Privacy Policy

CrossRem Privacy Policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain pieces of personal information about you. When we do so we are subject to various laws in the United States and the across Europe and the United Kingdom (including the GDPR, UK GDPR, Data Protection Act 2018 and any other applicable data protection and privacy legislation) and we are responsible as “controller” of that personal information for the purposes of those laws.

Part A: United States (“U.S.”) Privacy Protection

I. Introduction

In this Part A. we explain the processing of your personal data when you use the app. Personal data refers to all data that can be related to you personally, such as login name, email or even your IP address. In the following, we will simply use the term “data’.

Which of your data we process depends on your particular use of the app. In any case, we strive to adhere to the highest standards of data security. Presently, the most favorable legal regime for the protection of user data is the European one, known as the GDPR. The GDPR establishes the floor on which we also strive to comply with less strict, but not always identical data protection law of several states. Part B. describes the strict GDPR rules which will also benefit you even if you are in the United States, in addition to the specific U.S. protections, except that the state institutions under the GDPR rules are not available to persons not in the U.K. or the European Economic Area.

II. U.S. State Law Data Protection

U.S. State law usually protects users who are residents or consumers from a particular state with certain exceptions. This Section II. contains specific protections we apply under the state laws discussed below.

Some jurisdictions provide consumers or certain other users with special rights which we respect. In this document, we disclose information about certain state rights and our general privacy policy and your rights. Depending on the particular issue and situation, we protect your data under California, Colorado, Connecticut, Delaware, Nevada, Virginia, Utah or other state privacy laws, under some aspects of U.S. federal law, and under the generally stricter European data protection law. In the interest of transparency, we state the options you have as well. In the event of conflicts between laws, we will strive to implement the stricter rules in order protect your privacy and your data.

1. California Disclosure

The California Consumer Privacy Act of 2018 as amended (CCPA) gives California consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. This law secures privacy rights for California consumers, including:

The right to know about the personal information a business collects about them, how it is used and shared, and to limit the use and disclosure of sensitive personal information
The right to opt out of, or the sale of, personal information;
The right to delete and correct personal information collected from them (with some exceptions);
The right to opt-out of the sale of their personal information; and
The right to non-discrimination for exercising their CCPA rights.
The right to complain to the California supervisory authority if you believe that your rights are infringed.

These rights overlap with those under the generally stricter rules that we practice. In addition, California consumers may ignore provisions of this privacy policy they believe may conflict with the CCPA. They may also take advantage of those CCPA provisions that are not listed below. If there is a conflict between the rules, we will apply the rules that better protect you.

2. Colorado Disclosure

Colorado Privacy Act

We strive to abide by the Colorado Privacy Act. Under this Act, you enjoy certain rights, including the right to opt out of the processing of personal information for targeted advertising, its sale, and certain profiling. You may authorize another person to exercise your rights. You also have the right to access your personal information, correct it and request that we delete it. We are required to ensure data portability and will respond to consumer requests. We comply with the requirement of de-identifying your personal information and strive minimize the use of personal information as stated below.

3. Connecticut Disclosure

Connecticut Data Privacy Law

You have the right to: (i) Confirm whether or not a controller is processing your personal data and to access such personal data, unless such confirmation or access would require us to reveal a trade secret; (ii) correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data; (iii) delete personal data provided by or obtained about you; (iv) obtain a copy of your personal data processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided we shall not be required to reveal any trade secret; and (v) opt out of the processing of the personal data for purposes of: (a) targeted advertising, (b) the sale of personal data (except as provided under Connecticut law), or (c) profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer. We also strive to comply promptly with all other requirements, procedural and substantive, of the law as it may apply to us and you or your authorized representative.

4. Delaware Online Privacy

Delaware law requires that we identify the information collected, offer users an opportunity to review and change the data, describe the notification process for changes in the Privacy Policy, identify third parties to the information, and include an effective date. In particular, it also protects your rights with respect any Do Not Track request that you may submit to us. These protections are reflected in our general policy that follows, and to the extent that it conflicts with stronger rights that apply to a user under Delaware law, we will abide by its provisions for the enforcement and protection of your rights.

5. Nevada Online Privacy

We apply our Privacy Policy to comply with the terms of the Nevada online privacy statute and, in the event that the statute applies to you, we will abide by its provisions for the enforcement and protection of your rights.

If you are a Nevada resident, you have the right the right to request the following Personal Information from us regarding the collection and sale of your Personal Information acquired through your use of our service (website or app): (i) First and last name; (ii) Home or other physical address, which includes the name of a street and the name of a city or town; (iii) Email address; (iv) Telephone number; (v) Social security number; (vi) Identifiers that allow a specific person to be contacted, either physically or online; and (vii) Any other information concerning a person collected from the person through the Internet or Service and maintained by the operator in combination with an identifier in a form that makes the information personally identifiable.

We collect the Personal Information listed above directly from Users and devices or from third parties, such as social media networks, Partners, and other analytics providers. This Personal Information may be shared with third parties. We do not sell Personal Information about you to other companies for money. We do allow some third parties, such as advertising partners, to collect information about your website activity via technologies on the Sites, such as Cookies. This is used to provide you with targeted advertising. You may exercise control over the use of these technologies.

While we generally do not profit from collected above-defined Personal Information, under Nevada law, you have the right to direct us not to sell or license this Personal Information to third parties. If you would like to review, correct, or update your Personal Information, you may make a verifiable request to the following:

Data protection Officer:
Manny Alia
300 Cadman Plaza W, 12th Floor
Brooklyn Heights, New York 11201
[email protected]
+1-888-228-2146

Such request shall include your full name, your email address, and a Nevada postal address. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. We will notify you of any delay in our response and will provide a date of our response.

6. Virginia Disclosure

Virginia Consumer Data Protection Act

Under Virginia law, consumers enjoy special rights to transparency, correction, deletion, requests for data, appeal, opting out of the processing and sale of personal data in addition to the terms of our general Privacy Policy. In the event that the statute applies to you, we will abide by its provisions for the enforcement and protection of your rights. In addition, we are required to perform assessments of our practices which we do.

7. Protection Under the Laws of Utah, Florida, California, Washington, Oregon, Texas, Montana, Iowa, Tennessee, and Indiana

We comply with the privacy protection laws of these states.

III. Protections Under U.S. Federal Law

Please note that we comply with federal law as well. While there presently is no general privacy law at the federal law, the Trade Commission Act prohibits unfair or deceptive trade practices, including practices that violate consumers’ privacy. Similarly, privacy protection is built into the Children’s Online Privacy Protection Act requires websites and online services that target children under the age of 13 to obtain parental consent before collecting personal information from those children. We do not target such children and do not permit their use of our App and Sites.

Any inquiries to us, for the deletion, correction, revocation of consent, or required release of information to you under these laws should be directed to our data protection officer:

Data protection officer:
Manny Alia
300 Cadman Plaza W, 12th Floor
Brooklyn Heights, New York 11201
[email protected]
+1-888-228-2146

You will need to provide your name, contact information, and a clear message in English that identifies your request so that the data protection officer can respond to you. You should disclose the state where you use our App as a consumer or resident so that we can abide by the specific rights and options that apply to you.

Part B: GDPR Privacy Policy for Consumers or Residents from Regions not protected by Specific Rules

Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	CrossRem LLC
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers)	Sender: Real name Postal address Email address Account name Recipient: Real name Mailing address Email address Vendors or Representatives of Vendor: Real name, Email address, Vendor’s address, phone numbers
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	None.
Characteristics of protected classifications under California or federal law.	None.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)	None.
Biometric information	None.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	None
Geolocation data	None
Audio, electronic, visual, thermal, olfactory, or similar information	None.
Professional or employment-related information	None.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	None.
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	None.
Other	Any personal information voluntarily provided by a Sender to accompany a product purchased through the CrossRem website or application (e.g. as part of a message in a gift card).

This personal information is required to provide products and services to you or on your behalf. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to/for you.

We do not process any of your payment information (such as credit card details, bank details etc.). When you provide your credit or debit card details to us, it is encrypted so that we are unable to access the data, and passed to third-party payment gateway providers that are responsible for processing your payments.

How Your Personal Information is Collected. We collect most of this personal information directly from you—by telephone, text or email and/or via our website and apps. However, we may also collect information:

Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
From a third party with your consent (e.g., your bank);
To help us improve our website and the products and services we offer, we collect data about the ways in which you use our website. This includes, for example, technical data such as your IP address, which is collected through our use of cookies. More information (including the retention period for each cookie) can be found in our cookie policy, available here [our website click the cookie icon].

How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:

To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.

Where we are relying on a legitimate interest as the justification for our processing, this will occur when processing your personal information is necessary for a business, commercial or other reason, so long as this reason is not overridden by your own rights, freedoms and/or interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or CrossRem	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
To send you relevant marketing communications and make personalised suggestions and recommendations to you abut goods or services that may be of interest to you.	Consent, having obtained your prior consent to receiving direct marketing communications or legitimate interests where you are an existing customer.

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Promotional Communications.

We may use your personal information to send you updates (by email, text message, or post) about our products and services, including exclusive offers, promotions or new products and services if we have a lawful basis for doing so. This will usually be where we either have your prior explicit consent to receive marketing/promotional material or, where you are an existing customer and have not opted out of receiving marketing/promotional material and the product/service is sufficiently relevant or similar to that which you have previously purchased.

We will always treat your personal information with the utmost respect and never sell OR share it with other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at [contact details for marketing opt-out];
Using the “unsubscribe” link in emails or “STOP” number in texts; or
[updating your marketing preferences on our website click the cookie icon].

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Information With.

Your personal information is only shared/transferred to the extent that it is necessary. Recipients of your personal information may include:

service providers we use to help deliver our products and services to you, such as payment service providers, vendors with which we have partnered to supply certain goods/services to you, warehouses and delivery companies, providers of IT services and software and information storage providers;
other third parties we use to help us run our business, such as marketing agencies or website hosts;
third parties approved by you, including social media sites you choose to link your account to;
credit reporting agencies;
our insurers and brokers;
our bank;
legal advisors and accountants to the extent they need to see your personal information to provide their services to us; and
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this policy.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Personal Information We Sold or Disclosed for a Business Purpose.

In the preceding 12 months, we have sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
Characteristics of protected classifications under California or federal law;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Biometric information;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Geolocation data;
Audio, electronic, visual, thermal, olfactory, or similar information;
Professional or employment-related information;
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
Characteristics of protected classifications under California or federal law;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Biometric information;
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Geolocation data;
Audio, electronic, visual, thermal, olfactory, or similar information;
Professional or employment-related information;
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Where Your Personal Information is Held.

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

How Long Your Personal Information Will Be Kept.

We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Typically, where you are the sender or recipient of a product purchased through us, your personal information will not be retained for no more than 6 years from the date of purchase. This enables us to deal with returns, queries, complaints, claims and warranties. After that date your personal information will be deleted or anonymised so that it is no longer personally identifiable.

Part C: Rules Applicable Only to UK and EEA-based Users

Transferring Your Personal Information Out of the EEA or United Kingdom (as applicable).

Where you are based in the European Economic Area (EEA) or the United Kingdom (UK) we may be required to transfer or process your personal information outside of these regions in order to facilitate the delivery of products/services to you (or on your behalf)

Whenever we transfer your personal information out of the EEA or UK (as applicable), we ensure a similar degree of protection is afforded to it by ensuring that one of the approved appropriate safeguards are in place (such as): we will only transfer your personal information to countries that have been deemed by either the European Commission or the UK Government depending on the origin of the personal information to provide an adequate level of protection for personal information); or we use specific standard contractual terms approved for use in the EEA or the UK which give the transferred personal information the same protection as it has in the EEA or UK. If you would like further information, please contact us (see “How to Contact Us” below).

Your Rights Under the GDPR.

You benefit from a number of rights in respect of the personal information we hold about you under GDPR and/or UK GDPR to the extent they apply. We have summarised your rights below and these apply for the period in which we process your personal information. There are certain caveats and exemptions to those rights which mean that in some circumstances you may not be entitled to exercise them, if we believe that is the case upon receipt of a request from you we will let you know.

Right	Description
Right to Access	You have the right to ask us to confirm that we process your personal information, as well as access to and copies of your personal information. You can also ask us to provide a range of information, although most of that information corresponds to the information set out in this fair policy.
Right to Rectification	If you believe personal information we hold about you is inaccurate or incomplete, you can ask us to rectify that information.
Right to be Forgotten	In some circumstances, you have the right to ask us to delete personal information we hold about you.
Right to Restriction of Processing	In some circumstances you are entitled to ask us to suppress processing of your personal information. This means we will stop actively processing your personal information but we do not have to delete it.
Right to Data Portability	You have the right to ask us to provide your personal information in a structured, commonly used and machine-readable format so that you are able to transmit the personal information to another data controller.
Right to Object	You are entitled to object to us processing your personal information: if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority; for direct marketing purposes (including profiling); and/or for the purposes of scientific or historical research and statistics. We do not intend to use your personal information for scientific or historical research and statistics.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not carry out any automated decision-making.

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/).

Your Rights Under the CCPA.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Right	Description
Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale [or disclosure] of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: [URL].
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.

Keeping Your Personal Information Secure.

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. [We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.] We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this privacy policy, please contact us using the information detailed at the “How to Contact Us” section at the bottom of this policy.

We are not obligated to comply with the request to exercise your rights if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf (and, therefore, may be required to verify your identity prior to responding to your request).

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

How to File a GDPR Complaint.

We hope that we can resolve any query or concern you raise about our use of your information and would welcome the opportunity to do so prior to raising a formal complaint. However, under the GDPR and UK GDPR you have the right to report your concerns/complaint to the supervisory authority responsible for data protection in your jurisdiction.

Changes to This Privacy Notice.

This privacy notice was published on 2022/09/28 and last updated on 2024/03/31. We keep this policy under regular review and reserve the right to amend and update it from time to time where necessary.

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your relationship with us (for example where your email address changes).

How to Contact Us.

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details
Emmanuel Alia
300 Cadman Plaza W
Brooklyn, NY 11201
[email protected]
[email protected]
888-228-2146

Do You Need Extra Help?

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

CONTACT US

888-228-2146
[email protected]