CrossVista Privacy Policy

March 23, 2020

This Privacy Policy explains how CrossVista Inc. (“CrossVista”) collects, uses and shares your information. The protection of your privacy and personal data is an important matter for us. To ensure a high level of transparency and security, our privacy statement as set forth below will inform you about the nature, scope and purpose of any collection, use and processing of personal data recorded by us. This Privacy Policy applies to information we collect when you use our websites, mobile applications, customer support portals, and other online products and services (collectively, the “Services”) or when you otherwise interact with us, including when you attend events hosted or attended by CrossVista and when you contact us for customer support.  This CrossVista Privacy Policy does not apply to the information processed by CrossVista on behalf of its customers via the Services.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our website homepages or sending you an email notification) or otherwise seek additional consent in accordance with applicable law.  We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

Technical and Organizational Data Protection

CrossVista implements the technical and organizational measures that are commercially reasonable in relation to the respective purpose of data protection, in order to protect the information provided by you against abuse and loss. Such data is stored in a secure operating environment that is not accessible to the public. In addition, each of our employees is instructed on data protection and obliged to enter into a confidentiality agreement.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us.  For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, register for an event or an online course, make a purchase, apply for a job, request customer support or otherwise communicate with us.  The types of information you may choose to provide include your name, email address, postal address, phone number, fax number, payment information, gender, information about your company and current position, and employment history.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect the following information about you:

• Log Information:  We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
• Device Information:  We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
• Location Information:  We may with your consent collect information about the location of your device each time you access or use one of our mobile applications.  For more details, please see “Your Choices” below.
• Information Collected by Cookies and Other Tracking Technologies:  We use various technologies to collect information, and this may include sending cookies to your computer or mobile device.  Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits.  We may also collect information using web beacons (also known as “tracking pixels”).  Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.  For more information about cookies, and how to disable them, please see “Your Choices” below.

Information We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through our Services.  For example, if you connect a CrossVista account with your social media account, we may have access to certain information from the company that owns or operates the social media account in accordance with the authorization procedures determined by such social media company.  Additionally, CrossVista may receive information about you from other third parties whom you have authorized to share your information or who collect information in connection with co-branded offerings.

Use of Information

CrossVista collects, processes, and uses your personal data to the extent required to fulfill the respective purpose or for purposes which you have consented to including:

• Provide, maintain and improve our Services;
• Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by CrossVista and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage and activities in connection with our Services;
• Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
• Process and deliver contest entries and rewards;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose for which the information was collected, and which is necessarily contemplated by the collection of such information or is otherwise explicitly mentioned in the process of collection.
• Moreover, the information provided to us may be combined with data on you that has already been stored by us. Such data combination allows us to keep the data collected by us updated, in order to provide for the accuracy of the collected information and to optimize our service to you.
• Beyond these purposes, we use and process your data only if you have expressly granted your prior consent thereto and if you have been informed about such purposes. Thus, for example, you may stipulate in an online job application whether we may also review such application with respect to other positions in our company. Only if this is the case, we will use such data for the respective purpose.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• In connection with a joint marketing campaign, seminar, CrossVista product offering or a product or service offered by CrossVista in conjunction with a third party, we may share your information with any third parties participating in such offering and such parties may use this information for their direct marketing purposes.  Please see “Your Rights to Information about Sharing” below for more information about this sharing.
• With resellers of CrossVista products and services or with sellers of products and services complementary to CrossVista products and services, in order to pursue sales opportunities and for other direct marketing purposes.  Please see “Your Rights to Information about Sharing” below for more information about this sharing.
• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
• In response to a request for information if we are required by, or believe disclosure is required by, any applicable law, regulation or legal process, including in connection with lawful requests by law enforcement, national security, or other public authorities;
• To protect the rights, property and safety of CrossVista or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Data Protection for Minors

The offers and services on this website are not directed at children. We therefore assume that we will not become aware of any personal data pertaining to children.

Social Sharing Features

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media and vice versa.  The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.  For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Advertising and Analytics Services Provided by Others

We allow others to serve advertisements on our behalf across the Internet and to provide analytics services on our behalf.  These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information.  This information may be used by CrossVista and these entities to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.  This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies. For more information about interest-based ads, or to opt out of having your web browsing information used in this way, please visit www.aboutads.info/choices.

Security

CrossVista takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Access Rights

If you are a resident of a country that provides you with the right to request a copy of the personal data CrossVista holds about you and/or to correct any inaccuracies within such data, and CrossVista is required by applicable laws to respond to such requests, then you may address such requests to the contact information provided in the “Contact Us” section below.  CrossVista will use reasonable efforts to supply, correct or delete information that we hold about you or to advise you if we are not required by applicable laws to comply with such requests.

Account Information

If you have registered for an account via our Services, you may update, correct or delete your account information by logging into your online account.

Location Information

Some of our mobile applications collect precise geolocation information from your mobile device.  Prior to collecting such information, you will be asked to consent to the application’s collection of this information.  If you initially consent to our collection of location information, you may be able to subsequently stop the collection of this information through your device operating system settings.  You may also stop our collection of location information by following the standard uninstall process to remove our mobile applications from your device.

Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications

You may opt out of receiving promotional communications from CrossVista by following the instructions provided in those communications or by sending an email to unsubscribe@crossvista.com.  If you email us to unsubscribe from our commercial email messages, please include the word “UNSUBSCRIBE” in the email subject line.  Please note that if you opt out of receiving promotional communications, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Your Rights to Information about Sharing

Residents of certain states and residents of certain international countries may request certain details, pursuant to applicable laws, about how their information is shared with third parties for direct marketing purposes.  If you are a resident of one of these jurisdictions, and would like to make such a request, please contact us at privacy@crossvista.com.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

CrossVista Inc.
Attn: Privacy & Data Protection Officer
99 Derby Street, Suite 200
Hingham, MA 02043 U.S.A.
Fax: +1.847.745.0132
privacy@crossvista.com