Privacy Policy

1. INTRODUCTION

1.1  We are Crowd2Fund Limited (referred to as "we",“us” and “Crowd2Fund”) and we are committed to protecting and respecting your privacy when you are visiting any website maintained by us including without limitation the Website at www.crowd2fund.com, our mobile application and our social networking pages, as we may publish and operate from time to time or communicating electronically with us.

1.2   This Privacy Policy is part of the User Terms and should be read in conjunction with the other applicable documents making up the User Terms.

1.3  Capitalised terms not otherwise defined in this Privacy Policy shall have the meanings given in the other documents that make up the User Terms.

1.4  This policy (together with the User Terms) explains what types of personal and non-personal information we collect when you use the Website and the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

1.5  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By disclosing your personal information to us by using the Website or speaking to us over the telephone you consent to the collection, storage and processing of your personal information as stated in this policy.

1.6  Crowd2Fund uses the personal information we collect from you to provide our Services to you. We will not rent, sell or share your personal information with any other company for its own marketing purposes without your consent except where mentioned in this policy.

1.7  For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Crowd2Fund Limited of 242 Acklam Road, London, W10 5JJ, which is registered with the ICO with registered number ZA045236.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

2.1  We may collect, store and use the following kinds of personal information:

  • (a) if you decide to register as a User of the Website, you will be asked to either:
    1. complete a form which will require you to provide some or all of your name, address and email address, email address and mobile number; or
    2. authorise LinkedIn or Facebook to provide Crowd2Fund with profile information for the purposes of accessing and using the Website.
  • (b) if you sign up as a User and decide to create a Campaign or pledge a Support Contribution, Donation or Investment Amount, you will be required to provide your bank details and possibly your debit/credit card details to our payment providers, GoCardless and MangoPay. Crowd2Fund will receive and securely store debit/credit card or bank account information;
  • (c) when you contact us by email or telephone or through any contact form provided on the Website, we may ask you to provide some or all of the information set out in paragraphs (a) and (b) above;
  • (d) a User who uses the Services provided by Crowd2Fund may be required to provide some or all of the personal information set out in the User Terms;
  • (e) we may collect, store and use information about your computer, mobile device or other item of hardware through which you access the Website and your visits to and use of the Website (including without limitation your IP address, geographical location, browser/platform type and version, Internet Service Provider, operating system, referral source/exit pages, length of visit, page views, website navigation and search terms that you use);
  • (f) in order to improve your experience in using the Website, we may store information relating to your previous browsing habits in order to select and suggest Campaigns that may be of interest to you; and
  • (g) if you access the Website through a social networking profile, we may collect, store and use the details of that social networking profile and any information contained therein in order to populate any forms you might wish to complete on the Website.

2.2  We may also ask you to complete surveys and give feedback that we use for research purposes, although you do not have to respond to them.

3. HOW DO WE USE PERSONAL INFORMATION?

3.1  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.

3.2  We may use for promotional, sales or any other use that we consider appropriate your correspondence with us or User Content submitted for publication on our Website.

3.3  We may use third-party advertising companies to serve advertisements when you visit our Website. These companies may use information about your visits to the Website and other websites in order to provide advertisements about goods and services of interest to you. This information does NOT include information like your name, address, email address, or telephone number

3.4  We may use your personal information for the following purposes:

  • (a) to manage and administer the Website;
  • (b) to improve your browsing experience by personalising the Website;
  • (c) to enable you to use the Website;
  • (d) to enable us to set up transfers between User’s Wallets and bank accounts;
  • (e) to send you newsletters and other relevant and targeted promotional communications;
  • (f) to deal with enquiries, complaints and feedback from you;
  • (g) to provide third parties with statistical anonymised information about our users;
  • (h) to send you emails offering you to take part in a survey and/or give feedback; and
  • (i) to analyse and improve the services offered on the Website.

3.5  When you submit campaign, we will check the following personal and business records about the director, partner, or member who agree to this agreement on behalf of the main applicant:

  • (a) our own records;
  • (b) records of CRA’s (Credit Reference Agencies);
  • (c) records of FPA’s (Fraud Reference Agencies).
  • (i) to analyse and improve the services offered on the Website.

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

3.6  Fraud

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.

4. WHEN MIGHT WE DISCLOSE PERSONAL INFORMATION?

4.1  Except to the extent required by any applicable law or governmental or judicial body, if you are a User who is not a Campaign Creator, we will not disclose your personal information to any third party other than to:

  • (a) a Campaign Creator who has submitted a Campaign in which you have pledged either an Investment Amount or a Support Contribution and that Campaign is successful; and/or
  • (b) a Campaign Creator when the “Hidden User” function has been deactivated.

4.2  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.

4.3  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.

4.4  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.

4.5  The Hidden User function shall be deactivated if:

  • (a) 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
  • (b) you decide to manually deactivate the Hidden User function by visiting the settings dashboard page of the Website.

4.6  Though we make every effort to preserve Users’ privacy, we may need to disclose your personal data when required by law or if we have a good-faith belief that such action is necessary to:

  • (a) comply with a current judicial proceeding, a court order or legal process served on us or our Website;
  • (b) comply with any request by the FCA and/or the Prudential Regulation Authority in the UK (or any other regulator who may have jurisdiction over us from time to time);
  • (c) enforce this Privacy Policy or the User Terms;
  • (d) respond to claims that your personal data violates the rights of third parties;
  • (e) protect the rights, property or personal safety of Crowd2Fund, its Users and the public; or
  • (f) facilitate a sale of our business, its assets or Crowd2Fund Limited.

4.7  You authorise us to disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose us or you to legal liability.

4.8  We may disclose information with Credit Reference Agencies and Fraud Prevention Agencies or any similar organisation which provides a centralised application matching service that collects information from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud. We may also provide information to third parties to help them to make decisions about whether to lend to you, allow you extended payment terms or otherwise do business with you.

5. NEWSLETTERS AND OTHER PROMOTIONAL COMMUNICATIONS

5.1  If you wish to subscribe to any newsletter published by us or wish to receive other targeted and relevant promotional communications from us or other carefully chosen affiliates, we offer you the option to “opt-in” to this service. If you change your mind and wish to stop receiving any such communications, please either email us at info@crowd2fund.com or click the “unsubscribe” link in any email from us.

5.2  Due to the nature of the business of Crowd2Fund, it may be necessary for Crowd2Fund to send emails or other communications to Users to update them with regards to the services that are provided. For the avoidance of doubt, these communications do not constitute “direct marketing” under section 11(3) of the Act and as such, cannot be unsubscribed from.

6. OUR USE OF COOKIES AND WEB BEACONS

6.1  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.

6.2  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

6.3  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.

6.4  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.

6.5  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.

6.6  If you register with us or if you continue to use the Website, you agree to our use of cookies.

7. WHERE WE STORE YOUR PERSONAL DATA

7.1  The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our Owners. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7.2  All information you provide to us is stored on our secure servers.

7.3  We take the security of your personal data very seriously. In particular, we use all reasonable endeavours to ensure that appropriate security measures are in place to protect your personal data. Unfortunately, the transmission of information via the internet is not completely secure and so we cannot guarantee the security of your data transmitted through the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

8. SECURITY

8.1  Crowd2Fund continually tries to keep all information secure from unauthorised access by using SSL encryption on sensitive data. However, transmission over the internet cannot be guaranteed to be 100% secure, so any information you submit is done so at your own risk.

The Website may include links to third party websites. We are not responsible for the content of third party websites. Please ensure that prior to using any such website, you have read and understood its Privacy Policy and Terms and Conditions. These documents will govern your rights and obligations when using the relevant third party website.

10. YOUR RIGHTS

The Act gives you the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at info@crowd2fund.com

11. ACCESS TO INFORMATION

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

12. CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy. Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

13. CONTACT

13.1  Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to info@crowd2fund.com

13.2  For more information about data protection and the protection of personal information, please visit www.ico.org.uk.

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