The Crosby Group LLC (“Crosby”) understands the importance of the privacy of its customers and the protection of their personal data. This policy outlines the handling and processing of the personal data Crosby collects.
This website is operated by Crosby. It is important to Crosby that an environment is created and maintained where Crosby customers feel comfortable that their information will not be misused.
Crosby complies with the applicable data protection laws, such as the General Data Protection Regulation 2016/679 and national data protection laws. These data protection laws relate to the protection of your personal data and grant you rights with respect to your personal data.
This policy sets forth what personal data Crosby collects from you and how your data will be used following the use of Crosby’s website in order to assure you of the proper handling of your data.
- What personal data is collected.
You do not have to provide your personal data in order to use most of Crosby’s website.
For the purposes mentioned in Addendum 1 attached hereto, Crosby may gather and process certain categories of personal data about you.
You may also choose to provide additional/optional information when completing forms on Crosby’s website or that you give to us when we have contact with you (by telephone, by e-mail or at trade fairs or events).
Furthermore, Crosby may also collect and process information obtained through its websites or the devices you are using. This information can be:
- Location data (location information collected from social media networks or IP addresses from your device; GPS signals sent by a mobile device);
- Data Crosby obtains from other websites (for example, if you ask Crosby to connect with your Facebook account);
Crosby may also collect publicly accessible information in order to verify information we have collected and to manage and expand our business.
- Why do we collect this information?
Crosby collects the above-mentioned information to understand your needs and to provide you with a better service. More specifically, Crosby collects your information for the following purposes:
- Your personal data will be used to respond to your (online) queries about Crosby products or services, to provide you with information on Crosby products, and to follow-up online offers;
- Provide the products and services you have ordered;
- Verify your identity and financial data for payment of Crosby products and services;
- The information will be used to improve Crosby products and services;
- Investigate complaints about the products or services or regarding Crosby website;
- Meet legal, regulatory and compliance obligations and requirements;
- Analyse and monitor the use of accounts to prevent or investigate fraud, terrorism, misrepresentation, security incidents or crime and/or report this to the competent authorities;
- Sending promotional e-mails periodically about Crosby products and services, about special offers or other information which Crosby believes might be of interest to you;
- Contacting you for market research purposes from time to time. Crosby may contact you by e-mail or phone;
- Process your personal data for specific purposes as mentioned on specific forms as published on Crosby’s website, on written notices or via e-mail;
- How will your information be used and shared?
Crosby may share your personal data:
- with companies in Crosby’s group and/or its affiliates and its authorized distributors; or
- with any third party you have asked Crosby to share your personal data with – such as Facebook or any other social media site if you have asked us to connect with your account; or
Crosby can also share your personal data, based on our legitimate interest, to third party providers who help us with our products and services. Examples include hosting our web servers, analysing data, providing marketing assistance, and providing customer service. These companies will have access to your personal data but only when strictly necessary to perform their functions and they may not use that data for any other purpose.
Your personal data will not be sold or rented to third parties.
Crosby may disclose your personal data to enforce our policies, to comply with our legal obligations or in the interests of security, public interest or law enforcement in any country where we have entities or affiliates. For example, we may respond to a request by a law enforcement agency or regulatory or governmental authority. We may also disclose data in connection with actual or proposed litigation, or to protect our property, security, people and other rights or interests.
In the event that the business of Crosby is sold or integrated with another business, your details will be disclosed to any prospective purchaser’s advisor and will be transferred to the new owners of the business. In this case, Crosby will implement the appropriate safeguards to ensure the integrity and confidentiality of your personal data. However, use of your personal information will remain subject to this Policy.
- Transfer of your personal data
Crosby will transfer your personal data to third party providers who are located in third countries (outside the European Economic Area (EEA)), i.e. United States of America. This data transfer outside the EEA is legitimate if the recipient of the data is located in a country which provides an adequate level of protection following a European Commission adequacy decision. Some countries may not have equivalent data protection legislation to protection the use of your personal data. In this case, Crosby has assessed whether appropriate safeguards as those within the EU are possible by, for example, executing standard contractual clauses. In particular cases, we will obtain your preliminary consent for transferring your personal data outside the EEA. For more information regarding the transfer of information you can follow the procedure as described in the Article on the ‘Rights of the Data Subjects’.
Cookies may contain identifying information. Cookies enable Crosby to gain information about the use of its website. This information may be analysed by third parties on behalf of Crosby.
a. We use the following categories of cookies on our website:
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided.
These cookies collect anonymous information on how people use Crosby’s website. For example, we use Google Analytics and HubSpot cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
These cookies remember choices you make such as the country from which you visit our website, the language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting cookies or advertising cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, Crosby uses third party companies to provide you with more personalised advertisements when visiting other websites.
Social Media Cookies
These cookies allow you to share what you have been doing on the website on social media such as Facebook and Twitter. These cookies are not within Crosby’s control. Please refer to the respective privacy policies for how their cookies work.
Crosby also uses third party services such as Google Analytics to collect information about visitors to our website. This information is aggregated to determine number of visits, average time spent, pages viewed, etc. Crosby uses this information to measure site usage, as well as to improve the content and value of our site. More information about the way Google processes your information is here – http://www.google.com/analytics/learn/privacy.html. If you wish to disable Google Analytics on your browser, please follow [these steps].
Using the Google Analytics opt-out browser add-on will not prevent site owners from using other tools to measure site analytics. It does not prevent data from being sent to the website itself or in other ways to web analytics services.
b. Deletion of cookies and more information about cookies.
Some cookies are deleted when you close down your browser (session cookies). Others remain on your device until they expire or you delete them from your cache (persistent cookies or tracking code) and enable us to remember things about you as a returning visitor.
If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. The help option on the toolbar of most browsers will also tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please bear in mind that some personalized services may not be available if you choose to disable cookies.
Please note that by deleting Crosby cookies or disabling future cookies you may not be able to access certain areas or features of our site.
c. Web beacons
Some of our web pages may contain electronic images known as web beacons (sometimes known as clear gifs) that allow us to count users who have visited these pages. Web beacons collect only limited information which includes a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any personally identifiable information and are only used to track the effectiveness of a particular campaign.
- Rights of Data Subjects
You are entitled to see the information held about you and to obtain a copy of the information we hold. If your personal data have been changed, you are entitled to ask us to rectify or complete or erase the outdated, incorrect or incomplete data we have about you. Furthermore, you have the right to restriction of the processing of your data and to object to the processing of your personal data. You have also the right to data to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
If you have opted to receive commercial e-mails, newsletters, etc. from Crosby at the time you registered on the website, you may opt-out whenever you have changed your mind.
We may require you to provide verification of your identity to ensure that you have a legitimate right to make the request and to verify that we provide the answer to the person that has the legitimate right to send us one of the above-mentioned requests and to obtain the information.
Please note that in certain circumstances, as provided by law, we may withhold access to your information or we may not grant your request where we have the right to do so under applicable data protection legislation.
If you wish to obtain more information regarding the processing of your personal data or if you wish to exercise your rights, please contact us at firstname.lastname@example.org.
You have the right to lodge a complaint with the competent supervisory (data protection) authority.
Crosby is committed to trying to make sure that your information is secure. We have implemented reasonable technical and organisational measures to secure your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. You should, however, remember that the internet is an open system and we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use your personal data for improper purposes.
This website may contain links to third party websites. Crosby is not responsible for the content of these websites and is not responsible for the privacy standards and practices of that third party. We recommend that you read and understand the relevant privacy policies of these third parties and their websites before you accept their cookies and visit their website to ensure yourself that your personal data is sufficiently protected.
- Changes to this policy.
Crosby may amend and update this policy from time to time to ensure that the policy represents the way we process your personal data at that time. We will place an updated version of this policy on the same webpage and it will automatically be effective when published. Please return to this webpage regularly to ensure that you are always aware of the information we collect and process, how your data is being used, in which circumstances, and in which cases we will share your data with third parties.
ADDENDUM NO. 1
For purposes of this Privacy Statement, personal information is any information about a specific individual or that identifies or may identify a specific individual. In other words, it is any piece of information than can be linked to you. Certain jurisdictions may prohibit or limit the collection of specific categories of personal information. Subject to local law and any attached appendices, examples of personal information that we may collect include, but are not limited to:
- Contact Information (e.g., name, address, telephone number, emergency contact(s) information);
- Social Security Number or other national/taxpayer identification numbers;
- Identification and Verification Information (e.g., photographs, driver’s license, passport, other proofs of identity);
- Information Security Data (e.g., communications created, stored or transmitted by a person using Crosby’s information technology or communications equipment);
- Information to fulfill items such as, but not limited to, communications, contracts, purchase orders, payments, and receivables; and
- Other information required to comply with applicable laws, including valid search warrants, subpoenas, or court orders.
Different categories of persons may be subject to additional collection of personal information, including but not limited to:
- Business Contact Information (e.g., company name, address, telephone number);
- Individual Representative Contact Information: (e.g., name, address, telephone number, email address);
- Billing Information (e.g., financial account data, invoices, receipts);
- Client Relationship Management Information (e.g., information necessary to populate a customer’s profile or to facilitate marketing automation);
- Repair Information (e.g., repair needs and status);
- Warranty Information (e.g., purchase history, extended warranties); and
- Customer Satisfaction Information.
- Background Information (e.g., birth date, marital status, dependent information, ethnicity and/or nationality);
- Residency Information (e.g., work permit status);
- Financial Account Information;
- Reference Information (e.g., letters of recommendation or reference, or reports provided by former employers or colleagues);
- Background Check Information (e.g., credit and criminal background checks, drug and alcohol testing);
- Health Information (e.g., prescription records, benefit claims, and the Explanation of Benefits sent in connection with claims);
- Biometric Information (e.g., thumbprints);
- Trade Union affiliation;
- Automotive Information (e.g., driving history, vehicle registration, driver’s license number);
- Professional Qualifications Information (e.g., work experience, education); and
- Employment-related Information (e.g., work history, new hire forms, skills, education and training, performance appraisals, goals, attendance, work absences, vacation entitlement and requests, compensation history, workplace injury and illness reporting, disciplinary issues, and grievances).
- Residency Information (e.g., work permit status);
- Financial Account Information;
- Background Information (e.g. due diligence)
- Professional Qualifications Information (e.g., work experience, education);
- Reference Information (e.g., letters of recommendation or reference, or reports provided by former employers or colleagues)