CROWD PRIVACY NOTICE

Last Updated: 12/11/2023

CROWD is owned and operated by Miami Labs, Inc. (d/b/a OpenStore). This Privacy Notice describes how information is collected, used, disclosed, and otherwise processed when you access or use the CROWD mobile application or when you otherwise interact with us in connection with CROWD, such as through our customer support channels (collectively, the “Services”).

This Privacy Notice does not apply to the Shop OpenStore website, to the collection or use of personal information of any OpenStore merchant, or to any of our other websites, mobile applications, or online products and services that do not link to this Notice.

We may change this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of this Notice. We may also provide you with additional notice (such as by adding a statement to the Services or sending you a notification), such as in connection with making material changes to this Privacy Notice. We encourage you to review this Privacy Notice regularly to stay informed about our information practices and the choices available to you.

1.              PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us. We collect information that you provide to us, automatically when you use our Services, and from other sources as described below.

1. Information You Provide to Us Directly

We collect information that you provide directly to us. For example, we collect information directly from you when you create an account, make a purchase, submit or post content (for example, when you “like” a product or post a product review or comment), participate in a contest or promotion, request customer support, or otherwise communicate with us. The types of information that we collect include name, email address, postal address, phone number, gender, and any other information you chose to provide.

1. Information Collected Automatically

We collect certain information automatically when you interact with our Services, including:

●      Activity Information. We collect information about your activity on our Services, such as the items you purchase or put in your card, products that you like, and information about what you click, how long you spend on the Services, and the pages you view.

●      Device and Usage Information. We collect information about how you access our Services, including data about the device and network you use to access the Services, such as your hardware model, operating system version, mobile network, Internet protocol (IP) address, unique device identifiers, browser type, and app version.

●      Transactional Information. When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction. 

●      Information Collected by Cookies and Similar Tracking Technologies. We use tracking technologies such as cookies, pixel tags, and SDKs to collect information about your interactions with our Services. These technologies help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. See the Your Privacy Rights and Choices section below to understand your choices regarding these technologies.

1. Information Collected from Other Sources

We obtain information from other sources. For example, we collect information about you from merchants that run on the OpenStore platform. We may also collect information about you from third parties such as identity verification services, financial services providers, data brokers, advertising networks, data analytics providers, or mailing list providers. This information may include identifiers such as real name, alias, postal address, or other similar identifiers, purchase history, and inferences reflecting your consumer preferences, characteristics, and predispositions. Additionally, if applicable, if you create or log into your account with us through a third-party application, such as an app store, a third-party login service, or a social networking site, we will have access to certain information from that application, such as your name and profile picture, in accordance with the authorization procedures determined by such application.

1. Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about infer that you are interested particular products based on your previous interactions on our Services or with merchants who operation on the OpenStore platform.

2.              HOW WE USE YOUR INFORMATION

We use the information we collect to provide our Services, including to customize your experience with us, and to improve and develop new products and services. We also use the information we collect to:

●      Promote and communicate with you about products, services, and events offered by us and other merchants that operate on the OpenStore platform and others (see the Your Privacy Rights and Choices section below for information about how to opt out of these communications at any time);

●      Monitor and analyze trends, usage, and activities in connection with our products and Services;

●      Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;

●      Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of us and others;

●      Comply with our legal and financial obligations; and

●      Carry out any other purpose described to you at the time the information was collected.

3.              ANALYTICS

We engage others to provide analytics services, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used to analyze and track data, determine the popularity of certain content, and better understand your online activity.

4.              DISCLOSURE OF INFORMATION

In certain circumstances, we disclose (or permit others to directly collect) information about you. We disclose the categories of personal information described above in the following ways:

●      We disclose personal information with vendors, service providers, contractors, and consultants that need this information to provide services to us, such as companies that assist us with IT support, web hosting, customer service, banking and legal services, fraud prevention, insurance, and marketing and advertising.

●      If you “like” a product, others will be able to see that like. Similarly, if you provide a product review or comment, or otherwise share content on our Services, we disclose this information publicly/with other users of our Service.

●      We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

●      We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of OpenStore, our users, the public, or others.

●      We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

●      Personal information is disclosed between and among OpenStore’s current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.

●      We disclose personal information with your consent or at your direction.

We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. We will not attempt to re-identify such information, except as permitted by law.

5.              YOUR PRIVACY RIGHTS AND CHOICES

●      Access, Correction, Deletion. Depending on where you reside, you may have the right to (1) request to know more about and access your personal information, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information. To request access, correction, or deletion of your personal information, contact us as described in the Contact Us section below. You can also access, correct, or delete certain information stored within your online account in your account dashboard. We may verify your request by asking you to provide certain information about yourself or your recent interactions with us. Note that if we deny a request you make to access, delete, or correct your information, you may have the right to appeal our decision.

●      Promotional Communications. As described above, we may use the information we collect to promote merchants owned and operated by OpenStore. You may opt out of receiving these messages by following the instructions in those communications. If you would like to opt out of the sharing disclosure of your personal information across OpenStore’s merchants for such purposes, you may opt out by contacting us as set forth in the “Contact Us” section below.

●      Nondiscrimination. We will not discriminate against you for exercising your privacy rights.

●      Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

●      Communication Preferences. You may opt out of receiving text messages or promotional emails from us by following the instructions in those communications. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations. 

●      Mobile Push Notifications. With your permission, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device. 

6.              DATA RETENTION

We store personal data associated with your account for as long as your account remains active. If you close your account, we will delete your account data within 90 days; otherwise, we will delete your account data after two years of inactivity. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Notice.

7.              SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

California law requires us to disclose the following additional information with respect to our collection, use, and disclosure of personal information. If you are a California resident, this section applies to you.

Additional Disclosures. We collect the following categories of personal information: identifiers; categories of personal information described in Cal. Civ. Code § 1798.80(e); commercial information; Internet or other electronic network activity information; audio and visual information; and inferences drawn from any of the categories identified above. For more information about the data points we collect and the categories of sources of such collection, please see the Collection of Personal Information section above. We collect personal information for the business and commercial purposes described in the How We Use Your Information section above. We may disclose personal information for the business and commercial purposes described in the Disclosure of Information section above and we have made disclosures for business purposes to the following categories of recipients: