CROWDCASTER PRIVACY POLICY

This Privacy Policy was last updated on 31 August 2019

Audience

This Privacy Policy applies to all users of the crowdCaster Platform including any developers, mobile and application users (“you”, “your”, “users”).


Who we are

The Platform is operated by crowdCaster Limited, a company registered in England and Wales under company number 09810749 (“crowdCaster”, “we”, “us”, “our”). crowdCaster is the controller of your personal information.


Purpose of this policy

We respect your privacy and take the protection of personal information very seriously. The purpose of this policy (the “Privacy Policy”) is to describe the way we collect, store, use, and protect your personal information when providing the crowdCaster Platform, including our website (https://www.crowdcaster.com/), any related services, digital applications and software provided by crowdCaster, or any updated or modified versions thereof (the “Platform”).


Terms which apply to your use of the Platform

Please read the terms of this Privacy Policy carefully and in conjunction with the Terms of Use and the Acceptable Use Policy, and make sure that they are understood, before using the Platform.

IF YOU DO NOT WISH FOR YOUR PERSONAL DATA TO BE USED IN THE WAYS DESCRIBED WITHIN THIS PRIVACY POLICY THEN YOU MUST NOT ACCESS OR USE THE PLATFORM.


Changes to Privacy Policy

We may change the terms of this Privacy Policy at any time. We will notify you of any changes by placing a notice on the Platform or by email or a message on your account sign-up page. If you do not agree with the change you must stop using the Platform. If you continue to use the Platform following notification of a change to this Privacy Policy, the changed terms will apply to you and you will be deemed to have accepted such terms.


Personal Information

Your personal information is any information that can be associated with a specific natural or juristic person and can be used to identify that person (“personal information”).

Personal information includes:
  • certain information collected on registration (see below);
  • information we collect about you (see below); and
  • optional information that you provide to us (see below);
Personal information excludes:
  • information that has been made truly anonymous so that it does not identify a specific person; and
  • permanently de-identified information that does not relate or cannot be traced back to you specifically, even when combined with other information.

Collection of Information

On registration. 

Once you sign up to the Platform, you will no longer be anonymous to us as you will provide us with personal information. This personal information will include:

  • your email address; and
  • your password.

If you sign up to the Platform through a third party service (such as Facebook or Google+), we will receive information about you from such third party service, such as your name, email address, gender, locale and time zone and other information in your public profile. You can manage the information you share with crowdCaster by accessing your account permissions in the third party service.

Payment details. 

All credit card information is entered directly into our payment system partner and we do not see or keep these details.

Service information. 

When using certain services or functionalities of crowdCaster, you may be asked to provide us with additional information, such as your date of birth, telephone number and IP address. This service information may include any information that we require in order to provide the requested service or functionalities.

Optional details.

You may also provide additional information to us on a voluntary basis. This includes content or products that you decide to upload or download from crowdCaster, or when you subscribe to additional services offered by us or when you communicate directly with us (eg. when you contact us with any enquiries).

Your disclosure through communication channels.

crowdCaster allows users to communicate with each other through various communication channels, including public message boards. Please be aware that you are capable of disclosing your own personal information to other users through these communication channels. Other users can collect and use your personal information in this way. We take no responsibility for this and this Privacy Policy does not apply to any personal information that you disclose in this way.

Collection from the browser.

We automatically receive and record internet usage information on our server logs from your browser, such as your internet protocol address (“IP address”), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the Platform, and the dates and times that you visit the Platform, paths taken, and time spent on sites and pages within the Platform. Please note that other websites visited before entering the Platform might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

Third party cookies.

Please note that some of our business partners (e.g. advertisers) use their own cookies or widgets on the Platform. We have no access to or control over them. Information collected by any such cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

Web beacons.

the Platform may contain electronic image requests (called a “single-pixel gif” or “web beacon” request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about the Platform.

Other information.

We also work closely with third parties (such as sub-contractors in payment and delivery services) in order to give you the best experience possible and we may receive information about you from them.


Legal bases on which we process your personal information

We will process your personal information

  • where we need to, to perform and enforce the obligations contained within a contract we are about to enter into or have entered into with you, including the Terms of Use; or
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests means the interests of our organisation in conducting and managing our business to enable us to give the best possible service to our users and the best and most secure experience on our Platform; or
  • where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending direct marketing communications to you.


Purposes for which we process your personal information

We may use any personal information that we have collected or obtained in order to:

  • validate you as a registered user and enable you to access and enjoy the Platform;
  • notify you about changes to the Platform;
  • ensure that content from the Platform is presented in the most effective manner for you and for your computer;
  • administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • remember your information so that you will not have to re-enter it during your visit or the next time you access the Platform;
  • monitor the Platform and website usage metrics such as total number of visitors and pages accessed;
  • track your entries, submissions, and status in any promotions or other activities in connection with your usage of the Platform;
  • allow you to participate in interactive features of our service, when you choose to do so;
  • ensure the security and safety of you, our staff and other users of the Platform;
  • prevent and detect criminal activity, fraud and misuse of, damage to, the Platform and to prosecute those responsible, to defend our rights and property and to protect the rights and interests of our users and third parties;
  • to comply with applicable laws, regulations, court orders and government and law enforcement agencies’ requests;
  • measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • provide you with information about goods or services we feel may interest you;
  • make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them; and/or
  • processing payments for Premium Accounts.

Messages and updates. 

We may send administrative messages and email updates to you about crowdCaster. Where we have obtained your express consent to do so, we may also send you promotional messages. You can choose to opt-out of promotional emails at any time, either by contacting us using the details provided at the end of this Privacy Policy, or by clicking on the unsubscribe link at the bottom of any of the promotional emails we send to you.

Target content.

While you are logged into the Platform, we may display targeted adverts and other relevant information based on the personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a customer is visiting from the Platform. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.


Disclosing your information

Sharing.

You may voluntarily share your personal information and any content that you upload to, or share on, the Platform. You should carefully choose who you share information with and be particularly careful about sharing any content that includes sensitive information about yourself, such as religious denomination, sexual orientation, ethnic background and health details. We cannot accept responsibility or liability for information shared in this way.


Disclosing.

We may share your personal information with:

  • other divisions or companies within the group of companies to which we belong, being Online Radio Broadcasting Limited (registered office at 13-21 High Street Guildford United Kingdom GU1 3DL and company number 07462851), so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
  • an affiliate, in which case we will seek to require the affiliates to honour this Privacy Policy;
  • our service providers under contract who help with parts of our business operations, including payment processing, fraud prevention, bill collection, marketing, technology services (our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit);
  • credit bureaux to report account information, as permitted by law; and
  • banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria).

Regulators.

If you contact us regarding your experience with using any of our products, we may disclose your personal information as required by law or governmental audit.

Law enforcement.

We may disclose personal information if required:

  • by a subpoena or court order;
  • to comply with any law;
  • to protect the safety of any individual or the general public; and
  • to prevent violation of our terms of use.

Copyright infringement. 

We have the right to disclose your identity to any third party who is claiming that any content posted, uploaded, shared by you using the Platform constitutes a violation of their intellectual property rights, or of their right to privacy.

No selling.

We will not sell personal information. No personal information will be disclosed to anyone except as provided in this Privacy Policy.

Marketing purposes. 

We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

Employees.  

We may need to disclose personal information to our employees that require the personal information to do their jobs.

Changes of ownership. 

If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on crowdCaster. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.


Security of personal information

Our hosting company will host crowdCaster in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities.

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 site; any transmission is at your own risk.


Accurate and up to date

We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes explicitly defined in this policy. From time to time we may request you to update your personal information on the Platform. You are able to review or update any personal information that we hold on you by accessing your account online, by emailing us, or by phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.


Retention of personal information

We will only retain your personal information for as long as it is necessary for business purposes or for legal requirements.

During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information except as provided for by this Privacy Policy.


Our Commitment to Children’s Privacy

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain personally identifiable information from persons under 13 years old. If we learn that personally-identifiable information of persons less than 13 years old has been collected on or through the Platform, then we will take the appropriate steps to delete this information.

If you are the parent or legal guardian of a child under 13 who has become a registered user, then please contact us at info@crowdcaster.com to have that child’s account terminated and information deleted.


Cross-border transfer of personal information

We may transfer your personal information to third parties which are based outside of the European Economic Area (“EEA”). For example, your personal information may be hosted on a server which is located in a foreign country which is located outside of the EEA.

Wherever we transfer your personal information outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

  • We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details see here.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in the EEA. For further details, see here.
  • Where we use providers based in the USA, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the EEA and the USA. For further details, see here.

Please contact us using the details provided at the end of this Privacy Policies if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.


Your rights

If you are located in the EEA, you have a number of rights in relation to how we process your personal information. These include:

  • the right to access the personal information that we may hold about you;
  • the right to rectify any inaccurate personal information that we may hold about you;
  • the right to have your personal information erased in certain circumstances, for example, where it is no longer necessary for us to process your personal information to fulfil our processing purposes; or where you have exercised your right to object to the processing;
  • the right to restrict the processing of your personal information where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;
  • the right to object to the processing of your personal information which may be exercised in certain circumstances, for example, where we are processing your personal information for direct marketing purposes, or where your own legitimate interests outweigh ours; and
  • the right to have your data ported to a new service provider if you no longer wish to use the Platform.

You can exercise any of these rights any time by contacting us using the details provided at the end of this Privacy Policy.

No fee usually required.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise your rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


Limitation

This Privacy Policy does not apply to third party websites or services linked to the Platform or which advertise on the Platform. These third party websites, apps and services operate their own privacy policies which we encourage you to read and for which we cannot be responsible.


Enquiries

If you have any questions or concerns arising from this Privacy Policy or the way in which we handle personal information, please contact us at info@crowdcaster.com

EEA residents only

Should you have any concerns about how we handle your personal data, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to your national supervisory authority which, in the United Kingdom is the Information Commissioner’s Office.