Last Modified: September 13, 2018
For the purposes of EU data protection laws ("Data Protection Law"), Crossbeam is data controller of the information collected from visitors via the Site and where we process basic contact details of our Corporate Customers for the purposes of entering into a contract with those Corporate Customers.
We collect personal information from our Site visitors in order to provide you with a personalized, useful and efficient experience and we collect personal information from our Customers to provide them with our Services. The categories of information we collect can include:
"Corporate Customer Content" and "End-User Content" to be referred to collectively as "User Content".
Please note that User Content is published on our Site, but will only be viewable by other users with whom you have formed connections or when you have designated it as public content. Additionally, we collect information that you may upload through the Site or push through to us through our API or through the API of one of our third party service providers (“Business Content”).
When Site visitors and our Corporate Customers' end-users interact with our Site through various social media, such as when they share Crossbeam content on LinkedIn, Google or other sites, or when Corporate Customers login through your LinkedIn or Google account, we may receive information from the social network including without limitation, profile information, profile picture, gender, user name, user ID associated with that social media account, age range, language, country, friends list, and any other information which the Site visitors or Corporate Customers permit the social network to share with third parties. The data we receive is dependent upon privacy settings with the social network. Please review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Site or Service.
Customers, Crossbeam may access their contact list available on their systems, email accounts, or in Google or LinkedIn accounts so that they can locate contacts on the Service and invite those contacts to connect with our Service. Crossbeam obtains an individual's permission via an opt-in onboarding process within the Service. When we send the invitation to those contacts to join the Service, we will include the Corporate Customer's name, business and photo to let them know the identity of the person extending the invitation. After sending these invitations, we may also send reminder emails to those invitees on behalf of the Corporate Customer, which may also include the Corporate Customer's name, business and photo. We will store these contacts for purposes of alerting the Corporate Customers when those contacts join the Service at a later time so that Corporate Customers may connect with them on the Service, solely to the extent that such contacts have not opted out of this feature. Please note that there is an option for Corporate Customers to opt-out within the Service.
We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also send you Service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Service, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Control Over Your Information” below.
In the EU, the purposes for which we process your personal data are:
Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.
We, and our third party partners, automatically collect certain types of usage information when you visit our Site, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including without limitation, cookies, web beacons, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Site, for example, the site from which you came and the site to which you are going when you leave our Site, the pages you visit, the links you click, how frequently you access the Site, whether you open emails or click the links contained in emails, and other actions you take on the Site. When you access our Site from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including without limitation, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including without limitation, GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Site and to understand more about the demographics of our users. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Site; (b) provide custom, personalized content and information, including without limitation, targeted content and advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our Service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Site, as some features and services on our Site may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
We may share your personal information in the instances described below. For further information on your choices regarding your information, see “Control Over Your Information.”
In providing our Service, our Corporate Customers may upload or push Business Content to our Service, which may include personal information or data about our Corporate Customers’ end users (all of which we call “Customer Data”). Customer Data is owned and controlled by our Corporate Customers, and any Customer Data that we maintain or process we consider to be strictly confidential. We collect and process Customer Data solely on behalf of our Corporate Customers, and in accordance with our agreements with the Corporate Customers, including without limitation, the Terms of Service. We do not use or disclose Customer Data except as authorized and required by our Corporate Customers and as provided for in our agreements with our Corporate Customers, including without limitation, the Terms of Service.
Email Communications. From time to time, we may send you emails regarding updates to our Site, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
Modifying Account Information. Where Corporate Customers have an online account with us, they have the ability to modify certain information in their account (e.g., your contact information) through “profile,” “account,” “settings,” or “preferences” options provided on the Site or Service. If Corporate Customers have any questions about modifying or updating any information in their account, please contact us at the email or postal address provided below. Please note that Crossbeam does not own or control the Business Content uploaded to our Service by our Corporate Customers, and cannot modify or delete Business Content except at the request of our Corporate Customer, or as permitted by our Terms of Service.
We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Site over time so that they may play or display ads that may be relevant to your interests on our Site as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including without limitation, hashed data, click stream information, browser type, time and date you visited the Site, and other information. This information is used to display targeted ads on or through our Site or on other websites or apps, including without limitation, on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at email@example.com.
Data Retention. Following termination or deactivation of your user account, Crossbeam may retain your information for a commercially reasonable time for recordkeeping, audit or other purposes. Any Business Content, including without limitation, any Customer Data that we have access to shall be retained, stored, and deleted according to our agreement with our business customer, including without limitation, the Terms of Service.
For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfil the purposes for which we collect the data (see above under "How we collect and use information?"), except if required otherwise by law.
Keeping information safe. Crossbeam cares about the security of your information and uses commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Crossbeam’s Site and Services are intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that any personal information has been collected inadvertently from a child under 13, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 13, please contact us at firstname.lastname@example.org.
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at email@example.com or mailing us at 1339 Chestnut St, Suite 1500, Philadelphia, PA 19107.
If you are located in the EU, you have the following rights under the General Data Protection Regulation (GDPR) in respect of your personal data that we hold:
a) Right of access. The right to obtain access to your personal data.
b) Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
c) Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
e) Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
f) Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact the appropriate data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
1339 Chestnut St, Suite 1500
Philadelphia, PA 19107
To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
This Statement applies to any personal information received by Crossbeam from the European Union or Switzerland in reliance on Privacy Shield.
Choice. We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents and service providers, or before we use it for a purpose other than it was originally collected or subsequently authorized. Please note that data sharing only takes place after an active opt-in using functionality within the Service. To limit the use and disclosure of your personal information, please submit a written request to firstname.lastname@example.org.
Security. We take reasonable and appropriate measures to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have implemented appropriate physical, electronic and managerial procedures to help safeguard and secure personal information from loss, misuse, unauthorized access or disclosure, alteration or destruction.
Data Integrity and Purpose Limitation. We will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.
Access. EU and Swiss individuals have the right to reasonable access to the personal information about you that we hold. On request, we will also take reasonable steps to correct, update, amend or delete any information that is demonstrated to be inaccurate, except where the burden or expense of doing so would be disproportionate to the risks to your privacy in the case in question or where the rights of third parties would be violated.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to email@example.com. If requested to remove data, we will respond within a reasonable timeframe.
Jurisdiction and Enforcement. As part of our participation in Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission.
Lawful Requests. Crossbeam may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Contact Crossbeam and Recourse. In compliance with the Privacy Shield Principles, Crossbeam commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. If you have any questions about this Statement or the information that we collect from you in reliance on Privacy Shield, please contact us at firstname.lastname@example.org or write to:
[Privacy Department], Crossbeam, Inc., 1339 Chestnut St, Suite 1500, Philadelphia, PA 19107
In the event that you are concerned about how personal information 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 information 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.