Privacy Policy

1. Definitions

"User(s)", "you", "your" shall mean and include business organizations, commercial establishments, and their permitted users that avail the Services through the Website.

"UK Data Protection Law" means the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing.

"Visitor" shall mean individuals who visit the Website or may opt to share Personal Information to reach out to us.

2. What Information Do We Collect?

In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and payment information.

As part of providing our Services, we may connect to client systems, including but not limited to CRM platforms, to process or access data necessary for delivering our Services. When doing so, we will comply with the client's privacy, security, and compliance requirements, and only access such systems for purposes necessary to deliver our Services.

We collect personal information that you voluntarily provide to us when registering at the Services expressing an interest in obtaining information about us or our products and Services, when participating in activities on the Services or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:

• Publicly Available Personal Information. We collect first name, last name, phone numbers, email addresses, business email, business phone number, social media, and other similar data.
• Personal Information Provided by You. We collect app usage, financial information (credit card number, purchase history, invoices), and other similar data.
• Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
• Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Stripe. You may find their privacy policy here.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Online Identifiers. We collect devices, applications, tools and protocols, such as IP (Internet Protocol) addresses, cookie identifiers, or others such as the ones used for analytics and marketing, and other similar data.

3. How Do We Use Your Information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We use the information we collect or receive:

• To facilitate account creation and login process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
• To send you marketing and promotional communications. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time.
• To send administrative information to you. We may use your personal information to send you product, Service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us at privacy@crescerelabs.com.
• Request Feedback. We may use your information to request feedback and to contact you about your use of our Services.
• To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, and determining the effectiveness of our promotional campaigns.

Additionally, when connecting to client CRM or related systems, we will comply with the client's privacy, security, and compliance requirements, and only access such systems for purposes necessary to deliver our Services.

4. Will Your Information Be Shared With Anyone?

In Short: We only share information to third parties with your prior consent, to comply with laws, to provide you with Services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, or situations involving potential threats to the safety of any person.

More specifically, we may need to share your personal information in the following situations: Vendors, Consultants, and Other Third-Party Service Providers who perform services for us or on our behalf; and in connection with Business Transfers such as any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Who Will Your Information Be Shared With?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties:

• Allow Users to Connect to their Third-Party Accounts: Google account, Facebook account, LinkedIn account, Twitter account, and Mailchimp account
• Invoice and Billing: Stripe
• User Account Registration and Authentication: Google OAuth 2.0 and Google sign-in
• Web and Mobile Analytics: Google Analytics, MixPanel, Amplitude, and Segment

You can learn more about how Google uses your data here.

6. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Policy will require us keeping your personal information for longer than 1 year past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

Our Services are intended for business organizations and their authorized users, not for individuals under 18. By using the Services, you represent that you are at least 18 or are an authorized user of a business organization. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

9. What Are The Security Measures Taken By Us?

Your information is stored on secure cloud infrastructure. We adhere to industry-standard security practices, including the use of firewalls, encryption, and access controls, to protect your personal information. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and therefore we cannot guarantee absolute security. We will take necessary measures to mitigate risks in the event of unauthorized access, hacking, or technical issues.

10. What Are Your Privacy Rights?

In Short: You may review, change, or terminate your account at any time.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided, or log into your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we will still need to send you service-related emails that are necessary for the administration and use of your account.

11. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

12. Do California Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

If you are a California resident, you have the following rights:

• Access: You have the right to request and obtain from us, once a year and free of charge, information about categories of personal information we have collected, categories of sources, our business or commercial purpose for collecting that personal information, the categories of third parties with whom we share that personal information, and specific pieces of personal information we collected about you.
• Deletion: You have the right to request that we delete the personal information that we have collected from you.

If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services.

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information and (2) describes your request in sufficient detail. We will respond to your valid request within 45 days of receipt. To exercise these rights, please email privacy@crescerelabs.com.

No Discrimination

We will not discriminate against you for exercising your rights under the CCPA.

Do Not Sell My Personal Information

Crescere Labs, Inc. will not sell your personal information.

13. Do EU and UK Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of EU or UK, you are granted specific rights regarding access to your personal information.

Residents of the European Union ("EU") and United Kingdom ("UK") should note that this policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (the "GDPR") and UK Privacy Laws. We shall be considered the Controllers of the personal information collected as a result of your use of the Website.

Legal Basis: We will not process your personal information without a lawful basis to do so. We will process your personal information only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.

Transfer of your personal information across borders (for EU Residents): The personal information we collect (of EU and UK residents) is stored on servers located in the EU region. Personal information might be processed outside the EU and UK in accordance with the provisions of the GDPR and UK Privacy Laws. If you have questions, please contact privacy@crescerelabs.com.

If you are a EU and UK resident, you have the following rights:

• To let you know what personal information belonging to you we hold in our possession
• Withdraw consent at any time where we are relying on consent to process your personal information
• Right to have us rectify or modify any such personal information
• Right to have us erase/delete your personal information
• Right to restrict us from processing such personal information
• Right to object to our use of your personal information
• Right to lodge a complaint with a data protection authority

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

UK residents have the right to make a complaint at any time to the Information Commissioner's Office ("ICO") at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance at privacy@crescerelabs.com.

Governing Laws: For any EU and UK residents, this Policy shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.

14. Links To Other Websites

Our Website may contain links to other platforms/websites of your interest. Please note that we do not have any control over such other platforms/websites, and you will be accessing these platforms/websites at your own risk and those are not governed by this Policy. You should exercise caution and look at the policy applicable to such platforms/websites.

15. Governing Laws

This Policy shall in all respects be governed by and construed and enforced in accordance with the laws of State of California, USA and the courts of California shall have exclusive jurisdiction to adjudicate any subject matter under this Policy.

16. Do We Make Updates To This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

17. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, you may email us at privacy@crescerelabs.com or by post to:

18. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us at privacy@crescerelabs.com.