Welcome to CrowdFund NFT. This policy explains how we handle and use your personal data and your rights in relation to that information. Under data protection law, CrowdFund NFT is the controller of that information and responsible for its use and protection. As we operate a platform that allows our Registered Users to run fundraising Campaigns and reach out to others for funding, those Registered Users may also be separately legally responsible for the use of your information in connection with those Campaigns.
CrowdFund NFT (we, our or us) is committed to protecting and respecting your privacy.
This policy explains why and how we will use the personal data 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 data that we obtain from all of the various interactions you may have with us as a business, including when you visit our website www.crowdfund-nft.com (the Website).
We, CrowdFund NFT, are the controller in relation to the processing activities described below. This means that we decide why and how your personal data is processed. Please see the section at the end of this policy for our contact and legal information.
Our Registered Users run fundraising campaigns from the Website and in doing so may collect personal data from you if you pledge funds to their Campaigns. Their use of that information during and after their campaign (e.g. to keep in contact with you about progress of their Campaign and their achievements) are uses of your information which those Registered Users determine, independently of us. As a result, those Registered Users will be separate controllers of your personal data.
We refer to ‘Campaigns’ ‘Campaign Owners’, ‘Backers’, ‘Registered Users’, ‘Contributions’ and ‘Rewards’ throughout this document. For more information regarding these definitions, please see our Terms.
2. How and when we collect personal data about you
This is personal data about you that you give to us when:
- submitting personal data via the Website
- following us, interacting with us and posting on our social media pages including our official pages on various social media platforms
- participating in surveys for research purposes
- corresponding with us by phone, email or in some other manner.
This information is provided by you entirely voluntarily.
This includes information provided on the Website at the time of registering as a Registered User, posting details of Campaigns, using any of the communication tools we provide for our Registered Users, pledging funds to a Campaign on the Website or cancelling a Contribution and when generally using the Website. For example, you may give us your personal data by filling in forms, uploading profile information and other content to the Website, managing your account online, engaging in correspondence with us by phone, email or otherwise. We may also ask you for information and copies of identity documents when you report a problem with the Website or when you exercise your legal rights.
If we do not receive this information, you may be unable to register with the Website, list Campaigns or raise funds, pledge funds to Campaigns, communicate with other Registered Users 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:
- details of your visits to the Website, including, but not limited to traffic data, location data, weblogs and other communication data, and the resources you access;
- technical information, including anonymous data collected by the hosting server for statistical purposes, the Internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.; and
- details regarding how and when you consented to receive marketing communications from us (including the time and date you provided your consent).
We may also view any personal data which you allow to be shared, such as the information you upload to the Website (such as your CrowdFund NFT profile), and information you share on third party social networks.
When you visit our social media pages we collect:
- the information you post on those pages;
- information regarding your interactions with the content we post; and
- statistical information regarding all our followers’ activities (but from which we cannot identify you because we only have access to this information in aggregated form).
Personal data we may receive from other sources
We may obtain certain personal data 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 data about you are as follows:
Other Registered Users
Registered Users of the Website may share personal data about you with us, for example, if you misuse the Website or breach our Guidelines.
Governmental and other public authorities
We may receive your personal data from the police, HMRC and other public authorities, for example, in connection with their investigations. We may also receive your personal data 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 the Website using your existing social media profile and log-in details.
3. Categories of personal data we use about you
We process different types of personal data about you. To make it easier to understand the information that we use about you, we have categorised this data in the table below and provided a short explanation of the type of information each category covers.
We process the following categories of personal data about you:
Behavioural Information Your activities, actions and behaviours
Biographical Information Your life experiences and background
Contact Information Information which can be used to address, send or otherwise communicate a message to you
Fundraising Information relating to your Contributions and fundraising
Marketing Preferences Your preferences in respect of any marketing communications form us from time to time with respect to services which we believe may be of interest to you
Correspondence Information contained in our correspondence or other communications with you about Campaigns and other activities on the Website, our services or our business
Sensitive data We do not knowingly collect personal data about children or personal data that is ‘sensitive’ personal data from a legal perspective (also known as ‘special category data’) or that relates to criminal convictions or offences
Banking/Billing Information used to send/receive funds to/from you
Fraud Information relating to the occurrence, investigation or prevention of fraud
Identity Data that verifies your identity including formal identification documents or unique identification numbers linked to you
Legal Information relating to legal claims made by you or against you or the claims process
4. Use of your personal data
We use your personal data for a variety of reasons. We rely on different legal grounds to process your personal data, 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 data with companies that would send their marketing to you.
We use your personal data in the following ways:
4.1) Where you have provided consent
We may use and process your personal data for the following purposes where you have consented for us to do so:
- to contact you via email with marketing information about our campaigns, funding opportunities and business (see 'Marketing' for further details); and
You may withdraw your consent for us to use your data in any of these ways at any time. Please see 'Your rights in relation to your personal data' for further details.
4.2 Where necessary for us to carry out pre-contractual steps you have requested or for the performance of our contract
We will use your personal data where this is necessary for us to perform our contract with you or to carry out any pre-contractual steps you’ve requested us to do so that you can enter into that contract, for the following purposes:
- to register and set you up as a Registered User on the Website;
- to publish details of your Contributions (unless you choose to pledge anonymously), your Campaigns and the Rewards you wish to offer;
- to process your Contributions and share your details with our payment processors so that payments can be made from you.
4.3 Where necessary to comply with our legal obligations
We will use your personal data to comply with our legal obligations:
- to keep a record relating to the exercise of any of your rights relating to our processing of your personal data;
- to perform anti-money laundering and related checks where the law requires them;
- to anonymise, pseudonymise and destroy your personal data in accordance with our retention policies and data protection law;
- to handle and resolve any complaints we receive relating to the services we provide.
4.4 Where necessary for us to pursue a legitimate interest
We may use and process your personal data where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
(a) Processing necessary for us to promote our business, brand and activities and measure the reach and effectiveness of our campaigns
- for analysis and insight conducted to inform our marketing strategies, and to enhance and your visitor experience;
- to tailor and personalise our marketing communications based on your particular attributes;
- to supply your details to social media and other online platforms operated by other companies for them to contact you with our targeted advertising online, unless you object. To find out more details, please see further ‘Our use of social media’;
- to identify and record when you have received, opened or engaged with the Website or electronic communications;
(b) Processing necessary for us to support our Registered Users with their enquiries
- to respond to correspondence you send to us and fulfil the requests you make to us.
(c) Processing necessary for us to respond to changing market conditions and the needs of our guests and visitors
- to analyse, evaluate and improve the Website and other services so that your visit and use of the Website, fundraising support and other services and social media pages, are more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);
- to undertake market analysis and research (including contacting you with surveys) so that we can better understand you;
- for the purposes of developing new initiatives and features on the Website (for example new varieties of fundraising options or support).
(d) Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
- to administer the Website and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
- for the prevention or detection of fraud and other criminal activities or to assist in the apprehension of offenders, including by sharing your personal data with the relevant partner(s);
- to verify the accuracy of data that we hold about you and create a better understanding of you as an account holder or visitor;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access, including to archive, destroy, pseudonymise or anonymise your personal data;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our exclusion lists in order to be able to comply with your request);
- for the purposes of corporate restructure or reorganisation or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
- to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
- to inform you of updates to our terms and conditions and policies; and
- for other general administration including managing your queries, complaints, or claims, and to send service messages to you.
Marketing communications: If you give your consent, we may use your personal data to contact you by email to send you newsletters or to notify you with details of our services. We try to adapt any marketing material that we send to you, for example by notifying you of campaigns 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, or if you have a registered account on the Website, by changing your Profile settings from within your account.
We provide tools that allow Campaign Owners to send Backers news and updates on their Campaigns. However, we do not permit Campaign Owners to send fundraising requests or any other type of marketing communications using these tools. Campaign Owners can access contact details for the Backers relating to their Campaigns. 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 data. 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 exclusion list for a defined period to ensure that we comply with your wishes.
5. Disclosure and sharing of your personal data by us
We only disclose and share your personal data outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal data, 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 data to third parties.
As the controller of your personal data, 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 data 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 social media platforms and certain suppliers, such as the payment service providers we work with.
We may disclose the personal data to other third parties as follows:
- any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
- if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, courts, tribunals, regulators or similar authorities or if we voluntarily decide to cooperate with such authorities.
6. Our use of social media
We use social media platforms in a variety of different ways, including by publishing pages through which you can interact, advertising to you using information you have provided those platforms or which has been provided by us or collected from the Website. Our legal relationship with each platform varies with the particular manner in which we use that platform.
7. Transfers of your personal data outside of Europe
Except in a limited number of cases, we do not transfer your personal data outside of Europe. Where we do, we take measures to protect your personal data.
All the personal data 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 data to the same extent.
If we transfer your information outside of the UK and EEA in this manner, 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 data 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 located outside the UK and EEA, your information may be necessarily transferred outside the UK and EEA in order to provide you with those services.
8. Security and links to other websites
We take the security of your personal data seriously and use a variety of measures based on good industry practice to keep it secure. Nonetheless, transmissions over the internet and to the Website 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 data.
We employ security measures to protect the personal data 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 allowing you access to certain parts of the Website, 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 data, we cannot guarantee the security of any personal data 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 the Website 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.
9. Retention of your personal data
We will not hold your personal data 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 data 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, in order to enable us to deal with any legal proceedings that could arise.
10. Your rights in relation to your personal data
You have a number of rights in relation to your personal data 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 data. 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 data (this is what this policy sets out to do)
10.2) To have your personal data corrected if it is inaccurate and to have incomplete personal data completed
The accuracy of your information is important to us and we make it easy for you to review and correct the personal data 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 Campaign, Campaign Owners will see the address details of those Registered Users who pledged on their Campaign. Please note that if you change your address after the Campaign Owner has downloaded this data (this usually happens once their Campaign is successful) the details the Campaign Owner has may become out of date, until the Campaign Owner downloads a new list of data - so we would recommend also contacting the Campaign Owner to inform them of a change to your contact details.
10.3) To object to processing of your personal data
Where we rely on our legitimate interests as the legal basis for processing your personal data for particular purposes, you may object to us using your personal data 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 data, we will temporarily stop processing your personal data 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 data 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 data
Where we rely on your consent as the legal basis for processing your personal data, 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.
You can choose to receive or opt-out of future marketing from Campaigns you have contributed to.
The Campaign Owner will be responsible for handling your information after they receive it from us. The Campaign Owner, when downloading a list of Backers on their Campaign, will see who has elected to receive further updates.
You can also choose to receive or opt-out of updates from Campaigns you have contributed to.
Please note that our standard receipt emails and notifications of a Campaign closing successfully or unsuccessfully contain important financial information regarding your Contribution and so cannot be turned off.
If you withdraw your consent, our use of your personal data before you withdraw is still lawful.
10.5) To restrict processing of your personal data
You may ask us to restrict the processing your personal data 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 data 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 data erased
In certain circumstances, you may ask for your personal data 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 data for longer, we will make reasonable efforts to comply with your request.
10.7) To request access to your personal data 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 data if this concerns other individuals or we have another lawful reason to withhold that information. You should note that you can access a lot of your personal data through your account:
- You can see a record of the Campaigns you have created and run;
- You can also review and edit the personal data you have provided to CrowdFund NFT via your Profile settings.
If you wish to make a Subject access request please first check to ascertain that you are unable to obtain 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@example.com. We will then, in adherence with the ICO guidelines, respond to your request.
10.8) To electronically move, copy or transfer your personal data in a standard, machine-readable form
Where we rely on your consent as the legal basis for processing your personal data 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 data 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 data if this concerns other individuals or we have another lawful reason to withhold that information.
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 the Website and, where appropriate, by contacting you by email. Any changes will take effect 7 days after we post the modified terms on the Website 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 the Website.
12. Contact Information
You can contact us with your queries in relation to this policy or for any other reason by email.
Our contact details are:
CrowdFund NFT Email: firstname.lastname@example.org