Crowst Ltd. Privacy Policy

Updated on 25 May 2018

Hello there!

At Crowst, we are committed to safeguarding the privacy of our website visitors and service users. The EU has introduced GDPR (General Data Protection Regulation) to enhance the transparency in handling and processing of personal data. You can view the details of our GDPR compliant Privacy Policy on the following pages.


Here we have listed some of the main points:

  • At Crowst, we want to be 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 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 study data they have access to.
    • Here is a concrete example of typical study data delivered to a client. Based on the study 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@crowst.com
    • Contact for professional / B2B enquiries: contact@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) 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:

(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.

3.2 We may process data about your use of our website and 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 Analytics, ActiveDemand and Facebook 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, email address, phone number and home address. 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 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.

3.4 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, and personality traits. 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, 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 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 (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 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 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 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 and/or newsletters. 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 communications 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 2, 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 (www.nemesys.fi) 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:

(a) 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.

(b) 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, insights & research business of Crowst 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 existing 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:

(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) 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@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@crowst.com
  • Contact for professional / B2B enquiries: contact@crowst.com

9. Cookies used by our service providers

9.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

9.2 We use Google Analytics to analyse the use of our website. 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://www.google.com/policies/privacy/

9.3 We use ActiveDemand to analyse the use of our website and communicate with our company users. The information gathered relating to our website is used to create reports about the use of our website, and for communication and marketing. ActiveDemand’s privacy policy is available at: https://www.activedemand.com/privacy-policy/

10. Special Note about Children’s Privacy

Based on the GDPR and country provision of Finland, the Crowst mobile app user must be at least thirteen (13) years old. 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.

11. Our details

11.1 This website, the Crowst Dashboard, the Crowst mobile application and related services 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 Our principal place of business is at Hämeentie 15, 00500 Helsinki, Finland.

11.4 You can contact us:

(a) Contact for Crowst mobile app users and private enquiries: support@crowst.com
(b) Contact for professional / B2B enquiries: contact@crowst.com

12. Data Protection Officer

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