Privacy Policy

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to Hear The Crowd Limited, 10 Beverley Road, London.
• Cookies are small files placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: United Kingdom
• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
• Website refers to Hear The Crowd, accessible from www.hearthecrowd.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Address, State, Province, ZIP/Postal code, City
• Usage Data

Usage Data

Usage Data is collected automatically when using the Service. It may include information such as Your Device's IP address, browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, and unique device identifiers.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons that permit the Company to count users who have visited those pages or opened an email.

Where required by law, we use non-essential cookies (such as analytics cookies) only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool or through Your browser/device settings.

Types of Cookies We Use

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service.
• To contact You: To contact You by email or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities or security updates.
• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, or other sale or transfer of some or all of Our assets.
• For other purposes such as data analysis, identifying usage trends, and evaluating and improving our Service.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We apply different retention periods to different categories of Personal Data:

• User Accounts: retained for the duration of your account relationship plus up to 24 months after account closure.
• Support tickets and correspondence: up to 24 months from the date of ticket closure.
• Website analytics data: up to 24 months from the date of collection.
• Server logs: up to 24 months for security monitoring and troubleshooting purposes.
• Email Marketing: retained until you unsubscribe or up to 24 months from your last engagement, whichever comes first.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. You may update, amend, or delete Your information at any time by signing in to Your Account and visiting the account settings section. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.

Disclosure of Your Personal Data

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send.

We use Mailchimp as our Email Marketing Service Provider. For more information on the privacy practices of Mailchimp, please visit their Privacy Policy.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Rights under the GDPR

If You are within the EU, You have the following rights:

• Request access to Your Personal Data — access, update or request deletion of information We have on You.
• Request correction of any incomplete or inaccurate information We hold about You.
• Object to processing of Your Personal Data where We are relying on a legitimate interest as the legal basis.
• Request erasure of Your Personal Data when there is no good reason for Us to continue processing it.
• Request the transfer of Your Personal Data in a structured, commonly used, machine-readable format.
• Withdraw Your consent at any time.
• Request restriction of processing in certain circumstances.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. If You are in the EEA, please contact Your local data protection authority.

Facebook Fan Page

As operator of the Facebook Fan Page at Hear The Crowd on Facebook, the Company and the operator of the social network Facebook are Joint Controllers.

For more information on the privacy practices of Facebook, please visit the Facebook Privacy Policy.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This section applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We may collect the following categories of personal information from California residents:

• Category A: Identifiers (e.g. email address, IP address, account name) — Collected: Yes
• Category B: Personal information per Cal. Civ. Code § 1798.80(e) (e.g. name, address) — Collected: Yes
• Category F: Internet or other similar network activity (e.g. browsing history, interactions with our website) — Collected: Yes
• All other categories — Collected: No

Your Rights under the CCPA/CPRA

• The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which they are used.
• The right to know/access. You have the right to request disclosure of Our collection, use, sale, and disclosure of personal information.
• The right to opt-out of the sale or sharing of Your personal information.
• The right to correct inaccurate personal information.
• The right to delete Your Personal Information under certain circumstances.
• The right not to be discriminated against for exercising any of Your consumer rights.

To exercise Your rights, contact Us at support@hearthecrowd.com. We generally respond within 45 days.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. We strongly advise You to review the Privacy Policy of every site You visit.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

• By email: support@hearthecrowd.com