CROWDY (“Crowdy”, “we”, “us”, “our” and terms of similar meaning) takes your privacy rights very seriously. We are committed to transparently describing our privacy practices, including how we collect, use and disclose (a) your personal or personally identifiable information or business information (if and as applicable) (“Information”); and (b) data we obtain from your activity on the Platform (as defined below) (“Data”) as part of providing the website (https://getcrowdy.app) and/or the Crowdy iOS, Android and/or web based applications and the software and services available thereon (each an “Application” and collectively the “Applications”). The Site and/or each Application shall collectively be referred to as the “Platform”.
We encourage you to read and understand our terms and conditions (“Terms”) that apply to your particular use of the Platform, and this privacy policy (“Privacy Policy”) before accessing and/or using the Platform. By accepting the Terms and/or Privacy Policy or accessing and/or using the Platform, you consent to our collection, use and disclosure of Information and Data in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms.
All capitalized terms or terms that were otherwise defined in the applicable set of Terms that are not otherwise defined herein obtain their meaning from the Terms.
1. What Information and Data Do We Collect?
(a) Information.
(i)
Our primary purpose in collecting Information from you voluntarily is to provide you with a safe, smooth, efficient, and customized experience when using the Platform. We will only ask for and collect Information that we consider necessary for achieving this purpose.
(ii)
You can browse the public facing sections of the Platform without telling us who you are or revealing any Information. When applying for or registering for a User Account, as applicable, you must provide Information as requested or where indicated on the Platform. At that time, you will no longer be anonymous to us. Where possible, we indicate which fields are required and which fields are optional. In addition, as you use the Platform, you may be requested or required, from time to time to share through the Platform (either with us or other Users) further Information. Information you may be requested or required to provide may include, without limitation:
Registered Business: your name, phone number, e-mail address, password, business name, business logo, trademarks, spoken languages, Business Offerings, certifications, awards, qualifications, licenses and/or Verifying Information.
(iii)
You represent that you have the right and authority or have obtained all necessary consents and approvals to provide any Information, including any Information of another individual or entity, that is provided by you to Crowdy and/or another User through the Platform or otherwise.
(iv)
If you are able to and do sign up for a User Account using a Third-Party Provider Account, we may also get basic Information from your Third-Party Provider Account profile, which may include your name, gender, profile photo and/or connections.
(v)
You always have the option to not provide Information by choosing not to use, access and/or become a User.
(b) User Feedback.
We may collect ratings and reviews, feedback and other Information from other Users. Such ratings and reviews, feedback and other Information shall be made in accordance with the Terms.
(c) Data Collected Automatically
(i)
When you use the Platform, Crowdy automatically receives and records Data from your device, including, without limitation, your location, IP address, browser type (if applicable), operating Data, device Data, mobile carrier (if applicable), device and application IDs, “cookie” information, and the page you requested. Unless otherwise stated in this Privacy Policy, Crowdy only uses this Data in aggregate form.
(ii)
“Cookies” and similar technologies are small files placed on your computer and devices that assist us in providing the Platform. We and our third-party service providers use cookies and similar technologies to provide and personalize the Platform, analyze use, and prevent fraud. You can disable cookies in your browser settings, however, if you do so, some parts of the Platform may not function properly.
(iii)
The Platform uses location services made available online by other platforms. Location services allow location-based applications and websites, like the Platform, to use Data from internet service providers, cellular, Wi-Fi and Global Positioning System (GPS) networks to determine your approximate location. We use location services to facilitate the ordinary operation of the Platform, including to identify and display Businesses, Business Offerings, events, promotions, recommendations, and other information that may be relevant based on your location.
(iv)
If you turn on “Bar check-ins with Crowdy closed” in the Crowdy mobile application, with or without a User Account, your device may use location in the background, only near bars listed in Crowdy, to determine when you arrive at and leave a bar. The determination is made on your device. Crowdy receives only which bar, the time you arrived, the time you left and how long you stayed; Crowdy does not receive or store your coordinates through this feature. Crowdy uses this to send you one notification asking about the scene after you have been at a bar for a while, and keeps stays in aggregate to understand how busy bars are and how long people tend to stay. You can turn this off at any time in the application or in your device’s location settings.
2. How Do We Use Information and Data?
We may use Information to determine your eligibility to have a User Account. We may also use your Information and Data to provide to you the License to use the Platform, to provide you with the Platform; to communicate with you, either directly or through one of our partners, including for marketing and promotional purposes; to improve our marketing and promotional efforts; to advise of pricing and Platform related updates; to resolve service disputes; to troubleshoot problems; to inform you about online and offline offers, products, services, events and updates; to analyze usage of the Platform; to improve our Platform and Content offerings; to deliver information to you that, in some cases, is relevant to your interests; to provide in-app and push notifications based on your preferences, saved Businesses or Business Offerings, plans, and other activity on the Platform, where permitted by applicable law and your notification settings and express consent; to customize your experience, layout, and the Platform; to detect and protect us against error, fraud and other criminal activity; to enforce our Terms; to provide you with system or administrative messages; and/or as otherwise described to you at the time of collection. These uses improve the Platform and better tailor it to meet your needs.
3. Our Disclosure of Information and Data
(a)
General Disclosure. We may share your Information and Data with third parties only in the ways that are described in this Privacy Policy, the Terms and in accordance with your consent. We will not share, sell or rent your Information and Data to third parties without your explicit consent.
(b)
Sharing Between Users. Users of the Platform may be able to see basic Information about each other, including, as applicable, names, photos, ratings, itineraries, polls, and any other Information added to a User Account or to User Content. If you send us a photo of a bar, it is checked by a person and, if approved, shown publicly on that bar’s page in the app and on the website, with your name only if you choose to show it. Your bar photos are removed when you delete your account. To ask us to take a photo down, email hello@getcrowdy.app.
(c)
Anonymized Aggregated Data. We may aggregate and anonymize Data and use and disclose it for a variety of purposes, including analytics. However, in these situations, we do not disclose any Information.
(d)
Public Areas of the Platform. User activities in the public areas of the Platform may be identifiable to a User Account, and all or certain users of the Platform may be able to see your published content.
(e)
Laws and Jurisdictions. Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose Information and Data if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or any other person’s or entity’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your Information and Data.
(f)
Sale of Business. We may disclose Information and Data to the acquiror or its agents in the course of the sale of our business. If we do this, the disclosure will be subject to confidentiality arrangements customary in such transactions.
(g)
Storing and Processing Information and Data. In some cases, Information and Data that we collect may be stored or processed outside of Canada. When that occurs, we continue to protect the Information and Data with appropriate safeguards and data export requirements, but it may be subject to the legal jurisdiction of those countries and governmental authorities in those countries.
(h)
Subsidiaries, Affiliates and Service Providers. We may use the services of affiliates, subsidiaries and/or unrelated service providers (collectively, “Third Parties”) in connection with our provision of the Platform, including, without limitation, if applicable, for the processing of payments, off-premise data hosting, communication services, and mapping and location-related functionality, including through Google Maps. We may disclose your Information and Data to the Third Parties in the course of our use of their services. We take care to use Third Parties that we believe are reputable and capable of performing the services we require of them, including, without limitation, the handling of confidential information and Information and Data and the compliance with all applicable laws.
4. Accessing, Correcting and Deleting Information and Data
You may review and update certain Information through your User Account or by contacting us to ensure that it is accurate and complete. You may also request the deletion of your User Account using the account-deletion functionality available within the Application. Upon completion of the account-deletion process, we will delete or de-identify the Information and Data associated with your User Account, except to the extent that retention is permitted or required under this Privacy Policy or applicable law.
How to delete your account
In the app, go to your Profile and tap Delete my account. If you cannot get into the app, email hello@getcrowdy.app from the address on your account and we will delete it for you.
5. Information and Data Retention
(a)
General Retention Policy. We keep Information and Data for as long as it is required for the purposes for which it was collected, which is determined in our sole discretion, in accordance with the applicable laws. Notwithstanding the foregoing, we may periodically de-identify (a) Information from collected Data in unused User Accounts; and (b) unnecessary Information from Data collected elsewhere on and/or through the Platform. Subject to the Terms, this Privacy Policy, and applicable law, with the exception of aggregated Data, we may delete unused User Accounts and the Information and Data associated with them within a time period as required by applicable law, if any.
(b)
Termination of Account and/or Login. If your User Account is terminated, we will deactivate the User Account and delete or de-identify the associated Information and Data, subject to any limited retention permitted or required by applicable law. For example, we may retain records of your consent to receive commercial electronic messages, and any withdrawal of that consent, for the purpose of demonstrating compliance with applicable anti-spam laws. We may also retain Information and Data where reasonably necessary in accordance with applicable law, and disclose it in a manner consistent with our practices under this Privacy Policy.
6. Age Restrictions
The Platform is not intended for individuals who are under the legal drinking age in their province or territory of residence. Crowdy does not target the Platform to individuals who are under the applicable legal drinking age, does not intentionally or knowingly collect Information or Data from such individuals, and does not knowingly permit such individuals to use the Platform.
7. Security
Each User Account is protected by a password for your privacy and security. You must prevent unauthorized access to your User Account by selecting and protecting your password appropriately and limiting access to your device. We strive to protect your Information and Data by putting in place a range of technical and organizational measures to safeguard and secure the Information and Data we receive from you, including without limitation, security technologies. We are continuously utilizing security measures to protect your Information and Data from unauthorized access or against loss, misuse or alteration. Despite our efforts, we cannot guarantee the security of any Information and Data. Unauthorized entry or use, hardware or Platform failure and other factors, may compromise the security of Information and Data at any time.
8. Other Information and Data Collectors
Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of Information and Data we collect from you. To the extent that you disclose Information and Data to other parties (including other Users) through the Platform, different rules may apply to their use, collection and disclosure of Information and Data. Since we do not control the Information and Data use, collection or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose Information and Data to others.
9. Changes to This Privacy Policy
Crowdy may amend this Privacy Policy from time to time. The use of Information and Data we collect is subject to this Privacy Policy and the Terms in effect at the time the Information and Data is used. If we make any material changes in the way we use Information and Data you provide to us, we will notify you by (i) posting a notice on your User Account page or otherwise through the Platform; (ii) sending you an email at the address registered on the applicable User Account or provided in your Registration Data; and/or (iii) otherwise notifying you pursuant to the notice or modification provisions in the Terms. You are bound by any changes to the Privacy Policy and the Terms when you access or use the Platform after such changes have been first posted, subject to the terms and conditions of the Terms.
10. Questions?
It is our goal to make our privacy practices easy to understand. If you have questions, concerns or if you would like more detailed information, please email us at hello@getcrowdy.app.
