CROWDSURFR Privacy Policy


1. Background

This privacy policy lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data.

This privacy notice applies to personal information processed by or on behalf of CROWDSURFR. 

Changes to this privacy notice

We may change this privacy policy from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy policy for changes whenever you use our services.

CROWDSURFR ApS and our Data Protection Officer

We are CROWDSURFR ApS located at Amagerbrogade 250, 4. Th., 2300 Copenhagen S, Denmark. We are a data controller of your personal data. You can contact us with any questions regarding this policy and our processing of your data by writing to the above address or to this E-mail address: privacy@crowdsurfr.com

2. What kinds of personal information about you do we process?

Personal information that we may process in connection with our products and services, if relevant, includes: 

•	Personal and contact details, such as title, full name, contact details and contact details history
•	Your date of birth, gender and/or age
•	Your nationality, if needed for the product or service
•	Records of your contact with us if you get in touch with us online using our online services or via our smartphone app, details such as your mobile phone location data, IP address and MAC address
•	Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used
•	The usage of our products and services and details related to this
•	Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you. 
•	Information we obtain, buy or rent from third parties including demographic information, marketing lists, publicly available information, and information to help improve the relevance of our products and services
•	Insights about you and our customers gained from analysis or profiling of customers

3. What is the source of your personal information?

We’ll collect personal information from the following general sources:
•	From you directly
•	Information generated about you when you use our products and services
•	From a broker or other intermediary (for example, comparison site) who we work with to provide products or services to you
•	Business partners or others who are a part of providing your products and services or operating our business
•	From other sources such as publicly available directories and information (for example, telephone directory, social media, internet, news articles)
•	We buy or rent information about you or customers generally from third parties including demographic information, marketing lists, publicly available information and other information to help improve our products and services or our business

4. What do we use your personal data for?

We use your personal data for the following purposes:
•	Managing the product or service you have with us
•	Updating your records
•	Managing any aspect of the product or service
•	To make automated decisions on whether to offer you a product or service or terms of it
•	To perform and/or test the performance of, our products, services and internal processes
•	To improve the operation of our business and that of our business partners
•	For management and auditing of our business operations 
•	To monitor and to keep records of our communications with you and our staff 
•	For market research and analysis and developing statistics
•	For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We may send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match). 
•	To provide personalized content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
•	To develop new products and services and to review and improve current products and services
•	To comply with legal and regulatory obligations, requirements and guidance
•	To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses
•	To share information, as needed, with business partners, service providers or as part of providing and administering our products and services or operating our business
•	To facilitate the sale of one or more parts of our business

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

1.	Where it is needed to provide you with our products or services, such as:

a) Managing products and services you hold with us, or an application for one
b) Updating your records
c) Sharing your personal information with business partners and services providers to help manage your products and services
d) All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts
e) For some of our profiling and other automated decision making to decide whether to offer you a product and/or service

2.	Where it is in our legitimate interests to do so, such as:

a) Managing your products and services relating to that, updating your records and tracing your whereabouts to provide better service
b) To perform and/or test the performance of, our products, services and internal processes
c) To follow guidance and recommended best practice of government and regulatory bodies
d) For management and audit of our business operations
e) To carry out monitoring and to keep records of our communications with you and our staff 
f) For market research and analysis and developing statistics
g) For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We will send marketing to you by SMS, email, phone, post and social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match
h) Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses
i) For some of our profiling and other automated decision making
j) Where we need to share your personal information with people or organizations in order to run our business or comply with any legal and/or regulatory obligations

3.	To comply with our legal obligations

4.	With your consent or explicit consent:

a) For some direct marketing communications
b) For some of our profiling and other automated decision making

6. When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:
•	Affiliated companies and service providers
•	Business partners or others who are a part of providing your products and services or operating our business
•	Governmental and regulatory bodies 
•	Other organizations and businesses who provide services to us such as back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
•	Market research organizations who help us to develop and improve our products and services

7. How and when can you withdraw your consent?

Where we are relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.

8. Is your personal information transferred outside of Denmark?

We are based in Denmark but sometimes your personal information may be transferred outside Denmark or the EU. If we do so, we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply. 

9. What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website. We will then update your records if we can. 

10. Do you have to provide your personal information to us?

We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

11. Do we do any monitoring involving processing of your personal information?
 
In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications. 

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.
12. What about other automated decision making? 

We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. For instance, we may do this to decide: whether to offer you a product or service, what terms and conditions to offer you. We may also do this using data including product or services details (including usage of them) and location information. 
We’ll do this where it is necessary for entering into or performing the relevant service, is authorized by laws that apply to us, or is based on your explicit consent. 

13. For how long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:
•	For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
•	For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
•	Retention periods in line with legal and regulatory requirements or guidance.

14. What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. 

•	The right to be informed about the processing of your personal information
•	The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
•	The right to object to processing of your personal information
•	The right to restrict processing of your personal information
•	The right to have your personal information erased (the “right to be forgotten”)
•	The right to request access to your personal information and to obtain information about how we process it
•	The right to move, copy or transfer your personal information (“data portability”)
•	Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to Datatilsynet which enforces data protection laws: www.datatilsynet.dk. You can contact us through the e-mail address in section 1. 

15. Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us through the e-mail address in section 1.
16. What are your marketing preferences and what do they mean?

We may use your email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. 

You can opt out of any email or text marketing by contacting us or following any unsubscribe links. 

Contact Us

If you have any questions about this privacy policy, you can contact us by writing to this e-mail address: privacy@crowdsurfr.com


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