Section 1. Who We Are
CrowdPoint Technologies, Inc. collects your personal data directly from You, through our Platform and Services. All capitalized terms not otherwise defined in this Privacy Policy (for a list of definitions see our “Definitions” section on Appendix A below)shall have the same definitions ascribed to them in the Terms of Use.
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Platform and Services and tells You about Your privacy rights and how the law protects You. By using the Platform and Services, You agree to the collection and use of information in accordance with this Privacy Policy.
Section2. CrowdPoint Data Rights
Our goal is always to be as transparent, upfront, and open as possible regarding what information We collect and how We use it. As part of that transparency, our Data Rights showcase and explain the fundamental principles that guide all of the technical terms and details about Data collection and use that You’ll find in this Privacy Policy.
Our Data Rights involve five key principles, each of which is described in more detail below:
1. Data Agency. To Us, Data Agency is a combination of ownership and agency. Ownership is the first building block of Your Data Agency. Your Data is owned by You. Period. No exceptions. By using Our Platform and Services, You are giving Us permission to serve as your agent for that Data. As Your agent for Your Data You grant Us permission to store, organize, refine, and take other actions on Your behalf, but only as You direct Us. Think of us as the caretaker for Your Data. Agency is the second building block of Your Data Agency, and we facilitate this through our unique data control tools. We will assume You have provided Your consent for Us to do something on Your behalf only when You take affirmative actions to direct Our Platform and Services to take an action. Similarly, if You direct the Platform and Services to securely store Your data, but keep it private, We will honor that request.
2. Openness. We believe there is nothing worse than having to fight against a site to figure out what data they have on You. We strive to be as open and transparent as possible. We will show You all data We have or are collecting, storing and using as You’ve directed Us to, whetherYou directly imported it from another data-source, entered it manually, iscollected from Your interactions with Our Platform and Services, is inferredabout You, or if it is a collection of aggregated data about You from cookiesand similar tracking tools.
3. Transferability. You may at any time add datasources from third parties to the Platform or Services to the extent suchtransfer is supported by Us, or export a copy of all data We have on You. Youmay also elect to license some or all of Your data to Our partners to monetizeit. If You elect to be presented with such opportunities, You must also selectwhat data about You is shared, and it will be pushed from the Platform andServices to the third part(ies).
4. Deletability. As the owner of Your Data, Youhave the unconditional ability to delete it from Our Platform and Services atany time. This includes any data You may have uploaded or linked from otherservices. If You elect to delete this data and or Your account, You may loseearnings which have not yet been deposited, as well as earnings potential.To the extent it is technically possible, We will delete data You havepreviously shared and which is being utilized by a third party, but this maytake up to 30 days.
5. Respect. WhileWe cannot control all of the digital advertising messaging which reach You, tothe extent You utilize Our Platform and Services, You may influence the type ofadvertisers and content of such advertisements which You see within OurPlatform and Services. Similarly, You are able to configure Your interests sothat We can show You relevant information. You may tell Us about these preferencesdirectly in Your account, or We may infer them from Your ongoing feedback andinteractions. We will do Our best to honor these preferences, but cannotguarantee every single potential engagement You see will exactly conform withyour chosen preferences. Note that Your data rights arewith respect to Us only. We are not able to enforce the terms of this privacystatement between Us and You against other third parties. Notwithstanding, We willmake reasonable efforts to honor and enforce Your rights and preferences via Ourthird-party dealings.
Section3. What We Do
To put it simply, We help Youestablish Data Agency over Your Data. Data Agency is a concept unique to Us,and it is at the core of Our vision for the future of data collection andusage.
We use Your Data to help youestablish Data Agency in two main ways:
Acting as Your agent in puttingYour Data to Work for You.
We do this by:
1. paying You for it via ourpartnerships with data buyers, and
2. personalizing Your online world,surfacing only the most relevant content, deals and opportunities based on whatWe know about You. To this end, building Your profile by linking existing datasources, answering questions, or simply interacting with Our Platform andServices empowers an algorithm to work on Your behalf.
The Services provided throughthe Platform allow you to determine what personal information You would like toshare and be included in the compensation for the sale of Your personalinformation to various third parties, including, but not limited to, brands,advertisers, ad agencies market researchers, retailers, distributors,resellers, and data management platforms (collectively, the “Purchasers”) inaccordance with Our Terms and Conditions.
We provide the Platform andServices directly to You as the owner of the Data by providing a medium toexchange your Data with the Purchasers through the Platform. Purchasersgenerally use the Data to help their marketing and advertising programs and tobetter understand consumer perceptions and behaviors. Purchasers may use thisdata to show You offers and ads within the Platform and Services.
Acting as Your agent in puttingYour Data to Work for everyone.
Ourvision for the Platform and Services has both individual and collectiveimplications, and because of that we are constantly striving to make thembetter for everyone. We do this by using Your Personal Data to provide andimprove the Platform and Services.
Section4. Collection and Use of Your Data
The Types of Data We Collect
Personal Data. While using Our Service, We mayask You to provide Us with certain personally identifiable information that canbe used to contact or identify You. Personally identifiable information mayinclude, but is not limited to: 1) Email address, 2) First nameand last name, and 3) Usage Data.
Usage Data. Usage Data is collectedautomatically when using the Platform and Services.
Usage Data may includeinformation such as Your Device's Internet Protocol address (e.g. IP address),browser type, browser version, the pages of Our Platform and Services that Youvisit, the time and date of Your visit, the time spent on those pages, uniquedevice identifiers and other diagnostic data.
When You access the Platform andServices by or through a mobile device, We may collect certain informationautomatically, including, but not limited to, the type of mobile device Youuse, Your mobile device unique ID, the IP address of Your mobile device, Yourmobile operating system, the type of mobile Internet browser You use, uniquedevice identifiers and other diagnostic data.
We may also collect informationthat Your browser sends whenever You visit Our Platform and Services or whenYou access the Platform and Services by or through a mobile device.
The Types of Data We Do NotCollect
We do not intentionally collect “Sensitive Personal Information”, such as personal data revealingracial or ethnic origin, political opinions, religious or philosophicalbeliefs, or trade union membership, and the processing of genetic data,biometric data for the purpose of uniquely identifying a natural person, dataconcerning health or data concerning a natural person’s sex life or sexualorientation. If You choose to store any Sensitive Personal Information on Ourservers, You are responsible for complying with any regulatory controlsregarding that data.
Tracking Technologies andCookies
We use Cookies and similartracking technologies to track the activity on Our Platform and Services andstore certain information. Tracking technologies used are beacons, tags, andscripts to collect and track information and to improve and analyze Our Platformand Service. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small fileplaced on Your Device. You can instruct Your browser to refuse all Cookies orto indicate when a Cookie is being sent. However, if You do not accept Cookies,You may not be able to use some parts of our Service. Unless you have adjustedYour browser setting so that it will refuse Cookies, our Service may useCookies.
Flash Cookies. Certain features of ourService may use local stored objects (or Flash Cookies) to collect and storeinformation about Your preferences or Your activity on our Service. FlashCookies are not managed by the same browser settings as those used for BrowserCookies. For more information on how You can delete Flash Cookies, please read"Where can I change the settings for disabling, or deleting local sharedobjects?" available athttps://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons. Certain sections of ourService and our emails may contain small electronic files known as web beacons(also referred to as clear gifs, pixel tags, and single-pixel gifs) that permitthe Company, for example, to count users who have visited those pages or openedan email and for other related website statistics (for example, recording thepopularity of a certain section and verifying system and server integrity).
Cookies can be"Persistent" or "Session" Cookies. Persistent Cookiesremain on Your personal computer or mobile device when You go offline, whileSession Cookies are deleted as soon as You close Your web browser. You canlearn more about cookies here: All About Cookies by TermsFeed.
We use both Session andPersistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Osano
Purpose: These Cookies areessential to provide You with services available through the Website and toenable You to use some of its features. They help to authenticate users andprevent fraudulent use of user accounts. Without these Cookies, the servicesthat You have asked for cannot be provided, and We only use these Cookies toprovide You with those services.
Cookies Policy / NoticeAcceptance Cookies
Type: Persistent Cookies
Administered by: Osano
Purpose: These Cookies identifyif users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies
Administered by: Osano
Purpose: These Cookies allow usto remember choices You make when You use the Website, such as remembering yourlogin details or language preference. The purpose of these Cookies is toprovide You with a more personal experience and to avoid You having to re-enteryour preferences every time You use the Website.
Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Osano
Purpose: These Cookies are usedto track information about traffic to the Website and how users use theWebsite. The information gathered via these Cookies may directly or indirectlyidentify you as an individual visitor. This is because the informationcollected is typically linked to a pseudonymous identifier associated with thedevice you use to access the Website. We may also use these Cookies to test newpages, features or new functionality of the Website to see how our users reactto them.
For more information about thecookies we use and your choices regarding cookies, please visit our CookiesPolicy or the Cookies section of our Privacy Policy.
Section 5. Use of Your Data
We may use Your Data for thefollowing purposes:
To provide and maintain Our Platformand Services, including to monitor the usage of Our Platform and Services.
To manage Your Account: to manage Your registration as auser of the Platform and Services. The Data You provide can give You access todifferent functionalities of the Platform and Services that are available toYou as a registered user.
For the performance of acontract: the development, compliance andundertaking of the purchase contract for the products, items or services Youhave purchased or of any other contract with Us through the Platform or Services.
To contact You: To contact You by email,telephone calls, SMS, or other equivalent forms of electronic communication,such as a mobile application's push notifications regarding updates orinformative communications related to the functionalities, products orcontracted services, including the security updates, when necessary orreasonable for their implementation.
To provide You with: news, special offers andgeneral information about other goods, services and events which we offer thatare similar to those that you have already purchased or enquired about unlessYou have opted not to receive such information.
To manage Your requests: To attend and manage Yourrequests to Us.
For business transfers: We may use Yourinformation to evaluate or conduct a merger, divestiture, restructuring,reorganization, dissolution, or other sale or transfer of some or all of Ourassets, whether as a going concern or as part of bankruptcy, liquidation, orsimilar proceeding, in which Data held by Us about our Platform and Servicesusers is among the assets transferred.
For other purposes: We may use Yourinformation for other purposes, such as data analysis, identifying usagetrends, determining the effectiveness of our promotional campaigns and toevaluate and improve Our Platform and Services, products, services, marketing andyour experience.
We may share Your personalinformation in the following situations:
With Service Providers: We may share Your personalinformation with Service Providers to monitor and analyze the use of Our Platformand Services, to contact You.
For business transfers: We may share or transfer Yourpersonal information in connection with, or during negotiations of, any merger,sale of Company assets, financing, or acquisition of all or a portion of Ourbusiness to another company.
With Affiliates: We may share Yourinformation with Our affiliates, in which case We will require those affiliatesto honor this Privacy Policy. Affiliates include Our parent company and anyother subsidiaries, joint venture partners or other companies that We controlor that are under common control with Us.
• With business partners:We may share Your information with Our business partners to offer You certainproducts, services or promotions.
• With otherusers: when You share personal information or otherwise interact inthe public areas with other users, such information may be viewed by all usersand may be publicly distributed outside.
• With Yourconsent: We may disclose Your personal information for any otherpurpose with Your consent.
Section 6. Retention of YourData
We retain Data only so long as YourAccount is active, although We do Our best to ensure that the Data We have on Youis accurate and up to date. We reserve the right, in Our sole discretion, todelete Your Account if Your Account has not been in use for 180 consecutivedays. Any time Your Data is shared as part of the Platform and Services, Wewill use an anonymized ID to recognize You, Your browser and/or or Your devicewithout allowing a Purchaser to know Your real world identity.
We will retain and use YourPersonal Data to the extent necessary to comply with our legal obligations (forexample, if We are required to retain Your Data to comply with applicablelaws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retainUsage Data for internal analysis purposes. Usage Data is generally retained fora shorter period of time, except when this data is used to strengthen thesecurity or to improve the functionality of Our Platform and Services, or Weare legally obligated to retain this data for longer time periods.
Section 7. Disclosure and Transferof Your Data
Your Data, including PersonalData, is processed at Our operating offices and in any other places where theparties involved in the processing are located. It means that this informationmay be transferred to — and maintained on — computers located outside of Yourstate, province, country or other governmental jurisdiction where the dataprotection laws may differ than those from Your jurisdiction.
Your consent to this PrivacyPolicy followed by Your submission of such information represents Youragreement to that transfer.
We will take all stepsreasonably necessary to ensure that Your data is treated securely and inaccordance with this Privacy Policy and no transfer of Your Personal Data willtake place to an organization or a country unless there are adequate controlsin place including the security of Your data and other personal information.
In addition to the above, We shareinformation with trusted third-party vendors who may help Us to manage OurPlatform and Services (e.g., cloud hosting services, email and SMS messagingcompanies). These third party vendors are prohibited via written contract fromusing the information for purposes other than performing services for Us.
We may be required to discloseyour information to third parties when obligated to do so by law and in orderto investigate, prevent, or take action regarding suspected, or actualprohibited activities, including transfer reasonably intended to meet nationalsecurity or law enforcement requirements, or when We believe in good faith thatdisclosure is necessary to protect Our rights, including but not limited tofraud and situations involving potential threats to the physical safety of anyperson.
Finally, We may transferinformation, including any Data We have on the Platform and Services, to asuccessor entity in connection with a corporate merger, consolidation, sale ofassets, bankruptcy, or other corporate change. We will provide notice of thistransfer in Our privacy policy.
Section 8. Security of YourPersonal Data
We are committed to safeguardingthe Data collected or accessed. We have implemented reasonable securityprocedures to protect the storage and disclosure of Data We process. No methodof transmission over the Internet or method of electronic storage is 100%secure; therefore, while We strive to use reasonable means to protect Yourinformation, We cannot guarantee absolute security.
Section9. Details of the Processing of Your Data
The Service Providers We use mayhave access to Your Data. These third-party vendors collect, store, use,process and transfer information about Your activity on Our Service inaccordance with their Privacy Policies.
Analytics
We may use third-party Serviceproviders to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a webanalytics service offered by Google that tracks and reports website traffic.Google uses the data collected to track and monitor the use of our Service. Thisdata is shared with other Google services. Google may use the collected data tocontextualize and personalize the ads of its own advertising network.
You can opt-out of having madeyour activity on the Service available to Google Analytics by installing theGoogle Analytics opt-out browser add-on. The add-on prevents the GoogleAnalytics JavaScript (ga.js, analytics.js and dc.js) from sharing informationwith Google Analytics about visits activity.
For more information on theprivacy practices of Google, please visit the Google Privacy & Terms webpage: https://policies.google.com/privacy
Email Marketing
We may use Your Personal Data tocontact You with newsletters, marketing or promotional materials and otherinformation that may be of interest to You. You may opt-out of receiving any,or all, of these communications from Us by following the unsubscribe link orinstructions provided in any email We send or by contacting Us.
We may use Email MarketingService Providers to manage and send emails to You.
Section 10. Do Not Sell MyPersonal Information
You have the right to opt-out ofthe sale of Your personal information. Once We receive and confirm a verifiableconsumer request from You, we will stop selling Your personal information. Toexercise Your right to opt-out, please contact Us.
The Service Providers we partnerwith (for example, our analytics or advertising partners) may use technology onthe Service that sells personal information as defined by the CCPA law. If youwish to opt out of the use of Your personal information for interest-basedadvertising purposes and these potential sales as defined under CCPA law, youmay do so by following the instructions below.
Please note that any opt out isspecific to the browser You use. You may need to opt out on every browser thatYou use.
Section 11. Website
You can opt out of receiving adsthat are personalized as served by Our Service Providers by following ourinstructions presented on the Service:
• The NAI's opt-out platform:http://www.networkadvertising.org/choices/
• The EDAA's opt-out platformhttp://www.youronlinechoices.com/
• The DAA's opt-out platform:http://optout.aboutads.info/?c=2&lang=EN
The opt out will place a cookieon Your computer that is unique to the browser You use to opt out. If youchange browsers or delete the cookies saved by your browser, You will need toopt out again.
Section 12. Mobile Devices
Your mobile device may give Youthe ability to opt out of the use of information about the apps You use inorder to serve You ads that are targeted to Your interests:
• "Opt out ofInterest-Based Ads" or "Opt out of Ads Personalization" onAndroid devices
• "Limit Ad Tracking"on iOS devices
You can also stop the collectionof location information from Your mobile device by changing the preferences onYour mobile device.
Section13. "Do Not Track" Policy as Required by California Online PrivacyProtection Act (CalOPPA)
Our Platform and Services doesnot respond to Do Not Track signals.
However, some third partywebsites do keep track of Your browsing activities. If You are visiting suchwebsites, You can set Your preferences in Your web browser to inform websitesthat You do not want to be tracked. You can enable or disable DNT by visitingthe preferences or settings page of Your web browser.
Section14. Children's Privacy and Collection and Sale of Minor’s Data
Anyone under the age of 13 maynot have an account on Our Platform and Services. We do not knowingly collectpersonally identifiable information from anyone under the age of 13. If Webecome aware that We have collected Personal Data from anyone under the age of13 without verification of parental consent, We take steps to remove thatinformation from Our servers in any manner we see fit, including but notlimited to closing or removing any related accounts.
While We do not knowinglycollect personal information from minors under the age of 13 through Our Platformand Services, although certain third party websites that We link to may do so.These third-party websites have their own terms of use and privacy policies andWe encourage parents and legal guardians to monitor their children's Internetusage and instruct their children to never provide information on otherwebsites without their permission.
We do not sell the personalinformation of Consumers We actually know are less than 16 years of age, unlessWe receive affirmative authorization (the "right to opt-in") fromeither the Consumer who is between 13 and 16 years of age, or the parent orguardian of a Consumer less than 13 years of age. Consumers who opt-in to thesale of personal information may opt-out of future sales at any time. Toexercise the right to opt-out, You (or Your authorized representative) maysubmit a request to Us by contacting Us.
If You have reason to believethat a child under the age of 13 (or 16) has provided Us with personalinformation, please contact Us with sufficient detail to enable Us to deletethat information.
Section15. Your California Privacy Rights (California's Shine the Light law)
Under California Civil CodeSection 1798 (California's Shine the Light law), California residents with anestablished business relationship with us can request information once a yearabout sharing their Personal Data with third parties for the third parties'direct marketing purposes.
If you'd like to request moreinformation under the California Shine the Light law, and if You are aCalifornia resident, You can contact Us using the contact information providedbelow.
CaliforniaPrivacy Rights for Minor Users (California Business and Professions CodeSection 22581)
California Business andProfessions Code section 22581 allow California residents under the age of 18who are registered users of online sites, services or applications to requestand obtain removal of content or information they have publicly posted.
To request removal of such data,and if You are a California resident, You can contact Us using the contactinformation provided below, and include the email address associated with Youraccount.
Be aware that Your request doesnot guarantee complete or comprehensive removal of content or informationposted online and that the law may not permit or require removal in certaincircumstances.
Section16. Links to Other Websites
Our Service may contain links toother websites that are not operated by Us. If You click on a third party link,You will be directed to that third party's site. We strongly advise You toreview the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of anythird party sites or services.
Section17. Other topics of interest
Appendix/Appendices
Thereare additional rules, terms, and conditions that some users may be subject tobased on their geographic location. Those additional rules, terms, andconditions can be found on the Appendices to this Privacy Policy. Appendix Aaddresses additional rules, terms, and conditions as required by the GDPR.Appendix B addresses additional rules, terms, and conditions as required by theCCPA.
Governing Law
We are aDelaware corporation with our corporate headquarters in Austin, TX, and byusing the Platform and Services you consent to this Privacy Policy and ourTerms of Use being interpreted under Texas law.
Changesto the Privacy Policy
We reserve the right to modifythis Privacy Policy from time to time for any reason, in our sole discretion.Each version will apply to information collected while it was in place. If Wemake changes to it, we will notify You by revising the “Last Updated” date atthe top of our Privacy Policy page. The most current version of this PrivacyPolicy will govern Our current use of Your Data and Your use of Our Platformand Services. We encourage You to review Our Privacy Policy regularly to stayinformed about Our privacy practices. In the event that the modifications materially alter Your rightsor obligations hereunder, We will make reasonable efforts to notify You of thechange, but the method and style of Our attempts may vary and change over timeor based on the modifications We made. For example, We may send a message to Youremail address or generate a pop-up or similar notification when You access the Platformand Services for the first time after such material changes are made. Your continued use of the Platformand Services following a change or changes to this Privacy Policy, constitutesYour binding acceptance of the change or changes.
Contact Us
If youhave questions about the Privacy Policy, or concerning the collection, use, anddisclosure of Your Data please contact us at:
Email: (info@crwd.id)
APPENDIX A
GDPR Privacy
Legal Basis for ProcessingPersonal Data under GDPR
We may process Data under thefollowing conditions:
Consent: You havegiven Your consent for processing Personal Data for one or more specificpurposes.
Performance of a contract: Provision of Personal Data isnecessary for the performance of an agreement with You and/or for anypre-contractual obligations thereof.
Legal obligations: Processing Personal Datais necessary for compliance with a legal obligation to which We are subject.
Vital interests: Processing Personal Data isnecessary in order to protect Your vital interests or of another naturalperson.
Public interests: Processing Personal Datais related to a task that is carried out in the public interest or in theexercise of official authority vested in Us.
Legitimate interests: Processing Personal Datais necessary for the purposes of the legitimate interests pursued by Us.
In any case, the Company willgladly help to clarify the specific legal basis that applies to the processing,and in particular whether the provision of Personal Data is a statutory orcontractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
We undertake to respect theconfidentiality of Your Personal Data and to guarantee You can exercise Yourrights.
You have the right under thisPrivacy Policy, and by law if You are within the EU, to:
Request access to Your Data. The right to access, update ordelete the information We have on You. Whenever made possible, you can access,update or request deletion of Your Personal Data directly within Your accountsettings section. If you are unable to perform these actions yourself, pleasecontact Us to assist You. This also enables You to receive a copy of the DataWe hold about You.
Request correction of the Datathat We hold about You. Youhave the right to have any incomplete or inaccurate information We hold aboutYou corrected.
Object to processing of YourData. This right exists where We arerelying on a legitimate interest as the legal basis for Our processing andthere is something about Your particular situation, which makes You want toobject to our processing of Your Data on this ground. You also have the rightto object where We are processing Your Data for direct marketing purposes.
Request erasure of YourData. You have the right to ask Us todelete or remove Data when there is no good reason for Us to continueprocessing it.
Request the transfer of YourData. We will provide to You, orto a third-party You have chosen, Your Data in a structured, commonly used,machine-readable format. Please note that this right only applies to automatedinformation which You initially provided consent for Us to use or where We usedthe information to perform a contract with You.
Withdraw Your consent. You have the right to withdrawYour consent on using your Data. If You withdraw Your consent, We may not beable to provide You with access to certain specific functionalities of the Platformand Services.
Exercising of Your GDPR DataProtection Rights
You may exercise Your rights ofaccess, rectification, cancellation and opposition by contacting Us. Pleasenote that we may ask You to verify Your identity before responding to suchrequests. If You make a request, We will try our best to respond to You as soonas possible.
You have the right to complainto a Data Protection Authority about Our collection and use of Your PersonalData. For more information, if You are in the European Economic Area (EEA),please contact Your local data protection authority in the EEA.
APPENDIX B
CCPA Privacy
This privacy notice section forCalifornia residents supplements the information contained in Our PrivacyPolicy and it applies solely to all visitors, users, and others who reside inthe State of California.
Categories of PersonalInformation Collected
We collect information thatidentifies, relates to, describes, references, is capable of being associatedwith, or could reasonably be linked, directly or indirectly, with a particularConsumer or Device. The following is a list of categories of personalinformation which we may collect or may have been collected from Californiaresidents within the last twelve (12) months.
Please note that the categoriesand examples provided in the list below are those defined in the CCPA. Thisdoes not mean that all examples of that category of personal information werein fact collected by Us, but reflects our good faith belief to the best of ourknowledge that some of that information from the applicable category may be andmay have been collected. For example, certain categories of personalinformation would only be collected if You provided such personal informationdirectly to Us.
Category A: Identifiers.
Examples: A real name, alias,postal address, unique personal identifier, online identifier, InternetProtocol address, email address, account name, driver's license number,passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal informationcategories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e)).
Examples: A name, signature,Social Security number, physical characteristics or description, address,telephone number, passport number, driver's license or state identificationcard number, insurance policy number, education, employment, employmenthistory, bank account number, credit card number, debit card number, or anyother financial information, medical information, or health insuranceinformation. Some personal information included in this category may overlapwith other categories.
Collected: Yes.
Category C: Protectedclassification characteristics under California or federal law.
Examples: Age (40 years orolder), race, color, ancestry, national origin, citizenship, religion or creed,marital status, medical condition, physical or mental disability, sex(including gender, gender identity, gender expression, pregnancy or childbirthand related medical conditions), sexual orientation, veteran or militarystatus, genetic information (including familial genetic information).
Collected: No.
Category D: Commercialinformation.
Examples: Records and history ofproducts or services purchased or considered.
Collected: No.
Category E: Biometricinformation.
Examples: Genetic,physiological, behavioral, and biological characteristics, or activity patternsused to extract a template or other identifier or identifying information, suchas, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Category F: Internet or othersimilar network activity.
Examples: Interaction with ourService or advertisement.
Collected: Yes.
Category G: Geolocation data.
Examples: Approximate physicallocation.
Collected: No.
Category H: Sensory data.
Examples: Audio, electronic,visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional oremployment-related information.
Examples: Current or past jobhistory or performance evaluations.
Collected: No.
Category J: Non-public educationinformation (per the Family Educational Rights and Privacy Act (20 U.S.C.Section 1232g, 34 C.F.R. Part 99)).
Examples: Education recordsdirectly related to a student maintained by an educational institution or partyacting on its behalf, such as grades, transcripts, class lists, studentschedules, student identification codes, student financial information, orstudent disciplinary records.
Collected: No.
Category K: Inferences drawnfrom other personal information.
Examples: Profile reflecting aperson's preferences, characteristics, psychological trends, predispositions,behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Under CCPA, personal informationdoes not include:
• Publicly available informationfrom government records
• Deidentified or aggregatedconsumer information
• Information excluded from theCCPA's scope, such as:
• Health or medical informationcovered by the Health Insurance Portability and Accountability Act of 1996(HIPAA) and the California Confidentiality of Medical Information Act (CMIA) orclinical trial data
• Personal Information coveredby certain sector-specific privacy laws, including the Fair Credit ReportingAct (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California FinancialInformation Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories ofpersonal information listed above from the following categories of sources:
Directly from You. For example, from the forms You completeon our Service, preferences You express or provide through Our Platform and Services.
Indirectly from You. For example, from observing Youractivity on Our Platform and Services.
Automatically from You. For example, through cookiesWe or Our Service Providers set on Your Device as You navigate through Our Platformand Services.
From Service Providers. For example, third-party vendorsto monitor and analyze the use of Our Platform and Services, or other third-partyvendors that We use to provide the Platform and Services to You.
Use of Personal Information forBusiness Purposes or Commercial Purposes
We may use or disclose personalinformation We collect for "business purposes" or "commercialpurposes" (as defined under the CCPA), which may include the followingexamples:
• To operate our Service andprovide You with Our Platform and Services.
• To provide You with supportand to respond to Your inquiries, including to investigate and address Yourconcerns and monitor and improve Our Platform and Services.
• To fulfill or meet the reasonYou provided the information. For example, if You share Your contactinformation to ask a question about Our Platform and Services, We will use thatpersonal information to respond to Your inquiry.
• To respond to law enforcementrequests and as required by applicable law, court order, or governmentalregulations.
• As described to You whencollecting Your personal information or as otherwise set forth in the CCPA.
• For internal administrativeand auditing purposes.
• To detect security incidentsand protect against malicious, deceptive, fraudulent or illegal activity,including, when necessary, to prosecute those responsible for such activities.
Please note that the examplesprovided above are illustrative and not intended to be exhaustive. For moredetails on how we use this information, please refer to the "Collectionand Use of Your Personal Data" section.
If We decide to collectadditional categories of personal information or use the personal informationWe collected for materially different, unrelated, or incompatible purposes Wewill update this Privacy Policy.
Disclosure of PersonalInformation for Business Purposes or Commercial Purposes
We may use or disclose and mayhave used or disclosed in the last twelve (12) months the following categoriesof personal information for business or commercial purposes:
Category A: Identifiers
Category B: Personal information categories listed in the CaliforniaCustomer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in theCCPA. This does not mean that all examples of that category of personalinformation were in fact disclosed, but reflects our good faith belief to thebest of our knowledge that some of that information from the applicablecategory may be and may have been disclosed.
When We disclose personalinformation for a business purpose or a commercial purpose, We enter a contractthat describes the purpose and requires the recipient to both keep thatpersonal information confidential and not use it for any purpose exceptperforming the contract.
Sale of Personal Information
As defined in the CCPA,"sell" and "sale" mean selling, renting, releasing,disclosing, disseminating, making available, transferring, or otherwisecommunicating orally, in writing, or by electronic or other means, a consumer'spersonal information by the business to a third party for valuableconsideration. This means that We may have received some kind of benefit inreturn for sharing personal information, but not necessarily a monetarybenefit.
Please note that the categorieslisted below are those defined in the CCPA. This does not mean that allexamples of that category of personal information were in fact sold, butreflects Our good faith belief to the best of Our knowledge that some of thatinformation from the applicable category may be and may have been shared forvalue in return.
We may sell and may have sold inthe last twelve (12) months the following categories of personal information:
Category A: Identifiers
Category B: Personal information categories listed in the CaliforniaCustomer Records statute (Cal. Civ. Code § 1798.80(e))
Category F: Internet or other similar network activity
Share of Personal Information
We may share Your personal information identified in the abovecategories with the following categories of third parties:
Service Providers
Our affiliates
Our business partners
Third party vendors to whom You or Your agents authorize Us to discloseYour personal information in connection with products or services We provide toYou
Your Rights under the CCPA
The CCPA provides Californiaresidents with specific rights regarding their personal information. If You area resident of California, You have the following rights:
The right to notice. Youhave the right to be notified which categories of Personal Data are beingcollected and the purposes for which the Personal Data is being used.
The right to request. Under CCPA, You have theright to request that We disclose information to You about Our collection, use,sale, disclosure for business purposes and share of personal information. OnceWe receive and confirm Your request, We will disclose to You:
•The categories of personal information We collected about You
•The categories of sources for the personal information We collected about You
•Our business or commercial purpose for collecting or selling that personalinformation
•The categories of third parties with whom We share that personal information
•The specific pieces of personal information We collected about You
•If we sold Your personal information or disclosed Your personal information fora business purpose,
We will disclose to You:
•The categories of personal information categories sold
•The categories of personal information categories disclosed
The right to say no to the saleof Personal Data (opt-out). You have the right to direct Us to not sell Your personalinformation. To submit an opt-out request please contact Us.
The right to delete PersonalData. You have the right torequest the deletion of Your Personal Data, subject to certain exceptions. OnceWe receive and confirm Your request, We will delete (and direct Our ServiceProviders to delete) Your personal information from our records, unless anexception applies. We may deny Your deletion request if retaining theinformation is necessary for Us or Our Service Providers to:
•Complete the transaction for which We collected the personal information,provide a good or service that You requested, take actions reasonablyanticipated within the context of our ongoing business relationship with You,or otherwise perform our contract with You.
•Detect security incidents, protect against malicious, deceptive, fraudulent, orillegal activity, or prosecute those responsible for such activities.
•Debug products to identify and repair errors that impair existing intendedfunctionality.
•Exercise free speech, ensure the right of another consumer to exercise theirfree speech rights, or exercise another right provided for by law.
•Comply with the California Electronic Communications Privacy Act (Cal. PenalCode § 1546 et. seq.).
•Engage in public or peer-reviewed scientific, historical, or statisticalresearch in the public interest that adheres to all other applicable ethics andprivacy laws, when the information's deletion may likely render impossible orseriously impair the research's achievement, if You previously providedinformed consent.
•Enable solely internal uses that are reasonably aligned with consumerexpectations based on Your relationship with Us.
•Comply with a legal obligation.
•Make other internal and lawful uses of that information that are compatiblewith the context in which You provided it.
The right not to bediscriminated against. Youhave the right not to be discriminated against for exercising any of Yourconsumer's rights, including by:
•Denying goods or services to You
•Charging different prices or rates for goods or services, including the use ofdiscounts or other benefits or imposing penalties
•Providing a different level or quality of goods or services to You
•Suggesting that You will receive a different price or rate for goods orservices or a different level or quality of goods or services
Exercising Your CCPA DataProtection Rights
In order to exercise any of Yourrights under the CCPA, and if You are a California resident, You can contactUs:
By email: (info@crwd.id)
Only You, or a person registeredwith the California Secretary of State that You authorize to act on Yourbehalf, may make a verifiable request related to Your personal information.
Your request to Us must:
• Provide sufficient informationthat allows Us to reasonably verify You are the person about whom We collectedpersonal information or an authorized representative
• Describe Your request withsufficient detail that allows Us to properly understand, evaluate, and respondto it
We cannot respond to Yourrequest or provide You with the required information if We cannot:
• Verify Your identity orauthority to make the request
• And confirm that the personalinformation relates to You
We will disclose and deliver therequired information free of charge within 45 days of receiving Your verifiablerequest. The time period to provide the required information may be extended onceby an additional 45 days when reasonable necessary and with prior notice.
Any disclosures We provide willonly cover the 12-month period preceding the verifiable request's receipt.
For data portability requests,We will select a format to provide Your personal information that is readilyuseable and should allow You to transmit the information from one entity toanother entity without hindrance.
APPENDIX C
DEFINITIONS
For the purposes of this Privacy Policy:
Account meansa unique account created for or by You to access our Platform and Services orparts of Our Platform and Services.
Business, forthe purpose of the CCPA (California Consumer Privacy Act), refers to theCompany as the legal entity that collects Consumers' personal information anddetermines the purposes and means of the processing of Consumers' personalinformation, or on behalf of which such information is collected and thatalone, or jointly with others, determines the purposes and means of theprocessing of consumers' personal information, that does business in the Stateof California.
Company (referredto as either "the Company", "We", "Us" or"Our" or “CrowdPoint” in this Agreement) refers to CrowdPointTechnologies Inc. 10815 Ranch Rd 2222, Building 3, Suite 100-527, Austin, TX78730.
Forthe purpose of the GDPR, We are the Data Controller.
Consumer,for the purpose of the CCPA (California Consumer Privacy Act), means a naturalperson who is a California resident. A resident, as defined in the law,includes (1) every individual who is in the USA for other than a temporary ortransitory purpose, and (2) every individual who is domiciled in the USA who isoutside the USA for a temporary or transitory purpose.
Cookies aresmall files that are placed on Your computer, mobile device or any other deviceby a website, containing the details of Your browsing history on that websiteamong its many uses.
Country refers to: Texas, United States
Data refers both to Personal Data and Usage Data, collectively.
Data Agency is a general term We use to represent the principal-agent relationship created in Our Privacy Policy terms. This principle is based on the concept that You own your Data, but We act on Your behalf to help monetize and use the Data for Your benefit and on Your behalf pursuant to the terms of this Privacy Policy.
Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to Usas the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Platform and Services such as a computer, gameconsole, gaming handheld, cellphone, or a digital tablet.
Do Not Track (DNT)is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
PersonalData isany information that relates to an identified or identifiable individual.
Forthe purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to oneor more factors specific to the physical, physiological, genetic, mental,economic, cultural or social identity.
Forthe purposes of the CCPA, Personal Data means any information that identifies,relates to, describes or is capable of being associated with, or couldreasonably be linked, directly or indirectly, with You.
Platform(sometimes “Website”) refers to OurWebsite, accessible at (www.crowdpointtech.com), and any of Our online, mobile,web, or downloadable products or platforms.
Sale,for the purpose of the CCPA (California Consumer Privacy Act), means selling,renting, releasing, disclosing, disseminating, making available, transferring,or otherwise communicating orally, in writing, or by electronic or other means,a Consumer's personal information to another business or a third party formonetary or other valuable consideration.
Service(s) refers to any of the products, services, tools and functions available on Our Platform.
Service Provider means any natural or legal person who processes the data on behalf of the Company. Itrefers to third-party companies or individuals employed by the Company tofacilitate the Platform and Services, to provide the Platform and Services on behalf of the Company, to perform services related to the Platform and Services or toassist the Company in analyzing how the Platform and Services is used. For thepurpose of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Platform and Services or from the Platform and Services infrastructure itself (for example, the duration of a page visit).
You means the individual accessing or using the Platform and Services, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform and Services, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Platform and Services.
