Privacy Policy

Introduction

Crew considers that the protection of the personal data of its users is a serious matter. The management and protection of the personal data of the users of the website at www.crewhq.io (the “Site”) and/or Crew App at app.crewhq.io (the “App”) and / or the services accessible through the Site or the App (the “Services”) is subject to the terms of this policy and also to the provisions of Dutch and EU law with regards to the protection of persons from the processing of their personal data as in force. In any case Crew reserves the right to adjust the terms of this policy to the each time applicable legal framework. Therefore, these terms may be modified and updated at any time without prior notice. The users of Crew have to check regularly these terms for changes because the use of the website entails that all amendments thereof have been accepted.

Categories of personal data and purpose of processing

Crew collects personal data of its users which are provided by the latter to the extent that this is absolutely necessary and proportional for the purposes of processing for which these data have been collected and which is the provision of the Services of the Site and the App. In our effort to always improve our services, we may process part or all users’ data for statistical purposes. Those data help us to better understand the users and the manner with which we can improve our website.

The legal basis for the processing of such data is the performance of the contract concluded between Crew and the users by acceptance of the terms of use or our legitimate interest of ours, as the case may be, as a business in conducting and managing Crew to enable us to provide to you the Crew Services and offer the most secure experience. We make sure we consider and balance any potential impact on users (both positive and negative) and users’ rights before we process their personal data for our legitimate interests. We do not use users’ personal data for activities where our interests are overridden by the impact on them (unless we have your consent or are otherwise required or permitted to by law). In addition, we will process users’ personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Personal data are any information relating to an identified or identifiable natural person.

The personal data we are collecting are:

1. Submitted information: This is information users give us about them by filling in forms on the App and/or the Site, or by corresponding with. Such information may

include users’ full name, address, phone number, email address of the users.

2.  Information we collect about users and their device. Each time users visit the App or our Site we will automatically collect the following information:

(i) technical information, including the internet protocol (IP) address used by users to connect their computer to the Internet, their login information, browser type and version, time zone setting, operating system and platform, device information and the type of mobile device they use, their mobile operating system, the type of mobile browser they use;

(ii) information about the users’ visit, including the full uniform resource locators (URL), clickstream to, through and from our Site (including date and time), services the users viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;

3.  details of users’ use of our App or their visits to our Site including transaction details relating to their use of our services.

4. Information to help us deliver our service to users. We work closely with third parties in order to help us deliver our Services to users. These third parties are business partners.

5. If users allow us to, we will collect friends lists from Facebook and similar information from other third parties such as Twitter and Google – the App will periodically re-collect this information in order to stay up-to-date.


Recipients of the data

Crew will make best efforts to ensure the integrity and confidentiality of the personal data of its users. To this end, it will not disclose or otherwise transfer or dispose for sale or for other commercial purposes or publish the personal data of the users/visitors to any third parties with the exception of i) cases where this is required by law and only to the competent authorities ii) for the exercise and defense of Crew’s own lawful interests and rights iii) cases where the explicit consent by Crew users has been given.

We may use users’ personal data to form a view on what we think they may want or need, or what may be of interest to them. This is how we decide which products, services and offers may be relevant for them.

Users will receive marketing communications from us if they have signed up to and/or utilise the Crew Services and, in each case, they have not opted out of receiving marketing notifications.

We will obtain users’ express opt-in consent before we share their personal data with any company outside Crew for marketing or promotional purposes.

Users can ask us or third parties to stop sending them marketing messages at any time by adjusting their marketing preferences via their profile in the App, contacting us via [email protected], or by following the unsubscribe links on any marketing message sent to them.


Data retention

Crew will store and retain the personal data of users for as long as it is necessary for the provision of the services to the users and for the time period that is required for the fulfillment if its lawful obligations and the exercise of its rights.

Exercise of the rights of the users

Users have rights under data protection laws in relation to their personal data. Please see below to find out more about these rights:

Users have the right to:

Users should note that this right only applies to automated information which they initially provided consent for us to use or where we used the information to perform a contract with them. If they require this then they should reach out to our support team in [email protected] .

Withdraw consent at any time where we are relying on consent to process their personal data. However, this will not affect the lawfulness of any processing carried out before they withdraw their consent. If they withdraw their consent, we may not be able to provide the Crew Services to them. We will advise them if this is the case at the time they withdraw their consent.

Cookies

The website www.crewhq.io and the app app.crewhq.io use cookies in order to facilitate the access of the users, for statistical purposes and for determining areas which are useful or popular. This will enable us to update and redesign the website so as to provide better and qualitative services and to improve the browsing of the users.

Cookies are small text files which comprise letters and figures which are stored by the central server of the webpage in the hard disk of the computer of the user when the user gains access to certain websites and do not become in knowledge of any document or file from the computer of the user. Cookies allow to the website to recognize the device of the user.

Necessary cookies are cookies for the proper function of the website and allow the proper browsing and the use of the possibilities provided by the website.

Session cookies are cookies which expire upon expiry of a browsing session

Persistent cookies are cookies which remain stored in the device of the user for more than one browsing sessions and allow the recordation of the preferences or the actions of the user throughout the website (and in some cases in other websites as well). Persistent cookies may be used for other purposes such as the recording of preferences or for targeted advertisements.

Third party Cookies /Google Analytics are stored for all visitors of a website. They collect information on the manner that users use the website and the term of their storage is set forth by Google. These cookies collect information on a no name basis including information on the number of visitors of a webpage, the origins of the visitors and the pages visited within the website.  We use this information in order to draft reports that could help us improve our webpage.

For more information about cookies including the way you can find out which cookies have been set and how to manage, exclude or delete them, you can visit the website www.allaboutcookies.org.

Questions

If anything in this document is unclear please email your questions or concerns to [email protected].