Crossbeam Privacy Policy

Last Modified: September 13, 2018

Crossbeam, Inc. (“Crossbeam,” “we,” “our” or “us”) is committed to protecting your privacy. This Privacy Policy explains how Crossbeam collects, uses, and shares the personal information we collect from visitors to our website (“Site”) as well as how we collect and use information from our Corporate Customers and our Corporate Customers' end-users (collectively referred to as our “Customers”) during the provision of our services to those Customers (“Service(s)”). By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service [insert link].

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.

How We Collect and Use Information.

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:

Information that you provide to us

  1. Site visitors We collect your personal information (e.g., name, postal address, email address) in order for you to communicate with us. We may also collect any communications that you exchange with us, as well as any information you provide if you take part in any interactive features of the Site (e.g., promotions, surveys, etc.).
  2. Customers

    • Corporate Customers We collect information that Corporate Customers provide to us when they set up an account with us, use our Services, or communicate with us. For example, we may request Corporate Customers personal information (e.g., name, postal address, email address, telephone number) or applicable business information (e.g., company name, title, social profile links) when the Corporate Customer registers for an account or purchases our Service. We may also collect any communications that Corporate Customers exchange with us, as well as any information provided if they take part in any interactive features of the Service (e.g., promotions, surveys, etc.). We collect information provided when providing content or commentary to our Service in the form of profile information, content posts, comments, and the like (“Corporate Customer Content”).
    • Customers' end-users We collect information that end-users provide to us when using our Services or communicating with us. This may include an end-user's name and any communications that they exchange with us, as well as any information provided if they take part in any interactive features of the Service (e.g., promotions, surveys, etc.). We collect information end-users provide when providing content or commentary to our Service in the form of profile information, content posts, comments, and the like (“End-User Content”).


    "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”).

Information we receive from social networking sites

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.

Address Book Information With the permission of Corporate

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.

Information from other sources

We may obtain information from other sources, such as third-party information providers, or through mergers and acquisitions, and combine this with information previously collected. In these cases, our Privacy Policy governs the handling of the combined personal information.

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:

  1. where we need to perform the contract we are about to enter into or have entered into with you for the Service;
  2. 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; and
  3. Where we need to comply with a legal or regulatory obligation in the EU.

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.

3 How We Use Cookies and Other Tracking Technology To Collect Information

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 and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.

4 How We Share Personal Information

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.”

5 Customer Data

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.

6 Control Over Your Information

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.

7 Third Party Tracking and Online Advertising

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 privacy@getcrossbeam.com.

8 Data Protection and Security

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.

Data storage and transfer. Your information may be stored and processed in the United States or any other country in which Crossbeam or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please view our International Privacy Policy [insert link]. In addition, if you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards. If you wish to enquire further about these transfers, please contact us using the details set out at the end of this Privacy Policy. For more information regarding Crossbeam’s compliance with the U.S.-EU and U.S.-Swiss Privacy Shield Principles, please see our Privacy Shield Privacy Statement.

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 obligations with respect Customer Data are defined in our agreements with our customers, including without limitation, the Terms of Service, and are not made part of this Privacy Policy. Each customer will remain responsible for the privacy and security of the Customer Data that it collects and processes and for compliance with applicable data protection laws that may apply to the collection, processing and disclosure of Customer Data through the Services.

For your convenience, our Site and Services may provide links to third-party websites or services that are not governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by Crossbeam, we are not responsible for those websites’ or services’ content or information practices. We encourage you to review the privacy policies of any site or service before providing any personal information.

10 Children’s Privacy

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 privacy@getcrossbeam.com.

11 Changes to Privacy Policy

We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will post changes on this page and indicate the “last modified” date at the bottom of this page. Please check back often for any updates. Your continued use of our Site or Services after any change in this Privacy Policy will constitute your acceptance of such change.

12 Your California Privacy Rights

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 privacy@getcrossbeam.com or mailing us at 1339 Chestnut St, Suite 1500, Philadelphia, PA 19107.

13 Your rights under GDPR in respect of your personal information if you are located in the EU

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.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

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.

14 Contact Us

For additional inquiries about this Privacy Policy, please send us an email at privacy@getcrossbeam.com, or contact us at:

Crossbeam, Inc. 1339 Chestnut St, Suite 1500 Philadelphia, PA 19107

Crossbeam Privacy Shield Statement For EU and Swiss Personal Data Transferred to the US

Crossbeam complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Crossbeam has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Purpose

The purpose of this Crossbeam Privacy Shield Statement (“Statement”) is to outline how we comply with the Principles with respect to the EU and Swiss personal information we collect and subsequently transfer into the United States. If you would like to obtain additional information regarding our privacy practices in connection with information collected on this website in general, please refer to our Privacy Policy. If there is any conflict between this Statement and the Privacy Policy, this Statement shall prevail.

Scope

This Statement applies to any personal information received by Crossbeam from the European Union or Switzerland in reliance on Privacy Shield.

Crossbeam Data Processing Activities

Crossbeam at times acts as a data processor or a data controller when processing personal data transferred from the EEA or Switzerland. Though the types of data Crossbeam collects and processes may vary depending on the Terms of Service and our customers’ preferences, data we collect typically includes personal information relating to contact information, work history, transaction and purchase history information, web browsing behavior and other information relating to a user’s device used to access the services, and other information as described in our Privacy Policy. Crossbeam processes this data to provide our business and consumer services; customer service and product support; communications and marketing; online advertising; analytics to inform and improve our services; and for other internal purposes.

Principles

  1. Notice. We will provide individuals with notice of our data collection and processing practices in our Privacy Policy, describing what personal information we collect, the purpose and use of personal information, the categories of third parties with whom we may share such information (and the purposes for which we do so), the individual’s right to access such information, the choices and means through which the individual may limit the use and disclosure of personal information, and other disclosures consistent with the Notice Principle.

    You can read about our data collection and processing practices in our main Privacy Policy.

  2. 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 privacy@getcrossbeam.com.

  3. Onward Transfers (Transfer to Third Parties). Crossbeam may transfer personal information to certain third parties (as described in our Privacy Policy). Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with Crossbeam’s Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, Crossbeam may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage.

  4. 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.

  5. 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.

  6. 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 privacy@getcrossbeam.com. If requested to remove data, we will respond within a reasonable timeframe.

  7. 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.

  8. 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.

  9. 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 privacy@getcrossbeam.com 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.