Last modified: March 9, 2022
In this policy, “we”, “us”, “ our” and “Crowdfire” refer to Crowdfire
Inc. and its subsidiary Codigami Labs PVT Ltd. For more information about
us and how to contact us, see Section 11.
We respect your privacy and are committed to protecting it through our
compliance with this Policy.
as a data controller with respect to the personal data of our users. This
Policy describes how we collect, use and share personal data of consumer
users across our websites, including www.crowdfireapp.com (the “Website”), Crowdfire’s mobile application (the “ App”) and services offered to users (collectively with the
Website and the App, the “Services”), and from our
partners and other third parties. When using any of our Services you
consent to the collection, transfer, storage, disclosure, and use of your
personal data as described in this Policy.
Please read this Policy carefully to understand our policies and practices
regarding your personal data and how we will treat it. By accessing or
using the Services, you agree to this Policy. Our Services also incorporate
privacy controls which affect how we will process your personal data.
Please refer to Section 5 for a list of rights with regard to your
personal data and how to exercise them.
This Policy may change from time to time. Your continued use of the
Services after we make changes is deemed to be acceptance of those changes,
so please check the Policy periodically for updates.
2. Information We Collect About You and How We Collect It
There are three general categories of information we collect.
2.1. Information You Give to Us.
2.2. Information We Automatically Collect from Your Use of the Services.
We collect your account data, which may include your name,
email address (“Account Data”). The Account
Data may be processed for the purposes of providing to you our
Services and of ensuring their security, maintaining back-ups
of our databases and communicating with you. This information
is necessary for the adequate performance of the contract
between you and us and to allow us to comply with our legal
obligations. Without it, we may not be able to provide you with
all the requested Services.
We process information that you post for publication through
our Services (“Publication Data”), including
the content that you share to your social profiles. The
Publication Data is processed for the purposes of enabling such
publication and administering our Services. The legal basis for
this processing is the performance of a contract between you
and us and/or taking steps, at your request, to enter into such
a contract. Without it, we may not be able to provide you with
all the requested Services.
We process financial information such as credit card or PayPal
information when you order Services in order to facilitate the
processing of payments (“Payment Information
”). The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your
request, to enter into such a contract and our legitimate
interests, namely our interest in the proper administration of
our website and business.
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. 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 and business and communications with users.
We may process information included in your personal profile,
which may include your location, time zone and website (“ Profile Data”). The Profile Data may be
processed for the purposes of providing you a better user
experience when using the Services. The legal basis for this
processing is your consent.
2.3. Information We Collect from Third Parties.
When you use the Services, we may automatically process
information about your computer and internet connection
(including your IP address, operating system and browser type),
your mobile carrier, device information (including device and
application IDs), search terms, cookie information, as well as
information about the timing, frequency and pattern of your
service use (“Service Data”). The Service Data
is processed for the purpose of providing our Services. The
legal basis for this processing is the adequate performance of
the contract between you and us, to enable us to comply with
legal obligations and our legitimate interest in being able to
provide and improve the functionalities of the Services.
You may choose to connect the Services to your accounts on
third party services such as Twitter, Facebook, Instagram,
Tiktok, Linkedin, Pinterest, Shopify, Etsy, Twitch, Wordpress and
Youtube (“ Social Networking Service”) for the purpose of
managing your social media presence through our Services. Crowdfire uses a third party vendor
(Zapier) to facilitate your connection to the Social Networking Services.
When you do this, we automatically process personal information
about you on such Social Networking Services, including your
account and profile data, RSS, lists of followers, social media
content and your actions with respect to such content (the “ Social Media Information”). The Social Media
Information is processed for the purposes of optimizing your
social media activity on the Social Networking Services and
administering our Services. The legal basis for the processing
of Social Media Information is the performance of a contract
between you and us and/or taking steps, at your request, to
enter into such a contract.
3. Disclosure of Personal Data
3.1. We may disclose your personal data to any member of our group of
companies (this means 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. International transfers of your personal data
3.2. Financial transactions relating to the Services are handled by our
payment services providers, Paypal, Braintree and Stripe. We will
share Payment Information with our payment services providers only
to the extent necessary for the purposes of processing your
payments, refunding such payments and dealing with complaints and
queries relating to such payments and refunds. You can find
information about the payment services providers' privacy policies
and practices at
3.3. We may disclose personal data to Social Networking Services insofar
as reasonably necessary to allow you to manage your social media
presence through our Services.
3.4. We may disclose Service Data to a variety of third party service
providers insofar as reasonably necessary to improve the
functionalities of the Services. For example, we may disclose
Service Data to obtain useful analytics, provide in-app support to
mobile app users, determine location data and provide search engine
functionality to our users.
3.5. We may share aggregated data (information about our users that we
combine together so that it no longer identifies or references an
individual user) and other anonymized information for regulatory
compliance, industry and market analysis, demographic profiling,
marketing and advertising, and other business purposes.
3.6. In addition to the specific disclosures of personal data set out in
this Section 3, we may disclose your personal data if we believe
that it is reasonably necessary to comply with a law, regulation,
legal process, or governmental request; or in order to protect your
vital interests or the vital interests of another natural person;
to protect the safety or integrity of the Services, or to explain
why we have removed content or accounts from the Services; or to
address fraud, security, or technical issues; or to protect our
rights or property or the rights or property of those who use the
3.7. We offer individuals the opportunity to choose (opt out) whether
their personal information is (i) to be disclosed to a third party
or (ii) to be used for a purpose that is materially different from
the purpose(s) for which it was originally collected or
subsequently authorized by the individuals. In order to opt out
from disclosure of your personal information, please email us at [email protected].
In this Section 4, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European
Economic Area (EEA). We and our other group companies have offices and
facilities in the United States and India. To facilitate our operations we
may transfer, store, and process your information within those countries or
with service providers based in Europe, India, Asia Pacific and North
America. Laws in these countries may differ from the laws applicable to
your Country of Residence. For example, information collected within the
EEA may be transferred, stored, and processed outside of the EEA for the
process your personal information outside of the EEA we have ensured that
appropriate safeguards are in place to ensure an adequate level of data
4.1. EU-US Privacy Shield Framework
5. Your Rights with Regard to Personal Data
4.2. Transfers to our subsidiary in India, to our service providers and
other third parties will be protected by appropriate safeguards,
namely the use of standard data protection clauses adopted or
approved by the European Commission or applicable certification
schemes - for example, the EU - U.S. Privacy Shield Framework.
In addition, Crowdfire complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S.
Department of Commerce regarding the collection, use, and retention of Personally Identifiable
Information transferred from the European Union to the United States. Crowdfire has certified to the
Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict
Principles shall govern. To learn more about the Privacy Shield program, and to view our certification,
Individuals may file a complaint concerning Crowdfire’s
processing of their Personally Identifiable Information.
Crowdfire will take steps to remedy issues arising out of its
alleged failure to comply with the Privacy Shield Principles.
Individuals may contact Crowdfire as specified below about
complaints regarding the company’s Personally Identifiable
Where Crowdfire has transferred personal information of EU
residents to third parties, Crowdfire shall be liable if those
third parties do not process personal information in compliance
with the Privacy Shield Principles. This shall not be the case
where Crowdfire establishes that it is not responsible for the
damage caused by the third party.
If an Individuals’ complaint cannot be resolved through
Crowdfire's internal processes, Crowdfire will cooperate with
JAMS pursuant to the JAMS International Mediation Rules,
available on the JAMS website at
www.jamsadr.com/international-mediation-rules. Individuals may
launch a Privacy Shield case by visiting
https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation
may be commenced as provided for in the relevant JAMS rules.
The mediator may propose any appropriate remedy, such as
deletion of the relevant Personally Identifiable Information,
publicity for findings of noncompliance, payment of
compensation for losses incurred as a result of noncompliance,
or cessation of processing of the Personally Identifiable
Information of the Individual who brought the complaint. The
mediator or the individual also may refer the matter to the
U.S. Federal Trade Commission, which has Privacy Shield
investigatory and enforcement powers over Crowdfire. Under
certain circumstances, Individuals also may be able to invoke
binding arbitration to address complaints about Crowdfire’s
compliance with the Privacy Shield Principles.
In this Section 5, we have summarized the rights that you have under data
protection law. Some of the rights are complex, and not all of the details
have been included in our summaries. Accordingly, you should read the
relevant laws and guidance from the regulatory authorities for a full
explanation of these rights.
5.1 Your principal rights under data protection law are:
5.2. You have the right to confirmation as to whether or not we process
your personal data and, where we do, access to the personal data,
together with certain additional information. That additional
information includes details of the purposes of the processing, the
categories of personal data concerned and the recipients of the
personal data. Providing the rights and freedoms of others are not
affected, we will supply to you a copy of your personal data. The
first copy will be provided free of charge, but additional copies
may be subject to a reasonable fee. You can access your personal
data by following the instructions
the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.
5.3. 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. You can
request correction or modification of your personal data by
following the instructions
5.4. 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; you object to the processing
under certain rules of applicable data protection law; the
processing is for direct marketing purposes; and the personal data
have been unlawfully processed. 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 defense of legal claims. You
can request the deletion of your account by following the
5.5. 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 defense 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. You can manage your privacy settings and other account
5.6. 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 data 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.
5.7. You have the right to object to our processing of your personal
data for direct marketing purposes (including profiling for direct
marketing purposes). If you make such an objection, we will cease
to process your personal data for this purpose.
5.8. You have the right to object to our processing of your personal
data for scientific or historical research purposes or statistical
purposes on grounds relating to your particular situation, unless
the processing is necessary for the performance of a task carried
out for reasons of public interest.
5.9. To the extent that the legal basis for our processing of your
personal data is:
that the processing is necessary for the performance of a
contract to which you are party or in order to take steps at
your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right
to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others. You can download your
account information, by following the instructions here.
5.10. To the extent that the legal basis for our processing of your
personal data is consent, you have the right to withdraw that
consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
6. Retaining and deleting personal data
5.11. You may exercise any of your rights in relation to your personal
data by written notice to us, in addition to the other methods
specified in this Section 5.
6.1. This Section 6 sets out our data retention policies and procedure,
which are designed to help ensure that we comply with our legal
obligations in relation to the retention and deletion of personal
6.2. Personal data that we process for any purpose or purposes shall not
be kept for longer than is necessary for that purpose or those
6.3. We generally retain your personal information for as long as is
necessary for the performance of the contract between you and us
and to comply with our legal obligations. If you no longer want us
to use your information to provide the Services to you, you can
request that we erase your personal information and close your
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.
Our Services are not intended for children. You must also be old enough to
consent to the processing of your personal data in your country without
parental consent. No one under age 13 may provide any personal data through
the Services. We do not knowingly collect personal data from children under
13. If you are under 13, do not use or provide any information through the
Services or on or through any of their features or register an account,
make any purchases through the Services, use any of the interactive
features of the Services or provide any information about yourself to us,
including your name, address, telephone number, e-mail address or any
screen name or user name you may use. If we learn we have collected or
received personal data from a child under 13, we will delete that
information. If you believe we might have any information from or about a
child under 13, please contact us at [email protected].
8.1. About cookies
8.2. We use these technologies for the following purposes:
A cookie is a file containing an identifier (a string of
letters and numbers) that is sent by a web server to a web
browser and is stored by the browser. The identifier is then
sent back to the server each time the browser requests a page
from the server.
Cookies may be either “persistent” cookies or “session”
cookies: a persistent cookie will be stored by a web browser
and will remain valid until its set expiry date, unless deleted
by the user before the expiry date; a session cookie, on the
other hand, will expire at the end of the user session, when
the web browser is closed.
Cookies do not typically contain any information that
personally identifies a user, but personal information that we
store about you may be linked to the information stored in and
obtained from cookies.
We also use other technologies with similar functionality to
cookies, such as web beacons, web storage, and unique
advertising identifiers, to collect information about your
activity, browser, and device.
8.3. Cookies used by our service providers
to identify you and log you into the Services;
to store information about your preferences and to personalise
the Services for you;
as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;
to help us display content that will be relevant to you;
to help us analyse the use and performance of the Services ;
We use the following service providers to analyse the use of
the Services. Each service provider gathers information about
the Services by means of cookies and this information is used
to create reports about with usage information. You can find
information about the service providers’ privacy policies and
practices at the URLs set forth below:
8.4 Managing cookies
Most browsers allow you to refuse to accept cookies and to
delete cookies. The methods for doing so vary from browser to
browser, and from version to version.
Your mobile device may allow you to control cookies through its
settings function. Refer to your device manufacturer’s
instructions for more information.
If you choose to decline cookies, some parts of the Services
may not work as intended or may not work at all.
9. Data Security
9.1. We have implemented measures designed to secure your personal data
from accidental loss and from unauthorized access, use, alteration
and disclosure. The safety and security of your information also
depends on you. Where we have given you (or where you have chosen)
a password for access to certain parts of the Services, you are
responsible for keeping this password confidential. We ask you not
to share your password with anyone.
9.2. Steps taken to ensure data security:
9.3. Unfortunately, the transmission of information via public networks
such as the internet is not completely secure. Although we do our
best to protect your personal data, we cannot guarantee the
security of your personal data transmitted through the Services.
Any transmission of personal data is at your own risk. We are not
responsible for the circumvention of any privacy settings or
security measures contained on the Services.
All the user information can only be accessed by authorized
Users need to authenticate themselves with a username-password
All data is hosted on Amazon AWS servers.
11. Contact Information
It is our policy to post any changes we make to our Policy on
this page. If we make material changes to how we treat our
users' personal data, we will notify you by e-mail to the
primary e-mail address specified in your account. The date the
Policy was last revised is identified at the top of the page.
You are responsible for ensuring we have an up-to-date active
and deliverable e-mail address for you, and for periodically
visiting our Website and this Policy to check for any changes.
The data controller responsible for your personal data is Crowdfire Inc.
Please contact us by email at [email protected] or by post at:
16192 Coastal Highway
Lewes, DE 19958
12. Privacy Notice For California Residents
This section applies solely to consumers who reside in the State of California.
If you are a California resident, and you wish to access your personal data, request from us that we delete your personal information, or require information about our disclosure practices, you can choose to send us a verifiable consumer request by email at [email protected], in addition to using the means set forth above.
In our assessment, we do not “sell” your personal information to third parties for monetary or other valuable consideration.
13. Crowdfire as Data Processor
All transfers of your Personal Data out of the European Union, European Economic Area,
and Switzerland are governed by the Standard Contractual Clauses which are incorporated
into our standard data processing addendum. Crowdfire will abide by the requirements of
European Economic Area and Swiss data protection law regarding the collection, use, transfer,
retention, and other processing of Personal Data from the European Economic Area and Switzerland.
All transfers of Personal Data to a third country or an international organization will be subject
to appropriate safeguards as described in Article 46 of the GDPR and such transfers and safeguards
will be documented according to Article 30(2) of the GDPR.
14. Standard Contractual Clauses
The below provisions and the applicable standard contractual clauses referenced below shall
be deemed automatically incorporated into the relevant agreement (the “Agreement”) that is
concluded between Crowdfire Inc., on behalf of itself and its affiliates (“Crowdfire”), and
you (“Business Partner”) and shall be binding upon the parties to the Agreement (including their affiliates),
by virtue of reference to this page in and signature of such Agreement.
For data transfers from the European Economic Area that are subject to the 2021 Standard Contractual
Clauses as implemented by the Commission Implementing Decision (EU) 2021/914 of June 4th, 2021 on
standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU)
2016/679 of the European Parliament and of the Council (the “2021 Standard Contractual Clauses”), the 2021
Standard Contractual Clauses will apply in the following manner:
1. Module One (Transfer controller to controller) will apply to the extent that Crowdfire acts as controller and Business Partner acts as controller.
2. Module Two (Transfer controller to processor) will apply to the extent that Crowdfire acts as controller and Business Partner acts as processor; and
3. Module Three (Transfer processor to processor) will apply to the extent that Crowdfire acts as processor and Business Partner acts as sub-processor.
For each Module, where applicable:
1. in Clause 7, the option docking clause will not apply;
2. in Clause 9, Option 2 will apply, and the time period for prior notice of sub-processor changes will be 10 days;
3. in Clause 11, the optional language will not apply;
4. in Clause 17 (Option 1), the 2021 Standard Contractual Clauses will be governed by Irish law.
5. in Clause 18(b), disputes will be resolved before the courts of Ireland;
6. In Annex I, Part A:
Data Exporter: Crowdfire Inc.
Contact Details: Crowdfire Privacy Team – [email protected]
Data Exporter Role: the Data exporter processes personal data in connection with its business
activities such as client services and other business operations.
Signature & Date: By entering into the Agreement, Data Exporter is deemed to have signed these Standard Contractual Clauses
incorporated herein, including their Annexes, as of the Effective Date of the Agreement.
Data Importer: Business Partner and authorized affiliates of Business Partner.
Contact Details: the email address(es) to which Business Partner elects to receive privacy communications in the Agreement.
Data Importer Role: Data importer provides services to data exporter as required for the
latter to accomplish its legitimate business purposes and as described
in or instructed by the data exporter pursuant to the relevant services agreement entered into by the Parties.
Signature & Date: By entering into the Agreement, Data Importer is deemed to have signed these Standard Contractual Clauses,
incorporated herein, including their Annexes, as of the Effective Date of the Agreement.
7. In Annex I, Part B:
The categories of Data Subjects to whom the Personal Data relates include the individuals about whom
data is provided to Business Partner via the Services (as defined in the Agreement)
by (or at the direction of) Data Exporter.
The categories of personal data transferred include data relating to Data Subjects provided to
Business Partner via the Services by (or at the direction of) Data Exporter.
Sensitive data transferred (if applicable) and applied restrictions or safeguards that fully
take into consideration the nature of the data and the risks involved, such as for instance
strict purpose limitation, access restrictions (including access only for staff having followed
specialized training), keeping a record of access to the data, restrictions for onward transfers
or additional security measures.
The frequency of the transfer is a continuous basis for the duration of the Agreement.
The nature of the processing. Detailed in Agreement.
The purpose of the processing of personal data by Data Importer is the performance
of the Services pursuant to the Agreement with Data Exporter.
The period for which the Personal Data will be retained, or, if that is not possible,
the criteria used to determine that period: Crowdfire will process stored Personal Data
for the purpose of providing the Services until Data Exporter elects to delete such
Personal Data via the Services or in accordance with the Agreement.
For transfers to sub-processors, the subject matter, nature, and duration of the processing:
Personal Data may be transferred to sub-processors to process data, on Data Importer’s behalf,
consistent with Data Exporter’s instructions to data importer and data importers published documentation.
Data Importer makes available to Data Exporter a current list of sub-processors engaged in connection with
the Services with the identities of those sub-processors in its documentation (at ).
Notice of additions or changes to the list of sub-processors will be provided to Data Exporter from time to time.
8. In Annex I, Part C: The Irish Data Protection Commission will be the competent supervisory authority.
9. Schedule 2 serves as Annex II of the Standard Contractual Clauses.