Interpretation of the Terms
"Personal data" refers to any information about you that, either alone or in conjunction with other details, allows the entity collecting and processing said information to identify you as an individual.
"Processing of the personal data" encompasses any activity involving your personal data, automated or otherwise, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, usage, disclosure by transmission, dissemination, or other forms of availability, alignment or combination, restriction, erasure, or destruction.
"Data subject" denotes any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing. In this context, it refers to you as a Customer of the Website.
"Consent of the data subject/user" is defined as a clear, specific, informed, and unambiguous expression of the data subject/user's preference, through which they, via a statement or clear affirmative action, indicate agreement to the processing of their personal data.
"Website" signifies a website and an application owned and operated by Crumb4life LTD, registered under Estonian law with registration number 16189904, located at Rüütli tn 24/1 Kesklinna linnaosa, Tallinn Harju maakond, Eesti, 10130.
Additional terms such as Customer, Writer, Company, etc., are defined in our Terms and Conditions.
Each time you visit our Website, we gather log information and place cookies on your device, allowing us to monitor your activity on the Website. You have the option to decline cookies, except for those essential for the Website's functionality.
As a registered Customer, we may collect and process data you provide during registration, including but not limited to cookie identifiers, first name, last name, email, phone number, social network ID (if registered through Facebook or Google), time zone, IP address, and device type.
If you are an Writer, we may additionally collect and process further information provided by you, including but not limited to your zip code, gender, year of birth, city of residence, and educational experience.
Please note that we only process your personal data when we have lawful bases for doing so.
Data We Collect: Scope
Our company collects only specific data from you for outlined purposes as described below:
- Account for Customer
We collect and process personal data provided by you during registration and any subsequent modifications to your account settings.
Mandatory information for registration includes your email and password. Additional optional information includes first name, last name, phone number, date of birth, country, time zone, and links to social accounts. You may update your account with additional information at any time. However, providing additional information not explicitly required for registration is optional.
Please note that we are not liable for any consequences arising from sharing your personal information with the Writers.
- Order Details
We collect and process your order details, which include all information provided when you complete the order form. This extends to any information shared with the Writer via the Messaging System and instructions for the assignment.
- Posting of Information
We process personal data that you voluntarily submit on the Website. This may include surveys you complete on the Website or feedback you provide. Our communication details include any information you provide when you contact our customer support team with questions or to resolve potential issues.
We may also process information, including personal identifiers and messages, that you post on or through our Website. By doing so, you acknowledge that any information you share will be accessible to both the Website and the Writers. You also acknowledge that certain aspects of your content cannot be deleted as it may be connected to the Services received by you and used by the Writers.
Unless you opt-out, we retain this information as necessary to resolve disputes, provide customer support, and troubleshoot issues, as permitted by law.
- Service Use, Cookies, and Other Similar Technologies
If you have previously agreed to cookies on our website and wish to change or disable them, please follow the instructions for your specific browser: Safari, Google Chrome, Internet Explorer, Firefox.
- Billing Information
When you pay for a service on our Website, you provide us with payment and other personal information. We do not collect, process, or store your payment card details or other payment-related information on our Website. This data is sent directly to third-party payment providers. Without this data, the Company would not be able to bill and provide you with the Service you have selected. For tax and financial reporting purposes, we store only the following information for a certain period of time: the Customer's first name and last name, the last four digits of the card, the transaction number, and in some cases, the mobile phone number.
- Sensitive Data
The Company does not process your sensitive data unless you provide explicit consent.
Data We Collect: Purposes
We may process the personal data you provided voluntarily for the following purposes. Our goal is to personalize the use of the Website to the fullest extent possible and to provide you with high-quality Services under the Terms and Conditions.
- Provision of Services
We process your personal data to authorize access to our Services and fulfill our obligations under the Terms and Conditions for Services provision. This includes using your personal data upon registration to help Writers find your account or profile to provide you the Services. Please note, without the information you provide under our Terms and Conditions, we cannot provide you with the functionality of our Website and connect you with the Writers.
- Payment Services
You need to provide payment (e.g., credit card details) and billing information through our third-party payment providers, which process your personal data using encryption and other security measures. Please see our Refund Policy for more information.
We may contact you via various means for Services-related purposes. This includes enabling you to communicate with the Writers. We may also use your contact data for feedback and research to improve the user experience of our product. You can always opt-out of such communications in each message, excluding legal notices or changes to user settings on the Website.
- Marketing and Promotion
We may process your personal data to analyze, personalize, and improve our marketing practices. This may also include sending you direct marketing emails and special offers. You may always opt-out of our marketing messages.
- Analytics and Development
We monitor and analyze the personal data you provide us with to establish new ways to improve the Website and for the purposes of analytics. This may include carrying out polls and surveys. However, you're not obliged to respond to them, and you may opt-out of such polls and surveys.
We may use data (including communications) to resolve disputes, supervise Customer and Writer behavior on the Website, and respond to any complaints or requests.
- Compliance with Legal Requirements
We process certain payment information to comply with applicable legal requirements in the field of finances and/or accounting. We also may process the data collected on the platform in connection with legal requests we receive, and we may use this information to exercise, defend, and/or establish our legal rights.
- Fraud Prevention
Certain information, such as your log information, payment information, and your behavior on the Website are subject to our supervision to prevent fraudulent activities on the Website and assist you with your needs.
If the Website decides to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal data within the newly set purposes.
- Archival Purposes
We may archive your information in the event of a legal need to prove certain events, which is our legitimate interest.
- Responding to Contact Initiated by You
When you contact us, you may provide us with your contact info, which we may use to respond to you.
- Combating Inappropriate Behavior and Promoting Safety
We examine information about the operation and use of our Website to verify Customers and accounts, enhance security, and combat inappropriate behavior, spam, or fraud.
- Aggregate/De-Identify/Anonymize Data
We may aggregate, de-identify, and/or anonymize any information collected through our Website and our services so that such information is no longer linked to your personally identifiable information. We may use this information for any purpose, including for research and marketing purposes, and we may also share such information with third parties at our discretion.
What Are the Legal Bases for Data Processing?
We process your personal data based on one or more of the following legal bases, depending on the circumstances:
- Consent: Processing is based on the consent you have given.
- Contractual Obligations: Processing is necessary to provide our Services to you according to our Terms and Conditions.
- Legitimate Interests: Processing is necessary for the purposes of our legitimate interests, which include compliance with financial and accounting legislation, business efficiency assessment through website traffic and financial performance analysis, Website promotion through social media networks, media outlets, and affiliates (such as bloggers or influencers), fraud prevention, appropriate personal data protection, and expert verification.
- Legal Compliance: Where necessary, processing is performed in compliance with applicable legislation (e.g., data subject request processing).
- Vital Interests and Public Interest: In exceptional cases, processing may be necessary to protect your vital interests or those of another person, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
In all cases, we will notify you of the specific legal basis for processing and other relevant details before we begin processing your personal data on that basis, unless we are prevented from doing so by applicable law.
With Whom Does the Company Share Your Personal Data?
We never share, sell, or transfer your personal information to outside parties, except third parties we collaborate with to operate our Website and provide the Services or Products you request. Such cooperation is possible only if these parties also commit to never share, sell, or transfer any customer or visitor information they receive from us.
We may share your personal data with the following entities:
- Subcontractors: These include hosting service providers, IT specialists and technicians managing our technical infrastructure, service providers ensuring our Website's functionality, claims adjusters (including insurers), advertising and marketing companies, accounting and bookkeeping offices, and legal advisors. All subcontractors process data under contracts with us and only according to our instructions.
- Advertisers, Advertising Agencies, and Intermediaries: Based on the information in cookies or other online identifiers (if they contain personal data), these parties participate in selecting the content of ads displayed to you on our website.
- Payment Intermediaries: When you pay for Services, we provide your payment data to our payment intermediaries.
For How Long Does the Company Store Your Personal Data?
We retain your personal data for varying periods depending on the purpose for which it is processed:
- In Order to Perform the Services: We store your data as long as you maintain a user account on our Website. If your user account is deleted (either by you or by us due to violations of our Terms and Conditions or legal breaches), your personal data will be anonymized. However, some data may be retained longer to fulfill legal, tax, and accounting requirements (e.g., until expiration of statutory limitation periods for contractual claims or tax liabilities arising from your use of our services) or if necessary for ongoing or anticipated legal proceedings. We strive to minimize the data retained and to keep it only as long as necessary.
- On the Basis of a Legitimate Interest (Ours or that of a Third Party): We retain the data until you object to the processing or until we determine that the data is no longer relevant or our purpose for using it has been fulfilled.
- As Required by Law: We retain the data for the duration mandated by applicable laws.
- Based on Your Consent: We keep the data until either (i) you withdraw your consent, or (ii) the purpose for which the data was collected has been fulfilled.
Your Rights as Data Subject Regarding Your Personal Data the Company Processes
As a data subject, you have several rights concerning your personal data that the Company processes. These rights include:
- Right of Confirmation: You have the right to obtain confirmation from the Company as to whether personal data concerning you is being processed.
- Right of Access: You have the right to access your personal data processed by the Company.
- Right to Rectification: If you identify any incomplete or incorrect personal data, you have the right to request that the Company correct it.
- Right to Erasure (Right to Be Forgotten): You have the right to request the Company to erase your personal data. In most cases, the Company will comply unless otherwise required by law.
- Right of Restriction of Processing: If you contest the accuracy of your personal data, or if the Company no longer needs your personal data but you require it for legal claims, you have the right to request a restriction on the processing of your personal data.
- Right to Data Portability: You have the right to have your personal data transmitted directly from one controller to another, where technically feasible, and doing so does not adversely affect the rights and freedoms of others.
- Right to Object: You have the right to object to the Company's processing of your personal data in certain circumstances. If you object, the Company will stop processing your personal data unless there are compelling legitimate grounds for the processing.
- Right to Withdraw Consent: You have the right to withdraw your consent to data processing at any time. Once the Company receives a withdrawal request, it will no longer process your personal data unless required by law.
- Right to Request a Copy of Your Personal Data: As a registered user, you can request a copy of the data you have provided in your account.
- Right to Request Correction of Information: If any information about you is incorrect, outdated, or incomplete, you have the right to request that the Company correct it.
For California residents, additional rights are granted under the California Consumer Protection Act (CCPA). These include:
- Exercising CCPA Rights: If you are a California resident, you may request certain details about how the Company collects, uses, and shares your personal data.
- Shine the Light Disclosure: Under the California "Shine the Light" law, you have the right to request information regarding how the Company shares certain categories of personal information with third parties for their direct marketing purposes. The Company does not share your personal information with third parties for their own direct marketing purposes.
Other Privacy Commitments
- Cross-Border Transfers: The Company processes your personal data both within and outside the United States. Regardless of the differing laws in these countries, the Company ensures a high level of privacy compliance.
- Time for Reply and Reaction: The Company commits to providing information on actions taken on your request related to your rights within a maximum of one month from receipt. This period may be extended by up to two additional months if necessary due to the volume or complexity of requests.
- Security: The Company takes technical and organizational measures to secure your information, protecting it against unauthorized or unlawful processing and accidental loss, destruction, or damage.
- Accessing Account to Provide Support: In exceptional circumstances, such as required customer support, our support specialists may need to access your account. They will always ask for your permission before doing so.
- Children’s Privacy: The Company does not intend its Services for use by children under the age of 16 without the express permission of their parent or legal guardian. Any data of children under 16 is processed only if consent is provided by parents or legal guardians for the purpose of using Services.
- Breach Notifications: If a breach of your personal data occurs, the Company will inform you and the respective data protection agencies without undue delay if there are high risks to your rights as a data subject.
- “DoNotTrack” Requests: The Company does not share personal data with third parties for their direct marketing purposes and does not support “Do Not Track” requests.
Providing Data is Voluntary
Providing personal data to the Company is entirely voluntary. However, to create a user account and use our Website, providing personal data is necessary. Failure to provide personal data may limit your ability to use all of the features on our Website.
Personal Data Controller
Crumb4life LTD, registered under Estonian law with registration number 16189904, located at Rüütli tn 24/1 Kesklinna linnaosa, Tallinn Harju maakond, Eesti, 10130, will be the controller of your personal data.
Updating This Policy