Privacy Policy

Privacy 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 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 EuropeanCommission’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 to 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:
CrossTower, Inc.
Email:[email protected]

Cookie Policy

CrossTower uses cookies and similar technologies when you visit our website or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”), when you use the CrossTower mobile app, and/or interact with CrossTower online advertisements or marketing emails (collectively the “Services”). It explains what these technologies are and why we use them, as well as your rights to control our use of them.
In some cases, we may use cookies and similar technologies to collect personal information, or information that becomes personal information if we combine it with other information. In such cases the CrossTower Privacy Policy will apply in addition to this Cookie Policy.
If you have any questions about our use of cookies or other technologies, please email us at [email protected]

WHAT ARE COOKIES?

Cookies are small files, typically of letters and numbers, downloaded onto your computer or mobile device when you visit certain websites. When you return to these websites, or visit other websites that use the same cookies, the websites recognize these cookies and your browsing device. A cookie cannot read data off your hard drive or read cookie files created by other websites.
Cookies set by the website operator are called “first-party cookies”. Cookies set by parties other than the website operator are called “third-party cookies”. The parties that set third-party cookies can recognize your computer both when it visits the CrossTower website and when it visits certain other websites and/or mobile apps.
We treat information collected by cookies and other technologies as non-personal information. However, to the extent that IP addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. If we combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.
More information on cookies and their use can be found at www.aboutcookies.org or www.allaboutcookies.org.

WHY DO WE USE COOKIES?

When you access our Services, we or companies we work with may place cookies on your computer or other device. These technologies help us better understand user behavior, and inform us about which parts of our websites people have visited.
We use first-party and third-party cookies to recognize you as a CrossTower customer, customize CrossTower Services, content, and advertising, to measure promotional effectiveness, and to collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from CrossTower. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies.
The following are some examples of non-personal information that we collect and how we may use it:

  • We may collect and store details of how you use our Services. Except in limited instances to ensure quality of our Services over the Internet, such information will not be associated with your IP address.
  • We may collect information such as your language, zip code, area code, unique device identifier, referrer URL, location, and the time zone so that we can better understand customer behavior and improve our Services.
  • We may collect information regarding customer activities on our website, which is used to understand which parts of our Sites and Services are of most interest. This data is aggregated, and thus is considered non-personal information for the purposes of this Privacy Policy.

WHAT TYPES OF COOKIES DO WE USE?

We use the following types of cookies:

  • Strictly Necessary Cookies
    These cookies are essential because they enable you to move around our Services and use certain features on our Services. For example, strictly necessary cookies allow you to access secure areas. Without these cookies, some Services cannot be provided.
  • Performance/Analytics Cookies
    These cookies collect information about how you use a website. For example, a performance/analytics cookie will collect information about which pages you go to most often, how much time you spend on that page, or if you get error messages from certain pages. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is only used to improve how our Services work.
  • Functionality Cookies

These cookies allow us to remember the choices you make and to tailor our Services so we can provide relevant content to you. For example, a functionality cookie can remember your preferences (e.g., country or language selection), or your username. Session Cookies. We use session cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser.

HOW LONG WILL COOKIES STAY ON MY BROWSING DEVICE?

The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).
WHAT OTHER SIMILAR TECHNOLOGIES DOES CROSSTOWER USE?
In addition to cookies, we may use other similar technologies, like web beacons to track users of our Services. Web beacons, or “clear gifs,” are tiny graphics with a unique identifier, similar in function to cookies. They are used to track the online movements of web users.
In contrast to cookies, which are stored on a user’s computer hard drive or device, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We and our third-party service provider employ web beacons for the reasons stated above (under “Cookies”), but primarily to help us better manage content on our Services by informing us which content is effective.
We may also use so-called “Flash Cookies” (also known as “Local Shared Objects or “LSOs”) to collect and store information about your use of our services, fraud prevention and for other site operations.

DOES CROSSTOWER USE ADVERTISING COOKIES?

CrossTower may choose to use third-party service providers to display advertising on our Services and serve advertising on other third party sites that are more relevant to you or your interests. They are also used to limit the number of times you see an advertisement, as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information may be shared with other organizations, such as advertisers. This means that after you have been to our websites, you may see some advertisements about our Services elsewhere on the Internet. The information collected through this process by the third party service providers does not enable us or them to identify your name, contact details or other personal information that directly identifies you unless you choose to provide these. Such advertising will only be delivered where permitted by applicable law.
HOW TO MANAGE COOKIES, SIMILAR TECHNOLOGIES AND TARGETED ONLINE MOBILE ADVERTISING
You have the right to decide whether to accept cookies. You can exercise your preferences in relation to cookies served on our Sites by taking the steps outlined below.
Our Cookies (or, “First-Party Cookies”).You can use the browser with which you are viewing this website to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings athttp://www.allaboutcookies.org.
Mobile Advertising:You can opt out of having your mobile advertising identifiers used for certain types of advertising by accessing the settings in mobile device and following the instructions. If you opt-out, we will remove all data about you and will not collect any further data. The random ID previously assigned to you will be removed. Thus, if at a later stage, you decide to opt-in, we will be unable to continue and track you using the prior ID and you will for all practical purposes be a new user.
Third-Party Cookies.To opt-out of third-party advertising networks and similar entities that use targeting/advertising cookies, go to http://www.aboutads.info/choices. Once you click the link, you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers.
Do Not Track: Some Internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.

WILL THIS COOKIE POLICY BE UPDATED?

We may update this Cookie Notice from time to time to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. If we do, you will be notified when you first visit our website after the change. You can also revisit this page if you wish to keep yourself informed.

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