Privacy Notice – CCPA

Updated: January 10, 2023

Applicability

This California Consumer Privacy Act disclosure explains how Crosslake Technologies (Crosslake or the Company) collects, uses and discloses personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (CCPA) and Consumer Rights Privacy Act of 2020 (CPRA). We are providing this California-specific privacy notice to supplement the information and disclosures already contained in our Crosslake Privacy Notice.

Introduction

Under the California regulations, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the regulations will vary based on our relationship or interaction with that individual.

Keeping Personal Information secure is one of our most important priorities. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, or access, whether it is processed by us or by application service providers that we use to support our business.

Collection or disclosure of personal information

The chart below outlines the categories (as defined by the California regulations) of Personal Information that we have collected or disclosed for a business purpose in the preceding 12 months. The examples of Personal Information provided for each category are taken from the regulations and are included to help you understand what the categories mean. The Personal Information that we actually collect or disclose is also listed in the last column of the table.

Categories of sources of the collection of personal information

In the preceding 12 months, we have collected Personal Information from general sources including you, your use of our services, your devices, our product vendors, and the media companies we use for promotions and campaigns. The categories of sources from whom we collected this Personal Information are:

• Directly from a California resident or the individual’s representatives
• The Crosslake website and Applications
• Public record sources (federal, state or local government sources)
• Commercial sources (Pitchbook)

Categories of third parties to whom we disclosed personal information and business purpose

The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:

• Service providers who provide services such as website hosting, data analysis, web traffic analysis, information technology and related infrastructure, customer service, text messaging or email delivery, auditing, marketing and marketing research activities, communication infrastructure and storage.
• Media companies and social media providers who promote the Company and products to customers and other prospective buyers.
• Third parties who provide services such as payment processing, banking, legal expertise, tax expertise, notaries and auditors. 
• Government agencies, as required by laws and regulations.
• Third parties in connection with a merger, sale, or asset transfer.
• Other third parties for whom we have obtained your permission to disclose your Personal Information. 

Use of Personal Information

In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:

• Performing services, including maintaining or servicing accounts, providing customer service, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Short-term, transient use where the information is not disclosed to a third party and is not used to build a profile or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
• Debugging to identify and repair errors that impair existing intended functionality.
• Undertaking internal research for technological development and demonstration.
• Complying with laws and regulations and to comply with other legal process and law enforcement requirements (including any internal policy based on or reflecting legal or regulatory guidance, codes or opinions).

We may send Crosslake marketing information or newsletters to you. You may opt out from the receipt of additional marketing or newsletter materials from the company at any time.

Sale of Personal Information

We do not sell or share your Personal Information. For purposes of this notice “sell or share” means the disclosure of Personal Information to a third party for monetary or other valuable consideration.

Your California privacy rights 

If you are a California resident, you have the right to:

• Request we disclose to you free of charge the following information covering the 12 months preceding your request:
  • the categories of Personal Information about you that we collected;
  • the categories of sources from which the Personal Information was collected;
  • the purpose for collecting Personal Information about you;
  • the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
  • the specific pieces of Personal Information we collected about you;
• Request we delete Personal Information we collected from you, unless the CCPA/CPRA recognizes an exception; and
• Be free from unlawful discrimination for exercising your rights under the CCPA.

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information may require additional information to verify your identity.

If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as information needed to support human resource requirements, payroll information, or where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA/CPRA’s access or deletion rights.

We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.

We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

How to exercise Your rights

If you are a California resident, you may submit a request or contact us with questions or concerns about this Disclosure and our practices by:

• Writing us at: 5605 Carnegie Boulevard, Suite 175, Charlotte, NC 28209
• Emailing us at privacy@crosslaketech.com

Changes to this California Consumer Privacy Act Disclosure

We may change or update this Disclosure from time to time. When we do, we will post the revised Disclosure on this page with a new “Last Updated” date.