This Privacy Policy describes in detail who is responsible for the personal data that we collect about you, what personal data we collect, how we will use such personal data, who we may disclose it to and your rights and choices in relation to your personal data.

In this Privacy Policy we use the words “personal data” to describe information that is about you and which identifies you. Section 2 below sets out the personal data we collect in more detail.

1. Who is Responsible for the personal data that we Collect?

For the purpose of data protection law, Crossover Markets is the data controller in respect of the personal data that we collect and use as part of our business activities. This is because we determine the purpose for which your personal data is used and how we use your personal information. In certain instances, an entity related to Crossover, such as a subsidiary, may act as the data controller. 

2. What personal data do we Collect?

While some of the information collected is required for membership or business engagement purposes, other information is voluntarily given by the individual. The type of personal data that Crossover may collect could include, but is not limited to, the following:

• Your full name, address, phone, fax and email contact information
• Your practice areas
• Information about your employment such as employer name, title, address, the industry of your employer, and size of your employer or department
• Payment information
• Dietary preferences and requirements
• Photos
• Preference information, such as the communications you receive from us
• Information you provide to us for the purposes of attending meetings, events, webinars and other programs
• Any other information relating to you (or other individuals) that you provide to us

 If you are providing personal data to us relating to a third party, you confirm that (i) you have the consent of the third party or another legal basis to share such personal data with us; (ii) you have the consent of the third party or another legal basis for us to use their personal data in accordance with this Privacy Policy; and (iii) that you have made the information in this Privacy Policy available to the third party.

 Sensitive or Special Categories of Information

Some countries consider some personal data particularly sensitive or special. Crossover only collects this data when voluntarily given by the individual, such as for onboarding or related compliance requirements, processing for a stated purpose when necessary, and for statistical purposes only. Crossover does not share this information with third parties for direct marketing purposes. Such information may include the following:

• Date of birth
• Ethnicity, nationality, gender and other demographic information

 Website Usage Information

We collect information when you provide it to us, such as when you use the “contact us” feature on the website or otherwise communicate with us (such as by email or via our social media pages).

Crossover collects certain information automatically when you use the website, such as the IP addresses and domain names of visitors, browser type, history of pages viewed and other usage information about your use of the website. We collect this information for site administration purposes, such as to analyze this data for trends and statistics. We may share statistical or aggregated information about our users with advertisers, business partners, sponsors and other third parties. This data is used to customize our website content and advertising to deliver a better experience to our users. Please see the section below on cookies for more information.

3. How do we obtain your Personal Data?

As noted above, we collect information from you in the course of your use of the Crossover website, products and services. For example, we collect information from you when you enroll as a member. We collect information from you when you contact or communicate with us (including through the website, by email or otherwise). We also collect your personal data while monitoring the Crossover website, products and services. We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering for an event. We may also in certain cases collect or receive information about you from other sources, such as from an administrative user in your organisation in order to create a member account for you.

4. How do we use the personal data we Collect?

Crossover collects personal data for the following principal purposes. We have also set out below the legal basis (as set out in the General Data Protection Regulation “GDPR”) that we rely on to justify each use of your personal data.

Purpose: Legal Bases

• To provide the Crossover website to you and, depending on the circumstances, to perform a contract between you and us
• To register you for Crossover events 
• To provide you with products or services that you have requested and related information about those products and services; 
• To communicate with you and to respond to questions that you have raised with us; 
• To administer and improve the Website; and to improve and ensure the security of Crossover products and services) · We may request your consent in circumstances where a legal justification over and above legitimate interest is required by applicable law (e.g., in relation to our use of certain cookies)
• To process your payments· To send you, or for our third party partners to send you, information about products, services and events that may be of interest to you; 
• To administer surveys; 
• To prevent and detect fraud; · 
• To protect and enforce our legal rights and comply with legal obligations. · 

5. Who do we share your personal data with?

Crossover reserves the right to disclose and/or transfer personal data to a third party if Crossover has reason to believe that disclosing the personal data is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other website users or anyone else who could be harmed by such activities. Additionally, Crossover may disclose personal data in response to a subpoena, warrant or other court order, or when we believe in good faith that a law, regulation, subpoena, warrant or other court order requires it – or authorizes us to do so – or to respond to an emergency situation.

Crossover reserves the right to disclose and/or transfer personal data to a third party in the event of a proposed or actual purchase, sale (including a liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Crossover, or of any of the business of Crossover or a affiliate/division thereof, in order for you to continue to receive the same products and services from the third party.

We may share information with affiliated entities. See more information with respect to such transfers under the section entitled “Transfer of personal data Across Borders.”

We may share your information with professional advisors, such as accountants and lawyers, who assist us in carrying out our business activities.

Crossover may share personal data with third parties engaged to assist Crossover in providing services to you or to carry out one or more of the purposes described above. These service providers are prohibited from using your personal data for any purpose other than to provide this assistance and are contractually required to protect personal data disclosed by Crossover and to comply with law and the general privacy principles described in this Privacy Policy. We share your information with service providers, contractors and sub-contractors to help us provide the website, products, events and services. For example, we may use a service provider to process payment information, manage our events, provide a platform for our events, provide analytics or use third party software to manage our customer relationship management (CRM) system.

In addition to the uses and disclosure of personal data noted above, personal data of Crossover members and registrants at our events may be shared with the following entities based on our legitimate interest to do so:

• We share your personal data with our event sponsors so they may contact you with information about the sponsor’s activities, services and products. For example, personal data of registrants of educational programs may be shared with sponsors of these meetings for promotional purposes. You will have the option to opt out of sharing this information when you register for the programs or by contacting info@crossovermarkets.com at any time. In some instances, if you opt out of allowing us to share your personal data, you will be unable to participate in an program or event. The information provided will contain your name, title, company and mailing address.

6. Transfer of personal data Across Borders 

Crossover is headquartered in the United States of America. We may allow your personal data to be shared with our related entities or third-party service providers based in the United States and/or in other countries. This may entail a transfer of your information from a location within the European Economic Area (“EEA”) to one outside the EEA, or from outside the EEA to a location within the EEA. Please see the section entitled ‘Who do we Share your personal data with’ for more detail on how the information may be shared with Crossover related entities and third party service providers.

When we provide your personal data across borders, we do so in connection with providing you with member benefits, requested information or services or as required or authorized under law. The receiving entities we share your information with may not be subject to laws that provide the same level of protection of information as your country of residence or employment, or may not be subject to any privacy obligations. Those entities may be required or compelled to disclose your personal data to a third party, such as a national or local authority.

 When we transfer information outside the EEA, we will implement appropriate measures to ensure that your personal data remains protected and secure in accordance with applicable data protection laws. For example, we will implement EU standard contractual clauses (as contemplated by Article 46(2) of the GDPR) between the Crossover related entities that share and process personal data. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses. For more information about the measures in place, please contact us (see section below ‘Contacting Crossover with Questions, Concerns or Complaints’).

 Unfortunately, the transmission of information via the internet is not completely secure. Although we use reasonable efforts to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website and any transmission is at your own risk. Once we have received your personal data, we will use reasonable and appropriate procedures and security features to try to prevent unauthorized processing.

7. Your Rights, including Removing, Correcting or Updating Personal Information

If you change your mind on how Crossover discloses or uses your information, or wish to access, correct or update personal data (such as your address), we will endeavor to correct, update or remove the personal data you give us.

THE BELOW TABLE APPLIES TO INDIVIDUALS LOCATED IN THE EUROPEAN UNION (EU) AND EUROPEAN ECONOMIC AREA (EEA) ONLY: You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights and who to contact to exercise them.

Summary of your rights 

Who to contact: Legal at info@crossovermarkets.com 

Right of access to your personal information You have the right to receive a copy of the personal data that we hold about you, subject to certain exceptions. We may require further information in order to respond to your request (for instance, evidence of your identity and information to enable us to locate the specific personal data you require). 

Right to rectify your personal information You have the right to ask us to correct the personal data that we hold where it is incorrect or incomplete.  You may at any time revise this information or question it by directly contacting us.

Right to erasure of your personal information: You have the right to ask that your personal data be deleted in certain circumstances. For example where your personal data is no longer necessary in relation to the purposes for which they were collected or otherwise used by contacting us .

Summary of your rights Who to contact was based on your consent and there is no other legal ground for our continued use of your personal data; (iii) if you object to the use of your personal data (as set out below); (iv) if we have used your personal data unlawfully; or (v) if your personal data needs to be erased to comply with a legal obligation. If you do not want to make a long distance phone call, please email us with your contact information and best times to reach you, and we will contact you as soon as it is practical.

Right to restrict the use of your personal information: You have the right to suspend our use of your personal data in certain circumstances. For example (i) where you think your personal data is inaccurate and only for such period to enable us to verify the accuracy of your personal information; (ii) where you believe the use of your personal data is unlawful; (iii) when we no longer need your personal data, but you require it you for the establishment, exercise or defense of legal claims; or (iv) if you have objected to the use of your personal data and we are verifying whether our grounds for the use of your personal data override your objection. 

Right to data portability: You have the right to obtain your personal data in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your personal data is based on your consent or for the performance of a contract, and when the use of your personal data is carried out by automated (i.e. electronic) means. 

Right to object to the use of your personal data: You have the right to object to the use of your personal data in certain circumstances. For example where you have grounds relating to your particular situation and we use your personal data for our legitimate interests (or those of a third party).

Right to withdraw consent: You have the right to withdraw your consent at any time where we rely on consent to use your personal data. 

Right to complain to the relevant data protection authority: You have the right to complain to the relevant data protection authority where you think we have not used your personal data in accordance with data protection law. Find your National Data Protection Authority online.

8. How Long will we Keep your Personal Data?

We will keep your personal data for the period of in which we believe it is of use to us in accordance with this Privacy Policy plus 5 years.

9. Links to Other Websites

The Crossover Website may contain links to other sites. These sites are not controlled by Crossover and Crossover is not responsible for any content contained on any such website. We are not responsible for the privacy practices employed by other sites, and the privacy practices employed by such sites may not be the same as our practices. As with our website, you should become familiar with any external party’s privacy policy before visiting and/or providing any personal data through any such site.

10. Cookies

Crossover uses cookies to manage our website and email programs. A cookie is a small file placed on your computer when you visit a website. Cookies are used to store information to manage your website experience such as your type of web browser. A cookie can also store preference information to customize your website experience.

Cookies help us understand how consumers use our websites and emails so we can design better services in the future.

Web browsers can be adjusted to disable cookies. However, Crossover may not be able to provide you with all the service or functionality you require on the Crossover website if you choose to disable cookies.

You may also remove cookies from your browser. The cookie Crossover has loaded onto your browser is called cookieyes-consent. Please refer to your browser’s help menu for instructions.

11. Contacting Crossover with Questions, Concerns or Complaints

Should you have any questions, concerns or a complaint about this Privacy Policy, please contact INFO at info@crossovermarkets.com or via mail at 80 Morristown Rd, Unit 3B #255, Bernardsville, NJ 07920.You are entitled to make an anonymous complaint or inquiry in relation to this Privacy Policy or your privacy rights; however, we may require you to identify yourself if required by law or it is impracticable for us to deal with your matter otherwise.

We will endeavor to provide you with a written response within 30 days of receipt of your complaint. There may be instances where this is not possible due to the contents of the complaint. In such circumstances, we will respond to your complaint in a reasonable and practical time.

If you are not satisfied with the outcome of your complaint you may contact the appropriate authorities in your jurisdiction.

12. Crossover Website and Communications Terms of Use Please refer to Crossover’s Terms of Use on all issues related to accessing, posting and sharing information through our website and communication services.
13. Changes to our Privacy Policy

Any material changes to this Privacy Policy will be posted on this page. Subject to any applicable legal and/or regulatory requirements, the updated Privacy Policy will take effect and be binding on you as soon as it has been updated.

Crossover reserves the right to amend the terms of this Privacy Policy from time to time at its absolute discretion.

This Privacy Policy was last updated as 1 September 2022.