Date of posting: 08/07/2021
Welcome to Crowdfunder. This policy explains how we handle and use your personal information and your rights in relation to that information. Under data protection law, Crowdfunder Limited is the controller of that information and responsible for its use and protection. As we operate a platform that allows our members to run fundraising projects and reach out to others for funding, those members may also be separately legally responsible for the use of your information in connection with those projects.
Crowdfunder Limited (we, our or us) is committed to protecting and respecting your privacy.
This policy explains why and how we will use the personal information that we have obtained from you or others, with whom we share it and the rights you have in connection with the information we use. Please read the following carefully.
This policy describes the way we handle and use the personal information that we obtain from all the different interactions you may have with us as a business, including when you visit our offices, social media pages or our websites, including our main website currently located at www.crowdfunder.co.uk (collectively, Site) or when you contact us or take part in any of our competitions or promotions.
We, Crowdfunder Limited, are the controller in relation to the processing activities described below. This means that we decide why and how your personal information is processed. Please see the section at the end of this policy for our contact and legal information.
Our members run fundraising campaigns from our Site and in doing so may collect personal information from you if you pledge funds to their projects. Their use of that information during and after their campaign (e.g. to keep in contact with you about progress of their project and their achievements) are uses of your information which those members determine, independently of us. As a result, those members will be separate controllers of your personal information.
We refer to ‘project owners’, ‘backers’ and ‘pledges’ throughout this document. For more information regarding these, please see our Terms.
We also refer to our ‘partners’ in these Terms. These are commercial partners with whom we work in a variety of ways to expand the features on our Site. Our partners include:
Please see our Partners Privacy Policies page (or in the case of programme partners, the relevant programme/project page) for further information, including details of their own privacy policies that apply to their use of your personal information that they receive from us.
This is personal information about you that you give to us when:
This information is provided by you entirely voluntarily.
This includes information provided on the Site at the time of registering as a member, posting details of projects, using any of the communication tools we provide for our members, pledging funds to a project on the Site or cancelling a pledge and when generally using our Site. For example you may give us your personal information by filling in forms, uploading profile information and other content to the Site, managing your account online, engaging in correspondence with us by phone, email or otherwise and meeting with us at events (e.g. you may provide us with your business card). We may also ask you for information and copies of identity documents when you wish to apply for partner funding, when you report a problem with our Site or when you exercise your legal rights.
If we do not receive this information, you may be unable to register with the Site, list projects or raise funds, pledge funds to projects, communicate with other members or communicate with us effectively or allow us to comply with our own obligations.
Information that we collect about you
We may automatically collect the following information:
We may also view any personal information which you allow to be shared, such as the information you upload to the Site (such as your Crowdfunder profile), and information you share on third party social networks.
When you visit our social media pages we collect:
Personal information we may receive from other sources
We may obtain certain personal information about you from other sources (including those outside of our business) which may include our suppliers and our clients. The third parties that may send us personal information about you are as follows:
Members of the Site may share personal information about you with us, for example, if you misuse the Site or breach the our Guidelines.
We may receive your personal information from our partners if you have indicated to them that you would like us to contact you about funding opportunities or about a particular funding programme. We will only use this personal information for the purposes of email marketing if our partners have obtained your prior consent for us to do so.
Governmental and other public authorities
We may receive your personal information from the police, HMRC and other public authorities, for example, in connection with their investigations. We may also receive your personal information indirectly from such authorities e.g. from a third party sharing information originating from a court, or otherwise relating to legal or regulatory proceedings.
Social media networks (publicly available source)
We may view your social media profile registration data where you choose to register with our Site using your existing social media profile and log-in details.
We process different types of personal information about you. To make it easier to understand the information that we use about you, we have categorised this information in the table below and provided a short explanation of the type of information each category covers.
We process the following categories of personal information about you:
Your activities, actions and behaviours
Your life experiences
Information which can be used to address, send or otherwise communicate a message to you
Information used to send/receive funds to/from you
Information relating to the occurrence, investigation or prevention of fraud
Information that verifies your identity including formal identification documents or unique identification numbers linked to you
Information relating to legal claims made by you or against you or the claims process
Information relating to your pledges and fundraising, including information relating to your account with our loyalty partners
Your preferences in respect of any marketing communications form us from time to time in relation to products or services which we believe may be of interest to you
Information contained in our correspondence or other communications with you about projects and other activities on our Site, our services or our business
We do not knowingly collect personal information about children or personal information that is ‘sensitive’ personal data from a legal perspective (also known as ‘special category data’) or that relates to criminal convictions or offences.
We use your personal information for a variety of reasons. We rely on different legal grounds to process your personal information, depending on the purposes of our use and the risks to your privacy. You will only receive unsolicited marketing communications from us if you have consented and can opt-out of receiving them at any time. We do not share your personal information with companies that would send their marketing to you.
We use your personal information in the following ways:
4.1 Where you have provided CONSENT
We may use and process your personal information for the following purposes where you have consented for us to do so (whether by giving that consent to us directly or indirectly, for example to one of our partners):
You may withdraw your consent for us to use your information in any of these ways at any time. Please see 'Your rights over your personal information' for further details.
4.2 Where necessary for us to carry out PRE-CONTRACT STEPS you have requested or for the performance of our CONTRACT
We will use your personal information where this is necessary for us to perform our contract with you or to carry out any pre-contract steps you’ve asked us to so that you can enter into that contract, for the following purposes:
4.3 Where necessary to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations:
4.4 Where necessary for us to pursue a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
Processing necessary for us to promote our business, brand and activities and measure the reach and effectiveness of our campaigns
Processing necessary for us to support our members with their enquiries
Processing necessary for us to respond to changing market conditions and the needs of our guests and visitors
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
Marketing communications: If you give your consent, we may use your personal information to contact you by email to send you newsletters or to notify you with details of projects, services and competitions. We try to adapt any marketing material that we send to you, for example by notifying you of projects that apply to your interests and in your location. If you do not wish to receive email communications from us, please inform us by using the unsubscribe link inside the email messages we send, by using our comments form or, if you have a registered account on our Site, by changing your Profile settings from within your account.
We provide tools that allow project owners to send backers news and updates on their projects. However, we do not permit project owners to send fundraising requests or any other type of marketing communications using these tools. Project owners can access contact details for the backers relating to their projects. Any communications they send using these details will be sent solely based on their decisions and for which they will be acting as the controller of your personal information. Please see the Introduction to this policy above.
If you opt-out of receiving marketing communications from us, we keep your email address on our suppression list for a defined period to ensure that we comply with your wishes. Please see further 'The periods for which we retain your personal information.'
We only disclose and share your personal information outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal information, unless we are legally required to share that information. Any suppliers that work for us will be obliged to follow our instructions. We do not sell your personal information to third parties.
As the controller of your personal information, we decide why and how it is processed. Our responsibility for that processing extends to processing by our service providers if they process your personal information based on our instructions. We also work with other, more independent, organisations in connection with some of the processing activities described in this statement, such as our partners, social media platforms and certain suppliers, such as the payment service providers we work with.
We may disclose your information to the following:
Our Suppliers can be categorised as follows:
Accountants and legal and security advisers and consultants
Professional Services (Accountancy, Security & Legal)
Advertising, PR, digital and creative agencies
Media (Advertising & PR)
Banks, payment processors and financial services providers
Finance (Banking & Payment Processing)
Business intelligence and performance services
IT (Business Performance)
Cloud software system providers, including database, email and document management/monitoring providers
IT (Cloud Services)
Customer support services tool
Customer Services (Support)
Customer relationship management services
IT (Customer Relationship Management)
Delivery and mailing services providers
Logistics (Delivery Service)
Event booking service provider
Facilities and technology service providers including scanning and data destruction providers
IT (Data Management)
Fraud and identity verification services
Government (Tax Administration)
Health and safety claims administrators and consultants
Health & Safety (Claims)
Insurers and insurance brokers
Insurance (Underwriting & Broking)
Market and customer research providers
Media (Market Research)
Online survey platforms and services
Social media platforms
Media (Social Media)
Team and remote collaboration tools and services
Website and data analytics platform providers, and website performance tools
IT (Data Analytics)
Website and App developers
IT (Software Development)
Website marketing, search and integration services
IT (Software Development and Marketing)
Website hosting services providers
File and data transfer providers
The Suppliers above are located in the United Kingdom, European Economic Area or the USA.
When we use Suppliers, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information safe and secure.
You may be required to create an account with certain Suppliers to use their services, for example, with the payment service providers we work such as Stripe and Mangopay. These Suppliers will process your personal information in the ways described in their privacy policies (not ours) so please use the links to access and read their privacy policies.
We may disclose the personal information to other third parties as follows:
We use social media platforms in a variety of different ways, including by publishing pages through which you can interact, running competitions or advertising to you using information you have provided those platforms or which has been provided by us or collected from this Site. Our legal relationship with each platform varies with the particular way we use that platform.
We process your personal information using social media platforms in a variety of ways, as follows:
Pages. We use your personal information when you post content or otherwise interact with us on our official pages Facebook, Instagram, Twitter, LinkedIn and other social media platforms. We also use the Page Insights service for Facebook, Instagram and LinkedIn to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content. Where those interactions are recorded and form part of the information we access through the Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us.
Single sign-on. Our Site incorporates a feature provided by social media and other digital service providers that allows you to log into your account on this Site using the same login you have already set up with those providers. This feature is known as a ‘single sign-on service’. Any use we make of the personal information we receive from the platform using this feature is processing for which we are the sole controller.
Data from your profile. When you use single sign-on services, you will be prompted to confirm that you are happy to share with us your email address and certain other personal information you hold with those providers. You may be asked if you would like to share information with us that goes beyond what is needed to log you into your account on our Site. For example, you may be asked if you would like us to use your contact details or date of birth for direct marketing purposes. We will only use your personal information in this way if you agree.
Targeted advertising. We use social media platforms (as well as search engines and third party websites and other platforms) to deliver targeted advertising to you via those platforms, unless you object. You may receive advertising because you have previously interacted with us (such as by visiting one of our Sites) or because of your profile on a social media platform on which you have an account. You can find our more by consulting the help pages of the relevant social media platform but in summary we use social media platforms to send targeted advertising using two main methods:
Our relationship with social media platforms. As we are joint controllers/controllers with these platforms for certain processing, we and each platform have taken some or all of the following steps, depending on the platform:
Facebook, LinkedIn and Twitter also process, as our processors, personal information that we submit for the purposes of matching, online targeting, measurement, reporting and analytics purposes. These services include the processing these platforms carry out when they display our advertisements to you in your social media feed at our request after matching contact details for you that we have uploaded to them. These advertisements may include forms through which we collect contact information you give to us.
Further information. The Facebook company that is a joint controller of your personal information is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The LinkedIn company that is a joint controller of your personal information is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The Twitter company that is a controller of your personal information is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland. For further information regarding these platforms and their use of your personal information, please see:
Except in a limited number of cases, we do not transfer your personal information outside of Europe. Where we do, we take measures to protect your personal information.
All the personal information collected about you by us or on our behalf may be transferred to countries outside the United Kingdom (UK) European Economic Area (EEA). By way of example, this may happen where any of our suppliers are located in a country outside of the UK and EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK and so they may not protect the use of your personal information to the same extent.
If we transfer your information outside of the UK and EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. These steps include imposing contractual obligations on the recipients of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
If you use our services whilst you are outside the UK and EEA, your information may be transferred outside the UK and EEA in order to provide you with those services.
We take the security of your personal information seriously and use a variety of measures based on good industry practice to keep it secure. Nonetheless, transmissions over the internet and to our Site may not be completely secure, so please exercise caution. When accessing links to other websites, their privacy policies, not ours, will apply to your personal information.
We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password or pin allowing you access to certain parts of the Site, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.
In addition, if you linked to our Site from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information for a very short period whilst for others we retain it for a period of 7 years after the information is no longer required for business reasons so that we can deal with any legal proceedings that could arise.
We retain your personal information for the following periods:
The only exceptions to the periods mentioned above are where:
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to verify your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where no such information is required, after we have received full details of your request. You have the following rights, some of which may only apply in certain circumstances:
10.1. To be informed about the processing of your personal information (this is what this policy sets out to do)
10.2. To have your personal information corrected if it is inaccurate and to have incomplete personal information completed
The accuracy of your information is important to us and we make it easy for you to review and correct the personal information that we hold about you in your Profile. If you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, you can let us know by contacting us in any of the details described at the end of this policy but we ask you to first check that you cannot correct your details using the tools in your Profile.
When downloading a list of backers on their project, project owners will see the address details of those members who pledged on their project. Please note that if you change your address after the project owner has downloaded this data (this usually happens once their project is successful) the details the project owner may become out of date, until the project owner downloads a new list of data - so we would recommend also contacting the project owner to inform them of a change to your contact details.
10.3. To object to processing of your personal information
Where we rely on our legitimate interests as the legal basis for processing your personal information for particular purposes, you may object to us using your personal information for these purposes by emailing or writing to us at the address at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
10.4. To withdraw your consent to processing your personal information
Where we rely on your consent as the legal basis for processing your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this policy. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can also do so using our unsubscribe tool.
You can also opt out of receiving our newsletter at any time by editing your Profile settings (login, click your name at the top right of the website then choose Profile settings).
You can choose to receive or opt-out of future marketing from Projects you have pledged on.
The project owner will be responsible for handling your information after they receive it from us. The project owner, when downloading a list of backers on their project will see who has elected to receive further updates.
You can also choose to receive or opt-out of updates from Projects you have pledged on.
Please note that our standard receipt emails and notifications or a Project closing successfully or unsuccessfully contain important financial information regarding your pledge and so cannot be turned off.
If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
10.5. To restrict processing of your personal information
You may ask us to restrict the processing your personal information in the following situations:
- where you believe it is unlawful for us to do so; or
- you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
10.6. To have your personal information erased
In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address at the end of this policy. Unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
10.7. To request access to your personal information and information about how we process it
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Remember, you can access a lot of your personal information through your account: You can see a record of the pledges you have made in the My pledges section (login, click your name at the top right of the website then choose My pledges).
If you wish to make a Subject access request please first check you cannot get the data from the areas listed above. If you wish to access data not listed there please be specific in your request and send us a message to [email protected] . We will then, in adherence with the ICO guidelines, respond to your request.
10.8. To electronically move, copy or transfer your personal information in a standard, machine-readable form
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with a contract in place directly with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
10.9. Rights relating to automated decision making, including profiling
We do not envisage that any decisions that have a legal or significant effect on you will be taken about you using purely automated means, however we will update this policy and inform you if this position changes.
After completing an expression of interest form for funding from one of our funding partners we will show you partner funds you may be eligible for. You can view the full list of funds at any time. Part of your eligibility for a fund may include automated processes, but the decision to approve funding will not be purely automated.
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the data protection regulator in the UK (or if you are located outside the UK, a similar regulator in the country in which you live) where your personal information has or is being used in a way that you believe does not comply with privacy laws. The contact details for the ICO are available on the ICO website. However, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
Please check this page regularly for changes to this policy. We will email you with changes if we hold a valid email address for you.
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our Site and, where appropriate, by contacting you by email. Any changes will take effect 7 days after we post the modified terms on our Site or after the date we notify you by email. We recommend you regularly check this page for changes and review this policy each time you visit our Site.
You can contact us with your queries in relation to this policy or for any other reason using our webform or by post or email.
To contact us in relation to this policy, including to exercise any of your rights in relation to your personal information, please contact us or write to us by email at [email protected].
Crowdfunder Limited’s company registration number is 07831511 and registered office address is Crowdfunder, C-Space 5-7 The Crescent, Newquay, Cornwall, TR7 1DT.