Crowst Ltd. Terms of Service

Updated on 03 August 2021

(Please click here for Privacy Policy)

Hello! Thank you for your interest in the Crowst mobile app, we are excited to have you onboard.

Before starting to use the Crowst mobile application we ask you to read our Terms of Service and Privacy Policy, and give your consent that you agree to them. Our Terms of Service and Privacy Policy are GDPR (General Data Protection Regulation by the EU) compliant. You cannot use the Crowst App / Service if you do not agree to these Terms and Privacy Policy. In this document the Terms of Service are outlined in the beginning, followed by the Privacy Policy section.

Copyright, Trademarks and Intellectual Property

The Service and related software (including the Crowst mobile application, www.crowst.com website, The Crowst Dashboard, and other products, channels and their contents) are protected under international copyright laws and you are hereby notified that copyrights are claimed and owned by Crowst. Subject to the Terms, Crowst retains all rights, title and interest in the Service and in all Crowst’s products, software and other properties provided to you or used by you through the Service.

Crowst is a registered trademark of Crowst Oy. Crowst product, service, features and content names are either trade names, registered or unregistered trademarks of Crowst Oy. Other product and company names mentioned at the site or Service may be trademarks or trade names of their respective owners. Primary trademark is “CROWST”. Product names and slogans may also be registered. All trademarks, registered or unregistered, are owned by Crowst Oy. Ownership or registration by divisions, subsidiaries or third parties is strictly forbidden.

Your access to this site or Service should not be construed as granting, by implication, estoppel or otherwise, any license or right to use any marks appearing on the site without the prior written consent of Crowst or the third party owner thereof.

Right to Use the Service

The Service and the applications are Copyright ©Crowst Oy (or the respective Crowst’s affiliates or suppliers or other third parties).

Any rights not expressly granted herein are reserved. Reproduction, transfer, distribution or storage of part or all of the contents in any form without the prior written permission of Crowst is prohibited except in accordance with the following terms.

Crowst consents to you using the mobile app / Service on your computer, mobile terminal / device or other similar devices, as applicable, downloading the Terms of Service and Privacy Policy, and printing copies of them for your personal use only and not for redistribution unless consented to in writing by Crowst.

The Crowst mobile application, as part of the Service and the content thereof, may be used solely for private, non-commercial purposes, subject to these Terms and any applicable laws.

Please note that some of the apps, documents and/or services or their parts / sections may include specific and separately described terms, such as software end user terms that are that are outlined in conjunction with the apps, documents services and/or sections in question.

Age Limit

To use the Crowst mobile application, you must be at least fifteen (15) years of age. If you have registered as a user of the Crowst mobile app earlier (before 3 August 2021) and you are 13-14 year old, you may continue using the app normally.

Registration and End of Use

Use of the Service requires registration. You agree to provide truthful and complete information when registering for the Service and to keep that information updated. Providing misleading information about your identity is forbidden. You also understand that in order to be able to use the Service, your device has to be equipped with a GPS module for location tracking.

When you register, you will create a username and a password if you are using an email registration option. You can also register using your Facebook or Google account, when you only need to create your Crowst username. If you use either the Facebook or Google registering option, Crowst does not see or store your Facebook or Google account passwords.

You are personally responsible for any use of the Service with your username and password. You agree to take due care in protecting your username and password against misuse by others and promptly notify Crowst about any misuse.

Note: as the user of the Crowst mobile app, you are allowed to create only one (1) user account on the app. Creating multiple accounts is strictly forbidden, and Crowst constantly tracks the system-level data to identify multiple accounts created and linked with the same device(s). Crowst has the right to delete multiple accounts without notifying the user. Also, related to the user account and verification, Crowst has the right to request the user to prove his/her identity, e.g. in the form of a scanned or photographed personal ID document (such as driver’s license or passport). Upon such request by Crowst, the user agrees to provide with the requested proof of identity by accepting these terms.

You may stop using Crowst at any time and uninstall the mobile application whenever you wish. After this you will not be able to use or access the Service. Crowst may terminate your registration or restrict your access to certain parts of the Service if there is an indication that you have breached the Terms or with a prior notice if you have not used the Service (mobile application) with your username in the past six (6) months.

When your registration is terminated, Crowst shall anonymize your personal information on the service from that point onwards, and will not target any new studies to you.

Missions

Crowst missions are studies, surveys and tasks created by companies who have an interest in learning about the consumer view and perception on their products and/or services, or the market in general. These missions include instructions on how approved responses are qualified and assessed, approved or rejected. The missions also have set response quotas, meaning that the responses are evaluated both based on the defined instructions, as well as based on time and speed (the fastest respondents on any specific mission).

The missions include different types of questions and response options. They may also include taking one or more photographs in some cases. Crowst users respond to these studies using the Crowst mobile app.

Regarding the missions and information & responses you provide through them, Crowst never gives out your personal data to the company clients without your separate, explicit and documented consent. Our company customers, clients who run studies using the Crowst service, see the study results only at the level of aggregated, mass-segmented data. They do not have access to the personal data (e.g. names, email addresses, etc.) of our service users. Our clients cannot identify any specific individual based on the mission data they have access to. Please have a look at our Privacy Policy for further information later in this document.

Some of the missions are created by Crowst itself in order to activate the Crowst app user base and learn about Crowst users directly. This service data may be processed for the purposes of analysing the use of the Crowst services. The legal basis for this processing is your consent OR our legitimate interests, such as monitoring and improving the services OR running our normal business operations.

Mission Responses

Before responding to a mission on the Crowst mobile app, the user is responsible for reading carefully the mission-specific background; Description and Instructions. On location-based missions, the Crowst app users respond to the missions on the Crowst app on a specific, pre-defined location (such as a store, restaurant, shopping mall etc.). Some missions are not location-based, for these the users are able to respond from wherever they feel comfortable (within the Crowst service availability). The participant / Crowst app user will respond to missions as honestly and truthfully as possible. The respondent will also focus to give as high quality response (based on the specific mission descriptions) as possible. Each mission response will be validated for correctness and quality by Crowst before being approved for mission-specific rewards within 5 working days.

Once a mission is started, it will timeout automatically after a pre-defined period of respondent inactivity. The respondent will receive an alert on the phone screen notifying about the inactivity, and the mission can be completed or extended further by the respondent (e.g. by touching the screen and/or carrying out some action on the Crowst app) if needed. If the user chooses to abort the mission or times out due to inactivity, the mission will be released for other respondents to complete. In these cases the started response is lost and the participating respondent is not entitled to the rewards specific to that mission.

Some missions will accommodate only one response per respondent per location. In some cases, multiple responses from the same respondent may be possible. The mission instructions will advise the respondent in such cases. For non-location based missions, the service usually allows only one response per respondent per mission.

Crowst has the right to monitor and moderate all Mission response material; and remove any material from the Service and restrict access to any part of the Service at any time in its sole discretion. The reason for monitoring and moderation is our dedication to high quality, validity and reliability of our service to our company clients. Insufficient, false or inappropriate individual responses have a negative impact on the general quality.

Mission Responses, Feedback and Other Submissions by You

By submitting any Material (mission responses including imagery, user generated content, etc.) to any of Crowst’s servers, for example, by mobile application, e-mail, social media channels or via the website, you agree that:

1. the Material will not contain any item that is unlawful, invasive of another person’s right of privacy or right of publicity or otherwise inappropriate due to, without limitation, its libellous, slanderous or defamatory nature and recognizing the global nature of the Internet, you agree to comply with all local rules regarding online conduct and acceptable Materials;
2. you will use reasonable efforts to scan and remove any viruses or other contaminating or destructive features before submitting any Material; and
3. you own the Material or have the unlimited right to provide it to Crowst and you will grant Crowst worldwide, irrevocable, perpetual, non-exclusive, fully-paid, royalty-free and assignable license to use, copy, reproduce and have reproduced, modify and have modified, publicly perform and publicly display such Material and distribute reproduced and modified copies thereof. Crowst will not publicly perform or display any Material that is considered as personal data (e.g. your full name, email address; any data where you as an individual can be identified) of the user without the user’s separate, explicit and documented consent. With the exceptions above Crowst may incorporate the Material or any concepts described in it in its products without any compensation, accountability or liability;
4. your use of the Crowst application, Crowst website, Crowst social media channels and any other Crowst channel will not compromise the security or integrity of Crowst’s computer and IT systems, networks or web site(s) or servers, whether by allowing intruders into the same, introducing viruses or other threats, imposing a disproportionate or unreasonably large load on this site or its infrastructure, or using any computer programming routine, file or device to damage or interfere with the operation of the Service;
5. you agree not to take any action against Crowst in relation to the Material that you submit.

Mission Approval

For each mission, the Crowst app respondent undertakes to read the provided Description and Instructions thoroughly on the Crowst mobile app before responding, and then responds in line with the guidance given. Each submitted response will be checked for validity, correctness, appropriateness and quality before being approved for the mission rewards. Use of foul language, insufficient and/or inappropriate free-text responses or responses that are not in line with the mission Instructions given will be grounds for Mission response rejection and even for the termination of user account.

Photographs (if included in the mission) need to satisfy the mission Instructions and requested criteria, in addition to being sharp (in-focus). Obstructed or blurred images or those taken outside the specifications requested will result in the entire mission response being rejected. Images that are submitted as deliberately insufficient, falsified, or clearly against the instructions given in the mission in question lead to rejection of the mission, closure of the Crowst user account and removal from the Service.

Each mission has a pre-set quota of expected responses. Thus it is possible, that after receiving a notification on the new mission, a respondent will not be able to respond if the other respondents are quicker and the set response quota is met.

Each mission response will be validated for correctness and quality by Crowst before being approved for mission-specific rewards within 5 working days.

Mission Rewards

Crowst mission rewards may be Crowst points only, or combine Crowst points and monetary value. In some cases a product prize (or a benefit in the form of a product or service), a chance to win in a price draw, or some other separately described benefit may also be offered as mission-specific rewards.

Crowst points and monetary value rewards will be deposited to the respondent’s account on the Crowst app. Monetary value rewards can only be withdrawn in the form of gift cards, chosen among the gift card options available on the Crowst mobile app. The available gift card options are worth 10€ or 20€, and the actual availability of these depend on the monetary value the participating respondent has accumulated in the Crowst mobile app while taking part in the missions.

A respondent may choose either an electronic gift card that is delivered by email, or a physical gift card that is delivered by traditional mail. Available gift cards and gift card types may vary in different markets and countries. The local postal delivery schedules may influence on the delivery time of physical gift cards.

The redemption of a gift card by a respondent is done in the Crowst mobile app. Crowst provides instructions to respondents on special mission-specific benefits on the mission Description and Instructions of the respective missions.

Crowst has seven (7) respondent levels that are used to rank the respondents based on their activity and performance: Egg, Duckling, Sparrow, Peacock, Eagle, Phoenix and Dragon. On the three highest Crowst levels the respondent earns multipliers that are applied both to the monetary value and points earned by responding to the Crowst missions. If the respondent is inactive for 3 months, meaning the respondent does not answer to any Crowst mission during a 3-month period, the respondent’s level status is switched to the Sleeping Mode. This means that the respondent will temporarily lose the multiplier benefit if the respondent is on some of the three highest levels; Eagle, Phoenix or Dragon. The respondent can restore the multiplier benefits by responding to two Crowst missions within 3 months. See more information in the next sub-section “Crowst Points”.

According to Finland’s Prepayment Act (“Ennakonperintälaki”) the monetary mission rewards are subject to taxation based on specific conditions, as outlined in the Separately reported income types (300 series). The taxation is reported following the process on “Other taxable income deemed earned income” (code 316). In concrete terms this means, that there is no need to withdraw tax if the total, accumulated reward value in a calendar year is max. 100€. If the total, accumulated reward value in a calendar year exceeds 100€, Crowst will report the individual payment information to the Incomes Register of Finland (“Tulorekisteri”). Further information available on the Finnish Tax Office (“Verotoimisto”): https://www.vero.fi/en/incomes-register/companies-and-organisations/employers/earnings-payment-data/wage-income-types/wage-income-types-300-series/

Based on the law Crowst is obliged to declare the personal details of those Crowster respondents (mobile app users) whose accumulated monetary benefit earnings exceed 100€ in a calendar year. For this declaration Crowst need’s the full name and Finnish personal ID of the respondent. If the respondent does not have a Finnish personal ID, he/she is obliged to provide the personal ID of his/her country of origin. If the respondent does not provide the information upon Crowst’s request, Crowst is not able to pay the rewards on the part that exceeds 100€ in a calendar year. The respondent is responsible for providing only truthful and valid information regarding his/her personal details in this context. Deliberately given incomplete, false or fraudulent information will be reported to police.

Crowst Points

Each completed and approved mission grants the respondent Crowst points that are defined on a mission-by-mission basis. The accumulated Crowst points define the respondent’s Crowst level at any point in time. Higher Crowst points enable a respondent to reach higher Crowst levels, where the respondent will receive the benefit of multipliers to the monetary value rewards and points earned for each mission completed. The levels where the respondent enjoys multipliers are Eagle (x15% multiplier), Phoenix (x25% multiplier) and Dragon (x50% multiplier).

If the respondent is inactive for 3 months, meaning the respondent does not answer to any Crowst mission during a 3-month period, the respondent’s level status is switched to the Sleeping Mode. This means that the respondent temporarily loses the multiplier benefit if he/she is on some of the three highest levels; Eagle, Phoenix or Dragon. The respondent can restore the multiplier benefits by responding to two Crowst missions within 3 months. If the respondent takes part actively in Crowst missions, the Sleeping Mode will never activate.

Crowst reserves the right to change or re-define the ranking and level definitions, the points system applied, and benefits tied to Crowst points. The Crowst points start accumulating from the date of sign-up (“the hatching date”), based on the respondent’s activity and approved responses to Crowst missions.

Fees

The respondent’s (Crowster’s) use of the Service and mobile application as a private user is free of charge.

The respondent may incur additional fees from the use of mobile and/or Internet services of his/her network or other telecommunications operator/carrier and/or other service provider, including without limitation mobile broadband, Internet, SMS, MMS and WAP browsing and other services that require the use of airtime and mobile data services. Crowst assumes no responsibility for the payment of such fees. The respondent’s operator/carrier is in every respect solely responsible for the services it provides to the respondent.

Service availability

The Service may not be available in some countries, regions or cities, and may be provided only in selected languages. The Service may be network dependent; in such cases the respondent is advised to contact his/her network service provider for more information.

Crowst reserves the right, in its sole discretion, to change, improve and correct the Service. The Service may not be available during maintenance breaks and other possible times related to service development. Crowst may also decide to discontinue the Service or any part thereof in its sole discretion. In such case the respondent will be provided a prior notification.

Dealings with Others

Currently or in future, you as a respondent may be able to interact with other respondents through the Service or channels owned by Crowst. You agree that any such interactions do not involve Crowst and are solely between you and the other respondent(s). You may choose to disclose data about yourself in the course of contributing user-generated content to the public channels of Crowst. You acknowledge that the personal data that you submit for publication through our website or other public channels (e.g. on social media, public forums, blogs, chats) may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. There is no expectation of privacy or confidentiality with respect to that data. For further information, please have a look at our Privacy Policy later in this document.

Removal of the user from Crowst mobile app service

We at Crowst believe in common sense. Please use the Service complying with applicable laws, the Terms and good manners; do not submit unlawful, offensive, abusive, pornographic, harassing, libellous or other inappropriate Material; respect the privacy of others; obtain any consents, permission or licenses that may be required for you to have the legal right to submit any Material; and not distribute or post spam, files or technologies that may harm the Service, or the interest or property of the Service users.

Should the user misuse Crowst or cause any harm or detriment to the use of the Crowst app or to Crowst’s Collaborators and Customers (such as using vulgar language in responses), Crowst reserves the right to remove the user from the service with immediate effect and without notice.

Crowst has the right to terminate the user’s right to use the Service without notice at any time for any reason at Crowst’s sole discretion and in particular, if you breach these Terms or use the Service unlawfully or in a way that Crowst deems inappropriate, for example for commercial purposes or in case Crowst notices exceptionally high traffic to the site from a particular IP address(es).

Limitation of Liability

The Service is provided on “AS IS” and “AS AVAILABLE” basis. Crowst does not warrant that the Service will be uninterrupted or error or virus-free. Crowst reserves the right to revise the Service and the contents or withdraw access to the same at any time. No warranty of any kind, either express or implied, is granted. You expressly agree and acknowledge that the use of the Service is at your sole risk.

Crowst shall not be liable for any direct, indirect, incidental, punitive or consequential damages caused by the use or inability to use the Service, even if Crowst has been advised of the possibility of such damages.

Indemnification

You agree to defend, indemnify and hold Crowst harmless from and against any and all third party claims and all liabilities, assessments, losses, costs or damages resulting from or arising out of i) your breach of the Terms, ii) your infringement or violation of any intellectual property, other rights or privacy of a third party, iii) misuse of the Service by a third party where such misuse was made available by your failure to take reasonable measures to protect your username and password against misuse.

Amendments to the Terms of Service

Crowst reserves the right to modify the Terms at any time. Crowst will provide a separate prior notice advising of such change. You are responsible for regularly reviewing the Terms.

As a Crowster / user of the Crowst mobile app you agree to that in the event that Crowst is acquired by or merged with a third-party entity, or we transfer the Service to a third party based on other means, we reserve the right, in any of these circumstances, to transfer or assign the agreement with the user and transfer all data, including but not limited to personal information, as part of such merger, acquisition, sale, transfer or other change of control.

Links to Third Party Sites and Content

For your easy accessibility, Crowst may include links to sites on the Internet that are owned or operated by third parties and that are not part of the Service. Upon following a link to such a third-party site, you shall review and agree to that site’s rules of use before using such site.

You agree that Crowst has no control over third-party sites and cannot assume any responsibility for services provided or material created or published by such sites. A link to a third-party site does not imply that Crowst endorses the site or the products, services or other content referenced in the site.

In addition, Crowsters / participants of the mobile app service may create links within the Service to content that has not otherwise been submitted to the Service. You agree that Crowst is neither responsible for nor liable for any such links.

Choice of Law and Arbitration

Except where prohibited by applicable law or provided otherwise herein, the Terms shall be governed by the laws of Finland without regard to its conflict of law provisions. Possible conflicts will primarily be solved by negotiation. If negotiation proves to be unsuccessful, the arbitration shall take place in Helsinki local court in Finnish or in English, based on the choice of Crowst Oy.

Our Details

The Crowst website, the Crowst Dashboard, the Crowst mobile application and related services and channels are owned and operated by Crowst Oy.

We are registered in Finland under business ID 2718808-2, and our registered office is at Mannerheimintie 39A 17, 00250 Helsinki, Finland.

You can contact us:

1. Contact for Crowst mobile app users and private enquiries: support[at]crowst.com
2. Contact for professional / B2B enquiries: contact[at]crowst.com

Crowst Ltd. Privacy Policy

Updated on 03 August 2021

Hello there! At Crowst, we are committed to safeguarding the privacy of our website visitors and service users.

You can view the details of our GDPR compliant Privacy Policy on the following pages.

Here are some of the main points:

• At Crowst, we are open on what we do, what type of information we collect, and what are your rights.
• Crowst Oy is the data Controller and Processor with respect to the personal data of our website visitors and service users. The data is stored in the Customer and Marketing Register of Crowst Oy.
• We never give out your personal data to our company clients without your separate, explicit and documented consent.
• Our company customers, clients who run studies using the Crowst service, see the results only at the level of aggregated, mass-segmented data. They do not have access to the personal data (e.g. names, email addresses, etc.) of our service users. Our clients cannot identify any specific individual based on the data they have access to.
  • Here is a concrete example of typical data delivered to a client. Based on the results the client see e.g. that ”34% of female respondents of 25-30 years of age in Helsinki are active joggers.” The client DOES NOT have the data to conclude that ”the respondent X who lives in the location Y is an active jogger.”
• We tell you what are the general categories of personal data that we may process, and what are the purposes for which we may process personal data.
• You have rights to access and rectify your data, as well as the right to be forgotten. View the detailed description of your rights in Section 8.
• Do you have a question? Contact us, let’s sort it out!
  • Contact for Crowst mobile app users and private enquiries: support[a]crowst.com
  • Contact for professional / B2B enquiries: contact[a]crowst.com

1. Background

1.1 At Crowst, we are committed to safeguarding the privacy of our website visitors and service users. Our Privacy Policy is compliant with the GDPR (General Data Protection Regulation) of the EU.

1.2 This policy applies where we are acting as a data Controller and Processor with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.4 Our website and services (Crowst mobile application, Crowst Dashboard, and other related services and channels) incorporate privacy controls which affect how we will process your personal data. By using the privacy controls, you can sign up to the Crowst Newsletter or engage with other type of communication managed by Crowst. We ask you to consent to be added to the newsletter distribution list / be included in other type of communication explicitly when you are carrying out the action online.

1.5 In this policy, “we”, “us” and “our” refer to Crowst (data Controller and Processor). For more information about us, see Section 11.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data?

3.1 In this Section 3 we outline:

1. the general categories of personal data that we may process;
2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
3. the purposes for which we may process personal data; and
4. the legal bases of the processing.

3.2 We may process data about your use of our website, mobile app and other services (“usage data“). The usage data may include your IP address, device ID, geographical location, browser type and version, operating system, Crowst mobile app login and in-app events & usage data, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The usage data is tracked on the Google, Facebook and Apple services, using the Crowst accounts on these 3rd party services. This usage data may be processed for the purposes of analysing the use of the Crowst website and services. The legal basis for this processing is your consent OR our legitimate interests, such as monitoring and improving our website and services OR running our normal business operations.

3.3 We may process your account data (“account data“). The account data may include your name, gender, age / birthday, domicile and country, email address, username, phone number, home address and the language you use on the app / service. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing or developing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent OR our legitimate interests, such as the proper administration of our website, services and business OR the performance of a contract between you / your employer and us and/or taking steps, at your request, to enter into such a contract.

We may process your information included in your personal profile on our website, the online Crowst Dashboard, the Crowst mobile application, and/or the studies you have responded to using the Crowst mobile application (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, social status, interests and hobbies, educational details, employment details, consumption and purchasing behavior, personal characteristics, personality traits, and other behavioral information. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services, OR to develop our services. The legal basis for this processing is your consent OR our legitimate interests, such as the proper administration of our website, business and services, OR the performance of a contract between you / your employer and us and/or taking steps, at you request, to enter into such a contract.

3.5 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include IP address, geographical location- and GPS data, browser type and version, operating system, device IDs, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use, your name, address, domicile and country, telephone number, email address, profile pictures, gender, date of birth, relationship status, social status, interests and hobbies, educational details, employment details, consumption and purchasing behavior, personal characteristics, personality traits, pictures and other content you provide when using the service. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our website, providing or developing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent OR our legitimate interests, such as the proper administration of our website, services and business OR the performance of a contract between you / your employer and us and/or taking steps, at your request, to enter into such a contract.

3.6 We may process information and content that you post for publication on our website, on our digital profiles (including social media accounts such as Facebook, Instagram, Twitter, LinkedIn, YouTube) or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering and/or developing our website and services. The legal basis for this processing is your consent OR our legitimate interests, such as the proper administration of our website, services and business OR the performance of a contract between you / your employer and us and/or taking steps, at your request, to enter into such a contract.

3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent OR our legitimate interests, such as the proper administration of our website, services and business OR the performance of a contract between you / your employer and us and/or taking steps, at your request, to enter into such a contract.

3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website or through our services (“transaction data“). The transaction data may include your contact details, your card / payment details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you / your employer and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, such as our interest in the proper administration of our website, business and services.

3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications, newsletters, and digital notifications such as push notifications sent to your mobile device via the Crowst mobile app (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications, newsletters or other similar communication. The legal basis for this processing is your consent OR the performance of a contract between you / your employer and us and/or taking steps, at your request, to enter into such a contract, as well as our legitimate interests, such as our interest in the proper administration of our website, business and services.

3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, business, services and communication with users.

3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

4.1 We never disclose your personal data to our company clients without your separate, explicit and documented consent.

By default our company customers, clients who run studies using the Crowst service, see the study results only at the level of aggregated, mass-segmented data. They do not have access to the personal data (e.g. names, email addresses, etc.) of our service users. Our clients cannot identify any specific individual based on the data they have access to.

4.2 We may disclose your personal data to any member of our group of companies, meaning our subsidiaries, our ultimate holding company and all its subsidiaries, insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.3 We may disclose your personal data to our insurers and/or professional advisers, insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.4 We may disclose your IP address, geographical location- and GPS data, browser type and version, operating system, device IDs, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use, your name, address, domicile, telephone number, email address, profile pictures, gender, date of birth, relationship status, social status, interests and hobbies, educational details, employment details, consumption and purchasing behavior, personal characteristics, personality traits, pictures and other content you provide when using the service to our suppliers, partners or subcontractors insofar as reasonably necessary for the purposes of operating our website, providing and developing our services, ensuring the security of our website and services, maintaining back-ups of our databases, or communicating with you. The legal basis for this processing is our legitimate interests, such as the proper administration of our website and business OR the performance of a contract between you / your employer and us and/or taking steps, at your request, to enter into such a contract.

4.5 Financial transactions relating to our website, services and business may be handled by our payment services providers, Presentcard.fi, GoGift.com, and Oy Vassvik Ab. We will share transaction and Crowst app gift card payment data with our payment services providers only to the extent necessary for the purposes of processing your receivables or payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

4.6 Based on the nature, aim, will and purpose of your enquiry or request, we may disclose your enquiry data to one or more of our selected third party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market and/or sell to you relevant goods and/or services. We will not do this without your explicit request you outline in your enquiry. Each such third party will act as a data Controller and Processor in relation to the enquiry data that we supply to it. These third parties’ own privacy policies will govern that third party’s use of your personal data.

4.7 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. Information that you provide

5.1 You may choose to disclose data about yourself in the course of contributing user generated content to the public channels of Crowst. You acknowledge that the personal data that you submit for publication through our website or other public channels (e.g. on social media, public forums, blogs, chats) may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. There is no expectation of privacy or confidentiality with respect to that data.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure of personal data.

6.2 In order to safeguard your rights and freedom, the personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

1. Enquiry data, transaction data, notification data, and correspondence data will be retained for no longer than is necessary for the purposes for which the personal data are processed, based on the common policies and publicly established practices.
2. Usage data, account data, profile data, service data, and publication data will be retained for no longer than is necessary for the purposes for which the personal data are processed, taking statistical purposes, business management, as well as proper administration of our website and services into account.

6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We will notify the users of the Crowst mobile app on changes to this policy by newsletters.

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Your principal rights under the data protection law are:

1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to a supervisory authority; and
8. the right to withdraw consent.

8.2 You may instruct us to provide you with any personal information we hold about you. For this purpose, and to protect your privacy with appropriate evidence of your identity, we require a photocopy of your passport or other legally valid personal ID document based on the laws of Finland. You can email us your request along with the photocopy of your personal ID (as an email attachment) to the following address: support[a]crowst.com. Providing the rights of others are not affected, we will supply to you a copy of your personal data within 1 month.

8.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; or the processing is for direct marketing purposes. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.7 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.8 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. This means that your Crowst account (the Crowst mobile app user ID and/or the access to the Crowst Dashboard) will be closed and you will not have the access to the service(s) anymore. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.9 You may exercise any of your rights in relation to your personal data by written notice to us by email:

• Contact for Crowst mobile app users and private enquiries: support[a]crowst.com
• Contact for professional / B2B enquiries: contact[a]crowst.com

9. Cookies

9.1 We use cookies on our website(s) to improve your experience while you navigate through the site(s). The cookies that are categorized as necessary are stored on your browser as they are essential for the basic functionalities of the website.

We may also use third-party cookies that help us to analyse and understand how you use our website(s). These cookies will be stored in your browser only based on your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may have an effect on your browsing experience. You can adjust your cookies settings and see further information on specific cookies when you visit our website(s).

9.2 We use Google’s services to analyse the use of our website(s). Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://policies.google.com/privacy?hl=en-FI&fg=1

9.3 We use MailChimp and Benchmark to analyse the use of our website, based on our newsletter-based communication with our mobile app and company users / clients. The information gathered relating to our website is used to create reports about the use of our website, and for communication and marketing.

10. Special Note about Children’s Privacy

The Crowst mobile app user must be at least fifteen (15) years old. Further to this limit, in compliance with GDPR and country provision of Finland, Crowst does not knowingly collect personal information from children under 13 years of age. If Crowst learns that Crowst has inadvertently gathered personal data from children under 13 years of age, Crowst will take reasonable measures to promptly delete such personal data from Crowst’s records.

If you have registered as a user of the Crowst mobile app earlier (before 3 August 2021) and you are 13-14 year old, you may continue using the app normally.

11. Our details

11.1 The Crowst website, the Crowst Dashboard, the Crowst mobile application and related services and channels are owned and operated by Crowst Oy.

11.2 We are registered in Finland under business ID 2718808-2, and our registered office is at Mannerheimintie 39A 17, 00250 Helsinki, Finland.

11.3 Contact information:

• Contact for Crowst mobile app users and private enquiries: support[a]crowst.com
• Contact for professional / B2B enquiries: contact[a]crowst.com

12. Data Protection Officer

Our data protection officer’s contact details are: Richard Jerome, email: richard.jerome[a]crowst.com