Data Respect Statement

We are Crumb LLC, d.b.a Crumb ("Crumb", “we”, “us” or “our”). Our company details are set out at the end of this document. We are the Controller for the purposes of data protection laws. As a company we are committed to protecting and respecting the privacy of your personal information. We want you to be confident that your information will be properly protected whilst in our possession. The Privacy Policy below explains how we, and carefully selected third parties we work with, collect and use your personal information. Please read our Privacy Policy carefully and make sure you’re comfortable with the content. We will only ever use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
  • Where we need to perform the contract we are about to enter into, or have entered into, with you.
  • Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email, social media or text message. You have the right to withdraw consent to these activities at any time by contacting us at: [email protected].
If you have any questions about our use of your personal information, or you wish to exercise one of your rights under the GDPR, please contact us at: [email protected].

Privacy Policy

Personal Information. This Privacy Policy sets out the basis on which we process your personal data and information in connection with your use of our Services (the “Personal Information”). You should also read our Terms and Conditions which are incorporated by reference. When you use our Services, you acknowledge you have read and understood this Privacy Policy. Changes to this Privacy Policy. We may modify this Privacy Policy from time to time to reflect changes in, or requirements of, the law or modifications or updates to the Services made in accordance with our Terms and Conditions. We will notify you if such change materially affects your rights under this Privacy Policy. Changes will not apply retrospectively and, unless the change is required immediately for legal reasons, notice of the modified terms will be provided a reasonable period prior to the changes taking effect. If you do not accept and agree to this Privacy Policy, then you must not access or use the Services.

What Personal Information Do We Collect

Information you give us. When you sign up for a Crumb account and use our Services, we keep the basic account information you give us, like your name, email address, telephone number and password. We do not collect any Special categories of Personal Information. Information we collect. We also collect and store your Personal Information as you use the Services and each time you interact with Crumb, for example, when you:
  • update information in your dashboard,
  • communicate with us by telephone or email, and
  • complete forms on our website.
Automatic Information. We may collect information about the device you access the Services from, such as the IP address or other unique device identifiers. If you access your account from a mobile device, that mobile device may also provide us with details of your location. Most mobile devices allow you to disable this functionality. Cookies. Crumb uses "cookies" and other technologies to collect data that enable us to better understand and improve the usability, performance and effectiveness of our website. Cookies are files sent to your browser and stored on your computer. We use cookies to gather general information about your visits to our website. We use this information to understand traffic and referrals on our website, enabling us to improve the website, provide the best online experience possible, and improve our customer service. Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website and remembering which services you have signed up for. Without these cookies, Services you have asked for cannot be provided. Performance cookies: These cookies collect information about how you use the website. These cookies don’t collect information that identifies you and are only used to improve how the website works. Advertising cookies: These cookies are used to deliver adverts which are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement, as well as help measure the effectiveness of the advertising campaign. They are placed on the website by advertisers and advertising networks, with our permission. They remember that you have visited the site and this information is shared with other organisations such as advertisers. We use analytics data and the DoubleClick cookies for advertising purposes. You may opt out of the DoubleClick cookie by visiting the Google Advertising opt-out page or you may opt out of Google Analytics by visiting the Google Analytics opt-out page. The Google Website has additional information available about their Policy for Advertising based on Interests and Location. Other Technologies: We may also use other Internet technologies, such as web beacons or pixel tags and other similar technologies, to deliver or communicate with cookies and analyse your use of the Services. We may also include web beacons in e-mail messages so that we know when you have opened an email message received from Crumb. You may disable cookies by changing the settings on your browser. Check the help menu in your browser for further information. Remember that if you disable cookies it is likely to affect how our website works and you may not be able to access or use certain areas of our website or functionality. Unless you have adjusted your browser setting so that it will refuse cookies, our system will place cookies when you log on to our website. Personal Information regarding children:  The Services are not intended for use by individuals who cannot enter a legally binding contract. Accordingly, Crumb does not intentionally gather any Personal Information about individuals who are under the age of eighteen (18). If you are under eighteen (18) years of age or otherwise lack the capacity to enter into a binding contract do not use our Services. If Crumb becomes aware that it has collected Personal Information from someone under the age of majority, such information will be deleted immediately.

How We Use Your Personal Information

We use your Personal Information for the following reasons:
  • To perform our contract with you: When you sign up for our Services, we need to collect your Personal Information so that we can perform our contract with you as is set out in our Terms and Conditions. We will not be able to perform our Services if you do not provide us with your Personal Information.
  • To improve our website and Services: We want to continue to improve our Services and provide you with a better and more tailored user experience on our website. We also want to hear from you if you have a complaint or any feedback about our Services. We believe it is in our legitimate business interests to process your Personal Information in this way.
  • To send you information about our Services: We may want to connect with you to provide you information about related products and services that we think might interest you. We believe it is in our legitimate business interests to communicate with you in this way. Where you have opted in to direct marketing, we will process your information to provide you with information in line with your preferences. You can always opt-out from us communicating with you in this way and can withdraw your consent at any time by emailing us or by clicking to opt-out or unsubscribe at the bottom of the relevant communication.
  • If our business is sold: We may need to transfer your Personal Information to a third party in the event that we look to sell our business or assets. If we do this, we will always ensure that appropriate security is in place. It is in our legitimate business interests to ensure that our business can continue.
  • As part of a legal obligation: In very limited circumstances, we may need to share your Personal Information as part of a legal obligation.

Automated Decision-Making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
  1. where we have notified you of the decision and given you 3 days to request us to reconsider the decision;
  2. for performing our contract with you and ensuring appropriate measures are in place to safeguard your rights;
  3. in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

How We Share Your Personal Information

We may have to share your personal data with the parties set out below for the purposes set out above:
  • Our group companies
  • Carefully selected third parties who provide a service to us to support our core operations, such as: processing our mail, communicating with customers and prospective customers on our behalf (including via social media), running promotions, providing IT systems and administrative services and the development and improvement of internal systems and processes;
  • Competent authorities (statutory bodies, regulatory authorities, authorised bodies who have a role laid out by law);
  • Other organisations where we are legally obligated to disclose your personal information (such as requests made in the prevention and detection of crime) or where disclosure is necessary to protect the property, rights and safety of us and our staff or to comply with any law, regulation, or governmental or judicial warrant, rule, order or subpoena;
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy;
  • Other companies where we are trialling products and services which we consider may improve our offering to customers and/or our business processes; and
  • Other third parties where you have given your express consent or where we reasonably believe a third party is acting on your behalf.
If you have given consent to this, you can withdraw it at any time. Please use the unsubscribe link on the email communication you receive or contact us at [email protected]. We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions. Compliance with Laws and Policies Crumb reserves the right to disclose your Personal Information to third parties if we believe that such action is necessary to: (1) comply with a law, regulation, or governmental or judicial warrant, rule, order or subpoena; (2) protect and defend the rights or property of Crumb; or (3) enforce the Crumb Terms and Conditions, including this Privacy Policy.

How We Communicate With You

We may, from time to time, send you emails, desktop alerts or other communications, including: (1) notices concerning new or related Services from us; (2) notifications regarding suspected unlawful or inappropriate use; and (3) requests for feedback on the Services. If you wish to change the types of communications you receive from us or opt out of receiving any future communications, you can do so. See Your Options below. If you use the site, we may email, text message or phone you with updates or information we pertain to be of use in relation to the service we provide, we record the information you request and the details sent to you by email.

How We Protect Your Data

General Crumb has security measures in place to protect against the loss, misuse, and alteration of your Personal Information. Personal Information provided to us is stored in secure facilities with access restricted to authorised personnel only. Although we make good faith efforts to store the Personal Information we collect in a secure operating environment that is not accessible to unauthorised users, we cannot guarantee complete security. Secure Payments. If you choose to use our Services, your information is sent to us using SSL (Secure Socket Layer) encryption, an industry-standard method for protecting data as it travels over the Internet, or a similar encryption technology that may become accepted as an industry standard, or a better encryption method, in the future. Storage Your Personal information is collected and used for the reasons set out above, and will not be stored for longer than necessary for those purposes. Generally, we store your Personal Information for no longer than the time you have an account with us, plus an additional seven years. Where you do not sign up for an account or otherwise use our services, we only store your Personal Information for a maximum of two years.

Your Options

Email Communications If you wish to change the types of communications you receive from us or opt out of receiving any future communications, you may do so by modifying your profile on your control panel, by emailing your request to us at [email protected], or by clicking on the appropriate link in any Crumb email communication that you receive. Correcting Your Personal Information. You can access the Personal Information that we collect via your control panel. You can correct factual errors in your Personal Information on your control panel or by sending a request to [email protected]. Please provide sufficient details regarding the error. To protect your privacy and security, we take commercially reasonable steps to verify your identity before granting access or making any corrections to your Personal Information.

Your EU Data Protection Rights

Location of Personal Information and Transfers. Some of our external third parties may have operations or suppliers based outside the European Economic Area (EEA) so their processing of your Personal Information will involve a transfer of data outside the EEA. Whenever we transfer your Personal Information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  • We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Information in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Information to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact [email protected] if you want further information on the specific mechanism used by us when transferring your Personal Information out of the EEA.

Rights of Access, Correction, Erasure and Restriction

Your rights in connection with personal information. Under certain circumstances, by law you have the right to:
  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your Personal Information, or request that we transfer a copy of your personal information to another party, please contact [email protected].

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Third Party Links and Services

We may provide links to other third party websites as a convenience to you (collectively, the “Third Party Websites”). Please exercise care when visiting any Third Party Websites. The Third Party Websites have separate and independent privacy policies, notices and terms of use which govern your use of such websites and their use of any information they collect. We recommend you read these policies carefully. Crumb expressly disclaims all liability for Personal Information you provide to any Third Party Websites.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of Personal Information should be directed to us at the address given below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Privacy Policy. If we are unable to resolve your complaint, you can escalate the issue in accordance with the dispute resolution procedure set out in the Terms and Conditions. You have the right to make a complaint at any time to the Information Commissioner’s Office; the UK supervisory authority for data protection issues.

Crumb Contact Information

If you have any questions or comments, please contact us at [email protected] or at the address listed below: Crumb LLC d.b.a Crumb

256 Champan Road STE 105-4
United States