Privacy Policy

1 About this Privacy Policy

This privacy policy applies when you visit or use our website, apps and other services (each, a “Service”). This privacy policy may be supplimented by additional privacy statements, terms or notices provided to you. The CREFi company that owns or administers the Service, as identified therein, is the primary controller of your personal information provided to, or collect by or for, the Service.

2 Information We Collect

We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies.

2.1 Data You Provide to Us

The types of personal information that we collect directly from you depends on how you interest with us and the Service and may include:

Contact details, such as your name and work email address, postal address and phone number;
Account login credentials, such as usernames and passwords, password hints and similar security information;
Other account registration and profile information, such as educational and professional background and photo;
Payment information, such as a credit or debit card number;
Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and/or
Interests and communications preferences, including preferred language.

2.2 Data From Your Organisation

We may obtain information about you from the organisation with which which you are employed or affiliated in order to activate and manage your access to and use of the organisation’s subscription to the Service, including:

Contact details, such as your name and work email address, post address and phone number;
Other account related information, such as job title; and/or
Organisational user ID

2.3 Data From Other Sources

We also may obtain contact details and other information about you from our affiliates and from other this parties, including:

Service providers that help us determine a location in order to customise certain products to your location;
Partners with which we offer co-branded services or engage in joint marketing activities; and/or
Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

2.4 Data From Service Use

The Service may automatically collect information about how you and your device interact with the Service including:

Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
Usage data, such as the features you used, the settings you selected, your URL clickstream data, including data and time stamp and referring and exit pages, and pages you visited on the Service; and/or
For location-aware Services, the region, city or town where your device is located in order to provide you with more relevant content for where you are in the world.

We collect this data through our servers and the use of cookies and other technologies. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access parts or make full use of the Service. For more details, view the cookie notice of the Service.

3. How We Use Your Information

Depending on how you interact with us and the Service, we use your personal information to:

Provide, activate and manage your access to and use of the Service;
Process and fulfill a request, order, download, subscription or other transaction;
Provide technical, product and other support and to help keep the Service working, safe and secure;
Enhance and improve the Service and our other products and services and to develop new products, services and benefits;
Offer you customised content and other personalization to make the Service more relevant to your interests and geography;
Respond to your requests, inquiries, comments and concerns;
Notify you about changes, updates and other announcements related to the Service and our other products and services;
Deliver targeted advertisements, promotional messages, notices and other information related to the Service and your interests;
Provide you with promotional messages and other information about products, events and services of ours, our affiliates and third parties such as sponsors;
Invite you to participate in user testing and surveys as well as sweepstakes, competitions and similar promotions;
Identifying usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance, or in other ways pursuant to a customer agreement; and/or
Comply with our legal obligations, resolve disputes, and enforce our agreements

If you are an administrator of an organization with a subscription to the Service, we will use your details to communicate with you about your organization’s subscription and related services. If you supply us contact information of your colleagues, we may contact those individuals with communications about the Service that may include reference to you.

4. Sharing of Your Information

4.1. Your Organisation

If you access the Service through a subscription administered by your organisation, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorised by your organisation for the purposes of usage analysis, subscription management and compliance, cost attribution and departmental budgeting.

4.2 Application Licensor

If you access a third-party application on the Service through a license agreement with the licensor of that application, personal information relevant to that application will be shared with the licensor so that it can provide you access to the application, subject to the terms of its license agreement and privacy policy.

4.3 Your Choices

We share your personal information with our affiliates and with sponsors, joint venture partners and other third parties, including entities for which we are acting as an agent, licensee, application host our publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices in managing your communications preferences and other settings. The Service may let you post and share personal information, comments, materials and other connect. Any such contributions you disclose publicly may be collected and used by others, may be indexed by search engines, and might not be able to be removed. Please be careful when disclosing personal information in these public areas.

4.5 For Legal Reasons

We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

Meet any applicable law, regulation, legal process or other legal obligation;
Detect, investigate and help prevent security, fraud or technical issues; and/or
Protect the rights, property or safety of CREFi, our users, employees or others;
And as part of a corporate transaction, such as a transfer of assets or an acquisition by or merger with another company.

5. Your Communications Preferences

You can customize and manage your communications preferences and other settings when you register with the Service, by updating your account features and preferences, by using the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

6. Accessing and Updating Your Information

6.1 Your Account

The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is solely the responsibility of the user. Registered users may also close their account directly through the Service or by contacting the Service’s customer support.

6.2. Your Rights

You have the right under privacy and data protection laws, as may be applicable, to request free of charge:

Access to and correction or deletion of your personal information;
Restriction of our processing of your personal information, or to object to our processing; and
Portability of your personal information.

If you wish to exercise any of these rights, please contact us.

We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.

Access to personal information that CREFi gathers from public records and other sources to supply to organisations is subject to applicable laws and our processing notices.

7. Data Retention

We retain your personal information for as long as necessary to provide you the Service and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Service through a subscription administered or sponsored by your organization, we retain your organizational contact details after the termination of your organization’s subscription to continue to communicate with you.

8. Children’s Privacy

We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.

9. Data Security

We use a variety of administrative, physical and technical security measures to help safeguard your personal information.

10. Locations of Processing

Your personal information may be stored and processed in your region or another country where CREFi affiliates and our service providers maintain servers and facilities, including (but not limited to) Australia, Brazil, France, Germany, Iceland, Israel, India, Italy, Ireland, the Netherlands, the Philippines, Singapore, South Africa, the United Kingdom, Spain and the United States. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of the protection required under applicable law.

11. Grounds for Processing

When we collect from you any personal information within the scope of European data protection laws, we do so:

Where necessary to provide the Service, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
Where necessary for our compliance with applicable law or other legal obligations;
Where necessary for the performance of a task carried out in the public interest;
Where applicable, with your consent; and/or
As necessary top operate our business, protect the security of our systems, customers and users, detect or prevent fraud, enable our customers to comply with legal obligations, or fulfill our other legitimate interests as described in the “Information We Collect”, “How We Use Your Information” and “Sharing of Your Information” clauses above, except where our interests are overridden by your privacy rights.

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

12. Changes

We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

13. Contact

If you have any questions, comments, complaints or requests regarding this privacy policy or our processing of your information, please contact us online or in writing:

Data Protection Officer

CREFi

100 High Ash Drive

Leeds

LS17 8RE

You may also lodge a complaint with the data protection authority in the applicable jurisdiction.

14. Supplementary Notices

For more information about processing of personal information as required by applicable local laws, see our U.S. Consumer Privacy Notice, pertaining to residents of California, Colorado, Connecticut, Utah and Virginia.

U.S. Consumer Privacy Notice

1. About this Privacy Notice

Pursuant to the California Consumer Privacy Act (“CCPA”), Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act and Virginia Consumer Data Protection Act, and their respective implementing regulations (collectively, “U.S. Consumer Privacy Laws”), CREFi Limited in scope of the U.S. Consumer Privacy Laws (“CREFi”, “we”, “us” or “our”) are providing this U.S. Consumer Privacy Notice (“Notice”). This Notice supplements our Privacy Policy and applies solely to California, Colorado, Connecticut, Utah and Virginia consumers, except as outwise noted. Terms used but not defined shall have the meanings ascribed to them in the applicable U.S. Consumer Privacy Laws. This Notice does not apply to personal information that we process as a service provider on behalf of our customers or that we collect from job applicants, contractors or employees.

2. Personal Information Collected, Processed and Disclosed

We collect, and have collected in the preceding 12 month, the following categories of personal information:

Identifiers such as a real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers.
Personal information as defined in the applicable customer records law, such as name, contact information, education, employment, employment history, and financial information.
Characteristics of protected classifications under applicable state or federal law, such as gender, age, and marital status.
Commercial information, such as transaction information, purchase history, financial details, and payment information.
Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
Geolocation data, such as approximate device location.
Audio, electronic, visual, and similar information, such as images and audio, video or call recordings created in connection with our business activities.
Professional or employment-related information, such as job title, work history, and experience.

We collect this personal information from you and from other categories of sources such as: our affiliates; our customers; public and publicly available sources; our third-party resellers and referral partners, data suppliers and service providers; partners with which we offer co-branded services or engage in joint event or marketing activities; social networks; news outlets and related media; and the organization with which you are employed or affiliated.

We may use or process each of the above categories of personal information to operate, manage, and maintain our business, to provide our products and services, to communicate with you, for our vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using personal information to: develop, improve, repair, and maintain our products and services; process or fulfill a request or other transactions submitted to us; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions; comply with law, legal process, and internal policies; maintain records; exercise and defend legal claims; and fulfill legal obligations.

We disclose, and have disclosed in the preceding 12 months, each of the above categories of personal information for our operational business purposes to all of the following categories of third parties: affiliates; customers; service providers, agents and representatives; joint venture partners; and other parties where required by law or to protect our rights.

We may use sensitive personal information specifically for the following purposes: perform our services or provide products or services as requested by you or our customers; prevent, detect and investigate security incidents or malicious, deceptive, fraudulent or other illegal actions; short-term, transient use such as displaying first party, non-personalized advertising; perform services on our own behalf, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing analytic services, storage or similar services for the business; and activities relating to quality and safety control or product improvement.

3. Personal Information Sold

We do not sell and have not sold in the preceding 12 months any information collected to any third party business, or organization.

We do not knowingly sell the personal information, including sensitive personal information, of minors under 16 years of age within the scope of the applications of the U.S. Consumer Privacy Laws.

4. Personal Information Shared

We share for purposes of cross-context behavioral advertising or targeted advertising, and have shared for such purposes, including in the preceding 12 months, each of the following categories of personal information with advertising networks, internet service providers, data analytics providers, operating systems and platforms, and social networks:

Identifiers such as online identifier, Internet Protocol address, and other similar identifiers.
Internet or other electronic network activity information, such as browsing history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
Geolocation data, such as approximate device location.
Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We do not knowingly share the personal information, including the sensitive personal information, of minors under 16 years of age within the scope of the application of the U.S. Consumer Privacy Laws.

5. Retention

We retain your personal information for as long as necessary to provide our services and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. The criteria used to determine retention periods includes the legal limitation of liability period, agreed contractual provisions, applicable regulatory requirements, and industry standards.

6. Consumer Rights and Requests

You may request to know whether we process your personal information and to access such personal information.

In addition, if you are a California resident, you may request that we disclose to you the following information as required by law: (i) the categories of personal information we collected about you and the categories of sources from which we collected such information; (ii) the business or commercial purpose for collecting, selling or sharing personal information about you; (iii) the categories of personal information about you that we sold or shared and the categories of third parties to whom we sold or shared such information; and (iv) the categories of personal information about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such personal information.

You may request to correct inaccuracies in your personal information.

You may request to receive a copy of your personal information, including specific pieces of personal information, including, where applicable, to obtain a copy of your personal information in a portable, readily usable format.

You may request that we delete your personal information, subject to certain exceptions. If you are a California or Utah resident, this applies to personal information collected from you.

You may request to “opt-out” of your personal information being sold to certain third parties, as defined by applicable law. This right may be exercised by submitting a Do Not Sell or Share My Personal Information request.

Our use of tracking technologies through some of our websites may be considered a sale or sharing of your personal information for cross-context behavioral advertising or targeted advertising under the U.S. Consumer Privacy Laws. You may request to opt-out of such tracking technologies by utilizing the “Cookie Settings” link on our websites that use tracking technologies for cross-contextual behavioral advertising or targeted advertising or by sending an opt-out preference signal supported by your device or browser. Your use of an opt-out preference signal will apply only to your device or browser and not to other personal information that is not linked to your device or browser.

If you are a Colorado, Connecticut, or Virginia resident, you may request to opt out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

If you are a California resident, you may also request to limit the use or disclosure of your sensitive personal information to what is necessary for us to perform our services and provide goods as requested, as authorized by regulations, or as otherwise permitted under the CCPA. This right may be exercised by submitting a Limit the Use of My Sensitive Personal Information request.

We will not unlawfully discriminate against because you exercise any of your rights under the U.S. Consumer Privacy Laws.

We do not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.

7. How to Make a Request

You may make a request for the disclosures, correction, opt-out, or deletion described above through our email address: tslator@crefi.co.uk or via phone +44 7525 931200 or via Mail:

CREFi Limited

Attention of: US Consumer Privacy Request

100 High Ash Drive

Leeds

United Kingdom

LS17 8RE

You may be required to submit proof of your identity for certain of these requests to be processed. Such information may include your First Name, Last Name, Stress Address, City, Zipp, and Date of Birth and either your Social Security Number or your Driver’s Licence Number and State. This information will be used only for the purpose of verifying your identity and processing your request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession.

Authorized Agents

You may designate an authorized agent to make a request on your behalf subject to proof of identity and written authorization as required under the U.S. Consumer Privacy Laws, as applicable. Requests made through an authorized agent should be made to our consumer center via phone (+44 7525 931200) or by email at tslator@crefi.co.uk. As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent. In addition, we may require that you verify your identity as described above or confirm that you provided the agent permission to submit the request.

We will respond to your request consistent with the U.S. Consumer Privacy Laws, as applicable.

Appeal Process

If we refuse to act on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contract us via tslator@crefi.co.uk or +44 7525 931200

8. De-Identified Information

Where we maintain our use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

9. Changes

We will update this Notice from time to time. Any changes will be reflected in the updated revision date.

10. Contact

You may make a rights request described above via email: tslator@crefi.co.uk

If you have any questions, comments or complaints about this privacy policy or our processing of your information, please contact:

Privacy Manager

100 High Ash Drive

Leeds

United Kingdom

LS17 8RE