Safe Harbor Privacy Policy

As a general matter, Crowd Factory does not request personal information from its customers or their end users. You are not required to tell Crowd Factory who you are or reveal any information about yourself. Our servers may collect IP addresses or other anonymous IDs without any other reference to the end user and report aggregated usage statistics.

 

In the event that some information may be collected that is deemed “personal data,” this Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that Crowd Factory follows with respect to personal information transferred from the European Union (EU) to the United States.

 

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. Consistent with its commitment to protect personal privacy, Crowd Factory adheres to the Safe Harbor Principles.

 

SCOPE
This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by Crowd Factory in the United States from the EU, in any format including electronic, paper or verbal.

DEFINITIONS
For purposes of this Policy, the following definitions shall apply:

 

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Crowd Factory or to which Crowd Factory discloses personal information for use on their behalf.

 

"Personal Information" means any information or set of information that identifies or is used by or on behalf of Crowd Factory to identify an individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

 

PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.

 

NOTICE: Where Crowd Factory collects Personal Information directly from individuals in the EU, it will inform them about the type of Personal Information collected, the purposes for which it collects and uses the Personal Information, and the types of non-agent third parties to which Crowd Factory discloses or may disclose that information, and the choices and means, if any, Crowd Factory offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Crowd Factory, or as soon as practicable thereafter, and in any event before Crowd Factory uses or discloses the Personal Information for a purpose other than that for which it was originally collected.

 

Where Crowd Factory receives Personal Information from other entities in the EU, it will use and disclose such Personal Information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates.

 

CHOICE: Crowd Factory will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

 

Crowd Factory will provide individuals with reasonable mechanisms to exercise their choices with respect to their Personal Information.

 

DATA INTEGRITY: Crowd Factory will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Crowd Factory will take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.

 

TRANSFERS TO AGENTS: Crowd Factory will obtain assurances from their agents that they will safeguard Personal Information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding. Where Crowd Factory becomes aware that an agent is using or disclosing Personal Information in a manner contrary to this Policy, Crowd Factory will take reasonable steps to prevent or stop the use or disclosure.

 

ACCESS AND CORRECTION: Upon request, Crowd Factory will grant individuals reasonable access to Personal Information that it holds about them, if any. In addition, Crowd Factory will take reasonable steps to permit individuals to correct, amend, or delete Personal Information that is demonstrated to be inaccurate or incomplete.

 

SECURITY: Crowd Factory will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

 

ENFORCEMENT: Crowd Factory will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Crowd Factory determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

 

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to Crowd Factory at the address given below. Crowd Factory will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.

 

LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by Crowd Factory to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.

 

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to the following person by mail as follows:

 

Privacy [at] crowdfactory.com or

 

Crowd Factory, Inc.

Attn. Privacy Policy

5 Centerpoint Dr.

Lake Oswego, OR 97035

 

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on Crowd Factory’s web page (www.crowdfactory.com) for sixty (60) days whenever this Safe Harbor Privacy Policy is changed in a material way.

EFFECTIVE DATE: July 1, 2008