Privacy Notice

1. Introduction

This Privacy Notice describes how Crosslake Technologies, LLC and its affiliated companies (“Crosslake,” “we,” “our,” or “us”) process personal information. The specific Crosslake entity that determines the purposes and means of the relevant processing is responsible for that processing. We are committed to protecting and respecting your privacy. This Privacy Notice explains how we collect, use, disclose, retain, and safeguard personal information when you visit crosslaketech.com, interact with us, or use online applications and related services for which we determine the purposes and means of processing. Where we process personal information solely on behalf of a business client, our agreements with the relevant client shall govern the processing. This Privacy Notice is informational and does not request consent to processing. Where applicable law requires consent, including for non-essential cookies or similar technologies, we will request consent separately before the relevant processing occurs.

2. Information We Collect

We may collect and process the following data about you:

Personal Identification Information: First and last name, email address, phone number, billing and mailing addresses, professional title, and company name.

Technical, Device and Session Data: IP address, browser type and version, internet service provider (ISP), device identifiers, cookie and similar technology identifiers, current URL and referring/exit pages, operating system, date/time stamps, approximate location derived from IP address, and clickstream, session and other online activity data.

Usage Data: Information about how you use and interact with our website, products, communications, and services, including feature usage, navigation paths, pages and screens viewed, links and interface elements clicked, session duration, traffic source, and conversion, performance, error, and engagement events.

Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.

3. How We Use Your Information

To Provide Services: To deliver requested consulting services and application functionality, administer accounts, respond to inquiries, perform contracts with you, and take steps at your request before entering into a contract.

To Operate, Analyze, and Improve Our Website, Products, and Online Applications: To track, measure, and analyze user behavior and feature usage; generate real-time and historical insights; identify trends and errors; measure traffic, adoption, performance, and engagement; personalize and optimize user experiences; diagnose issues; and develop and improve our website, products, applications, and services, based on our legitimate interests where permitted and, for non-essential cookies or similar technologies, with your consent where required by applicable law.

To Communicate: To respond to you and send newsletters, marketing materials, and other information that may be of interest to you, based on consent where required by applicable law or otherwise on our legitimate interests, subject to your preferences and your right to withdraw consent or opt out at any time.

To Comply with Legal Obligations and Protect Rights: To comply with applicable laws, regulations, and legal process and, where permitted, to establish, exercise, or defend legal claims, prevent fraud or misuse, and protect the rights, property, security, and safety of Crosslake, our users, and others.

Cookies and Similar Technologies: The Crosslake website, products and online applications use necessary and analytics cookies and similar technologies, including Google Analytics and other analytics providers. These providers may process information on our behalf and, where disclosed in our Cookie Policy, for their own purposes, subject to their applicable terms and privacy notices. Before engaging such a third-party service provider, we perform a security and privacy assessment of the provider to ensure compliance with our policies and procedures; further details about the specific cookies, providers, purposes, durations, and available controls are provided at https://crosslaketech.com/cookie-policy/.

Where required by applicable law, non-essential cookies and similar technologies are disabled unless and until you consent through our cookie preference tool, and you may withdraw or modify your consent at any time through the tool or as described in our Cookie Policy. We use necessary cookies to enable the basic features of the website, such as providing secure log-in or adjusting your consent preferences.

We use analytics cookies to collect identifiers, device and browser information, session, approximate location, and website interaction data and provide us with aggregated and user-level reports about website and product use, feature adoption, engagement, performance and trends to help us understand how visitors navigate through the website. They allow us to analyze the siteʼs effectiveness, make design improvements to enhance site performance and implement improvements based on how visitors use the website. We may attempt to identify individuals with this information where reasonably necessary.

Your web browser can also be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. The Help section of your browser will tell you how to prevent your browser from accepting cookies or to delete persistent cookies that are already on your computer.

4. Data Sharing and Disclosure

We may disclose personal information to affiliates; analytics vendors and other service providers that support hosting, analytics, security, communications, marketing, and professional services; business clients where relevant to requested services; parties to a merger, financing, acquisition, reorganization, or sale of assets; and governmental authorities or other parties where required or permitted by law. We do not sell personal information for monetary consideration, but our use of certain advertising or analytics technologies may constitute “sharing,” “selling,” or targeted advertising under some U.S. state privacy laws, in which case eligible individuals may opt out through our cookie preference tool or a legally recognized opt-out preference signal. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect our or othersʼ rights, property, or safety.

5. International Data Transfers

Your personal information may be transferred to and processed in countries outside your jurisdiction, including the United States, whose data protection laws may differ from those in your jurisdiction. For transfers from the EEA, United Kingdom, or Switzerland, we use an applicable adequacy mechanism or appropriate safeguards, such as approved standard contractual clauses and any required supplementary measures.

6. Data Security

Crosslake maintains reasonable and appropriate administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal information, taking into account the nature of the information and processing risks; however, no security measure can guarantee absolute security. Access is restricted to Crosslake workforce team members or service providers who need to know such information to perform a specific job on Crosslakeʼs behalf.

All our workforce team members receive security and privacy training, are bound by confidentiality obligations regarding the use of information, and may be subject to discipline, including termination of services or contracts and criminal prosecution, for failure to comply with these obligations.

7. Children’s Privacy

We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you learn that your children have provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under age 18 without verification of parental consent, we will take steps to remove that information from our servers.

8. Your Data Protection Rights

Subject to applicable law and exceptions, you may have the following rights regarding your personal data:

Right to Access: Rights to confirm whether we process your personal data, access it, and receive information about the categories and specific pieces of personal data we process, the purposes of processing, and the categories of sources and recipients.

Right to Rectification: The right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

Right to Erasure: The right to request that we erase your personal data, under certain conditions.

Right to Restrict Processing: The right to request that we restrict the processing of your personal data, under certain conditions.

Right to Object to Processing: The right to object to our processing of your personal data, under certain conditions.

Right to Data Portability and Additional Rights: You may have the right to receive certain personal data in a structured, commonly used, machine-readable format and transmit it to another organization and, where applicable, to withdraw consent without affecting prior lawful processing, opt out of sale, sharing, targeted advertising, or profiling in furtherance of decisions producing legal or similarly significant effects, limit certain uses and disclosures of sensitive personal information, and not be discriminated or retaliated against for exercising privacy rights.

9. Additional Rights for Residents of Specific Regions

• European Economic Area and United Kingdom Individuals: Where the GDPR or UK GDPR applies, you may exercise the rights described above and lodge a complaint with the supervisory authority where you live or work or where an alleged infringement occurred; you may contact us for information about the relevant Crosslake controller or representative, if applicable.

• United States Residents: Residents of California and other states with applicable comprehensive privacy laws may have the rights described above, subject to statutory scope and exceptions; requests may be submitted to privacy@crosslaketech.com, authorized agents may submit requests where permitted, we may reasonably verify identity and authority, and you may appeal a denial by replying to our decision or using the contact information below.

10. Applications Provided to Business Clients

Our applications provided to business clients may collect personal information on behalf of those clients, in which case the client generally acts as controller or business and Crosslake acts as processor or service provider under the client’s instructions. We may process this information to provide services to our clients and, to the extent permitted by our agreements and applicable law, collect and use product telemetry and related personal, technical, device, session, and usage data to secure, support, analyze, develop, and improve our applications and services, including through analytics providers. This processing is governed by our agreements with the relevant client, and individuals should ordinarily direct privacy requests concerning client-controlled data to that client; we will assist the client with such requests as required by applicable law and our agreement.

11. Changes to This Privacy Policy

We may update this Privacy Notice from time to time, and if an update materially changes how we process personal information, we will provide notice as required by applicable law and obtain consent where required before applying the change to previously collected information. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Contact Us

To exercise applicable privacy rights, including access, correction, deletion, portability, objection, restriction, consent withdrawal, or U.S. state-law opt-out rights, contact Crosslake using the details below; we will respond within the period required by applicable law and may request information reasonably necessary to verify your identity, request, or authorized-agent status.

• Crosslakeʼs primary office is located at 5605 Carnegie Boulevard, Suite 175, Charlotte, NC 28209.
• Please use this address or, preferably, reach out to privacy@crosslaketech.com for any questions, complaints, or requests regarding this Privacy Notice