Capitalised terms used herein but not otherwise defined shall have the meaning given in the terms of service provided to you when you signed up as a User of the Website.
1. Important information and who we are
The Website is not intended for children and we do not knowingly collect data relating to children.
1.3 Contact details
Our full details are:
Full name of legal entity: Crowd2Fund Limited (company number 08472687)
Postal address: 242 Acklam Road, London, England, W10 5JJ
Email contact: firstname.lastname@example.org
Name or title of DPO: Chris Hancock
Email address of DPO: email@example.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.5 Third-party links
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.1 We use the information we collect about you (including your personal data) so that we can improve our Website and better customise it to meet your needs. We also use the information we collect about you to resolve disputes, troubleshoot problems, and enforce our User Terms.
2.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- (a) Identity Data includes name, username, marital status, title, date of birth and gender.
- (b) Contact Data includes address, email address and telephone number.
- (c) Financial Data includes bank account and payment card details.
- (d) Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- (e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, referral source / exit pages, length of visit, page views, website navigation and search terms that you use and other technology on the devices you use to access the Website.
- (f) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.4 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
3.1 We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our services;
- submit or invest in a Campaign;
- complete a form on our Website;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services including without limitation credit reference agencies and fraud reference agencies.
- Identity, Contact and Financial Data from data brokers or aggregators.
- Identity and Contact Data from publicly availably sources such as Companies House.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform our services to you including without limitation to set up, manage and close a Campaign and to enable you to invest through a Campaign.
- 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.
- 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 data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
4.1 Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer, either a Campaign Creator or an Investor||Performance of a contract with you|
|To carry out anti-money laundering checks, credit checks and identity checks on you||Legal obligation|
|To process and deliver services including:
|To provide you with information on Campaigns that you have indicated are of interest to you, or which we reasonably believe are of interest to you|
|To provide you with updates on any Campaign being run by you as Campaign Creator, or in which you have made a pledge as Investor|
|To provide information any fraud you commit or seek to commit on the Website|
|To manage defaults in respect of loans entered into on the Website, and to disclose information as required to third parties to assist with the management of such defaults|
|To manage our relationship with you which will include:
|To enable you to partake in a prize draw, competition or complete a survey|
|To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)|
|To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve the Website, services, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Necessary for our legitimate interests (to develop our products/services and grow our business)|
4.2 Checking databases
Please note that when you submit a Campaign, we will check the following personal and business records about the director, partner, or member who agrees to our terms on behalf of the main applicant:
- our own records;
- records of CRA’s (Credit Reference Agencies);
- records of FPA’s (Fraud Reference Agencies).
We check the records of CRA databases, which relate to the main applicant’s personal and business activities.
We will make checks such as assessing the application for credit and verifying identities to prevent and detect crime and money laundering. We may also make periodic searches at CRA’s and FPA’s to manage our relationship with you.
The agencies will link your records to those of your financial associate(s), including any previous names. These links will remain on your files until you or they tell the agency that you are no longer financially linked and the agency accepts this.
When CRA’s receive a search from us they will place a search on the credit file of the applicant(s) that may be seen by other lenders. This footprint differs from a consumer lending search and is less likely to impact the main applicant’s ability to obtain personal finance in the future, however, large numbers of credit applications within a short time period may impact the main applicant’s ability to obtain business finance in the future (as a director or a linked individual).The CRA’s supply to us both public (including the electoral register) and shared credit and fraud prevention information. If you are a director, we may also seek confirmation, from credit reference agencies, that the residential address that you provide is the same as that shown on the restricted register of director’s usual addresses at Companies House.
We will also provide details of your loan(s)/account(s) and how you manage it/them to CRA’s. If you borrow, or guarantee a loan, and do not repay in full and on time, CRA’s will record the outstanding debt, this information may be supplied to other organisations by CRA’s and FPA’s to perform similar checks and to trace your whereabouts and recover debts that you owe. Records remain on file for 6 years after they are closed, whether settled by you or defaulted. We will report such activities against the Business.
The Credit Reference Agencies that we use are Callcredit Limited (registration number 03961870) with registered office at One Park Lane, Leeds, West Yorkshire, LS3 1EP. You may call them on 0845 366 0071 or visit their website at www.callcredit.co.uk. We may also use Experian Ltd, who can be contacted via their Consumer Help Service, PO Box 8000, Nottingham NG80 7WF. You may contact them on 0844 4818000 or visit their website at www.experian.co.uk. We may also use Equifax Ltd (registration number: 2425920) with registered office at Capital House, 25 Chapel Street, London NW1 5DS. They may be contacted at Equifax Ltd, Customer Service Centre, PO Box 10036, Leicester, LE3 4FS or visit their website at www.equifax.co.uk
If you give us false or inaccurate information and we have reasonable grounds to suspect fraud or we identify fraud we may record this and will also pass this information to fraud prevention agencies and it may also be passed onto other organisations involved in crime and fraud prevention. We and other organisations may also access and use such information to prevent fraud and money laundering, for example, when (i) checking details on applications for credit and credit related or other facilities; (ii) managing credit and credit related accounts or facilities; (iii) recovering debt; (iv) checking details on proposals and claims for all types of insurance and (v) checking details of job applicants and employees. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.
For the avoidance of doubt, it may be necessary from time to time to send emails and other communications to Users to update them with regards to our services. For the avoidance of doubt, these communications do not constitute direct marketing and cannot be unsubscribed from.
4.5 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may withdraw any consent given to receive direct marketing communications from us by contacting us.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
4.6 Third-party marketing
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
4.7 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you purchasing services from us.
Cookies are text files stored, either on a temporary or persistent basis on the hard drive of your computer. Cookies are used for authenticating, session tracking and maintaining specific information about the use and users of the Website.
The data collected by cookies is anonymous. You can delete all cookies that are already on your computer's hard drive by searching for files with "cookie" in it and deleting them. In addition, if you want to stop cookies from being stored on your computer, you can edit your browser settings so that cookies are blocked. Unfortunately, if you block cookies you may not be able to use the full functionality of the Website. For more information about cookies, please visit: www.allaboutcookies.org
Web beacons consist of a small string of software code that represents a graphic image request on a page or email. There may or may not be a visible graphic image associated with the web beacon and often the image is designed to blend into the background of a page or email. Web beacons can be used for many purposes - including site traffic reporting, unique visitor counts, advertising auditing and reporting, and personalization. Web beacons used by www.crowd2fund.com collect only anonymous data.
In order to improve the Website and the services we offer you, we may use (temporary and persistent) cookies, authorized third parties cookies, web beacons and/or other technologies to collect non-personally identifiable data. This non-personally identifiable data helps us to track browsing behaviour, to create specific or tailor-made offers or advertisements, and to monitor and record the visits and use of the Website.
In order to understand how people use the Website and for marketing analysis and quality improvement purposes, we (and/or third party service providers) may collect, record, process and use on an anonymous basis certain information (including the total number of transactions, viewed pages, referring/exit pages, platform type, date/time stamp information and details like the number and location of mouse clicks on a given page, mouse movements, scrolling activity and the search words you use while being on and using the Website.
4.9 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties which are the following: Indebted (www.indebted.co), Mangopay (www.mangopay.com), Onfido (www.onfido.com), Comply Advantage (www.complyadvantage.com), Equifax (www.equifax.co.uk), Call Credit (www.callcredit.co.uk), Google Analytics (www.google.com/analytics), AdRoll (www.adroll.com), Facebook (www.facebook.com), LinkedIn (www.linkedin.com), Mailchimp (www.mailchimp.com), Twillio (www.twillio.com), Apple (www.apple.com), HMRC (www.online.hmrc.gov.uk), Postcode Anywhere (www.postcodesoftware.net), Mandrill (www.mandrill.com), New Relic (www.newrelic.com), Fabric (www.fabric.io), GoCardless (www.gocardless.com), Hubspot (www.hubspot.com), Intercom (www.intercom.com), Zendesk (www.zendesk.com)
5.1 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5.2 If you are a Campaign Creator, the information you provide will mostly be public information relating to your Campaign. To the extent that you provide additional personal and non-public information such as your bank account details and private contact details, we will not make such information public.
5.3 When you register as a User of the Website, the Hidden User function will be automatically activated. You may choose to opt out and deactivate the Hidden User function after registering with the Website. When you view a Campaign with the Hidden User function activated, no personal information shall be disclosed to a Campaign Creator save for an anonymous “tag” name, which you create after registering with the Website.
5.4 For the avoidance of doubt, Users are responsible for the data that they upload and any data which is uploaded on to the Website shall be considered public data. Consequently, any User who chooses a “tag” name pursuant to clause 4.3 that includes personal and/or sensitive data does so at their own risk.
5.5 The Hidden User function shall be deactivated if:
- pursuant to clause 4.1, you pledge a Support Contribution or Investment Amount in a Campaign and that Campaign goes on to be successful, in which case the User’s personal information shall be disclosed to the extent necessary to complete all post-Campaign documentation and/or formalities. For the avoidance of doubt, the Hidden User function shall remain activated for all other live Campaigns; or
- you decide to manually deactivate the Hidden User function by visiting the settings dashboard page of the Website.
6. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data: see Erasure Request below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (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 access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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.