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Privacy Policy

Last updated May 6, 2020

CrossCircles Inc. (“CrossCircles”, “us”, “our” or “we”) is committed to protecting your privacy. Our privacy policy, applies to all Users of our platform “Crossminds.ai” (the “Platform”), which is designed to explain the information we collect and how we use it to provide our services and give Users a better experience (“Privacy Policy”). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use, This Privacy Policy is part of, and incorporated into, the Terms of Use.

By accessing and using the Platform, you consent to our collection, storage, use and disclosure of your personal information and other information as described in this Privacy Policy.

Definitions

Registered Users: persons who use the Platform and have an Account with the Platform.

Unregistered Users: persons who use the Platform and do not have an Account with the Platform.

Users: Both Registered Users and Unregistered Users.

Personal Information: information that can be used to contact or identify you, such as your username and email address, as well as information that is linked to such information.

Anonymous Information: information that cannot be used to contact or identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Platform, such as usage data, to the extent that information is not linked to your Personal Information.

Types of Information We Collect about You

Unregistered Users

We collect Anonymous Information about our Unregistered Users. This includes your activities on the Platform, such as usage data. We may acquire your device information, such as IP address or browser information, during your activities on the Platform. We do not, however, store any additional information about an Unregistered User once the Unregistered User ceases interacting with the Platform. We do not require our Unregistered Users to provide any Personal Information. We may collect Unregistered Users’ Personal Information if it is voluntarily provided to us.

Registered Users

We collect both Personal Information and Anonymous Information about our Registered Users. Other than a username and a valid email address, a Registered User is not required to disclose other types of Personal Information.

We may obtain certain information from the devices of Registered Users, such as IP address and browser information, while the Registered Users use our Platform. We do not, however, store such device information.

We collect information about Registered Users that is voluntarily provided to us during use of our Platform, including when you reach out to us via the Contact Us page on our Platform.

Information Collected with Technologies

We use third party services, such as Google Analytics, to track and analyze online behavior data of all Users. We do this to better understand how you use our Platform, with a view toward offering improvements for all Users, and to tailor our business and marketing activities accordingly. If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en. Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.

We also use Mixpanel to track and analyze Users’ behavioral data. More information about this service can be found at its website at https://mixpanel.com/.

How We Use Your Information

Personal Information

We may use your Personal Information for the following representative business purposes:

  • Help you create an account on our Platform
  • Respond to messages you’ve sent us via the Contact Us page.
  • Send communications and administrative emails
  • Personalize and tailor the features, performance and support of the Platform, such as providing tailored content
  • Improve the quality of the Platform and perform internal operations, including fraud detection
  • Analyze, benchmark and conduct research on user data and interactions with the Platform
  • Where you have provided your Personal Information to us, you may withdraw your consent at any time and opt out. The use of your Personal Information and the withdrawal of the consent are subject to applicable legal and ethical obligations that may apply as well as our lawful ability to enforce our rights or your obligations to us including your obligations to us in separate agreement(s).

Anonymous Information

We may use Anonymous Information for the following representative purposes: Perform internal operations of the Platform Improve the Platform and customize the User experience Use in statistical analysis to help us track behaviors and analyze patterns

Advertising

We may target (and measure the performance of) content to Users, both on and off our Platform, using the following data, whether separately or combined: User-provided information (e.g., contact information) Data from your use of our Platform (e.g., connections, page visits, videos watched, or content clicked, etc.)

Information inferred from data described above

When you visit the Platform, we may show you content based on information we collected about you. If you take an action (such as like, comment or share) on this content, your action is associated with your Account and may be viewable by others.

How We Share and Disclose Information

We know how important it is to keep your information confidential. We will not rent, sell or share your Personal Information with third parties unless otherwise agreed upon. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Platform or provide your Personal Information at any time. Your Personal Information may be shared with the following third parties and/or for the following purposes:

Registered and Unregistered Information

As a Registered User, your profile information including your username and profile picture is visible to all Users of our Platform. We do not share Personal Information or Anonymous Information of an Unregistered User with other Users.

Third Party Analytics Tools

We share information collected about you with the third party services, including Google Analytics and Mixpanels, for behavioral analysis.

Compliance with Laws, Law Enforcement and Safety

We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend CrossCircles’, or a third party’s rights or property.

Aggregated Anonymous information

Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users (“Aggregated Anonymous Information”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties.

Business Transactions

We may share all or some of your Personal Information with any of our subsidiaries, joint ventures, other companies under common control, or entities that will control the Platform and are in the same corporate family as CrossCircles, in which case we will require them to honor this Privacy Policy. Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Privacy Policy.

Your Choices

By submitting Personal Information, you consent to receive certain communications from us. You may modify or opt out of receiving messages sent for marketing purposes, or certain other communications, by following the unsubscribe instructions in such messages. Please note that despite any indicated marketing preferences, we may send you administrative emails regarding the Platform, including, for example, notices of updates to our Privacy Policy.

Updating Your Personal Information

You may revise your Personal Information by updating your account on the Platform. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements. Note that if we have already disclosed some of your Personal Information to third parties, we may not be able to delete or modify any such information.

Children

This Website is not directed to or intended for persons under the age of 18. We do not knowingly solicit, collect or maintain information from those we actually know are under 18, and no part of our Website is targeted to attract anyone under 18. We also do not send e-mail correspondence to anyone who advises that they are under the age of 16. If we later obtain actual knowledge that a User is under 18 years of age, we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us via the methods specified in the Contact Us Section in this Privacy Policy so that we may delete and remove such information from our system.

Security and Data Retention

We employ all reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email and/or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. Your consent to such purpose remains valid after termination of our relationship with you.

Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. If you object to any changes we implement, you may close your Account. Your continued use of our Platform after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly.

California Privacy Rights

California’s Consumer Privacy Act (“CCPA”) (Civil Code Sections 1798.100 – 1798.199) grants California residents certain rights regarding the use of their Personal Information. You must be a resident in the State of California to enjoy the rights in this Section. You may use the methods specified in the Contact Us Section in this Privacy Policy to subject your requests pursuant to CCPA. We may deny your requests in whole or in part, in accordance with applicable law. If you would like more detailed information about your rights under the CCPA, please visit https://oag.ca.gov/privacy/ccpa.

The right to notice that personal information will be collected

If you are a resident in the State of California, you have the right to request certain information about our collection and use of your Personal Information over the past twelve (12) months. The categories of information that we have collected from consumers in the past twelve (12) months, and may collect from you along are identified in § 2 in this Privacy Policy. The purposes for which we collect your personal information and how we use it, are identified in the §§ 3, 4 in this Privacy Policy. We update the categories the Personal Information collected about the consumer regularly, including at least once every twelve (12) months.

The right to know what personal information has been collected, sold, or disclosed for a business purpose, and to whom it was sold or disclosed.

If you are a California resident you have the right to request that we disclose what Personal Information we have collected about you in the past twelve (12) months. Once we receive and confirm your verifiable request, we may disclose the following to you:

  • The categories of Personal Information we have collected about you.
  • The categories of sources for the Personal Information we have collected about you.
  • Our business or commercial purpose for collecting that Personal Information.
  • The categories of third parties with whom we’ve shared that Personal Information.
  • The specific pieces of Personal Information we have collected about you.
  • If we sold or disclosed your Personal Information for a business purpose, we may disclose to you two - separate lists disclosing:
  • All sales of your Personal Information, identifying the categories of Personal Information that were - sold and the categories of third parties who purchased that information; and
  • All disclosures of your Personal Information for a business purpose, identifying the categories of Personal Information that were disclosed and the categories of each third party who received such information.

The right to opt-out of the sale of personal information:

We do not sell User’s Personal Information absent another agreement between you and us. We have not sold any Personal Information in the past 12 months.

We, however, may sell information in the How We Use Your Information Section.

The right to have your Personal Information deleted

You have the right to request that we delete any of your Personal Information that we collected, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we may delete your Personal Information from our records, in accordance with applicable law.

The right to non-discrimination as a result of exercising these rights.

You have the right to be free from discrimination by any business, such as being charged different rates or denied services, as a result of exercising your rights under the CCPA. If you believe we have violated any of your rights under the CCPA, please contact us via the methods specified in the Contact Us Section in this Privacy Policy.

Contact Us

If you have any requests or have any questions regarding our Privacy Policy, you can contact us via email at contact@crossminds.ai or via https://www.crossminds.ai/contact-us on our Platform.

More information regarding how to contact us is found on our https://www.crossminds.ai/contact-us.