Privacy Policy

CrossTower Inc.
Website Privacy (GDPR) Policy

1. Privacy Statement

Your privacy is important to us. We are committed to the fair and transparent processing of our clients', consumers' and website visitors' information. Our Privacy Policy ("Policy") governs your access and use of websites produced and/or maintained by us ("Sites"). The Policy is designed to advise you about how we use, protect and disclose the information we receive or collect about you, explains your privacy rights and how you can manage the privacy of your information. Read the following information carefully.

Please note that this Policy does not govern the practices of third parties, such as our partners or third party service providers. Any information that you provide to a third party while utilizing their website or service will be governed by the third party's privacy policy and/or terms of use. You should read all third parties' privacy policies and terms of use carefully before providing your personal information.

2. Information We Collect

Personal information is defined in this Policy to include any information that can be used to identify, locate or contact you. It includes your name, physical address, email address, telephone number, and other identifying information. It also includes other information that may be associated with your personal information, such as your location, IP address, preferences or interests. We may collect your personal information when you use our Sites to contact us, subscribe to our publications or register for firm events, collectively referred to as "Services." We only collect the personal information from you that you choose to share with us through your use of the Sites.

We may also gather generic, or non-personal, information from our Sites' visitors automatically, which does not reveal a Site visitor's identity. This includes the number and frequency of visitors to our Sites, the specific CrossTower Sites visited, and the Sites clicked on, your language preferences for accessing our Sites, your browser information and screen resolution, your device's operating system and your network service provider, among other information. We gather this information for limited internal purposes, such as to track, customize and improve user experience with our Sites or Services.

3. How We Use Your Information

We will primarily use your information to provide you access to, and facilitate your: use of the Sites, or contact with us, subscription to our publications and registration for firm events, where you access the Sites for those purposes. Except as otherwise stated in this Policy, we will only use your personal information solely for the purpose for which you submitted the information.

We will also use certain types of information to enhance the operations of our Sites, improve and troubleshoot the performance of our Sites, statistically analyze use of the Sites, improve our marketing and promotional efforts, and customize the content, layout, and performance of our Sites or Services. We may use your information to assist us in delivering information and contacting you when needed (for example, providing information about changes in our Sites or this Policy). Importantly, we may use your information to resolve disputes, troubleshoot problems, and enforce our relevant agreements with you, including this Policy and our Terms of Use.

4. Purposes For Which We Seek Your Consent

We may also ask for your consent to process your personal information for a specific purpose that we communicate to you, for instance, to receive our newsletter and other such mailings you may be interested in. When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your personal information for that purpose.

5. How We Disclose or Share Your Information

We do not use or disclose personal information you provide on our Sites to any outside companies or parties except for third-party service providers who perform functions on our behalf relating to our provision of Services to you that you request through use of the Sites. We do not rent, sell or trade any of our mailing lists. We provide you with the right to opt-out of receiving marketing and other discretionary communications, and to update, supplement or delete your personal information.

We may also be required to disclose your information in response to a lawful and enforceable request by law enforcement, judicial body, or other public authorities, or in connection with a legal obligation. In such instances, we will disclose your personal information upon receipt of a court order, subpoena, or other lawful and enforceable process, or where otherwise required by law.

We reserve the right to report to law enforcement any information – including personal information – related to the use of our Sites that we determine was used to further any unlawful activity or activity we in good faith believe to be unlawful.

6. How We Protect Your Information

We employ reasonable and appropriate security measures to protect your personal information from loss, misuse, unauthorized access, alteration, disclosure and destruction. While we strive to make your information as secure as possible, no transmission system or data network is completely secure. Therefore, by use of the Sites, you acknowledge that there are data security and privacy limitations inherent in the Internet, and that the security, integrity and privacy of any and all information exchanged between you and us, cannot be guaranteed.

7. How Long We Keep Your Information

We keep your personal information to enable your continued use of the Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required by applicable law, as necessary to protect our rights and interests, or as otherwise communicated to you.

8. International Transfers of Your Information

If you are visiting the Sites or utilizing Services from a country other than the United States or Canada, the various communications you send and receive will necessarily result in the transfer of information across international boundaries. If you are located in the European Union you should be aware that information you provide or which is otherwise collected on the Sites or through any Services rendered may be transferred to countries (including the United States) which do not have data protection laws deemed as adequate as those in the EU.

In cases where we need to transfer personal information outside the European Union, we shall ensure that adequate safeguards, as required under applicable data protection legislation, will be implemented (including, as applicable, the European Commission's Standard Contractual Clauses, as appropriate).

9. Your Privacy Rights

We will ensure that you can exercise your rights pertaining to your personal information, including rights as provided by various data protection laws. Where applicable under relevant law, you are entitled:

To have access to your personal information upon simple request – that is, you may receive a copy of such data (if requested), unless such data is made directly available to you, for instance within your personal account.
To have access upon simple request, and free of charge, the categories and names of addresses of third parties that have received Personal Information for direct marketing purposes.
To obtain a rectification of your personal information should it be inaccurate, incomplete or obsolete.
To obtain the deletion of your personal information in the situations set forth by applicable data protection law (the "right to be forgotten").
To withdraw your consent to the data processing without affecting the lawfulness of processing, where your personal information has been collected and processed on the basis of your consent.
To object to the processing of your personal information (where it has been collected and processed on the basis of our legitimate interests) in which case we may ask you to justify your request by explaining to us your particular situation.
To request a limitation of the data processing in the situations set forth by applicable law.
To have your personal information directly transferred by us to a third-party processor of your choice (where technically feasible and when processing is based on your consent).
To non-discrimination, as defined under relevant law, in the Services or quality of Services you receive from us for exercising your rights.

For deletion/"right to be forgotten" requests, we will undertake a good faith effort to accommodate requests for access to or deletion of personal information. However, these requests may be subject to the evaluation of additional factors, including disproportionate burden or expense, or the risk to the rights, including the privacy rights, of others.

We will strive and work to resolve any inquiry you may have regarding our privacy practices. EU residents may also file a complaint before a competent data protection authority regarding the processing of your personal data. While we suggest that you contact us beforehand, if you wish to exercise this right, you should contact the competent data protection authority directly.

If you have any questions, would like to exercise any of these rights, or if you need any assistance with privacy related matters, please contact us as described in the "Contact Us" section below. We will take the necessary steps to respond to you as soon as possible.

10. Children

Our Sites and Services are intended for adults, and are not intended for or directed to anyone under 18 years of age. We therefore do not knowingly collect personal information from anyone under 18 years of age. If you are under 18 years of age, do not attempt use the Site to access Services, and do not provide us any personal information about yourself.

11. Changes to this Privacy Policy

The most current version of this Policy is accessible on this site at all times. We reserve the right to make changes to our Policy at any time and at our sole discretion. We encourage you to review the Policy from time to time to ensure that you are familiar with our practices, and aware of any changes. In addition, we will notify you via email or alert on our Sites if we make material changes to the Policy and what those material changes may be.

12. Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents who have supplied personal information, as defined in the statute, to us to request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2017 will receive information about 2016 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing to us at the below address. Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this address.

13. How to Contact Us

If you have any questions regarding this Policy or our privacy practices, please contact:

Vanessa Williams
Director of Compliance
CrossTower, Inc.
Email: privacy@crosstower.com
Phone: (609) 524-3722