Privacy Policy Addendum
Last Updated: October 1, 2020
This Privacy Policy Addendum applies in circumstances where the privacy practices of Caring Cross are subject to the General Data Protection Regulation (“GDPR”) of the European Union (“EU”). If you are a resident of the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the GDPR with respect to your Personal Data, as outlined below.
For this Addendum, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Caring Cross will be the controller of your Personal Data processed in connection with your use of Caring Cross’s website or the services that Caring Cross provides (such website and services, collectively the “Services” and each a “Service”).
Where applicable, this Addendum is intended to supplement, and not replace, Caring Cross’s Privacy Policy at https://staging.caringcross.org/privacy-policy/ (the “Privacy Policy”). If there are any conflicts between this Addendum and Caring Cross’s Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this notice or whether any of the following applies to you, please contact us at [email protected].
What Personal Data Do We Collect from You?
We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services.
Information we collect directly from you:
We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation your name, email address, telephone number, company or institution name and title.
Information we receive from third party sources:
Some third parties such as our service providers provide us with Personal Data about you, such as the following:
Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services, or if you share content from our Services through a third party social media service, the third party service will send us information about you, such as information from your public profile, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.
Contact information derived from third party sources: We may derive contact information about you from third party sources if the third-party source and your account settings with them allow such sharing.
Information from recruiting partners: If you apply for a job with us, we receive information about your application through third party recruiting services and applicant tracking systems. We may also receive contact information about you from third party recruiting services.
Information we automatically collect when you use our Services:
Some Personal Data is automatically collected when you use our Services, such as the following:
- IP address
- Device identifiers
- Web browser information
- Page view statistics
- Browsing history
- Usage information
- Location information (e.g. IP address, zip code)
- Log data (e.g. access times, hardware and software information)
Information we automatically collect from Tracking Tools: We and our third party service providers collect information about you, your device, and your use of the Service through cookies, clear gifs (a.k.a. web beacons/web bugs) (“Web Beacons”), and other tracking tools and technological methods (collectively, “Tracking Tools”). Tracking Tools collect information such as computer or device operating system type, IP address, browser type, browser language, mobile device ID, device hardware type, the website or application visited or used before or after accessing our Service, the parts of the Service accessed, the length of time spent on a page or using a feature, and access times for a webpage or feature. These Tracking Tools help us learn more about our users and analyze how users use the Service, such as how often users visit our Service, what features they use, what pages they visit, what emails they open, and what other sites or applications they used prior to and after visiting the Service.
Cookies: Like many websites and mobile application operators, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Service. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Service, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Service. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Service varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Service. For more information on cookies visit http://www.allaboutcookies.org/ .
Web Beacons: Web Beacons help us better manage content on our Service by informing us what content is effective. Web Beacons are embedded in, or otherwise associated with, certain emails or other communications that you receive from us or our partners. Web Beacons help us track your responses and interests and deliver relevant content and services to you. For example, they may let us know when you take actions based on the emails that we send.
How Do We Use Your Personal Data?
We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:
- Create and manage user accounts
- Communicate with you about the Services
- Contact you about Service announcements, updates or offers
- Provide support and assistance for the Services
- Log and analyze product usage to fix bugs and improve the Services
- Comply with our legal or contractual obligations
- Protect against or deter fraudulent, illegal or harmful actions
- Enforce our Terms of Use
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity: We process 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, which enables us to provide you with the Services. 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.
- User account data (Name, Address, Email, Phone)
Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.
- User account data
- User machine data
- Product analytics data
- Candidate and applicant data
Examples of these legitimate interests include:
- Operation and improvement of our business, products and services
- Provision of customer and member support
- Protection from fraud or security threats
- Completion of transactions
- Recruiting and hiring
Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we 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.
How and With Whom Do We Share Your Data?
We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Use. These parties include:
- Cloud hosting services
- Analytics services
- Email marketing services
- Customer relationship management services
- Applicant tracking services
- Customer support services
We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:
- Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
- Other parties authorized by you
We also share Personal Data when we believe it is necessary to:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
- Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
- Maintain the security of our products and services
We also share information with third parties when you give us consent to do so.
Furthermore, in the event Caring Cross goes through an organizational transition, such as a merger, acquisition or other strategic relationship, the Personal Information of Caring Cross’s Users will, in most instances, be part of the assets transferred or shared. You acknowledge that such transfers and/or sharing may occur, and that any acquirer or strategic partner may continue to use your Personal Data as set forth in this policy.
How Long Do We Retain Your Personal Data?
We retain Personal Data about you for as long as you have an open membership with us or for 13 months after you close your account. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
What Security Measures Do We Use?
We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity. All supplied sensitive information is transferred via Transport Layer Security (TLS) technology and stored encrypted at rest using AES-256 encryption.
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain types of your Personal Data by emailing [email protected].
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data by emailing [email protected].
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Caring Cross 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 Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Caring Cross in the U.S. and will be hosted on U.S. servers, and you authorize Caring Cross 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.
What If You Have Questions Regarding Your Personal Data?
If you have any questions about this Addendum or our data practices generally, please contact us by email at [email protected].
