personal data be completed, including by means of providing a supplementary statement.
Right to Erasure (“Right to be Forgotten): you have the right to obtain from us the erasure of your personal data without undue delay, and we have the obligation to erase personal data without undue delay when: a) your data are no longer necessary for the purposes for which they were collected; b) you had consented to the processing; c) you have objected to the processing, as per below; d) your persona data had been unlawfully collected; e) your personal data need to be erased as a matter of compliance with a legal obligation.
Right to Restriction of Processing: you have the right to obtain from us the restriction of processing if you: a) contest the accuracy of the personal data, until this is verified; b) the processing is unlawful but you don’t want erasure; c) we no longer need the personal data, but you require them to establish, exercise to defend a legal claim; d) you have objected to processing but there is a need to verify whether our legitimate grounds override your rights to object.
Right to Data Portability: where your personal data have been provided on the basis of your consent or for the performance of a contract, and their processing occurs in an automated way, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data– or have directly transmitted - to another controller.
Right to Object: you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on a legitimate ground point (e) or (f) of Article 6(1), including profiling based on those provisions. In this case, we can no longer process your personal data unless we show that there is a compelling legitimate ground for the processing which override your interests, rights and freedoms or for our establishment, exercise or defense of legal claims.
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us firstname.lastname@example.org. You can also change your marketing preferences. You can also exercise the rights listed above at any time by contacting us at email@example.com.
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at firstname.lastname@example.org. We will process your request within a reasonable time after receipt.
If you do not want your Personal Information or Personal Data shared with any third party who may use such information for direct marketing purposes, then you may opt-out of such disclosures by sending an email email@example.com. Please note that if you opt out in this manner, certain aspects of the site and platform may no longer be available to you. We will process your request within a reasonable time after receipt.
The Site uses its best endeavors to store all Personal Information on servers with restricted access, and all electronic storage and transmission of Personal Information are secured with appropriate security technologies. Not to withstand the foregoing, the app cannot guarantee that such precautions would render the Site and its servers immune to security breaches.
To learn more about our terms and conditions, please visit our Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of our website and services
You may update your subscription preferences with respect to receiving communications from us and/or our partners by signing into your account and visiting “Settings” under your profile page or alternatively emailing us at firstname.lastname@example.org.