As of 01-01-2020
This Policy applies to all of our operating divisions, subsidiaries, affiliates, and branches, including its U.S. affiliates certified under the Privacy Shield and any additional subsidiary, affiliate, or branch that we may subsequently form.
The categories of personal information we collect depend on whether you are a client, a customer of our client (“client customer”), a website user, applicant or visitor, and the requirements of applicable law.
When we engage a new client, we collect name and business contact information.
We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, apply for a job or otherwise communicate with us.
We collect client customer data, including but not limited to, names, demographic information, location information (e.g., city or zip code) and campaign interactions. We request that our clients hash, aggregate or otherwise de-identify client customer data before providing it to us.
We may collect certain information automatically from users who visit our website. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
We may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you.
We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/ . You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. .
We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, and email. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
We use your information for a variety of business purposes, including to:
We may use technologies considered automated decision making or profiling. We will not make automated decisions about you that would significantly affect you, unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to use such technology. You may escalate any concerns you have by contacting us below.
We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the data controller) who has contracted with us to use the Service to process this data. Our clients control the personal information in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to our clients to address any concerns you may have, in accordance with the terms of our contract with them. For a list of our sub-processors, contact us as described below.
The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
Except as provided below, we do not share personal information. For a list of the categories of personal information we have disclosed for a business purpose in the past 12 months, please refer to the categories of personal information page. We have not sold personal information in the preceding 12 months.
We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.
We may provide personal information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
We may share personal information with our affiliated companies.
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
With respect to onward transfers to agents under Privacy Shield, Privacy Shield requires that we remain liable should our agents process personal information in a manner inconsistent with the Privacy Shield Principles.
Additionally, we may protect information through other legally valid methods, including international data transfer agreements.
You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. Further details can be provided upon request.
You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use non-personal information regarding your activities on our Services and for other legal purposes as described above.
We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp , http://www.youronlinechoices.eu/ , https://youradchoices.ca/choices/ , and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice. Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
In accordance with applicable law, you may have the right to:
If you would like to exercise any of these rights, please contact us at email@example.com. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
The Services are not directed to children under 17 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
In addition, we have agreed to refer unresolved complaints related to personal information to Insight Association Privacy Shield Dispute Resolution Program and, with respect to employee and human resources data, has committed to cooperate with the panel established by local data protection authorities and comply with the advice given by the panel for EU and UK citizens and with the Swiss Federal Data Protection and Information Commissioner’s authority and advice for such data of Swiss citizens. For more information and to submit a complaint regarding Individual data to Insight Association, a dispute resolution provider which has locations in the United States and EU and UK, visit Insight Association Privacy Shield Program.
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Crossing Minds Inc at:
Emile Contal, CTO
22 Rausch Street, Unit B, 94103 San Francisco CA
Crossing Minds Inc has further committed to refer unresolved Privacy Shield complaints to Fenwick & West LLP, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit Fenwick & West website for more information or to file a complaint. The services of Fenwick & West LLP are provided at no cost to you.
Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your UK or EU Member State.
You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield. For additional information, see the Privacy Shield website introduction. The FTC has jurisdiction over our compliance with the Privacy Shield.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Crossing Minds, Inc.
22 Rausch Street, Suite B
San Francisco, CA 94103