Privacy Policy

E.B.I. Solutions Ltd (“We” or “us”) are committed to protecting and respecting your privacy.
We own the Crowdy App mobile application software (the “App”), which enables organisations and individuals (“Promoters”) to communicate with you (“Users”) and collect data from Users via promotions, tasks and surveys (“Services”) that they or We have created on the App. This data may include personal data. We hold the personal data (including submitted information) you provide directly to us, including through our websites and through Services. This policy sets out what personal data may be collected from you directly by us and/or by Promoters through Services created and distributed by Promoters. By accepting this privacy policy, together with our Terms of Use and using the App and Services (including, without limitation, the creation of Services) you are consenting to us using your data in the ways described here and sharing your data with Promoters. Due to the nature of the App, which is to communicate with Users and to collect data from Users, most Services will only be available to Users if you consent to your data being used in the ways described. If you do not want your data used in these ways please do not download the App, use our websites or agree to this policy. This policy also sets out the ways in which data collected by Promoters using the app platform will be collected and used by us.

SCOPE OF POLICY
This policy (together with our terms of use (“TOU”) and any additional terms of use incorporated by reference into the TOU, together “Our Terms of Use”) applies to your use of:
• The App downloadable free from http://appstore.com/ebisolutionsltd/crowdy website (“App Site”), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (“Device”) and registered as a User.
• Any of the Services accessible through the App that are available through the App, the App Site or any other sites of ours (“Services Sites”), unless the TOU states that a separate privacy policy applies to a particular Service, in which case that privacy policy only applies.
• The Crowdy Create Web admin that is used by Promoters to create Services once the Promoter has registered as a Promoter.
• Any of our websites, unless the TOU states that a separate privacy policy applies to a particular website, in which case that privacy policy only applies.
This policy sets out the basis on which any personal data We collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how We will treat it.
For the purpose of the Data Protection Act 1998, the data controller is E.B.I. Solutions Ltd (company number 04217074) having its registered office at 29 Arboretum Street, Nottingham, Nottinghamshire, NG1 4JA.

INFORMATION WE MAY COLLECT FROM YOU
We and Promoters may collect and process the following data about you:
• Submitted Information: information that you provide by filling in forms on the App Site and the Services Sites (together “Our Sites”) and in the App, and on the dashboard which may include your name, address, e-mail address, personal description, photograph and the Device’s telephone number. This includes information provided at the time of registering to use the App or any of the Services, subscribing to any of the Services, posting or submitting material (including but not limited to creation of and/or participation in Services), placing an order on Our Sites, participating in discussion boards or other social media functions in the App or on Our Sites, entering a competition, promotion or survey or requesting further services. You may also be asked for information when you complete a survey or promotion from a Promoter or us and when you report a problem with any of Our Sites or when We provide you with support services.

• Additional information:
• If you contact us, we may keep a record of that correspondence;
• We may also ask you to complete user surveys that we use for research purposes, although you do not have to respond to them;
• Details of transactions you carry out through the App or any of Our Sites;
• Details of your visits to the App or any of Our Sites including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
• Device information: We may collect technical information about the Device or any computer you may use to download or stream a copy of the App onto your Device, including, where available, the Device’s or computer’s unique Device identifiers, operating system, browser type and mobile network information as well as the Device’s telephone number, for system administration and to report aggregate information to Promoters. We may associate Device information with Submitted Information and will treat the combined information as personal data in accordance with this policy for as long as it is combined. We may collect information stored on your Device, including contact information, friends lists, login information, photos, videos or other digital content and check ins.
• Location information: when you use one of our location-enabled Services, We may collect and process information about your actual location. Some of these Services require your personal location data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose on the first time running the Crowdy application. You can withdraw your consent at any time by updating the location privacy settings on your Device.  If you do not provide consent or if you withdraw your consent at any point, some of the Services will not be able to operate on your Device.
• Log information: when you use the Services, the App or view content on Our Sites, We may automatically collect and store certain information in server logs, including but not limited to internet protocol (“IP”) addresses, internet service provider (“ISP”), clickstream data, browser type and language, viewed and exit pages, date or time stamps, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise.
• Information We receive from other sources (Third Party Information). We are working closely with third parties (including, for example, Promoters, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

INFORMATION WHICH WILL BE SHARED WITH PROMOTERS

The following information will automatically be shared with promoters who invite you to take part in a survey or promotion in any way.

• Submitted information at the time of registering or through your responses to surveys and promotions including your name, address, e-mail address, telephone number, personal description, demographic data, photograph or any other personal information you choose to provide through a survey or promotion.
• Location information collected when you participate in any survey or promotion.
• All information included in your responses to a survey or promotion.

Promoters may use this information in any way detailed in their own Terms and Conditions and Privacy Policy which is described in the survey, promotion or service. By completing a Promoters survey, promotion or service you consent to the Promoter using your data in the ways described.
Information which may be shared with promoters and used for marketing purposes by us includes usage data and aggregated data not limited to the following.

• Location information
• Device information
• Transaction data
• Visits and app usage data
• Information from user surveys
• Log information

We will not process any personal information you provide in a survey, promotion or service from a Promoter other than in usage or aggregated form without first gaining permission from the Promoter.

COOKIES
Our Sites use 5 cookies. A cookie is a small file of letters and numbers that We put on your computer if you agree. These cookies allow us to distinguish you from other users of Our Sites, which helps us to provide you with a good experience when you use or browse Our Sites and also allows us to improve our Sites. The cookies We use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around Our Sites when they are using it. This helps us to improve the way Our Sites work, for example by ensuring that users are finding what they are looking for easily. Read more about the individual cookies We use and how to recognise them by clicking here.

WHERE WE STORE YOUR PERSONAL DATA
The data that We collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted Secure Sockets Layer protocol (SSL) with an encryption key length of 128-bits.  We do not handle payment transactions and do not store any of your card information. Where We have given you (or where you have chosen) a password that enables you to access certain parts of the App or Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, We cannot guarantee the security of your data transmitted to Our Sites; any transmission is at your own risk. Once We have received your information, We will use strict procedures and security features to try to prevent unauthorised access.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
Certain Services include social networking, chat room, blog post or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

USES MADE OF THE INFORMATION
We use information held about you in the following ways:
• Submitted Information:
We will use this information:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us, including the processing of payments by a third party provider of payment processing services;
• to provide you with information about other goods and services We offer that are similar to those that you have already purchased or enquired about;
• to notify you about changes to our Services;
• to ensure that content in the App and from Our Sites is presented in the most effective manner for you, your Device and for your computer.

• Additional information:
We will use this information:
• to administer the App and Our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve the App and Our Sites to ensure that content is presented in the most effective manner for you, your Device and for your computer;
• to allow you to participate in interactive features of our Services, when you choose to do so;
• as part of our efforts to keep the App and Our Sites safe and secure;
• to make suggestions and recommendations to you and other users of the App and Our Sites about promotions, tasks, goods or services that may interest you or them.

• Device information: This information is used to ensure that content from the App and Our Sites is presented in the most effective manner for you, for your Device and for your computer.  The identification of your Device also used for authentication purposes for our servers.

• Location information: This information is used to allow you to participate in interactive features of the App and the Services, when you choose to do so.  It will also enable us to provide you with information on relevant promotions, products or services that you request from us or that We feel may interest you, where you have consented to be contacted for such purposes and to check your location when completing a promotion.

• Log information: We will use this information to maintain, protect and improve the App, the Services and Our Sites.

• Information we receive from other sources: We may combine this information with information you give to us and information We collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information We receive).
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We may also use, or may permit selected third parties (including Promoters) to use, your data (submitted information and/or additional information) to provide you with information about goods and services (including Services) that may be of interest to you. We or they may contact you about these by electronic means (email or SMS).
If you are an existing customer, We will only contact you by electronic means (e-mail or SMS or through the App) with information about goods and services similar to those that were the subject of a previous transaction with you.
If you are a new customer, and where We permit selected third parties to use your data, We (or they) will contact you by electronic means only if you have consented to this.
If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which We collect your data (the registration form).
In the event that you are a winner in respect of any promotion that is one of the Services you participate in, We may use your name, location, image and your winning response to such promotion in publicity materials for that promotion and our App or websites.

DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
• In the event that We sell or buy any business or assets, in which case We may disclose your personal data to the prospective seller or buyer of such business or assets.
• If E.B.I. Solutions Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If We are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• In order to:
• enforce or apply Our Terms of Use, and our other agreements or to investigate potential breaches; or
• protect the rights, property or safety of E.B.I. Solutions Ltd our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• allow your entries into any promotions to be submitted.
• We may share your personal information with business partners, suppliers, sub-contractors or Promoters for the performance of any contract We enter into with them or you.  We also make use of the personal information data We have collected from you to enable you to be invited to participate in relevant Services.
• We may share your personal information with analytics and search engine providers that assist us in the improvement and optimisation of the App and Our Sites.
• We may share your personal information with credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
• We may disclose your name, location, image and your winning response to a promotion in publicity materials for that promotion and for our App or websites, if you participate in and win any promotion Services.

INFORMATION WHICH WILL BE SHARED WITH PROMOTERS

We will disclose to Promoters some or all of the data We collect from you when you download or use the App or participate in Services created by that Promoter.

We will share the following information with the Promoter who invites you to take part in any Service if you accept the invitation and participate in those Services:

• Submitted information at the time of registering or through your participation in such Services including your name, address, e-mail address, telephone number, personal description, demographic data, photograph and/or any other personal information you choose to provide through that Service.
• Location information collected when you participate in any Service.
• All information included in your responses to a survey or promotion that forms the Service.

Promoters may use any information they obtain in the ways detailed in their own terms and conditions and privacy policy which are set out in any Crowdy you participate in. By participating in a Promoter’s Service you consent to that Promoter using your data in the ways detailed in their terms and conditions and privacy policy.

YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if We intend to use your data for such purposes or if We intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms We use to collect your data or by choosing not to participate in any Services you are invited to participate in. You can also exercise the right at any time by contacting us at team@crowdy.co
The App and Our Sites may, from time to time, contain links to and from the websites of our Promoters, partner networks, advertisers, promotion operators and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any Services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or Services, such as contact and location data.  All Services available through the App also have their own applicable privacy policies, for which We do not accept any responsibility or liability. Please check these policies before you submit any personal data to these websites or use these Services.

ACCESS TO INFORMATION
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information We hold about you.
You can access your personal data and correct, update or delete such data by selecting the “Profile” page in the App (for users) or the “Users” screen on Our Sites (for Promoters).

CHANGES TO PRIVACY POLICY
Any changes We may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by notifying you of a change when you next start the Crowdy App or log onto one of the Services Sites or the Crowdy Create Web admin. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.

CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to team@crowdy.co.

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