1. Information We Collect
There are three general categories of information that we collect.
1.1. Information You Give Us
We collect information you share with us when you use the 1000 Crumbs Platform in order to ensure the adequate performance of contracts between you and 1000 Crumbs. The provision of this information is necessary to use the 1000 Crumbs Platform and, without it, we will not be able to provide you with services that you request.
- i) Account Information: when you sign up for a 1000 Crumbs account, we require certain information such as your name and email address.
- ii) Profile Information: to use certain features within the 1000 Crumbs Platform, we may need to ask you to complete a profile, which may include your address and phone number.
iii) Other Authentication-Related Information: to help create and maintain a trusted environment, and to the extent permitted by applicable laws, we may collect identification that you provide.
- iv) Communications with 1000 Crumbs : when you communicate with 1000 Crumbs, we collect information about your communication and any information you choose to provide.
- v) Other Information: you may otherwise choose to provide us information when you fill in a form, speak to, or otherwise communicate with a 1000 Crumbs representative, conduct a search, update or add information to your 1000 Crumbs account, respond to surveys, participate in promotions, or use other features of the 1000 Crumbs Platform.
1.2. Information We Automatically Collect from Your Use of the 1000 Crumbs Platform
When you use the 1000 Crumbs Platform, we collect information about the services you use and how you use them, even if you don’t sign up for a 1000 Crumbs account. We process this information for the activities and legal bases described in Section 2 below.
- i) Usage Information: we collect information about your interactions with the 1000 Crumbs Platform, such as the pages or other content you view, the categories and products you view, the products you compare and/or add to wishlist, and other actions on the 1000 Crumbs Platform.
- ii) Location Information: when you use certain features of the 1000 Crumbs Platform, we may collect different types of information about your general location (e.g. city, country).
iii) Log Data: we automatically collect log information when you use the 1000 Crumbs Platform, even if you have not created a 1000 Crumbs account or logged in. That information includes, among other things: details about how you’ve used the 1000 Crumbs Platform (including if you clicked on links to third party applications), IP address, access times, hardware and software information, device information, device event information (e.g. browser type, crashes), unique identifiers, and the page you’ve viewed or engaged with before or after using the 1000 Crumbs Platform.
1.3. Information We Collect from Third Parties
We may collect information that others provide about you when they use the 1000 Crumbs Platform, or obtain information from other sources and combine that with information we collect through the 1000 Crumbs Platform. 1000 Crumbs does not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to 1000 Crumbs should be directed to such third parties.
- i) Third Party Services: if you link, connect, or login to your 1000 Crumbs account with a third party service (e.g., Facebook, Twitter, Google), we may collect information from the third party service, including but not limited to your registration and profile information. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.
- ii) Other Sources: to the extent permitted by applicable law, we may receive additional information about you, including but not limited to demographic data or fraud detection information, from third party service providers and/or partners and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the 1000 Crumbs Platform, including but not limited to your interactions from our partner ad networks. We may receive information about you and your activities on and off the 1000 Crumbs Platform through partnerships, or about your experiences and interactions from our partner ad networks.
2. How We Use The Information We Collect
We use, store, and process information about you to provide, understand, improve, and develop the 1000 Crumbs Platform, and to create and maintain a trusted and safer environment.
2.1. Provide, Improve, and Develop the 1000 Crumbs Platform
- i) Enable you to access and use the 1000 Crumbs Platform.
- ii) Enable you to communicate with other Members.
iii) Operate, provide, improve and optimise the 1000 Crumbs Platform and experience, such as by performing analytics and conducting research.
- iv) Personalise or otherwise customise your experience by, among other things making product suggestions, ranking search results or showing ads based on your search history, and any preferences you provide to us, or that are signified by your search history.
- v) Provide customer service.
- vi) Send you service or support messages, such as updates, security alerts, and account notifications.
vii) If you provide us with your contact information, we may use and store this information: a) to facilitate your referral invitations, b) for fraud detection and prevention, and c) for any other purpose you authorise at the time of collection.
We process this information given our legitimate interest in improving the 1000 Crumbs Platform and our users’ experience with it, and to ensure the adequate performance of our contract with you.
2.2. Create and Maintain a Trusted and Safer Environment
- i) Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
- ii) Conduct investigations and risk assessments.
iii) Conduct checks against databases and other information sources.
- iv) Comply with our legal obligations.
- v) Resolve any disputes with any of our users and enforce our agreements with third parties.
- vi) Enforce our Terms of Service, Member agreements, and policies.
We process this information given our legitimate interest in protecting the 1000 Crumbs Platform, to verify and ensure the adequate performance of our contract with you, and to comply with applicable laws.
2.3. Provide, Personalise, Measure, and Improve our Advertising and Marketing
- i) Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your communication preferences (including information about 1000 Crumbs or partner campaigns and services).
- ii) Personalise, measure, and improve advertising.
iii) Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by 1000 Crumbs or its third party business partners.
- iv) Carry out profiling on your characteristics and preferences (based on the information you provide to us, your interactions with our services, and your search history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.
We process this information given our legitimate interest in protecting the 1000 Crumbs Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.
3. Sharing & Disclosure
The information you share publicly on the 1000 Crumbs Platform may be indexed through third party search engines. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
3.1. Service Providers
We use a variety of third party service providers to help us provide services related to the 1000 Crumbs Platform and ensure we can adequately provide you with our services. For example, service providers may help us: a) verify or authenticate your identification, b) check information against public databases, c) assist us with background checks, fraud prevention, and risk assessment, or d) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually obligated to use it consistent with this policy.
3.2. Safety and Compliance with Law
1000 Crumbs may disclose your information to courts, law enforcement or governmental authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary:
- i) to comply with legal process and to respond to claims asserted against 1000 Crumbs,
- ii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability,
- iv) for fraud investigation and prevention, risk assessment, customer support, product development and debugging purposes, or (v) to protect the rights, property or personal safety of 1000 Crumbs, its employees, its Members, or members of the public.
We will attempt to notify Members about these requests unless:
- i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or
- ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon 1000 Crumbs property, its Members and the 1000 Crumbs Platform (collectively, “Risk Scenarios”).
In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no Risk Scenarios apply and any other reason/ decision based on our or any related party’s discretion.
3.3. Corporate Affiliates
To help us provide the 1000 Crumbs Platform, we may share your information within our corporate family of companies (both financial and non-financial entities) that are related by common ownership or control. Additionally, we share your information with our affiliates to support, integrate, promote, and improve the 1000 Crumbs Platform and our affiliates’ services. Our affiliates include other 1000 Crumbs companies.
We may display parts of the 1000 Crumbs Platform on sites operated by 1000 Crumbs business partners, using technologies such as widgets or APIs.
3.5. Business Transfers
3.6. Aggregated Data
We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other de-identified information for industry and market analysis, regulatory compliance, demographic profiling, marketing and advertising, and other business purposes.
4. Other Important Information
4.1. Analysing your Communications
We may review, scan, or analyse your communications on the 1000 Crumbs Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyse messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your communications to send third party marketing messages to you, and we will not sell reviews or analysis of these communications. These activities are carried out based on 1000 Crumbs legitimate interest in ensuring compliance with applicable laws, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.
4.2. Linking Third Party Accounts
You may link your 1000 Crumbs account with your account at a third party social networking service. When you create this link:
- i) the information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes; and
- ii) the publication and display of information that you provide to 1000 Crumbs through this linkage is subject to any of your settings and authorisations on the 1000 Crumbs Platform and the third party site.
We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.
5. Third Party Partners & Integration
The 1000 Crumbs Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). 1000 Crumbs doesn’t own or control these Third Party Partners and when you interact with them, you may be providing information directly to the Third Party Partner. These Third Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.
6. Your Choices
6.1. Managing Your Information
You may access, update, and correct most of your basic personal information by logging into your 1000 Crumbs account and reviewing your settings and profile. Where permitted by applicable law, you may request written copies of your personal information held by us. In some cases and where permitted by law, we may charge a fee which will be disclosed to you before we comply with your request. You are responsible for keeping your personal information up-to-date.
6.2 Data Retention & Account Cancellation
We generally retain your information for as long as is needed to provide the 1000 Crumbs Platform to you, or for as long as your account is active or any length of time we deem fit. If you no longer want us to use your information to provide the 1000 Crumbs Platform to you, you may cancel your account or request us to erase your personal information. To cancel your 1000 Crumbs account, contact us. If you cancel your account or request erasure of your personal information, note that:
- i) Information you have shared with others (such as Listing reviews) may continue to be publicly visible on the 1000 Crumbs Platform in association with your first name, even after your 1000 Crumbs account is cancelled.
- ii) Some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers.
iii) Because we maintain the 1000 Crumbs Platform to protect from accidental or malicious loss and destruction, residual copies of your information may not be removed from our backup systems for any period of time.
- iv) 1000 Crumbs may retain certain information to the extent necessary to comply with its legal obligations.
- v) 1000 Crumbs may retain certain information as necessary for its legitimate business interests, such as fraud detection and prevention, enhancing user safety, and defending itself against legal claims. For example, if 1000 Crumbs removes a user account for fraud or user safety reasons, 1000 Crumbs may retain certain information from that account to prevent that user from opening a new 1000 Crumbs account in the future.
6.3 Withdrawing Consent
6.4 Data Portability
In some jurisdictions, applicable law may entitle you to request a copy of your personal information that you have provided to us and/or to request us to move such personal information to another service provider. In such cases, and in line with our legal obligations, we will provide you or the service provider with information in a structured and commonly used format.
6.5 Restricting Processing
In certain extraordinary circumstances (e.g. where you think that 1000 Crumbs is not holding accurate data about you) and in line with applicable law, you may request 1000 Crumbs to temporarily restrict our use of your personal information for a limited period of time until the extraordinary circumstance that justified the restriction ends.
6.6 Objecting to Processing (including Automated Decision-Making)
In some jurisdictions, applicable law may entitle you to require 1000 Crumbs not to process your personal information for certain specific purposes, such as profiling or marketing purposes.
6.7 Exercising Rights and Lodging Complaints
If you would like to learn more about, or exercise any of, the rights described in this Section 6, contact us. We may ask you to verify your identity before taking further action on your request. You have the right to lodge complaints about the data processing activities carried out by 1000 Crumbs before competent data protection authorities.
7. Operating Globally
7.1 Service Providers
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you, or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or alteration.
Last Updated: 23rd May 2018