Last Updated: June 11, 2018
Collection of Information
Information You Provide to Us. We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services (e.g. posting, sharing, sending and receiving comments through the Services), fill out a form, make a purchase, apply for a job, communicate with us via third party social media sites, request customer support or otherwise communicate with us. The types of information we may collect include (a) basic user information such as your name, email address, postal address, phone number, username and password, (b) financial information to process your payment for the Services (if applicable) such as your credit card information, bank account information and billing address (although note that we do not store full credit card numbers as all payment transactions are processed by our third party payment processors), and (c) any other information you choose to provide such as any comments and other content that you post, share, send or receive through the Services (“User Generated Content”).
Information We Collect Automatically When You Use the Services. When you access or use our Services, we automatically collect information about you, including:
- Log Information: We collect log information about your use of the Services, including information about the computer you use to access our Services, hardware model, operating system and version, the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
- Location Information: We may collect information about the location of your computer or when you otherwise consent to the collection of this information in order to tailor your experience with the Services based on location.
- Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information, including cookies and pixel tags (or web beacons). Cookies are small data files stored on your hard drive or in device memory. Cookies allow our Services to recognize your browser or device, track your usage each time you each visit, help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Pixel tags are small blocks of code often used in connection with cookies. Pixel tags may be placed on our websites and emails, and allow us to track website usage, including to determine when emails have been opened and acted upon, help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see "Your Choices" below.
Information We Collect From Other Sources
We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to identity verification services, credit bureaus, mailing list providers and publicly available sources. If you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site.
Use of Information
We may use information about you for various purposes, including to:
- Provide, maintain and improve our Services (including permitting you to analyze your Targets and post, share, send or receive User Generated Content through the Services);
- Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices,
- Send you technical notices, updates, security alerts and support and administrative messages;
- Respond to your comments, questions and requests and provide customer service;
- Communicate with you about products, services, offers, promotions, rewards, and events offered by Crayon and others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage and activities in connection with our Services;
- Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Crayon and others;
- Personalize and improve the Services and provide content or features that match user profiles or interests;
- Link or combine with information we get from others (including from the public Internet) to provide you the Services, help understand your needs and provide you with a better experience with our Services; and
- Carry out any other purpose for which the information was collected.
Sharing of Information
- With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
- If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Crayon or others;
- In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
- Between and among Crayon and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
- With your consent or at your direction.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Social Sharing Features
The Services may offer social sharing features and other integrated tools (such as the Facebook "Like" button), which let you share actions you take on our Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
Analytics Services Provided by Others
We store the information we collect for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
Crayon takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Data Transfers and Privacy Shield
Crayon is based in the U.S. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it.
When we transfer personal data from the European Union or Switzerland to the United States, we comply with the EU-U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States, respectively. Crayon has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, we are committed to resolving complaints about our processing of your personal data. EU and Swiss individuals with inquiries or complaints regarding our compliance with the Privacy Shield program should first contact us at email@example.com. We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain conditions, you may be able to invoke binding arbitration to resolve your complaint. Crayon is subject to the investigatory and enforcement powers of the Federal Trade Commission.
Account Information. You may update, correct or delete information about you at any time by logging into your online account, emailing us at firstname.lastname@example.org or contacting our support team at email@example.com. If you wish to delete or deactivate your account, please email our support team at firstname.lastname@example.org, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Promotional Communications. You may opt out of receiving promotional emails from Crayon by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Residents of the European Economic Area
If you are a resident of the European Economic Area (EEA), you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing. If you are a resident of the EEA, we will only process your personal data:
- To perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested);
- When we have a legitimate interest in processing your personal data (e.g., to communicate with you about changes to our services, to advertise our services, and to provide, secure, and improve our services);
- When we have your consent to process your personal data; or
- To comply with our legal or regulatory obligations.
Data Subject Requests. If you are a resident of the EEA, you have the right to access personal data we hold about you and to have certain personal data corrected or erased. You may also have the right to restrict certain processing of your data.
To make any of these requests please email email@example.com. We will respond as soon as practicable and no later than one month after receipt of your request. We may request proof of identification to verify your request.
We may deny or restrict fulfillment of your request in some cases, such as when your access to data places another individual’s privacy rights at risk, or the continued processing of your data is necessary to comply with a legal obligation. If so, we will notify you of the reason(s) for this denial.
Questions or Complaints. If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.