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Krowd Privacy Policy

The Krowd app instantly connects people to those around them running the Krowd app who have recently used the same Wi-Fi. Any registered user can send a Krowdfeed message that is broadcast to all those nearby, review a list of co-located Krowd users or send personal 1-to-1 messages. 

This Privacy Policy describes how and when Krowd collects, uses and shares your information when you use our Services. Krowd receives your information through our various websites, email notifications, applications and widgets, (the "Services" or "Krowd") and from our partners and other third parties. For example, you send us information when you use The Krowd or our websites (www.krowdthink.com, www.krowdnet.com and www.thekrowdapp.com ) , post or receive Krowd messages or access Krowdthink services from an application such as The Krowd for iOS or The Krowd for Android. When using any of our Services you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country you reside in or supply information from, you authorize The Krowd to use your information in the United Kingdom or United States and any other country where The Krowd operates. All data stored in the cloud is maintained in Irish servers and thus subject to EU law.
If you have any questions or comments about this Privacy Policy, please contact us at  krowd@krowdthink.com and enter Privacy in the subject line.

Information Collection and Use

We collect and use your information below to provide our Services and to measure and improve them over time.

Basic Account Information: When you create or reconfigure a Krowd account, you are requested to provide an email address which we use for the purpose of password recovery or important administration notifications which you opt-in to receive. You may exchange this email address with others in a local Krowd via an opt-in mechanism. You are not obliged to provide a valid email address but you understand that our lack of access to an email prohibits us from assisting you in recovery of your password and you may miss important administration emails and you will not be able to use the email exchange tool in the app.

Additional Information: We obtain no other information personal to you. You may choose to create a profile with a short introduction and/or a picture which is visible to anyone co-located with you or anyone who searches your Krowdname or hashtag profile words. If you use the hashtag feature, we will associate those words with your account to enable users to search for you via these common interests. You may delete any or all of these hashtag profile words by visiting www.krowdnet.com . You may edit your profile and picture at anytime.

However we do not access this information in any way except to make it searchable by those using The Krowd application, unless required to by legal authorities or because the content has been reported as in contravention of our Terms of Service.  Note that URLs used by our customers in the Krowd app may include tracking information, we advise you carefully review the URL before clicking through.


Follower and Account Usage Statistics: Our Services are primarily designed to help you share information and chat with those around you. Most of the information you provide us is information you are asking us to make public, albeit in a limited localized (co-location) context. This includes not only the messages you post but statistical counts of your account activity that are visible to those nearby, such as how many followers you have and how many you have followed, as well as the number of times people nearby have chosen to ignore you in the local Krowd, in addition to the date that you first activated your account. This information is collated so that those around you can interrogate your level of Krowd participation and personal integrity. Our Services broadly and instantly disseminate your profile to all co-located Krowd users and is accessible to Krowd users that have visited the same locations as you and in which you have participated in the local Krowd conversation or have located you via name or hashtag searches. Your personal hashtags can be searched for by any user anywhere at anytime and thus allow them to review your personal profile. Your information is not accessible to anyone not participating in The Krowd application and it is not made generally available on the web. 

We do maintain a current record of the types of follows you have instigated (met in real life, met in the Krowd etc) in order to sustain your follow lists and identifiers. We do not use this information for any other purpose other than to enable your beneficial use of the app.

Location Information: Krowdthink goes to great effort to deliver a location-based service that does not track your location. We obtain information about which Wi-Fi you are connected to at a point in time and we co-locate you with those who have recently connected on the same Wi-Fi network. We do not know the physical location of that Wi-Fi network and we do not collate that information in any way, we also make efforts to encrypt the Wi-Fi information to inhibit hacker attacks seeking your current location. We only maintain a record of the last 10 (encrypted) Wi-Fi hotspots you were connected to (for future feature additions), we maintain no other history of Wi-Fi hotspot connections, nor any history of whom you were co-located with. All historic data related to Krowds (hotspots) that you can see in the app are on your device only and not maintained by Krowdthink’s servers.

Note that certain public Wi-Fi hotspot providers have Terms and Conditions that require you to allow them to track your location and movements between Wi-Fi hotspots through your proximity to any of their Wi-Fi hotspots (you may not have to connect to the Wi-Fi for this tracking to occur – so we advise turning off Wi-Fi when not in use). In addition phone manufacturers and Operating System providers often seek implicit consent to use Wi-Fi data to build location maps. This data is usually collected anonymously and may even work when Wi-Fi is turned off. We advise checking the phone settings and/or operating system privacy policies and opting out of this tracking. Note also that some mobile device manufacturers are seeking to minimize this Wi-Fi location tracking capability through Wi-Fi scanning anonymity techniques and we advise you to check for, and enable, these features when selecting and using a mobile device. 

It has also come to our attention that some telecom service providers are tracking your location all the time for the purpose of commercial resale. Please check your service provider privacy policy and, if available (for example in the EU), we advise opting-out of this tracking. 

Cookies: Our principled approach to avoiding tracking and profiling our customers extends to our approach to our website. We only use one cookie on our  www.krowdnet.com user website and none on our  www.krowdthink.com or www.thekrowdapp.com websites. The Krowdnet cookie is for login session authentication. 

However we have determined that our web service provider does integrate website analytics for their own purposes, which we cannot turn off and they provide us access to this information. We will only use this information to improve the website experience in general and we won’t track any individuals use of the website in isolation. It is our intention to move to an alternative web service provider and when we do so we will implement web page analytics that ensure only Krowdthink Ltd has access to this data. This policy will be updated when that occurs. 

Irrespective of our own policies we strongly advise you to use cookie blocking technology and/or your browser Do Not Track feature to empower yourself with controls over what aspects of your browsing history you make available to third parties. 

Log Data: When you use our Services, we may receive information ("Log Data") such as your IP address, browser type, operating system, the referring web page, pages visited, your mobile carrier, device information (including device and application IDs), search terms, and cookie information. We receive Log Data when you interact with our Services, for example, when you visit our websites, sign into our Services, interact with our email notifications. Krowd uses Log Data to provide, understand, and improve our Services. If not already done earlier we will either delete Log Data or remove any common account identifiers, such as your username, full IP address, or email address, after 18 months or less. No Log data will be used for commercial purposes except to improve our services to you.

Commerce Services: Krowdthink does not offer any commercial services on our platform at the moment, nor is our Krowd application warranted for such activity. 
You may be asked by the app store provider to exchange commercial information for access to our Krowd app and we expect you will assess and comply with their privacy policies. 

Third-Parties and Affiliates:  Krowd uses a variety of third-party services to help provide our Services, such as hosting our blogs. These third-party service providers may collect information sent by your browser as part of a web page request, such as cookies or your IP address. We do not solicit access to this information. If we need access to this information (in order to execute our engagement and enhance services to you) we will add it to our Transparency web page so that you are completely aware of what information is being obtained and how it is being used. 

Information Sharing and Disclosure

We do not disclose your private personal information except in the limited circumstances described here. The only private personal information we may hold is your email address and your profile and hashtags and a push notification identifier (that can only be linked to you by Apple or Google). We consider all the meta-data related to your usage of our services as profile data and thus personal data. Our principled approach is to minimize what meta-data we hold to the minimum needed to deliver the Service. Our web page Your Krowd data explained defines what data we hold and how it is used. You can raise questions on our online forum www.krowdnet.com and users may vote on which ones they'd like to see prioritized for our attention.

We do not disclose any of the data (as defined under Your Krowd data explained) we maintain on you to any third party. Disclosure of information to other Krowd users is solely as defined by the application and for which we provide comprehensive in-app control tools.

Law and Harm: Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Krowd's rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party's, including a government's, request to disclose your information. 

Business Transfers and Affiliates: In the event that Krowdthink is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your information as transferred to the new entity. 

Non-Private or Non-Personal Information: All data relating to you and your use of our services is considered private and thus will not be shared by Krowdthink Ltd. 

Modifying Your Personal Information

If you are a registered user of our Services, we provide you with tools and account settings to access or modify the personal information you provided to us and associated with your account. 

Our Policy Towards Children

Our Services are not directed to persons under 16. If you become aware that your child has provided us with personal information without your consent, please contact us at Krowd@Krowdthink.com and include the word Privacy in the subject line. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we take steps to remove such information and terminate the child's account. 

EU Data Protection Information

Krowdthink Ltd complies with EU Data Protection legislation. Krowdthink Ltd operates as if all the data and meta-data we hold related to your account is part of a profile of you and thus personal, even though it is used pseudonymously. Thus for the purposes of EU Data Protection compliance the following information is relevant:
Our EU Data Protection Authority is the UK. 
We have an appointed Data Controller. To contact them directly email krowd@krowdthink.com and include in the subject "FAO: The Data Controller". The Data Protection Officer is the company Managing Director. 
If we suffer a data breach we will inform the UK Data Protection Authority without delay and act upon their advice. If we can identify specific accounts that have been breached we will contact the users either via Krowd messaging tools or email (if you have a valid email address in your account details) at our earliest opportunity. 


Changes to this Policy

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at  http://thekrowdapp.com/pp.html
If we make a change to this policy that, in our sole discretion, is material, we will notify you via a Krowd personal message or email to the email address associated with your account. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy. 

Effective: November 20, 2014


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