Privacy Policy

1 About this Privacy Policy

This privacy policy applies when you visit or use our website, apps, and other services (each, a “Service”). This privacy policy may be supplemented by additional privacy statements, terms, or notices provided to you. The CRE Debt Project Ltd. company that owns or administers the Service, as identified therein, is the primary controller of your personal information provided to, or collected by or for, the Service.

2 Information We Collect

We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies.

2.1 Data You Provide to Us

The types of personal information that we collect directly from you depend on your interest in the Service and may include:

Contact details, such as your name and work email address, postal address, and phone number;
Account login credentials, such as usernames and passwords, password hints, and similar security information;
Other account registration and profile information, such as educational and professional background, and photo;
Payment information, such as a credit or debit card number;
Comments, feedback, and other information you provide to us, including search query data and questions or information you send to customer support, and/or
Interests and communications preferences, including preferred language.

2.2 Data From Your Organisation

We may obtain information about you from the organisation with which you are employed or affiliated to activate and manage your access to and use of the organisation’s subscription to the Service, including:

Contact details, such as your name and work email address, post address, and phone number;
Other account-related information, such as job title, and/or
Organisational user ID

2.3 Data From Other Sources

We also may obtain contact details and other information about you from our affiliates and from other third parties, including:

Service providers that help us determine a location in order to customise certain products to your location.
Partners with which we offer co-branded services or engage in joint marketing activities; and/or
Publicly available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

2.4 Data From Service Use

The Service may automatically collect information about how you and your device interact with the Service, including:

Computer, device, and connection information, such as IP address, browser type and version, operating system, and other software installed on your device, mobile platform, and unique device identifier, and other technical identifiers, error reports, and performance data;
Usage data, such as the features you used, the settings you selected, your URL clickstream data, including data and time stamp, referring and exit pages, and pages you visited on the Service; and/or
For location-aware Services, the region, city, or town where your device is located provides you with more relevant content for where you are in the world.

We collect this data through our servers and the use of cookies and other technologies. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, log in, or access parts or make full use of the Service. For more details, view the cookie notice of the Service.

3. How We Use Your Information

Depending on how you interact with the Service, we use your personal information to:

Provide, activate, and manage your access to and use of the Service;
Process and fulfill a request, order, download, subscription, or other transaction;
Provide technical, product, and other support to help keep the Service working, safe, and secure;
Enhance and improve the Service and our other products and services, and to develop new products, services, and benefits;
Offer you customised content and other personalization to make the Service more relevant to your interests and geography;
Respond to your requests, inquiries, comments, and concerns;
Notify you about changes, updates, and other announcements related to the Service and our other products and services;
Deliver targeted advertisements, promotional messages, notices, and other information related to the Service and your interests;
Provide you with promotional messages and other information about products, events, and services of ours, our affiliates, and third parties such as sponsors;
Invite you to participate in user testing and surveys as well as sweepstakes, competitions, and similar promotions;
Identifying usage trends and developing data analysis, including for purposes of research, audit, reporting, and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance, or in other ways pursuant to a customer agreement; and/or
Comply with our legal obligations, resolve disputes, and enforce our agreements

If you are an administrator of an organization with a subscription to the Service, we will use your details to communicate with you about your organization’s subscription and related services. If you supply us with the contact information of your colleagues, we may contact those individuals with communications about the Service that may include a reference to you.

4. Sharing of Your Information

4.1. Your Organisation

If you access the Service through a subscription administered by your organisation, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorised by your organisation for usage analysis, subscription management and compliance, cost attribution, and departmental budgeting.

4.2 Application Licensor

If you access a third-party application on the Service through a license agreement with the licensor of that application, personal information relevant to that application will be shared with the licensor so that it can provide you access to the application, subject to the terms of its license agreement and privacy policy.

4.3 Your Choices

We share your personal information with our affiliates and with sponsors, joint venture partners and other third parties, including entities for which we are acting as an agent, licensee, application host our publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices in managing your communications preferences and other settings.

The Service may let you post and share personal information, comments, materials, and other content.

Any such contributions you disclose publicly may be collected and used by others, may be indexed by search engines, and might not be able to be removed. Please be careful when disclosing personal information in these public areas.

4.5 For Legal Reasons

We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

Meet any applicable law, regulation, legal process, or other legal obligation;
Detect, investigate, and help prevent security, fraud, or technical issues; and/or
Protect the rights, property, or safety of CRE Debt Project Ltd., our users, employees, or others;
And as part of a corporate transaction, such as a transfer of assets or an acquisition by or merger with another company.

5. Your Communications Preferences

You can customize and manage your communications preferences and other settings when you register with the Service, by updating your account features and preferences, by using the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

6. Accessing and Updating Your Information

6.1 Your Account

The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is solely the responsibility of the user. Registered users may also close their accounts directly through the Service or by contacting the Service’s customer support.

6.2. Your Rights

You have the right under privacy and data protection laws, as may be applicable, to request free of charge:

Access to and correction or deletion of your personal information;
Restriction of our processing of your personal information, or to object to our processing; and
Portability of your personal information.

If you wish to exercise any of these rights, please contact us.

We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.

Access to personal information that CRE Debt Project Ltd. gathers from public records and other sources to supply to organisations is subject to applicable laws and our processing notices.

7. Data Retention

We retain your personal information for as long as necessary to provide you the Service and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Service through a subscription administered or sponsored by your organization, we retain your organizational contact details after the termination of your organization’s subscription to continue to communicate with you.

8. Children’s Privacy

We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.

9. Data Security

We use a variety of administrative, physical, and technical security measures to help safeguard your personal information.

CRE Debt Project Ltd. undertakes to comply with its duty to maintain the secrecy and confidentiality of personal data as provided by applicable law, as well as to provide them with secure processing in international data transfers and assignments, where appropriate.

In those services of the Website that require registration as a User, a password must be chosen. The User is responsible for maintaining the confidentiality of this password, as well as for all activities that occur during the session initiated with his/her name and password.

The User agrees to notify CRE Debt Project Ltd. as soon as possible of any unauthorized use of its User name and/or password or any other breach of security. CRE Debt Europe Ltd. will not be liable for any damage or loss that may arise due to the User's failure to comply with this obligation.

10. Locations of Processing

Your personal information may be stored and processed in your region or another country where CRE Debt Europe Ltd. affiliates and our service providers maintain servers and facilities, including (but not limited to) Australia, Brazil, France, Germany, Iceland, Israel, India, Italy, Ireland, the Netherlands, the Philippines, Singapore, South Africa, the United Kingdom, Spain and the United States. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of the protection required under applicable law.

11. Grounds for Processing

When we collect from you any personal information within the scope of European data protection laws, we do so:

Where necessary to provide the Service, fulfill a transaction, or otherwise perform a contract with you or at your request before entering into a contract;
Where necessary for our compliance with applicable law or other legal obligations;
Where necessary for the performance of a task carried out in the public interest;
Where applicable, with your consent; and/or
As necessary top operate our business, protect the security of our systems, customers and users, detect or prevent fraud, enable our customers to comply with legal obligations, or fulfill our other legitimate interests as described in the “Information We Collect”, “How We Use Your Information” and “Sharing of Your Information” clauses above, except where our interests are overridden by your privacy rights.

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

12. Changes

We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

13. Contact

If you have any questions, comments, complaints, or requests regarding this privacy policy or our processing of your information, please contact us online or in writing:

Data Protection Officer, nicole@credebteurope.com

CRE Debt Project Ltd., registered number 16914472,

Richford Street 62a,

London,

W6 7 HP,

You may also complain to the data protection authority in the applicable jurisdiction.