Privacy Policy

At Croo, we believe in transparency and honesty. We hope you will find this privacy policy clear and transparent. Do not hesitate to reach out to us at legal@croo.co if you have any questions.

Croo (“Croo,” “us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of our website, croo.co (the “Website(s)”), applications (“Apps”) and other products, services and features thereof (the Website, the Apps and such other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of Croo). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal data we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will collect, use and disclose your personal data.

What information does the application obtain and how is it used?

Personal data including, for example, your name, telephone number, data about your usage of the Products, data you provide in connection with your usage of the Products, and data collected by tracking technologies as further described in section 4 below that may identify you as an individual or allow online contact with you as an individual.

When you choose to invite friends and family to become part of your 'Croo', we will ask you for their phone number. We will use this data to invite him, her or them to join the App. We store this data for the sole purpose of sending invitations and confirming Croo member status. If your Croo member would like us to delete their data, they can do so by deleting their account from the settings page.

Croo does not collect or process credit or debit card (“Payment Card”) data. Apple and Google collect Payment Card data with respect to in-app purchases made through the Apps, and our payment processor collects Payment Card data with respect to purchases made through the Websites. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they've stored, and your card's type, expiration date, billing address, and the last four digits of your card number.

We will collect and store your responses to both the Daily Check In questionnaire. All the information you need to fill in the open text fields during account registration is mandatory. Any failure to complete that information or any response Croo considers abnormal may result in Croo refusing (or being unable) to process your request. You agree that the personal data you provide about yourself or 'Croo' members will be current, accurate, complete and unequivocal.

Security

The security of your personal data is important to us. We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal data, you can contact us at info@croo.co. Except as described under the “Disclosure of Your Data” section below, we do not provide your personal data to any third party without your specific consent, as defined by applicable law.

Analytics

Croo and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don't have to provide the same data several times during one task, to recognize that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how people are using the Products.

We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our Website. Our third-party partners may use technologies such as cookies to gather data about your activities within the Products to deliver such advertising to you, such as retargeting ads. We are not always able to respond to do-not-track signals. For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioural advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third-party platforms. You may also opt-out of receiving ads across devices by adjusting your ad preference in your Google account.

We use third-party trackers to let us know when users have visited the Products by “clicking-through” our sponsored advertising or content hosted on third-party platforms. The Products use Google Analytics code to gather statistical data. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more data on how Google Analytics processes this data, visit www.google.com/analytics.

We will acquire consent from you in order to use such trackers to the extent required by applicable law. For more information on the types of cookies used by Croo and your ability to restrict the behaviour of cookies or disable them in your browser's settings, please refer to the Croo Cookie Policy.

Mobile Analytics

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.

Where we store your personal data

All data you provide to us through the Products is stored on our secure AWS which are deployed in Sydney, Australia. This is subject to change. Any payment transactions will be encrypted using SSL technology; all payment data is stored with our payment processor and is never stored on Croo's servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.

Unfortunately, the transmission of data via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Products; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

Backup

We advise our users to regularly back up their data. Our users can choose to manually export the backup file and store it wherever they want or they can optionally make cloud backups. The cloud backups are kept in users' private cloud space where we have no access.

Android Google Drive Backups

Android users can optionally backup their data using Google Drive. Their backups are stored in their private Google Drive space and count against their quota. We use a secure connection to your Google Account and data is safely stored in a folder where we nor other apps have access. View Google Privacy Policy at https://www.google.com/policies/privacy/

The email and name permissions within the Android are requested in order to display the account details within the app to inform users about the account which is being used for the backups. The app does not keep email addresses and names within the app. The app asks Google Sign In for a connected account and displays the account info only when accessing the Backup section. Even if the user agreed to anonymous analytics data collection your email address or name is never sent with the analytics data.

iOS iCloud Backups

iOS users can optionally backup their data using iCloud Drive. Their backups are stored in their private iCloud Drive space and count against their quota. iCloud secures your information by encrypting it when it's in transit, storing it in iCloud in an encrypted format, and using secure tokens for authentication. For certain sensitive information, Apple uses end-to-end encryption. This means that only you can access your information, and only on devices where you're signed into iCloud. No one else, not even Apple, can access end-to-end encrypted information. You can find out more about iCloud security and privacy overview at https://support.apple.com/en-us/HT202303

Use of data

We use information held about you in the following ways:

  • To provide you with the Products.
  • To answer your questions or requests for information or handle your complaints.
  • To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other devices.
  • To carry out our obligations arising from any agreements entered into between you and us.
  • To allow you to participate in interactive features of the Products, when you choose to do so.
  • To notify you about updates or changes to Product features and content.
  • To understand your broad geographic location that might help us recommend the right experiences to you and your croos.
  • To inform Partners about your registration and use of the Products as described under Corporate and Other Community Sharing in section 6 above.
  • To serve our advertisements to you through third-party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law.

Data Retention

The retention periods applied by Croo comply with applicable legislation in effect on the date hereof, namely:

  • For data relating to your account: such data will be permanently and irrevocably anonymized in the event that your account is inactive for a period of one year.
  • For transactional data relating to your purchases: such data is kept for the entire period of the contractual relationship, then in accordance with legal obligations and applicable statute of limitation periods. Please note that this data does not include Payment Card information, which is processed by our third-party payment processors, and not Croo.
  • When your data are collected in the context of requests/queries: such data are kept for the period necessary to process and reply to such requests or queries.
  • When cookies or other trackers are placed on your terminal, they are kept for a period of 12 months. Other data will be kept as long as necessary for the purposes pursued and in compliance with our legal obligations, including the applicable statute of limitations.
  • We do NOT sell or rent your personal information to any third parties for their own advertising or marketing purposes.

Withdrawal of consent for processing activities

To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing legal@croo.co.

Links to third party sites

The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal data to these external websites.

Use of croo by minors

You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement of a parent or legal guardian under such person's account.

Photos

Your photos are stored locally on your phone in our app's storage. Photos you upload are uploaded into our storage in AWS/cloud for them to be accessed by the person you share with. We don't offer back up services and we have no access to your photos.

Changes

We reserve the right, at our sole discretion, to modify or replace this Policy at any time. Any changes we may make to our privacy policy in the future will be posted on this page. You should check this page from time to time and take note of any changes.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will permanently and irrevocably anonymize your personal information, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the Australian Privacy Act 1988.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: Emailing us at info@croo.co.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. We also provide an easy-to-view snapshot of your personal information that we have processed via the “My Data” tab in the Products.

Response timing and format

Upon receiving a request for access, portability, or deletion, we will confirm receipt of the request within ten (10) days and provide information about our verification process and how we will process the request.

We endeavour to respond to a verifiable consumer request within fifty (50) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response to the email address associated with the account for account holders, and to the email address provided with the request submission for non-account holders.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily readable and useable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Contact

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at info@croo.co.