CROWDFIRE INC.
PRIVACY POLICY
Last modified: February 28, 2024
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Introduction
In this policy, “we”, “us”, “ our” and “Crowdfire” refer to Crowdfire
Inc. and its subsidiary Codigami Labs PVT Ltd. For more information about
us and how to contact us, see Section 11.
We respect your privacy and are committed to protecting it through our
compliance with this Policy.
This privacy policy (“Policy”) applies when we are acting
as a data controller with respect to the personal data of our users. This
Policy describes how we collect, use and share personal data of consumer
users across our websites, including www.crowdfireapp.com (the “Website”), Crowdfire’s mobile application (the “ App”) and services offered to users (collectively with the
Website and the App, the “Services”), and from our
partners and other third parties. When using any of our Services you
consent to the collection, transfer, storage, disclosure, and use of your
personal data as described in this Policy.
Please read this Policy carefully to understand our policies and practices
regarding your personal data and how we will treat it. By accessing or
using the Services, you agree to this Policy. Our Services also incorporate
privacy controls which affect how we will process your personal data.
Please refer to Section 5 for a list of rights with regard to your
personal data and how to exercise them.
This Policy may change from time to time. Your continued use of the
Services after we make changes is deemed to be acceptance of those changes,
so please check the Policy periodically for updates.
2. Information We Collect About You and How We Collect It
There are three general categories of information we collect.
2.1. Information You Give to Us.
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We collect your account data, which may include your name,
email address (“Account Data”). The Account
Data may be processed for the purposes of providing to you our
Services and of ensuring their security, maintaining back-ups
of our databases and communicating with you. This information
is necessary for the adequate performance of the contract
between you and us and to allow us to comply with our legal
obligations. Without it, we may not be able to provide you with
all the requested Services.
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We process information that you post for publication through
our Services (“Publication Data”), including
the content that you share to your social profiles. The
Publication Data is processed for the purposes of enabling such
publication and administering our Services. The legal basis for
this processing is the performance of a contract between you
and us and/or taking steps, at your request, to enter into such
a contract. Without it, we may not be able to provide you with
all the requested Services.
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We process financial information such as credit card or PayPal
information when you order Services in order to facilitate the
processing of payments (“Payment Information
”). The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your
request, to enter into such a contract and our legitimate
interests, namely our interest in the proper administration of
our website and business.
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We may process information contained in or relating to any
communication that you send to us (“ Correspondence Data”). The Correspondence Data
may include the communication content and metadata associated
with the communication. The correspondence data may be
processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our
legitimate interests, namely the proper administration of our
website and business and communications with users.
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We may process information included in your personal profile, which may include your location, time zone and website (“Profile Data”).
The Profile Data may be processed for the purposes of providing you a better user experience when using the Services. We may also upload your profile image.
The legal basis for this processing is your consent.
2.2. Information We Automatically Collect from Your Use of the Services.
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When you use the Services, we may automatically process
information about your computer and internet connection
(including your IP address, operating system and browser type),
your mobile carrier, device information (including device and
application IDs), search terms, cookie information, as well as
information about the timing, frequency and pattern of your
service use (“Service Data”). The Service Data
is processed for the purpose of providing our Services. The
legal basis for this processing is the adequate performance of
the contract between you and us, to enable us to comply with
legal obligations and our legitimate interest in being able to
provide and improve the functionalities of the Services.
2.3. Information We Collect from Third Parties.
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You may choose to connect the Services to your accounts on
third party services such as Twitter, Facebook, Instagram,
Tiktok, Linkedin, Pinterest, Shopify, Etsy, Twitch, Wordpress and
Youtube (“ Social Networking Service”) for the purpose of
managing your social media presence through our Services. Crowdfire uses a third party vendor
(Zapier) to facilitate your connection to the Social Networking Services.
When you do this, we automatically process personal information
about you on such Social Networking Services, including your
account and profile data, RSS, lists of followers, social media
content and your actions with respect to such content (the “ Social Media Information”). The Social Media
Information is processed for the purposes of optimizing your
social media activity on the Social Networking Services and
administering our Services. The legal basis for the processing
of Social Media Information is the performance of a contract
between you and us and/or taking steps, at your request, to
enter into such a contract.
3. Disclosure of Personal Data
3.1. We may disclose your personal data to any member of our group of
companies (this means our subsidiaries, our ultimate holding
company and all its subsidiaries) insofar as reasonably necessary
for the purposes, and on the legal bases, set out in this policy.
3.2. Financial transactions relating to the Services are handled by our
payment services providers, Paypal, Braintree and Stripe. We will
share Payment Information with our payment services providers only
to the extent necessary for the purposes of processing your
payments, refunding such payments and dealing with complaints and
queries relating to such payments and refunds. You can find
information about the payment services providers' privacy policies
and practices at
https://www.paypal.com/in/webapps/mpp/ua/privacy-full
,
https://www.braintreepayments.com/leg
and
https://stripe.com/us/privacy/
.
3.3. We may disclose personal data to Social Networking Services insofar
as reasonably necessary to allow you to manage your social media
presence through our Services.
3.4. We may disclose Service Data to a variety of third party service
providers insofar as reasonably necessary to improve the
functionalities of the Services. For example, we may disclose
Service Data to obtain useful analytics, provide in-app support to
mobile app users, determine location data and provide search engine
functionality to our users.
3.5. We may share aggregated data (information about our users that we
combine together so that it no longer identifies or references an
individual user) and other anonymized information for regulatory
compliance, industry and market analysis, demographic profiling,
marketing and advertising, and other business purposes.
3.6. In addition to the specific disclosures of personal data set out in
this Section 3, we may disclose your personal data if we believe
that it is reasonably necessary to comply with a law, regulation,
legal process, or governmental request; or in order to protect your
vital interests or the vital interests of another natural person;
to protect the safety or integrity of the Services, or to explain
why we have removed content or accounts from the Services; or to
address fraud, security, or technical issues; or to protect our
rights or property or the rights or property of those who use the
Services.
3.7. We offer individuals the opportunity to choose (opt out) whether
their personal information is (i) to be disclosed to a third party
or (ii) to be used for a purpose that is materially different from
the purpose(s) for which it was originally collected or
subsequently authorized by the individuals. In order to opt out
from disclosure of your personal information, please email us at [email protected].
4. International transfers of your personal data
In this Section 4, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European
Economic Area (EEA). We and our other group companies have offices and
facilities in the United States and India. To facilitate our operations we
may transfer, store, and process your information within those countries or
with service providers based in Europe, India, Asia Pacific and North
America. Laws in these countries may differ from the laws applicable to
your Country of Residence. For example, information collected within the
EEA may be transferred, stored, and processed outside of the EEA for the
purposes described in this Privacy Policy. Where we transfer store, and
process your personal information outside of the EEA we have ensured that
appropriate safeguards are in place to ensure an adequate level of data
protection. Please refer to Section Section 10 below.
Transfers to our subsidiary in India, to our service providers and other third parties
will be protected by appropriate safeguards, namely the use of standard data protection
clauses adopted or approved by the European Commission or applicable certification schemes -
for example, the Data Privacy Framework (DPF) program referred to in Section 10 below.
5. Your Rights with Regard to Personal Data
In this Section 5, we have summarized the rights that you have under data
protection law. Some of the rights are complex, and not all of the details
have been included in our summaries. Accordingly, you should read the
relevant laws and guidance from the regulatory authorities for a full
explanation of these rights.
5.1 Your principal rights under data protection law are:
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the right to access;
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the right to rectification;
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the right to erasure;
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the right to restrict processing;
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the right to object to processing;
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the right to data portability;
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the right to complain to a supervisory authority; and
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the right to withdraw consent.
5.2. You have the right to confirmation as to whether or not we process
your personal data and, where we do, access to the personal data,
together with certain additional information. That additional
information includes details of the purposes of the processing, the
categories of personal data concerned and the recipients of the
personal data. Providing the rights and freedoms of others are not
affected, we will supply to you a copy of your personal data. The
first copy will be provided free of charge, but additional copies
may be subject to a reasonable fee. You can access your personal
data by following the instructions
here
.
5.3. You have the right to have any inaccurate personal data about you
rectified and, taking into account the purposes of the processing,
to have any incomplete personal data about you completed. You can
request correction or modification of your personal data by
following the instructions
here.
5.4. In some circumstances you have the right to the erasure of your
personal data without undue delay. Those circumstances include: the
personal data are no longer necessary in relation to the purposes
for which they were collected or otherwise processed; you withdraw
consent to consent-based processing; you object to the processing
under certain rules of applicable data protection law; the
processing is for direct marketing purposes; and the personal data
have been unlawfully processed. However, there are exclusions of
the right to erasure. The general exclusions include where
processing is necessary: for exercising the right of freedom of
expression and information; for compliance with a legal obligation;
or for the establishment, exercise or defense of legal claims. You
can request the deletion of your account by following the
instructions here.
5.5. In some circumstances you have the right to restrict the processing
of your personal data. Those circumstances are: you contest the
accuracy of the personal data; processing is unlawful but you
oppose erasure; we no longer need the personal data for the
purposes of our processing, but you require personal data for the
establishment, exercise or defense of legal claims; and you have
objected to processing, pending the verification of that objection.
Where processing has been restricted on this basis, we may continue
to store your personal data. However, we will only otherwise
process it: with your consent; for the establishment, exercise or
defence of legal claims; for the protection of the rights of
another natural or legal person; or for reasons of important public
interest. You can manage your privacy settings and other account
features
here
.
5.6. You have the right to object to our processing of your personal
data on grounds relating to your particular situation, but only to
the extent that the legal basis for the processing is that the
processing is necessary for: the performance of a task carried out
in the public interest or in the exercise of any official authority
vested in us; or the purposes of the legitimate interests pursued
by us or by a third party. If you make such an objection, we will
cease to process the personal data unless we can demonstrate
compelling legitimate grounds for the processing which override
your interests, rights and freedoms, or the processing is for the
establishment, exercise or defence of legal claims.
5.7. You have the right to object to our processing of your personal
data for direct marketing purposes (including profiling for direct
marketing purposes). If you make such an objection, we will cease
to process your personal data for this purpose.
5.8. You have the right to object to our processing of your personal
data for scientific or historical research purposes or statistical
purposes on grounds relating to your particular situation, unless
the processing is necessary for the performance of a task carried
out for reasons of public interest.
5.9. To the extent that the legal basis for our processing of your
personal data is:
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consent; or
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that the processing is necessary for the performance of a
contract to which you are party or in order to take steps at
your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right
to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others. You can download your
account information, by following the instructions here.
5.10. To the extent that the legal basis for our processing of your
personal data is consent, you have the right to withdraw that
consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
5.11. You may exercise any of your rights in relation to your personal
data by written notice to us, in addition to the other methods
specified in this Section 5.
6. Retaining and deleting personal data
6.1. This Section 6 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal
obligations in relation to the retention and deletion of personal
data.
6.2. Personal data that we process for any purpose or purposes shall not
be kept for longer than is necessary for that purpose or those
purposes.
6.3. We generally retain your personal information for as long as is
necessary for the performance of the contract between you and us
and to comply with our legal obligations. If you no longer want us
to use your information to provide the Services to you, you can
request that we erase your personal information and close your
account.
6.4. Notwithstanding the other provisions of this Section 6, we may
retain your personal data where such retention is necessary for
compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of
another natural person.
7. Children
7.1 Children’s Privacy & Data Protection
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Protecting the privacy of young children is especially important. For that reason, Crowdfire does not knowingly collect, store, process, or maintain personally identifiable information or non-personally-identifiable information on the Site from persons under 13 years of age, and no part of our website is directed to persons under 13 (or the minimum legal age in your jurisdiction). If you are under 13 years of age (or a minor in your jurisdiction), then please do not use or access the Site at any time or in any manner. No one under age 13 (or the minimum legal age in your jurisdiction) may provide any personal data through the Services.
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If you are under 13 (or a minor in your jurisdiction), do not use or provide any information through the Services or on or through any of their features or register an account, make any purchases through the Services, use any of the interactive features of the Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.
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If Crowdfire learns and verifies that personally identifiable information of persons under 13 years of age has been collected on the Site without verified parental consent, then Crowdfire will take the appropriate steps to delete this information. If a child accesses our services, we advise parents to monitor and restrict their child’s access. In compliance with the Children's Online Privacy Protection Act (COPPA) and the General Data Protection Regulation (GDPR-K), any personal data identified as belonging to a minor will be deleted upon verification. If you believe that we have unintentionally collected such data, please contact us immediately at [email protected].
7.2 Reporting Inappropriate Content or Child Safety Concerns
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We are committed to ensuring a safe environment for all users. If you encounter content or user behavior that violates our policies, especially concerning child safety, please report it immediately using our in-app/on-site reporting feature or by contacting [email protected]. We take all reports seriously and will investigate promptly, taking appropriate action, including content removal or account suspension.
8. Cookies
8.1. About cookies
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A cookie is a file containing an identifier (a string of
letters and numbers) that is sent by a web server to a web
browser and is stored by the browser. The identifier is then
sent back to the server each time the browser requests a page
from the server.
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Cookies may be either “persistent” cookies or “session”
cookies: a persistent cookie will be stored by a web browser
and will remain valid until its set expiry date, unless deleted
by the user before the expiry date; a session cookie, on the
other hand, will expire at the end of the user session, when
the web browser is closed.
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Cookies do not typically contain any information that
personally identifies a user, but personal information that we
store about you may be linked to the information stored in and
obtained from cookies.
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We also use other technologies with similar functionality to
cookies, such as web beacons, web storage, and unique
advertising identifiers, to collect information about your
activity, browser, and device.
8.2. We use these technologies for the following purposes:
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to identify you and log you into the Services;
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to store information about your preferences and to personalise
the Services for you;
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as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;
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to help us display content that will be relevant to you;
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to help us analyse the use and performance of the Services ;
and
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to store your preferences in relation to the use of cookies
more generally.
8.3. Cookies used by our service providers
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We use the following service providers to analyse the use of
the Services. Each service provider gathers information about
the Services by means of cookies and this information is used
to create reports about with usage information. You can find
information about the service providers’ privacy policies and
practices at the URLs set forth below:
8.4 Managing cookies
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Most browsers allow you to refuse to accept cookies and to
delete cookies. The methods for doing so vary from browser to
browser, and from version to version.
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Your mobile device may allow you to control cookies through its
settings function. Refer to your device manufacturer’s
instructions for more information.
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If you choose to decline cookies, some parts of the Services
may not work as intended or may not work at all.
9. Data Security
9.1. We have implemented measures designed to secure your personal data
from accidental loss and from unauthorized access, use, alteration
and disclosure. The safety and security of your information also
depends on you. Where we have given you (or where you have chosen)
a password for access to certain parts of the Services, you are
responsible for keeping this password confidential. We ask you not
to share your password with anyone.
9.2. Steps taken to ensure data security:
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All the user information can only be accessed by authorized
users;
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Users need to authenticate themselves with a username-password
combination; and
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All data is hosted on Amazon AWS servers.
9.3. Unfortunately, the transmission of information via public networks
such as the internet is not completely secure. Although we do our
best to protect your personal data, we cannot guarantee the
security of your personal data transmitted through the Services.
Any transmission of personal data is at your own risk. We are not
responsible for the circumvention of any privacy settings or
security measures contained on the Services.
10. Data Privacy Framework
Crowdfire complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and, as applicable the UK Extension to the EU-U.S. DPF,
and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce regarding the
collection, use, and retention of Personal Data transferred from the European Union, the United Kingdom and/or Switzerland to the United States, respectively.
Crowdfire LLC and Crowdfire Limited have certified to the Department of Commerce that they adhere to the Data Privacy Framework
Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Data Privacy
Framework Principles, the Data Privacy Framework Principles shall govern.
For more information about the Data Privacy Framework
Principles and to view Crowdfire’s certification, please visit the Data Privacy Framework website at
https://www.dataprivacyframework.gov/. You may also contact us directly at [email protected]
to learn more about this certification.
With respect to Personal Data received or transferred pursuant to the Data Privacy Framework, Crowdfire is subject to the regulatory enforcement
powers of the U.S. Federal Trade Commission. In some cases, Crowdfire is potentially liable if its agents process your Personal Data in a
manner that is inconsistent with the Data Privacy Framework Principles, including in cases of onward transfers to third parties.
Crowdfire may be required to disclose personal information in response to lawful requests by public authorities, including to
meet national security or law enforcement requirements.
11. Dispute resolution
Crowdfire will investigate and attempt to resolve complaints and disputes regarding collection,
use and disclosure of Personal Data in accordance with the principles contained in this Privacy Policy.
EU, United Kingdom, Gibraltar or Swiss individuals with inquiries or complaints regarding our Data
Privacy Framework policy should first contact Crowdfire through the following Form.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF,
Crowdfire commits to refer unresolved complaints concerning our handling of personal data received
in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS,
an alternative dispute resolution provider based in the United States. If you do not receive timely
acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your
DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution
for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, more fully described on the Data Privacy Framework website,
you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
12. YouTube
12.1. Please note that in order to provide you with analytics and listening features for YouTube we use the YouTube API Services
12.2. You can find information about Google’s privacy policy and practices at the URL set forth below:
http://www.google.com/policies/privacy
12.3. If at any given time you want to revoke access to your data on Crowdfire you can visit the following link:
https://www.crowdfireapp.com/data-management#delete. Additionally you can also revoke Crowdfire’s access to your data via the Google security settings page at https://security.google.com/settings/.
13. Google Chrome Extension
By adding the Crowdfire Google Chrome Extension, users can effortlessly manage and post to all their social media accounts from a single platform. Simply sign in with your existing accounts and start sharing content seamlessly. The extension allows you to create and share posts directly from any tab using the toolbar icon, with options to share immediately, schedule for a specific time, or use Crowdfire's "Best Time" feature to post when your followers are most active. Additionally, users can right-click on any web page, image, or selected text to share specific content easily. We are committed to protecting your privacy and ensuring a secure experience while using the Crowdfire Google Chrome Extension.
14. Changes to Our Privacy Policy
It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our user's personal data, we will notify you by e-mail to the primary e-mail address specified in your account. The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this Policy to check for any changes.
15. Contact Information
The data controller responsible for your personal data is Crowdfire Inc. Please contact us by email at [email protected] or by post at:
Crowdfire Inc.
16192 Coastal Highway
Lewes, DE 19958
United States
16. Privacy Notice For California Residents
This section applies solely to consumers who reside in the State of California.
If you are a California resident, and you wish to access your personal data,
request from us that we delete your personal information, or require information
about our disclosure practices, you can choose to send us a verifiable consumer
request by email at [email protected], in addition to using the means set forth above.
In our assessment, we do not “sell” your personal information to third parties for monetary or other valuable consideration.