PRIVACY
NOTICE

Last updated: January 31, 2019

This Website Privacy Notice (the “Notice”) describes how iCrossing, Inc. and its affiliates (collectively, “iCrossing,” “we,” “our” or “us”) handle personal information that is collected on www.icrossing.com, including country or region specific pages (collectively, the “Site”). This Notice describes how we can use this personal information and with whom we may share it. This Site is primarily directed to our clients and prospective clients, and to potential job applicants. This Site is not directed to individuals who are looking for digital marketing services for their personal, family, or household purposes.

This Notice applies only to personal information that iCrossing collects on or obtains through this Site and not to any information that we collected through other methods or our services, including the services we provide to our clients.

For purposes of this Notice, “personal information” refers to information or combinations of information that could reasonably allow you to be identified.

We maintain country and region-specific sections on our Site and our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements. Please visit the webpage of the specific country or region to learn more about available iCrossing services in the country or region. For more information about our privacy practices in relation to certain countries, please see the “ADDITIONAL INFORMATION FOR EUROPEAN VISITORS” and “ADDITIONAL INFORMATION FOR VISITORS IN MEXICO” sections further down below.

WHAT PERSONAL INFORMATION DO WE OBTAIN?

Information You Provide – If you choose to subscribe to our newsletter or contact us by email or otherwise, we collect the contact information that you provide us which may include your name, company name, job title, email address, phone number, and any other information you may choose to provide us when you contact us.

Information Automatically Collected About Your Visit – We may automatically receive certain information when you visit our Site, including through cookies and other tracking technologies, such as pixel tags. We use cookies and tracking technologies to collect your IP address, cookie or other unique identifiers, device ID and device type, ISP provider, browser type, access times and referring URLs, the pages and content you view on our Site, the search terms you enter on our Site, and the actions you take on our Site.

Third parties may also collect information from the Site using cookies and other tracking technologies. These third parties collect data directly from your web browser, and their processing of the information collected is subject to their own privacy policies.

For more information on the cookies and tracking technologies on the Site, see the ADDITIONAL INFORMATION REGARDING COOKIES AND OTHER TRACKING TECHNOLOGIES section below.

Information We Obtain From Other Sources – We may obtain your contact information from organizers of industry events or conferences, through clients and referrals, or other sources such as LinkedIn. This information generally consists of your business contact information such as your name, title, email, address and phone number.

Interest-Based Advertising - On our Site, we and third parties may collect information about your online activities to provide you with advertising about services or products tailored to your interests. You may see certain ads on other websites because we or such third parties participate in advertising networks. Ad networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The information ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites or apps that participate in the ad networks. This process allows us and third parties to deliver more tailored advertising. In addition, it helps us track the effectiveness of our marketing efforts. To learn how to opt out of certain ad network interest-based advertising, click here. Visitors from the EU can click here.

Social Media Widgets – The Site includes social media functions, such as Facebook, Instagram, LinkedIn, Twitter and YouTube widgets. These widgets may collect information about which pages you visit on the Site and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly. Social media functions and widgets are hosted either by a third party or directly on the Site. Your interactions with the social media functions and widgets located on the Site are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on this Site, we strongly suggest you review the privacy policies of the companies that provide those functions and features.

Job Application Through Our Careers Pages – If you submit a job application on our careers pages, you may provide your name, email address, phone number, information regarding your education and employment history, demographic information (e.g., salary, age, nationality), and any other information contained in your resume or cover letter. You also may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., LinkedIn). The information we may receive varies by site and is controlled by that site. By authorizing iCrossing to have access to this information, you agree that iCrossing may collect, store and use this information in accordance with this Notice. In addition, in connection with your job application for a position with us, we may receive personal information from current and past employers, employment and recruiting agencies (e.g., resumes and references), references, government agencies, educational institutions, certification bodies, and other third parties.

HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

Our primary purposes for processing your personal information are:

• providing you with the information you request from us and communicating with you in response to your correspondence or other requests;
• providing you with iCrossing services and other offerings;
• providing, maintaining, and protecting the Site;
• detecting, preventing, and responding to violations of this Notice, violations of law, or other misuse of the Site;
• complying with the legal obligations to which we are subject and cooperating with regulators and law enforcement bodies; and
• supporting our business operations.

We use the personal information we obtain in connection with the operation of this Site for the following additional purposes:

• marketing and advertising our services;

• customizing your experience when using the Site;

• personalizing the marketing messages we send to you to make them more relevant and interesting;

• improving the Site and the services we provide; and

• generating and analyzing statistics about your use of the Site.

If you submit a job application through our careers pages, we use the information you submit to process your application, assess your skills and interest in career opportunities at iCrossing, conduct background checks (as permitted by applicable law), and communicate with you about your application, requests, questions or comments.

WITH WHOM DO WE SHARE THE PERSONAL INFORMATION WE COLLECT?

We may share the personal information we collect from you through the Site with:

• service providers who provide or perform products, services or functions on our behalf and based on our instructions (such as sending emails, newsletters and other communications, or providing application tracking and recruiting services for our Careers pages);

• our affiliates and subsidiaries. We may share your contact information, Site usage information and other information with our affiliates and subsidiaries for marketing purposes, internal reporting, service optimization, contracting or billing, and recruiting;

• with law enforcement agencies, courts, regulators, government authorities or other third parties as required by law, such as to comply with a subpoena or other legal process, to comply with government reporting obligations or in response to requests by government or law enforcement authorities, or otherwise to protect our rights or the rights of any third party; and

• with affiliates, service providers, advisors, and other third parties to the extent reasonably necessary to proceed with the consideration, negotiation or completion of a merger, acquisition, or sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.

The recipients referred to above may be located outside of the jurisdiction in which you are located (or in which we provide the services). See the section on “International Data Transfer” below for more information.

HOW IS YOUR PERSONAL INFORMATION SECURED AND STORED?

We maintain reasonable administrative, technical, and physical safeguards designed to safeguard the personal information we collect through this Site. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks.

THIRD-PARTY WEBSITE LINKS AND FEATURES

This Site may contain links to third-party websites or features. iCrossing is not responsible for the collection and use of your personal information by such third parties that are not under our control. We encourage you to review the privacy policies applicable to third-party websites or features.

ADDITIONAL INFORMATION REGARDING COOKIES AND OTHER TRACKING TECHNOLOGIES

We use the information we collect from cookies and other tracking technologies (collectively, “Cookies”) to operate the Site, understand Site usage and improve the content and offerings on our Site. We also use the information to develop aggregate reports about Site users, to improve performance, and to improve your experience with the Site. We may also use Cookies to gather information about your interactions with email messages and other communications we send to you (e.g., B2B newsletter), such as whether you opened or forwarded the email or clicked on links contained in the email

The information collected for these purposes may be disclosed to or collected directly by our third-party web analytics service providers, such as Google Analytics. The following table describes the categories of Cookies we use and why we use them:

Most web browsers include an option that allows you to not accept web cookies. However, if you set your browser to refuse web cookies, some portions of our Site may not function efficiently. We do not currently respond to web browser “do not track” signals on this Site.

INTERNATIONAL DATA TRANSFERS

Your personal information will be collected in, transferred to, stored in, or processed in the United States, which may not provide the same level of protection for your personal information as your home country. When we transfer personal information across national borders, we put in place safeguards (such as contractual commitments) in accordance with applicable legal requirements to protect your personal information. For more information on the appropriate safeguards we have in place, please contact us at the details below.

MARKETING CHOICES

When you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional e-mail you receive or by contacting us as described in the Contact Us section below. We may still send you relationship and/or transactional (non-marketing) emails regarding our services, and notices of updates to our Notice if we choose to provide such notices to you in this manner.

CHANGES TO THIS WEBSITE PRIVACY NOTICE

We may update periodically this Notice and without prior notice to you to reflect changes in our personal information practices. If we make changes to this Notice, we will post a new Website Privacy Notice on this page. We encourage you to review our Notice periodically to remain informed of changes that may have occurred.

CONTACT US

The iCrossing entity responsible for the country or region specific Site that you are using or accessing is the entity responsible for the personal information we collect and process in relation to that portion of the Site. If you have any questions about this Notice or our use of your personal information collected through the Site, please contact the relevant entity as indicated below:

ADDITIONAL INFORMATION FOR EUROPEAN VISITORS

For the contact information of the iCrossing entity responsible (i.e., data controller) for the personal information we collect and process about Europeans through the Site, please review the “Contact Us” section above and contact the relevant iCrossing entity in Europe.

We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:

• to fulfil our contractual obligations to you, for example to provide the services you request. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations;

• to comply with our legal obligations, for example to respond to legally binding requests from regulators, law enforcement authorities or other government authorities;

• to meet our legitimate interests, for example to understand how you use the Site, to improve the Site, to identify new business opportunities, and to communicate with you regarding products and services that may be of interest to you. When we process personal information to meet our legitimate interests, we put in place safeguards to protect the information and your privacy;

• to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details provided above.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

• Maintain business records for analysis and/or audit purposes;

• Comply with record retention requirements under the law;

• Defend or bring any existing or potential legal claims;

• Deal with any complaints regarding the services;

• Enforce our commercial agreements.

Your Rights

You have certain rights regarding your personal information, subject to local law. These include the following rights to:

• request access to your personal information;

• request that we rectify the information we hold about you;

• request that we erase your personal information;

• request that we restrict our use of your personal information;

• object to our use of your personal information;

• request that we provide you with certain personal information that you have provided in a usable electronic format and transmit it to a third party (right to data portability);

• lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact us at the details listed above. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

We are committed to working with you to obtain a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority.

ADDITIONAL INFORMATION FOR VISITORS IN MEXICO

You have certain rights regarding your personal information. These include the following rights to:

• access your personal information;

• rectify the information we hold about you;

• erase your personal information; and

• object to our use of your personal information;

If you would like to discuss or exercise such rights, or if you wish to withdraw your consent to the processing of personal information for purposes other than those that are considered necessary to the existence, maintenance, and compliance of our legal relationship, please contact iCrossing Mexico by using the contact information provided in the Contact Us section above.