Last Updated: May 25, 2018.
CrossBorder Transactions LLC d/b/a CrossBorder Solutions (“CrossBorder”, “we”, “us”, “our” or the “Company”) is committed to respecting and protecting your privacy. This CrossBorder Privacy Statement (“Privacy Statement”) describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data”), and your rights and choices regarding our processing of your Personal Data.
“Personal Data” is information that, directly or indirectly, identifies you or another individual and which may include: name, title, company name, expertise, postal address, telephone number, email address, browser and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers in connection with the Site, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Notice.
“Other Information or Other Data” is any information or data that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Site and for other purposes described below.
CrossBorder is the “controller” and is responsible for deciding how personal information is used, collected and processed, unless expressly specified otherwise. We are a limited liability company organized under the laws of the State of Delaware, U.S.A., with offices at 520 White Plains Road, Tarrytown, New York 10591 USA.
Personal Data we collect
Personal Data you provide to us
This is information that you choose to provide to us, which may include: your name, job title, company name, contact information including email, postal address and telephone number(s) and your preferences or areas of interest.
You may provide your personal information in the following circumstances:
Subscribing to news, alerts or other publications
You can use the Site to subscribe to CrossBorder news, alerts or other publications. We will ask you to provide personal information such as your name, contact details and topics of interest. We will use this information to provide you with the content you have requested and to tailor this content to your preferences and areas of interest.
We may use your personal information to communicate with you about other topics that we believe may be of interest provided you have given your consent. You can unsubscribe from this content at any time (please see the “Opting-out of Communications” section below).
Webinars or Events
You may provide your personal information, including your name and contact details, through our Site to register for CrossBorder events and webinars. We will use this information to process the registration and contact you about any changes or updates regarding the event or webinar.
We may share your personal information with speakers or event sponsors, provided you have given your consent. We may also contact you with information about other events and other CrossBorder activities and services provided you have consented to receiving such information. You can unsubscribe from this information at any time (please see the “Opting-out of Communications” section below).
In some cases, our Site allows you to comment on CrossBorder blog posts and to share content with third parties via email or social media. Personal information may be shared in any comment and you may submit your name or email address with the comment. By sharing content on social media, you will provide Social Networks with information about your use of our Site.
You can use our Site to subscribe to an RSS feed or to receive email updates of our blogs by submitting your name and email address. We use this information to send you the content you request and to communicate with you in connection with our blogs. You can unsubscribe from this content at any time (please see the “Opting-out of Communications” section below).
You can use the careers section of our site, to learn about our company and apply for open positions by submitting a resume and other information via email. We may also receive resumes from recruitment consultants, CrossBorder employees or other third parties.
Resumes will typically include personal information, including name, contact details, information about academic and professional qualifications and experiences, your interests and the position at CrossBorder for which you are applying.
We will use this personal information to:
• Assess your suitability for the position for which you are applying;
• Contact you in relation to your application;
• Manage and administer our recruitment processes; and
• Provide updates on vacancies at CrossBorder which might be suitable for you, provided you have given your consent.
In the event you are not hired by our company, we will permanently delete your resume and any other personal information held about you within one year (as required by law) after receiving your application, unless you have given us your consent to keep this information for a longer period in order to inform you about future vacancies which may be of interest.
Contacting us by phone, e-mail or otherwise
When you communicate with us via our Contact Us page, you are asked to provide your name, email address, phone number and company name. We will use this information to respond to your questions and comments. We will request similar personal information in order to confirm your identity when you contact us by phone, email or otherwise.
We automatically collect log files and other information about your device and your usage of our website through cookies, web beacons or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data (view the “Device and usage data we process” section below);
In some cases, if you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
Personal Data we collect from other sources
We may also collect information about you from other sources, including third parties from whom we have purchased Personal Data, and combine this information with Personal Data provided by you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Data from the following sources:
Business contact information, including mailing address, job title, email address, phone number, ‘intent data’ which is web user behavior data, IP addresses, social handles, LinkedIn URL and custom profiles from third party data providers for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling.
Device and usage data we process
We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our website or interact with emails we have sent you.
As is true of most websites, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our website and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Company’s security features.
Cookies, web beacons and other tracking technologies
When you visit our website, our servers or an authorized third party may place a cookie on your browser, which can collect information, including Personal Data, about your online activities over time and across different Site. Cookies allow us to track overall usage, determine areas that you prefer, make your usage easier by recognizing you and providing you with a customized experience.
We also use web beacons on our website. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our website. Such tracking technologies are used to operate and improve our website and email communications and track the clicking of links or opening of emails.
We will use your personal information to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you, provided you have given your consent, which can be withdrawn at any time.
Site use information
Our web servers may collect information including the IP address of visitors to our Site, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
We use this personal information for the following purposes:
To measure the use of our Site, including number of visits, average time spent on a Site, pages viewed, page interaction information (such as scrolling, clicks, and mouse-overs), etc., and to improve the content we offer;
To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
As part of our efforts to keep the Site safe and secure;
We may share with third parties this information or other data on an aggregated basis without the use of any personal information.
You do not have to accept cookies and consent can be withdrawn at any time (see How to control cookies, below). You can change your browser settings to refuse or restrict cookies, and you may delete them after they have been placed on your device at any time. If you do not accept or delete our cookies, some areas of our Site that you access may take more time to work, or may not function properly.
What are cookies?
Cookies are small files containing a string of characters which we may store on your computer or mobile device when you visit the Site. When you visit the Site again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.
Types of cookies we use on our Site include:
Session cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We may use session cookies to grant our users access to content and to enable actions such as remembering form or payment information as you are in the process of entering it.
Persistent cookies: These cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We may use persistent cookies to better understand usage patterns so we can improve a Site for our users. For example, we may use a persistent cookie to associate you with your account or to remember your choices on a Site.
Third-party cookies: We may permit third-party service providers to place cookies through our Site to provide us with better insights into the use of the Site or user demographics or to provide relevant services to you. These third parties may collect information about a user’s online activities over time and across different websites when he or she uses our Site. For example, we may use a third-party tool to analyze usage patterns of the Site. Such a tool may generate a cookie to capture information about your use of a Site which the third-party provider uses to compile reports on website activity for us and to provide other related services. The third-party provider may use a portion of your IP address to identify its cookie. We do not control the use of third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.
Cookies we use*
*Please check back for any updates to this list.
How to control cookies
When you first access the Site from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By continuing to browse the Site, you signify that you understand and agree to the use of these technologies, as described in this Cookies Policy.
You do not have to accept cookies and consent can be withdrawn at any time, although you may not be able to use certain features on the Site. You can do this by activating the settings on your browser that allows you to refuse all or some cookies.
As well as cookies, we use other technologies to recognize and track visitors to our Site. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie.
Web beacons allows us, for example, to monitor how users move from one page within our Site to another, to track access to our communications, to understand whether users have come to our Site from an online advertisement displayed on a third-party website, to measure how ads have been viewed, and to improve Site performance.
We encourage you to check frequently to see the current Cookies Policy to be informed of how we are committed to protecting your information and providing you with improved content on our Site in order to enhance your experience.
You can also write to us at:
520 White Plains Road
Tarrytown, New York 10591
“Do Not Track” Browser Settings
We do not use technology that recognizes a “do-not-track” signal from your web browser, because we do not track users other than for aggregate statistical purposes.
Opting out of communications
If you have subscribed to or are otherwise receiving CrossBorder news, alerts, blog posts, or similar information from us by email and no longer want to receive such information in the future, you may opt-out of receiving these emails by clicking the “unsubscribe” link at the bottom of those emails you receive. Please allow ample time for us to process your request. If you are having difficulty unsubscribing, please contact us using the Contact Us page or at email@example.com or firstname.lastname@example.org.
Please note that even if you opt-out of receiving emails, you may still receive communications related to your interaction with us (such as confirmation of a registration or form submission) or otherwise as required by law. Also note that we may need to keep personal information we have collected about you to respect your decision to opt-out, for record-keeping, research and other purposes.
Disclosing information to third parties
We will not share, rent, sell or otherwise disclose any personal information that we collect about you through our Site, except in any of the following situations:
You request or consent to the release of your personal information;
We will disclose your personal information to third-party contractors and payment processors who perform services for us in connection with the Site, or to complete or confirm a transaction or series of transactions that you conduct with us;
We will disclose your personal information to service providers or suppliers where the disclosure will enable that party to perform business, professional or technical support for us;
Where you have provided your consent, which can be withdrawn at any time, we will provide your personal information to other select third parties approved by CrossBorder as offering products or services relevant and useful to you. The use by and/or content of communications from any third party will be pre-approved by CrossBorder;
We may disclose personal information about you as part of a merger, acquisition or other sale or transfer of the assets or business of CrossBorder. In such circumstances, we will take steps to inform you of the transfer either directly or indirectly through publishing news of the transaction; and
We will also share aggregated or anonymous information that cannot identify you with third parties. For example, we disclose the number of visitors to the Site or the number of people who have downloaded a particular document.
We will store your personal information, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the personal information is processed. We may retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your personal information quickly upon request.
Links to other websites
If you are under the age of majority in your home jurisdiction, please do not use or access the Site. It is not our intention to collect or use personal information from anyone under the age of majority, and we will not knowingly do so. If we are made aware that we have collected any personal information from minors and are asked to delete such information from our databases, we will promptly do so.
Access from outside the United States
If you access a Site from outside of the United States, information that we collect about you will be transferred to servers inside the United States, which may involve the transfer of information out of your country of origin. By allowing us to collect personal information about you, you consent to such transfer and processing of your personal information.
Your European Privacy Rights
For European residents only. Under European data protection law, in certain circumstances, you have the right to:
Request access to any personal information we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making;
Obtain without undue delay the rectification of any inaccurate personal information we hold about you;
Request that personal information held about you is deleted;
Prevent or restrict processing of your personal information; and
Request transfer of personal information directly to a third party where this is technically feasible.
You can exercise any of these rights by contacting us using the Contact Us page or at email@example.com or firstname.lastname@example.org.
You can also write to us at:
520 White Plains Road
Tarrytown, New York 10591
Attn: Marketing Compliance Team