Effective date: July 11, 2020
CReferral is committed to protecting the privacy of all individuals who:
• Visit CReferral’s website located at CReferral.com, which includes all subdomains, present and future (the “Website”); and
• Use the mobile applications that CReferral makes available from time to time (the "Applications")
To make this policy easier to read, we call the Website, the Applications and the Platform as "Services". When we talk about “Personal Information”, we mean information relating to you or other identifiable individuals.
CReferral Data and Customer Content
We collect Personal Information (such as registration and account information) from our customers and users of the Services for our own purposes, such as to provide and administer the Services (“CReferral Data”). We’re the data controller in respect of this information.
We also process Personal Information on behalf of our customers as their data processor, such as content generated, requested or published via the Platforms in accordance with the instructions our customers give us through the Services (including, for example, the information our customers monitor or collect from social media sites like Twitter and Facebook through the Services) (“Customer Content”). Our customers control how their Customer Content is collected and used by them. In legal terms, this means that our customers are the data controller of their Customer Content. Accordingly, we only use Customer Content to provide the Services to our customers in accordance with the lawful instructions they give us through the Services.
CReferral takes your privacy seriously and we want you to know that you can trust us with your personal information.
CReferral Data we receive or collect
When you first register for a CReferral account, and when you use the Services, we collect some Personal Information about you such as:
•Full name, user name
•Email address and other contact details including phone number;
•User’s billing address and any other necessary information to complete any financial transaction, and when making purchases through the Services, we may also collect your credit card or PayPal information
•CReferral may receive relating to communications user sends us, such as queries or comments concerning our Services
•Other optional information as part of your account profile
CReferral also automatically collects and receives certain information from your computer or mobile device, including the activities you perform on our Website, the Platforms, and the Applications, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies (see “Cookies and Related Technologies” below). For example, each time you visit the Website or otherwise use the Services, we automatically collect your IP address, browser and device type, access times, the web page from which you came, the regions from which you navigate the web page, and the web page(s) you access (as applicable).
CReferral allows you to sign up and/or log into CReferral using your Facebook account. If you sign up using Facebook, or otherwise link your Facebook and CReferral accounts, Facebook will ask your permission to share certain personal information from your account with CReferral. This may include your first name, last name, email address, gender, general location, a link to your Facebook profile, your time zone, birthday, profile picture, your "likes" and your list of friends. If you choose to grant Facebook that permission, it will share that information with CReferral on an ongoing basis and we will treat information we receive from Facebook the same as if you provided that information directly to CReferral. You can control the information that we receive from Facebook using the privacy settings on your Facebook account.
CReferral allows you to sign up and/or log into CReferral using your LinkedIn account. If you sign up using LinkedIn, or otherwise link your LinkedIn and CReferral accounts, LinkedIn will ask your permission to share certain personal information from your LinkedIn account with CReferral. This may include your first name, last name, email address, gender, general location, a link to your LinkedIn profile, your time zone, birthday, profile picture, your "likes" and your list of friends. If you choose to grant LinkedIn that permission, it will share that information with CReferral on an ongoing basis and we will treat information we receive from LinkedIn the same as if you provided that information directly to CReferral. You can control the information that we receive from LinkedIn using the privacy settings on your LinkedIn account.
How we use CReferral Data
CReferral uses CReferral Data for the following general purposes:
• to identify you when you login to your account
• to enable us to operate the Services and provide them to you
• to verify your transactions and for purchase confirmation, billing, security, and authentication (including security tokens for communication with installed Third-Party Apps)
• to analyze the Website or the other Services and information about our visitors and users, including research into our user demographics and user behavior in order to improve our content and Services
• to contact you about your account and provide customer service support, including responding to your comments and questions
• to keep you informed about the Services, features, surveys, newsletters, offers, contests and events we think you may find useful or which you have requested from us
• to sell or market CReferral products and services to you
• to better understand your needs and the needs of users in the aggregate, diagnose problems, analyze trends, improve the features and usability of the Services, and better understand and market to our customers and users
• to keep the Services safe and secure
We also use non-identifiable information gathered for statistical purposes to keep track of the number of visits to the Services with a view to introducing improvements and improving the usability of the Services. We may share this type of statistical data so that our partners also understand how often people use the Services, so that they, too, may provide you with an optimal experience.
Cookies and related technologies
The Services use “session cookies”, which improve your user experience by storing certain information from your current visit on your device, such as log-in information. These enable us to remember your login session so you can move easily within the Website or the other Services. Without these session cookies, we wouldn’t be able to provide the Services to you. Other examples of our use of session cookies include to track the number of visits by a particular visitor to a page.
Performance and Remarketing Cookies
i) Google Analytics
CReferral uses a specific cookie in order to facilitate the use of Google Universal Analytics for users logged-in to the Applications or the Platforms (“Logged-In User”). If you are a Logged-In User, CReferral may use your CReferral User ID in combination with Google Universal Analytics and Google Analytics to track and analyze the pages of the Services you visit. We do this only to better understand how you use the Website and the other Services, with a view to offering improvements for all CReferral users; and to tailor our business and marketing activities accordingly, both generally and specifically to you. Google Analytics cookies do not provide CReferral with any Personal Information.
Learn more about privacy at Google and to opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on.
ii) Google Display Advertising
Additionally, CReferral uses Google Analytics code that allows for certain forms of display advertising and other advanced features. Subject to change, the Google Display Advertising features CReferral currently uses are Remarketing, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting.
These features are used to advertise online; to allow third-party vendors, including Google, to show you advertising across the Internet; to allow CReferral and third-party vendors, including Google, to use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Website and to report how ad impressions, uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Website. Data from Google's interest-based advertising or third-party audience data (such as age, gender, and interests) is also combined with Google Analytics to better understand the needs of CReferral users and to improve the Services.
You may opt out of such display advertising at any time by visiting your Google Ads Settings page or by installing and running the Google Analytics Opt-out Browser Add-on.
CReferral uses other third-party performance and remarketing cookies, and further information on those third-party cookies can be obtained by contacting us.
CReferral may also use related technologies including web beacons, bugs, pixels, and software tokens in order to facilitate your use of the Services. Most notably, the Services use software tokens (stored securely on cloud) in order to facilitate the logging in to and the functioning of both the Supported Platforms and Third-Party Apps.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. The Network Advertising Initiative has also developed a tool that may help you understand which third parties have currently enabled cookies for your browser and opt-out of those cookies. Further information can be found at http://www.networkadvertising.org/managing/opt_out.asp. Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Website, Applications, Platforms, and/or Shop. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may affect your ability to view images in other emails that you receive.
When we may share Personal Information
(1) when you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;
(2) where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;
(3) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;
(4) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Services generally);
(5) to a parent company, subsidiaries, joint ventures, or other companies under common control with CReferral;
(7) if this information is not private, is aggregated or is otherwise non-Personal Information, such as your public user profile information and related public data or the number of users who clicked on a particular link (even if only one did so).
We use industry best practices to keep any information collected and/or transmitted to the Supported Platforms or Third-Party Apps secure. This includes the use of HTTPS with TLS (Transport Layer Security), which encrypts all transmitted data, and OAuth 2.0 protocols for authentication and data transfer to Supported Platforms and Third-Party Apps.
Certain Personal Information, most notably CReferral log-in details, is encrypted during transmission using TLS. In addition, CReferral uses third-party vendors and hosting partners such as Microsoft to provide the necessary hardware, software, networking, storage, and related technology required to run the Services. These vendors have been selected for their high standards of both physical and technological security, including ISO and SSAE16 certifications.
When payments are processed via credit card, CReferral uses third-party vendors that are PCI-DSS Compliant. At no point does CReferral have access to your credit card information.
You should bear in mind that submission of information over the Internet is never entirely secure. We cannot guarantee the security of information you submit via the Services whilst it is in transit over the Internet and any such submission is at your own risk, and this risk is specifically disclaimed in our Terms.
If you are a Logged-in User, it is advisable that you logout of your account at the end of every session and not leave a logged-in account unattended for any period of time, particularly if you use a shared computer or device.
CReferral uses email as the primary mode of communications with our users. We want to respect your privacy by only sending emails of interest to you. You can manage your email preferences, such as opting-out or unsubscribing from emails sent by CReferral, by adjusting your preferences in your account settings. You may also opt out or unsubscribe from any future email communications from within a link provided in each email correspondence that we send you.
You can contact us to obtain a copy of the Personal Information held about you by us. This may be subject to a fee not exceeding any prescribed fee permitted by applicable law. You can also ask us to correct and, where relevant, erase that information. Please note that certain Personal Information may need to be retained by CReferral for a period of time following cancellation of your account where this is necessary for our legitimate business purposes or required or authorized by applicable law. As mentioned above, you have a right to change your email preferences at any time.
PJP Consulting LLC
Attn: General Counsel
13801 NE 1st Pl
Bellevue, WA 98005