The CROSStrax Privacy Policy governs the manner in which CROSStrax collects, uses, maintains and discloses information collected from users (a “User”) of the CROSStrax website (“Site”) and the CROSStrax mobile application (“App”) for iPhone and Android. The CROSStrax Privacy Policy applies to the Site, App, and all products and services offered by CROSStrax, LLC.

By accepting the CROSStrax Privacy Policy when signing up for free, registering, entering into a paid subscription plan, or visiting and using the Site or App, you are consenting to our collection, use, and disclosure of your personal information in accordance with our Privacy Policy. If you have any questions relating to this Privacy Policy, please contact us.

Information We Collect

CROSStrax is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information on our website, our software, and our mobile services. The CROSStrax Privacy Policy describes our practices in connection with information that we collect on our site, software, and mobile services owned and controlled by CROSStrax for which you are accessing this Privacy Policy. By providing Personal Information to us, you agree to the terms and conditions of this Privacy Policy.

Personal Information We Collect

“Personal Information” is information that identifies you as an individual. The following is personal information we may collect from you:

• Name
• Postal address (including billing address)
• Telephone number
• Fax number
• Email address
• Gender
• Credit and debit card identifiers (such as last 4 digits, type of credit, etc.)
• Your photo
• Your company logo and company information

How We Use Personal Information

We may use Personal Information:

• To respond to your inquiries and fulfill your requests.
• To send you information we believe may be of interest to you, such as advising you of updates on the software or to inform you of upcoming events, and educational materials.
• To send you important information regarding CROSStrax, changes to terms, conditions, and policies and/or other administrative information.
• To send you calendar reminders, event reminders.
• To allow you to send information and documents to your clients.
• To send you marketing communications that we believe may be of interest to you.
• To personalize your experience on the Site, our software, and our mobile services by presenting products and offers tailored to you.
• To allow you to participate in sweepstakes, contests, and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your
• Personal Information, so we suggest that you read these rules carefully.
• To allow you to add friends to the CROSStrax Referral Program. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address.
• For our business purposes, such as data analysis, audits, developing new products, enhancing our website, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.
• To diagnose website technical problems or software bugs.
• To provide to our third party service providers who provide services such as website hosting, payment processing, email delivery services, credit card processing, text messaging services, customer service, auditing services and other similar services to enable them to provide services.
• To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.

CROSStrax may observe your activities, interactions, preferences, transactional information, and other computer and connection information (such as IP address) relating to your use of our websites and our services. We may also use log files, cookies and similar technologies to collect information about the pages you view, links you click on, and other actions you may take when accessing our websites, services, or emails.

We may use personal information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Non-Disclosure Agreement

CROSStrax LLC is willing to provide a signed Non-Disclosure Agreement to any CROSStrax user.  Please email info@crosstrax.co to request one.

Data Processing

Any personal information collected about our visitors via our website(s) is processed in the United States by CROSStrax or by a third party acting on our behalf. When you provide personal information to CROSStrax, you consent to the processing of your information in the United States. Our websites are hosted in the United States.

Third-Party Websites

This website contains links to other sites and integrations with other sites that CROSStrax does not own or control and whose privacy practices may differ from those of CROSStrax. Please be aware, CROSStrax is not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our websites. We recommend that you read the privacy statement of each website that collects personal information, as their privacy statement will govern any personal information you submit to those sites. This Privacy Statement applies only to information collected by CROSStrax. The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our affiliates.

Security

CROSStrax employs industry standard security measures to ensure the security of information. However, the security of information transmitted through the Internet can never be guaranteed. CROSStrax is not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of information. Users of our sites are responsible for maintaining the security of any password, user ID, or other forms of authentication involved in obtaining access to password protected or secure areas of any CROSStrax websites. In order to protect you and your information, CROSStrax may suspend your use of a website, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure area of any CROSStrax site is restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution. If you have reason to believe your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section herein.

We may disclose personal information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Other Information We Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser information
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you
• Aggregated information

How We Collect Other Information

We and our third-party service providers may collect Other Information in a variety of ways, including:

• Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version. We use this information to ensure that our Site functions properly.
• Using cookies: Cookies are pieces of information stored directly on your computer. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience while visiting the Site, as well as for online tracking purposes. We also use cookies to gather statistical information about the usage of the Site in order to continually improve the design and functionality, understand how customers use it, and to resolve questions about it. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allow you to decline the use of cookies. If you choose to decline cookies, some or all of the features, functionality, and promotions available through the Site may not be available to you.
• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.
• IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
• From you: Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site.
• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Site, (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat this information as Personal Information under applicable law, then, in addition to the uses listed in the “How We Collect Other Information” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

Choices & Access

Your choices regarding our use and disclosure of your Personal Information

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:

• Receiving marketing emails from us: If you no longer want to receive marketing emails from us on a going-forward basis, you may opt-out of receiving them by contacting us at info@crosstrax.co.
• Our sharing of your Personal Information with affiliates for their marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with our affiliates for their marketing purposes, you may opt-out of this sharing by contacting us at info@crosstrax.co
• Our sharing of your Personal Information with unaffiliated third parties for their marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with unaffiliated third parties for their marketing purposes, you may opt-out of this sharing by contacting us at info@crosstrax.co
• We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out as described above, we will not be able to remove your Personal Information from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Information. If you opt out of receiving marketing-related messages from us, we may still send you important administrative messages.

How you can access, change or suppress your Personal Information

• If you would like to review, correct, update, suppress, delete or otherwise limit our use of your personal information that has been previously provided to us, you may contact us at info@crosstrax.co
• In your request, please make clear what information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. We will try to comply with your request as soon as reasonably possible.

EEA Notices / Privacy Shield:

CROSStrax, LLC participates in and has certified its compliance with the EU – U.S. Privacy Shield and Swiss – U.S. Privacy Shield Frameworks. CROSStrax is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about each Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

CROSStrax is responsible for the processing of personal data it transfers to a third party acting as an agent on its behalf when such data has been received under the EU – U.S. and Swiss – U.S. Privacy Shield frameworks, to the extent provided by the EU – U.S. and Swiss – U.S. Privacy Shield frameworks. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, CROSStrax is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, CROSStrax may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Additional Disclosures for EEA Data Subjects:

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Sites and CROSStrax Services you use and how you use them. This means we collect and use your information only where:

• We need it to provide or operate the Sites and CROSStrax Services, including to provide customer support and process your orders, requests, questions and concerns;
• It satisfies another legitimate interest that is not overridden by your data protection interests, including our interest in:
  • collecting product usage, analytics and performance data relating to our Sites and the CROSStrax Services, in order to maintain, analyze, develop, update, and improve our products and services;
  • maintaining records of bugs, customer support requests and similar requests you file, and our response to these requests;
  • using information to personalize content and features on our Sites and the CROSStrax Services;
  • detecting, investigating and preventing activities that may violate our policies or applicable laws (such as fraud detection and prevention);
  • maintaining corporate or business records consistent with our retention policies and applicable laws;
  • protecting against activities that may threaten the security, integrity, or availability of our or another party’s products, systems, and services; and
  • for marketing and selling our products and services, consistent with applicable laws.
• We are processing your information to protect our legal rights;
• You give us consent to process your personal data;
• We need to process your data to comply with a legal obligation, such as a lawful subpoena or law-enforcement request or to fulfill the lawful instructions of our customers (when they are acting as the controller); and/or
• We have another lawful basis for processing in accordance with applicable EU laws.

If an individual in the EEA has consented to our use of their personal information, and our processing is based on that consent, that individual has the right to withdraw their consent in accordance with the General Data Protection Regulation (“GDPR”), but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, individuals in the EEA have the right to object to that use as specified in Article 21 of the GDPR, though, in some cases, this may mean no longer using the Sites or CROSStrax Service. CROSStrax further acknowledges that EEA data subjects have certain other rights under the GDPR, including the right to lodge a complaint with a supervisory authority and to request from the controller access to, and rectification or erasure of, personal data, restriction of processing concerning the data subject, and data portability (in each case, as specified under the GDPR). Where CROSStrax is acting as a controller, you can initiate a request by contacting us as specified in the “Contacting Us” section below. Please note that if you object to or restrict processing, you may not be able to use the Sites and CROSStrax Services or certain features any longer.

EEA and Swiss data subjects can contact CROSStrax’s data protection officer by emailing info@crosstrax.co.

Do Not Track and Cross-Site Tracking

Do Not Track is a privacy preference that users can set in their web browsers. When a user activates the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. For information about Do Not Track, visit www.allaboutdnt.org. At this time, we do not respond to Do Not Track browser settings or signals. In addition, some of the other third-party services and tools on our Site and/or the CROSStrax Service, may use standard technologies, such as cookies, pixel tags, and web beacons, to collect information about your internet activities across websites. You may be able to disable certain third-party cross-site tracking as described in the “Your Choices” section above.

Data Retention Period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

Use of Site by Minors

CROSStrax does not knowingly collect or solicit personal information from any minor.  The Site is not directed to individuals under the age of thirteen (13), and we request these individuals not provide personal information through the Site.  If you believe a minor may be using our service, please contact us immediately at support@crosstrax.co

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive personal information (defined to include: Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise to us.

Updates to This Privacy Policy

The CROSStrax Privacy Policy may be subject to updates. We encourage you to periodically review this Privacy Statement for any changes. Your use of the Site following these changes means that you accept the revised Privacy Policy. For new users, changes or updates are effective upon posting. For existing users, changes or updates are effective 30 days after posting.

Your acceptance of these terms

By using this Site and the App, you signify your acceptance of this policy. If you do not agree with this policy, please do not use our Site or App. Your continued use of the Site or App following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting Us

If you have any questions about the CROSStrax Privacy Policy, or if you have a complaint, an access request or any other issue, please contact us at info@crosstrax.co or by calling (844) 620-8555.