This privacy policy applies to the Croux platform and all sites, services, and applications (the “Platform”) by Croux, Inc. The Platform is owned by Croux, Inc. (“Croux”). The privacy policy also incorporates by reference the Terms of Service and any other policies available on the Platform. By using or accessing the Platform, you accept the practices and policies outlined below, and you consent that we will collect, use and share your information as described in this Privacy Policy.
Croux reserves the right, at its sole discretion, to change, modify, add or remove portions of this privacy policy, at any time. You are responsible for periodically reviewing the privacy policy for changes. By continuing to use the Platform, you accept any changes at the time they are implemented.
This privacy policy describes how any personal information collected as a result of your use of the Platform will be maintained by Croux.
When you access the Platform, Croux will collect some personal data from you. In some instances, Croux may gain access to some personal data through third-parties or affiliates. Some of the information that may be collected can include, but is not limited to:
• contact information such as name, email address, address and telephone number;
• login timestamps, source IP address and the user agent (browser and version);
• AWS account IDs;
• financial information such as credit card or bank account numbers;
• additional information required to verify your identity;
• logs, contact information and other information about the communications between registered users.
• information based on your activities using the Platform, such as search information, computer sign-on data, statistics on page views, traffic to, from and within the Platform, activity and performance data, Platform engagement, ad data, and IP address and standard web log information; and
• supplemental information from third parties (for example, if you incur a debt to Croux, a credit check may be conducted by obtaining additional information about you from a credit bureau, as permitted by law); and
• any other information you may provide.
In addition to the Personal Data described above, Croux may collect Company Data including but not limited to:
• Consumer Data;
• Analytics Data;
• Inventory and Supply Chain Data;
• Product Data;
• Marketing Data; and
• Employee Data.
If you sign in through a third-party company, you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that third-party company would provide to us through that company’s Application Programming Interface (“API”).
If you make a purchase or subscribe to a feature or service of the Platform, you may be required to provide Croux with your payment information, including, without limitation, bank account numbers, credit card or debit card numbers, account details, ACH information, and similar data (collectively, “Payment Information”). Such Payment Information will be collected and processed by Croux or Croux’s third-party payment vendors pursuant to the terms and conditions of their privacy policies and terms of use.
Croux seeks to protect Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. As a User, you should also help protect your data by appropriately selecting and protecting your password or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with access to the Platform. Log data is specifically held for a period of one year. In some cases, Croux may retain Personal Data for longer, if doing so is necessary to comply with legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule, or regulation. Croux may further retain information in an anonymous or aggregated form where that information would not identify users personally.
Croux and third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work may use third-party analytics services (e.g., Google Analytics) to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform usage. These third parties use cookies and other technologies to help analyze and provide Croux the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please contact Croux at support@Croux.co. Please be advised that if you opt out of any such service, you may not be able to use the full functionality of the Platform.
We may share, transfer, or otherwise make available your Personal Data or Company Data to authorized third parties for various purposes including, to process information on our behalf, including service providers, to host the Platform, serve advertisements, send emails on our behalf, run contests, promotions, conduct surveys and research, process any online transactions and to operate certain features on the Platform. Further, such third parties may obtain Personal Data that you voluntarily submit to them to make use of the Platform. Croux is not responsible for the collection and use of your Personal Data or Company Data by these third parties. Croux assumes no liability for any disclosure of Personal Data or Company Data due to unauthorized third-party access or other acts of third parties, or any other acts or omissions beyond reasonable control of Croux.
All personal data collected will be used, primarily, to provide the Services in an effective and personalized manner. Your personal information may be used to:
• Provide customer support and services as requested, including confirming emails related to the Platform, reminders, and transactions.
• Facilitate communication between interested parties registered on the Platform.
• Customize your experience and otherwise measure and improve the Platform.
• Keep you informed about targeted marketing, service updates, and promotional offers through various means of communication.
• Compare information for accuracy and verify it with third parties.
• Measure consumer interest in the products and other services offered by Croux.
• Help promote a safe service and detect and prevent error, fraud and other potentially prohibited or illegal activity.
• Enforce the Terms of Service and other agreements and policies of the Platform.
• To collect fees as otherwise described at the time of collection.
• To create a Trust Score via artificial intelligence.
Disclosure
Croux may share analytics and non-identifying information without your explicit consent. Croux may share some or all of your personal information with:
• Subsidiaries and assigns of Croux and affiliates. Affiliates will use this information to send you marketing communications only if you've requested their services.
• Law enforcement offices, third-party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to enforce the Terms of Use or Privacy Policy; respond to claims that a posting or other content violates the rights of a third party; or protect the rights, property or personal safety of other users or the general public.
• Parties to whom you grant permission for Croux to share.
• Service providers under contract who help with the business operations of the Platform; or
• As permitted by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders or other legal process.
Croux may collect information related to marketing and branding. You agree for someone from or on behalf of Croux to contact you by any means provided for contact through your use of the Platform.
All users have the opportunity to opt out of receiving nonessential (i.e., promotional or marketing-related) communications from Croux after setting up an account. To remove your contact information from Croux’s lists and newsletters, simply unsubscribe by following the opt-out link included in each email.
The Platform may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to recognize your web browser, tell us how and when you visit and use the Platform, analyze trends, learn about Croux’s user base and operate and improve the Platform. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access the Platform. We may also supplement the information we collect from you with information we receive from third parties, including third parties that have placed their own Cookies on your device(s).
We may utilize the following types of Cookies:
• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding the Platform, maintain your preferences over time and recognize you when you return to the Platform. These Cookies help Croux to personalize content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how users use the Platform by collecting information about the number of visitors to the Platform, what pages users view on our Services and how long users are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Platform’s content.
• Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
If you do not want Croux to deploy cookies, you can opt out by setting your device to reject cookies. You can still use the Platform if you choose to disable cookies, although your ability to use some of the features may be affected.
You are responsible for the personal information you provide upon registering. You are also responsible for making any necessary changes to your personal data. If you request, Croux will close your account and remove your personal data from the Platform according to applicable law. Some personal data will be maintained by Croux to comply with law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms of Service, and take other actions permitted by law.
Do not disclose your password to anyone. You are responsible for all actions of your username and password. Giving away your password will permit another person access to your personal data. If your password has been compromised, please change it immediately.
Croux will make every reasonable effort to protect your personal data. Croux, however, makes no warranty or promise that your personal data or private communications will not be intercepted due to unauthorized access or disclosure.
The Platform is not directed to children under the age of 13. Croux adheres to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. If a child under the age of 13 has provided Croux with Personal Information, a parent or guardian of that child may contact Croux and request that such information be deleted from our records.
If you are a California user, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household (“California Personal Information”). For California users, the provisions of this California Addendum prevail over any conflicting provisions in other sections of this Privacy Policy.
We have collected the following categories of California Personal Information within the last 12 months from the sources listed below:
(a) Identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. This category of information is collected from you, your devices, and third parties such as linked sites, and public databases.
(b) Personal information described in subdivision (e) of Section 1798.80 (California customer records statute): such as a name, address, telephone number, credit card number, debit card number, or other financial information. This category of information is collected from you, your devices, and third parties such as linked sites.
(c) Commercial information: including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. This category of information is collected from you, your devices, and third parties such as linked sites, and public databases.
(d) Internet or other similar network activity: including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with a website, application, or advertisement. This category of information is collected from you and your devices.
(e) Geolocation data: including physical location or movements. This category of information is collected from you and your devices.
(f) Sensory data: including electronic, visual, or similar information. This category of information is collected from you and third parties such as linked sites.
(g) Inferences: such as a profile about a consumer’s preferences, characteristics, and behavior, drawn from information we collect and insights we receive from third parties such as our marketing and advertising partners and data analytics providers.
Please see the Collection of Personal Data Section to learn more about the types of information we collect and how we collect them.
For each of the above categories, please see the Use Section for more information on how we use the California Personal Information for our business purposes.
We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.
Within the last 12 months, we have disclosed California Personal Information for our business purposes.
To learn more about the categories of third parties with whom we share such information, please see the Disclosure Section.
We do not sell, and within the last 12 months have not sold, California Personal Information.
If you are a California user, you have certain rights related to your California Personal Information, including:
The right to request that we disclose to you:
o the specific pieces of California Personal Information we have collected about you;
o the categories of California Personal Information we have collected about you;
o the categories of sources from which the California Personal Information is collected;
o our business or commercial purpose for collecting or selling California Personal Information; and
o the categories of third parties with whom we share California Personal Information.
The right to request that we delete California Personal Information about you, which we have collected from you.
You may request to exercise these rights by:
• Calling us at (205) 973-6689; or
• Emailing us at support@croux.co.
As required under applicable law, please note that we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your email address to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law.
We may not discriminate against you because of your exercise of any of the above rights or any other rights, subject to the rights and the obligations under the California Consumer Privacy Act, including by:
• Denying you goods or services;
• Charging different prices or rates for goods or services, including through the use of discounts, loyalty program, or other benefits or imposing penalties;
• Providing you a different level or quality of goods or services; or
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. As permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.
Contractual Necessity: Croux processes the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Service with you, to provide you with access to the Platform. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Profile or Contact Data
• Commercial Data
• Device/IP Data
• Web Analytics
• Social Network Data
• Geolocation Data
• Inferences Drawn From Other Personal Data Collected
• Other Identifying Information that You Voluntarily Choose to Provide
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
• Profile or Contact Data
• Commercial Data
• Device/IP Data
• Web Analytics
• Social Network Data
• Professional or Employment-Related Data
• Geolocation Data
• Inferences Drawn From Other Personal Data Collected
• Other Identifying Information that You Voluntarily Choose to Provide
• We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
• Providing, customizing and improving the Platform.
• Marketing the Platform.
• Corresponding with you.
• Hiring and managing employees.
• Meeting legal requirements and enforcing legal terms.
• Completing corporate transactions.
Consent: In some cases, we process Personal Data based on the consent you grant to us at the time we collect such data.
Other Processing Grounds: From time to time Croux may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
The “Disclosure” section above details how we share your Personal Data with third parties.
The Platform is hosted and operated in the United States (“U.S.”) through Croux and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Platform, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Croux in the U.S. and will be hosted on U.S. servers, and you authorize Croux to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. If you have questions or concerns regarding your personal data, you should contact Croux’s Data Protection Officer at support@Croux.co.
You may contact us with questions and concerns about our privacy policies or practices by contacting us using any of the methods provided in this policy.
The information contained in this policy is subject to change without notice.
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