This Privacy Policy informs you about how we use any personal data which you provide to us, including through our website thisiscrowd.com (the “Website”). The Website is owned and operated by [Crowd, incorporated and registered in England and Wales with company number 11084700 and registered office at 20-22 Wenlock Road, London N1 7GU[JD1] ] (referred to as “we”, “our”, “us” and “Crowd”)
When you use the website, or otherwise provide any information to us, you agree to this privacy policy, including the manner in which we use your information. if you do not agree to this privacy policy, or to any changes we subsequently make to this privacy policy, you must immediately stop using the website or otherwise providing any information to us.
When we use personal data about you or others in connection with promoting and administering our business, providing our services, or recruitment, we do so as data controller.
Please read this Privacy Policy carefully as it contains important information about the use of any information you provide to us. This Privacy Policy explains what information we collect about you, how we use your information and sets out the circumstances where it could be shared with third parties.
We do not meet the criteria for a mandatory appointment of a Data Protection Officer under the UK General Data Protection Regulation. We have allocated informal responsibility to a person in our business who can deal with any data protection-related matters. You can contact our Privacy Manager by email at: results@thisiscrowd.com marking the subject line, ‘For the attention of the Privacy Manager’.
Personal data, or personal information, means any information about a living individual from which that person can be identified, directly or indirectly. We may collect different kinds of personal data about you when you interact with us, including via the Website, social media, email, telephone, post or in person.
We may also receive this information from third parties (for example, a publicly available source or from someone who has recommended us to you and given us your contact details).
We have grouped this information together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the percentage of users accessing a specific feature, or we may aggregate your Marketing and Communications Data to calculate the percentage of recipients who open our email newsletter. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not usually collect any special categories of personal Data about you, but you may choose to disclose this data to us. Special categories of personal Data include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Unless we are required to do so to comply with a legal obligation, or as an integral part of providing the Service to you, we do not usually collect any personal data about you relating to criminal convictions or offences.
Our core purposes for processing personal data are to promote and operate the business of being a marketing firm, to provide marketing services to our clients, to maintain our client and business records, to recruit, and to comply with the law and regulations.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
We may also use personal data as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including those outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
This table sets out in more detail the lawful basis we rely on to process personal data, depending on the category of personal data and the reason we are processing it. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
| Purpose/activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To provide the Website to you | (a) Technical Data | Legitimate interests (to promote our business and services via the web) |
| To register you as a recipient of our newsletters and updates and to download our e-books | (a) Identity Data (b) Contact Data (c) Technical Data (d) Marketing and Communications Data | (a) Legitimate interests, including for any soft opt-in (to undertake direct marketing to promote our business and services) (b) In the limited circumstances where the Privacy and Electronic Communications Regulations mandate that consent is required for electronic marketing, and we are not relying on your opt-in, the lawful basis will be consent (See Advertising, marketing and your communications preferences below) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy (b) Asking for feedback | (a) Identity Data (b) Contact Data (c) Enquiry Data (d) Correspondence Data (e) Marketing and Communications Data | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to ensure we provide our services on our most recently updated terms) |
| To register you as a new client and respond to your enquiry | (a) Identity Data (b) Contact Data (c) Enquiry Data (d) Correspondence Data | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation |
| To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity Data (b) Contact Data (c) Enquiry Data (d) Correspondence Data (e) Technical Data (f) Marketing and Communications Data | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity Data (b) Contact Data (c) Enquiry Data (d) Correspondence Data (e) Technical Data (f) Tracking Data (g) Marketing and Communications Data | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Website and the client experience | (a) Identity Data (b) Technical Data (c) Tracking Data | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform and deliver our marketing strategy) |
| To target potential new clients via social media and the web | (a) Identity Data (b) Technical Data (c) Tracking Data | Necessary for our legitimate interests (to engage with the new clients and potential new lawyers via social media and the web (for example, via LinkedIn)) |
We may share your data with third parties to whom we have outsourced certain tasks, such as IT, business administration or marketing and analytics services.
We may share your personal data with our insurers, our professional advisors (lawyers, bankers, auditors, corporate financiers and brokers) in connection with services they provide to us.
We share personal data with the following third parties for advertising and analytics purposes:
For more information on personal data sharing connected to advertising and marketing, see Advertising, marketing and your communications preferences below.
We may also share data with 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 data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will not otherwise share personal information with any third party except where we are permitted to under data protection laws or required to by law.
We work with partners to try and promote the reach of our adverts and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media. Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new clients and colleagues. The cookies used for this purpose are often placed on our website by specialist organisations – and this is also why when you have been on our Website, you might see an advert for us quite soon afterwards. The partners we work with are: Facebook, Google, Instagram, LinkedIn, Pinterest, Sign-Up.to, and Twitter.
Cookies can also tell us if you have seen a specific advert, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our adverts and control the number of times people might be shown our adverts. Cookies also help us understand if you have opened a marketing email, because we prefer not to send you correspondence you prefer not to read.
If you want more information about Tracking Data, in particular cookies, see our Cookies Policy below.
Almost all the cookies that relate to advertising are part of third-party online advertising networks. If you would like to read about how you can control which adverts you see online, see opt-out programs established by the Digital Advertising Alliance (United States) and the European Interactive Digital Advertising Alliance (Europe).
Unfortunately, because the technical rules are not yet standardised, the Website currently does not respond to a Do Not Track signal.
For data transfers taking place outside of the UK, we ensure that a similar degree of protection is afforded to it, either by making our own assessment of adequacy, or using one of the standard mechanisms available to us. These may include:
We will only keep your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
We retain personal data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
You may exercise certain rights regarding your personal data. In particular, you have the right to do the following:
Where personal data is processed for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to their particular situation to justify the objection.
You must know that, however, should your personal data be processed for direct marketing purposes, you can object to that processing at any time without providing any justification.
Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within one month.
In addition to the information contained in this Privacy Policy, this Website may provide you with additional and contextual information concerning particular services or the collection and processing of personal data upon request.
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other personal data (such as the IP Address) for this purpose.
More details concerning the collection or processing of personal data may be requested from us at any time. Please see the contact information at the beginning of this document.
We reserve the right to make changes to this Privacy Policy at any time by notifying you on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to you via any contact information available to us.
It is strongly recommended to check this page often, referring to the date of the last modification listed at the top.
Should the changes affect processing activities performed on the basis of your consent, we shall collect new consent from you, where required.
If you experience any technical problems during your interaction with the Website, please contact us here: infrastructure AT thisiscrowd.com
Queries, concerns or complaints regarding your privacy or this Privacy Policy: If you have queries regarding this Privacy Policy please contact us by sending an email to the Data Protection Officer: DPO AT thisiscrowd.com.
In the United Kingdom we are supervised by the Information Commissioner’s Office (ICO). You can find out more about the ICO through its website: www.ico.org.uk
“Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website-browsing equipment for record-keeping purposes. Cookies allow the website to remember important information that will make your use of the site more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value. Like most websites, we use different categories of cookies for a variety of purposes in order to improve your online experience.
Depending on the purpose, we use session cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and persistent cookies, which remain in the cookie file of your browser to collect information that is used either in aggregate form to help us understand how our website is being used or how effective our marketing campaigns are, or to help us customise our Website for you.
Cookies can be categorised, following the International Chamber of Commerce guide, as follows:
‘Strictly necessary cookies’ tend to be session cookies which are deleted at the end of the browser session.
Accepting these cookies is a condition of using the website, so if you prevent these cookies, we can’t guarantee how our website will perform during your visit.
‘Performance cookies’ collect information about how you use our website such as which pages you visit and if you experience any errors. These cookies don’t collect any information that could identify you – all the information is collected on an anonymous aggregate basis and is only used to help us improve how our website works, understand what interests our users and measure the effectiveness of our advertising. They also enable us to track the total number of visitors to our site. Most performance cookies tend to be session cookies which are deleted at the end of the browser session.
In some cases, some of these cookies are managed for us by third parties, but we don’t allow the third party to use the cookies for any purpose other than those listed above. Some of these third-party performance cookies are persistent cookies.
Functionality cookies, by their very nature, are persistent cookies so that we remember your computer when you return to our website.
Some of these cookies are managed for us by third parties – where this is the case, we don’t allow the third party to use the cookies for any purpose other than those listed above.
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.] Only needed if targeting cookies are used.
Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. You can easily delete any cookies that have been installed in the cookie folder of your browser.
Important: Google Analytics does not collect any personal information about our website users.
Google Analytics is a simple, easy-to-use tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to “remember” what a user has done on previous pages / interactions with the website.
Please click here to see a detailed description on Google Analytics policy. If you would like to learn how to manage or remove cookies which have been set on your device please visit http://www.aboutcookies.org (http://www.aboutcookies.org). We gather this information for internal use only and will not authorize the release of this information to anyone outside Crowd.
HubSpot Analytics uses cookies and beacons to track how long Customers and potential Customers are on our site, what marketing pages they visit, what marketing offers they respond to, and a visitor’s identity in order for us to improve our customer education material, set up accounts, and provide the Services. For a description of all HubSpot cookies you can read about them on their site and check out their privacy policy.
