Effective Date: March 23, 2021 (Updated!)
Crossbeam, Inc., together with its affiliates (“Crossbeam”, “we”, “our” or “us”), is committed to transparency in our collection and processing of information of our customers, prospects, and website visitors (“you”). This Privacy Policy describes how we collect, use, disclose and protect information from and about you through our website https://www.crossbeam.com/, any other website or mobile application that links to this Privacy Policy (the “Site”), and any other interactions (e.g., customer service and other communications) that you may have with Crossbeam (collectively, the “Offerings”).
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE OFFERINGS.
California users: Click here to see our Privacy Information for California Users
SCOPE OF THIS PRIVACY POLICY
For purposes of this Privacy Policy:
● A “Customer” means an entity that has entered our Terms of Service, Master Cloud Agreement or other customer agreement with Crossbeam (a “Customer Agreement”) to access our products or solutions (our “Products”).
● A “User” means an individual who accesses our Products as or on behalf of a Customer, including Customer personnel.
● A “Site Visitor” means an individual who visits our Site outside of the context of our Customers’ use of the Products.
This Privacy Policy applies to our handling of information about:
● Site Visitors.
● Prospective Customers and their personnel.
● Current Customers and Users, but only in relation to their procurement of our Products and management of their relationship with Crossbeam.
We refer collectively to these categories of individuals as “you” throughout this Privacy Policy.
This Privacy Policy does not cover any data, content or materials that a Customer (including its Users) submits to the Products (“Customer Data”). As it relates to any “personal information” or “personal data” included in Customer Data, the Customer is the “data controller” or “business,” and Crossbeam processes such information on the Customer’s behalf as a “data processor” or “service provider” (or similar terms defined in applicable data protection laws). Crossbeam’s obligations with respect to Customer Data are set forth in the applicable Customer Agreement and not this Privacy Policy.
If you have questions about how your information is collected and processed through the Products, please contact the Customer who has provided your information to us for more information.
THE INFORMATION WE COLLECT
We collect, store and use certain information from or about you for the purposes described below.
1. INFORMATION YOU PROVIDE TO US
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
● When you register for an account with us
● Your use of the Offerings
● Requests or questions you submit to us via online forms, email, or otherwise
● When we reach out to you by phone or email in our sales and marketing efforts
● Your participation in surveys, sweepstakes, or contests
● When you communicate with our customer service teams via email, phone, or chat
● When you attend our conferences or events or interact with us at other conferences or events
The types of data we collect directly from you include:
● First, middle, and last name
● Email address
● Postal Address
● Telephone number
● Online account or screen name
● Your company or organization name
● Your title
● Your public, social profile links
● Any other information you choose to directly provide to us in connection with your use of the Offerings
We may also collect and store any data and related output created, derived or generated by you through the use of the Offerings, as well as your search history and Offerings usage. If you are a Customer, we may also collect and store technical logs, data and learnings about your use of the Products (which, for clarity, do not include the Customer Data that you submit).
2. INFORMATION WE COLLECT THROUGH AUTOMATED MEANS
When you use our Offerings, we and our service providers (who are third parties that perform services on our behalf) automatically collect certain information about your device and how you use the Offerings, including your IP address, browser type, browser language, operating system, the state or country from which you accessed the Offerings, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Offerings, error logs, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).
To collect this information, we and our service providers may also make use of “cookies” or similar tools that track, measure, and analyze the behaviors and usage patterns of our users. Cookies are small data files that can be stored on your browser and device so we can recognize you when you return. We use cookies for analytics purposes, to deliver certain features of the Offerings, to help us understand how users engage with the Offerings, and to improve your experience. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. However, if you elect not to accept cookies, some functionality and areas of the Offerings may be restricted. To learn how to manage your cookies, please follow the instructions from your specific browser, or if accessing the Offerings via a mobile device, refer to the manufacturer’s instructions.
3. INFORMATION WE COLLECT FROM OTHERS
From time to time we may collect information about you from other sources, including marketing vendors, survey providers, data enhancement services, social media, conferences, and other industry events or other purposes that we explain to you at the time of collection, to the extent permitted by applicable law. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and provide more relevant experiences for you and improve our Offerings, analytics, and advertising.
4. INFORMATION WE COLLECT FROM SOCIAL MEDIA AND OTHER CONTENT PLATFORMS
If you access the Offerings through a third-party connection or log-in (e.g., through a social network), you may allow us to have access to and store certain information from your profile on that third-party service. This may include your name, gender, profile picture, user name, age range, language, country, friends list, and any other information stored with such service that you permit the social network to share with third parties. The data we receive is dependent on your settings on such service. If you do not wish to have this information shared, do not use a third-party connection to access the Offerings. For a description on how third parties such as social networking sites handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.
When you “like” or “follow” us on Facebook, Instagram, Twitter or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us.
HOW WE USE YOUR INFORMATION
We use your information for various purposes depending on the types of information we have collected from and about you, in order to:
● Provide you with access to and to administer our Products and Offerings
● Respond to your requests for information and provide you with more effective and efficient customer service
● Contact you by email, postal mail, or phone with news, updates, information, promotions, surveys or contests relating to our Products or Offerings or other services that may be of interest to you, in accordance with applicable legal requirements related to such communications
● Customize the content you see on our Offerings
● Help us better understand your interests, and improve our Products and Offerings
● Secure our Offerings and resolve technical issues being reported
● Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
● Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others
Aggregate/De-Identified Information. We may aggregate and/or de-identify any information collected through our Offerings so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, partners, and sponsors.
LEGAL BASES FOR USE OF YOUR INFORMATION
The legal bases for using your information as set out in this Privacy Policy are as follows:
● Where we need to perform the contract we are about to enter into or have entered into with you for the Offerings
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
● Where we need to comply with a legal or regulatory obligation in the EU
● Where we have your consent to process your information in a certain way
ONLINE ANALYTICS AND ADVERTISING
ANALYTICS. We may use third-party web analytics services (such as those of Google Analytics) on our Offerings to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
ONLINE ADVERTISING. In using the Offerings, we allow select third party advertising technology partners to place cookies or other tracking technologies on the browser of your device to collect information about you as discussed above. These third parties (e.g., ad networks and ad servers such as Google, Facebook, and others) may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that if you use these mechanisms, you may still see advertising on our Offerings or across the Internet, but it will not be tailored to you based on your online behavior over time.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Offerings for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.
HOW WE SHARE AND DISCLOSE YOUR INFORMATION
We will share your information in the following ways:
● Service Providers. We provide access to or share your information with select third parties who help us deliver or improve our Products and Offerings or perform services on our behalf, including billing and credit card verification, advertising and marketing, Offerings content and features, analytics, research, customer service, shipping and fulfillment, data storage, security, fraud prevention, and legal services.
● Your Company. If you are a User, we may provide your information to the company you are engaged or employed by in order to fulfill and enforce our Customer Agreement with your company, and to inform your company regarding usage, support, or training needs.
● Our Partners. We may share your information with our partners that offer products and services either in connection with our Offerings or separately that we think would be of interest to you. If you do not want us to share your information for these purposes, please click on this link.
● Testimonials. We may display personal testimonials and endorsements of satisfied customers on the Offerings, and with your consent, will associate your name or your company’s name with such postings.
● Protection of Crossbeam and Others. By using the Products or Offerings, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by applicable law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce any contracts with you, including our Customer Agreement; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of Crossbeam, its agents and affiliates, its users and/or the public.
● Business Transactions. In accordance with applicable legal obligations, your information may be provided to third parties in connection with a merger or acquisition (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Crossbeam or our assets, or as part of a corporate reorganization or stock sale or other change in corporate control or fundamental business change, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
● Aggregate/De-Identified Information. From time to time, we may share Aggregate/De-identified Information about use of the Offerings or our user base with partners and others, but such information will not identify you personally.
● Otherwise with Your Consent or at Your Direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you consent to or direct such sharing.
RETENTION OF YOUR INFORMATION
We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
YOUR RIGHTS AND YOUR CHOICES
You have certain rights with respect to your information as further described in this section.
1. YOUR LEGAL RIGHTS
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Information” section below at any time. Your local laws (e.g., if you are a citizen or resident of the European Economic Area or California) may permit you to request that we:
● provide access to and/or a copy of certain information we hold about you
● update information which is out of date or incorrect
● delete certain information that we are holding about you
● restrict the way that we process and disclose certain of your information
They may also permit you to revoke your consent for the processing of your information.
We will consider all requests and provide our response within the time period stated by applicable law and as otherwise required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. To submit a request, please contact us at privacy@crossbeam.com or use the form available at this link.
If your information has been collected by or submitted to Crossbeam as a result of our Customer’s use of our Products, Crossbeam collects and processes such information under the directions of the relevant Customer pursuant to its Customer Agreement with Crossbeam. If these circumstances apply to you and you wish to access, edit, delete or exercise any rights you may have under applicable data protection laws with respect to any such information that we have collected about you, please direct your query to the relevant Customer, as this may expedite the completion of your request. We nevertheless provide reasonable assistance to our Customers to give effect to data subject rights as appropriate and required by applicable laws.
2. MARKETING COMMUNICATIONS
If, in accordance with applicable legal requirements, we send you marketing communications regarding our Offerings, or the services of third parties that we believe will be interesting to you, you can ask us to stop sending such communications at any time by contacting us using the information in the “Contact Information” section below at any time. In our marketing email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain transactional emails from us, such as those confirming your requests or providing you with updates regarding our Privacy Policy or other terms.
THIRD PARTY LINKS AND FEATURES
Our Offerings may contain links to third-party websites. If you choose to visit these sites and use their services, please note that we are not responsible for their content or privacy practices. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites, and not this Privacy Policy. We urge you to read the privacy policies of these third parties.
CHILDREN’S PRIVACY
The Offerings are intended for general audiences and not for children under the age of 13. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete it as soon as possible. We also do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.
INTERNATIONAL USERS
Your information is maintained and processed by us and our third-party service providers in the United States, and may also be maintained, processed, and stored in other jurisdictions that may have different data protection laws than those in your country of residence. In the event that your information is transferred in these ways, please note that we comply with applicable legal requirements governing the transfer of information across borders.
Crossbeam Privacy Shield Statement For EU and Swiss Personal Data
Crossbeam complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the European Union and Switzerland transferred to the United States, respectively. Crossbeam has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
Contact Crossbeam and Recourse. Crossbeam is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to its compliance with the provisions of the EU-US and Swiss-US Privacy Shield.
In compliance with the Privacy Shield Principles, Crossbeam commits to resolve complaints about your privacy and our collection or use of your personal data pursuant to the Privacy Shield. If you have any questions about this Privacy Policy or our compliance with the Privacy Shield Principles, please contact us at privacy@crossbeam.com or write to: Privacy Department, Crossbeam, Inc., 1315 Walnut Street, Suite 300, Philadelphia, PA 19107. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
In the event that you are concerned about how personal data you have provided to Crossbeam has been used, please address your inquiry or complaint first to us at the address listed above. Crossbeam takes all concerns about privacy and use of personal data very seriously, and shall endeavor to reply to you within 45 days of receiving a complaint.
Crossbeam has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction/.
We are aware of the July 16, 2020 decision from the European Union Court of Justice which invalidated the EU-US Privacy Shield. Nonetheless, we will continue to abide by the Privacy Shield Principles with respect to the protection of personal data. Crossbeam is closely monitoring developments and guidance from both European and U.S. regulatory authorities and will update this privacy policy as needed.
HOW WE PROTECT YOUR INFORMATION
Crossbeam takes a variety of technical and organizational security measures to protect the information provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to us online.
PRIVACY INFORMATION FOR CALIFORNIA USERS
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
A. Categories of Personal Information We Collect and How We Use Them.Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect and how we use each category of personal information. The categories we collect are:
|
Category of Personal Information |
How We Use this Personal Information |
|
Contact Information (such as your full name, phone number, address, email address) |
● Provide the services and respond to your requests ● Contact you with relevant information and offers ● Customize content, and analyze use of and improve the services ● Comply with law or defend our legal rights ● Security/fraud prevention ● Create aggregate/de-identified information |
|
Login Information (such as your account name and password) |
● Provide the services and respond to your requests ● Comply with law or defend our legal rights ● Security/fraud prevention ● Create aggregate/de-identified information |
|
Financial Information (such as credit card information if you make a purchase) |
● Provide the services and respond to your requests ● Comply with law or defend our legal rights ● Security/fraud prevention |
|
Professional or Employment Information (such as the name and address of the company you work for and your title) |
● Provide the services and respond to your requests ● Contact you with relevant information and offers ● Customize content, and analyze use of and improve the services ● Comply with law or defend our legal rights ● Security/fraud prevention ● Create aggregate/de-identified information |
|
Device and Online Information (such as mobile device content, IP address, browsing history, and usage information) |
● Provide the services and respond to your requests ● Contact you with relevant information and offers ● Customize content, and analyze use of and improve the services ● Comply with law or defend our legal rights ● Security/fraud prevention ● Create aggregate/de-identified information |
|
Other information (any other information you choose to provide directly to us) |
● Provide the services and respond to your requests ● Contact you with relevant information and offers ● Customize content, and analyze use of and improve the services ● Comply with law or defend our legal rights ● Security/fraud prevention ● Create aggregate/de-identified information |
Do Not Sell Rights.Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. As discussed above, we may share your information with our partners that offer products and services either in connection with our Offerings or separately that we think would be of interest to you. To opt out of our sharing of your information in this way, please click here.
B. Your California Privacy Rights. The CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:
● Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
● Provide access to and/or a copy of certain personal information we hold about you.
● Delete certain personal information we have about you.
● Provide you with information about the financial incentives that we offer to you, if any.
The CCPA further provides you with the right not to be discriminated against (as provided for in applicable law) for exercising your rights. Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Service to you. We also will take reasonable steps to verify your identity before responding to a request. In doing so, we may ask you for verification information so that we can match at least two verification points with information we maintain in our files about you. If we are unable to verify you through this method, we shall have the right, but not the obligation, to request additional information from you. If you would like further information regarding your legal rights under California law or would like to exercise any of them, or if you are an authorized agent making a request on a California consumer’s behalf, please contact us as follows:
Information Access and Data Deletion: https://preferences.crossbeam.com/privacy/
By Email: privacy@crossbeam.com
Shine the Light Disclosure: The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. Requests may be made once a year and are free of charge. If you are a California resident and would like to make such a request, please email us at privacy@crossbeam.com or write to: Privacy Department, Crossbeam, Inc., 1315 Walnut Street, Suite 300, Philadelphia, PA 19107.
NOTICE TO NEVADA RESIDENTS
Certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us using the methods outlined in the “Contact Information” section. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
CHANGES TO OUR PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, or advances in technology. We will make the revised Privacy Policy accessible on the Offerings, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Offerings, you are confirming that you have read and understood the latest version of this Privacy Policy.
CONTACT INFORMATION
Crossbeam welcomes your comments and questions regarding this Privacy Policy and the collection and use of your information. If you have questions or concerns, please email us at privacy@crossbeam.com, or write to: Privacy Department, Crossbeam, Inc., 1315 Walnut Street, Suite 300, Philadelphia, PA 19107.