Privacy Policy
February 11, 2020 AT “Crossword”,
WE TAKE PRIVACY VERY SERIOUSLY AND IT IS ALWAYS OUR GOAL TO COMMUNICATE WITH OUR SUPPORTERS IN THE MOST EFFICIENT AND EFFECTIVE WAY WHILE ALSO PROTECTING THE SENSITIVE PERSONAL
INFORMATION WE COLLECT. 1. Information Collection 2. Account Information3. Payment Information 4. Third Party Collection 5. Cookies 6. Log Files7. How We Use Your Information 8. How Your Information Is Shared 9. Links10. Newsletter11. Service and Contest12. Tele-friends 13. Security 14. Special Offers15. Site and Services Updates 16. Your Rights to Access and Control Your Personal Data17. Data Retention 18. Policies for Children 19. International Data Transfers 20. Correction/Updating Personal Information21. Notification of Changes 22. How to Contact Us
1. Information Collection
Crossword is the sole owner of the information collected on the Crossword Website. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. We may also collect Personal Information about you when you interact with us on social media sites and from other third parties and may also automatically collect information that may contain Personal Information as described in Crossword's Cookie Policy. We may use that Personal Information where in our legitimate interest to do so for the following purposes: to contact you and respond to your requests and enquiries; to personalise your visit and use of our Internet Services and to assist you while you use those services; to carry out, monitor and analyse our business or website operations; and to contact you (unless you tell us that you prefer us not to) regarding publications, newsletters, cleanups and other events that may be of interest to you. If you do not want to receive publications or details of events that we consider may be of interest to you, you may do so by clicking on the unsubscribe link in electronic marketing communications. Crossword collects information from our users at several different points on our Website including:Account InformationPayment InformationThird Party Collections
2. Account Information
In order to purchase products from the Website, a user must first complete the registration form. During registration a user is required to give their contact information (such as name and email address). This information is used to contact the user about the products on our site for which they have expressed interest.Full NameEmail AddressShipping AddressTelephone Number (optional)
3. Payment Information
We require information from the user on our order form in order to process any purchases using a third-party partner. Here a user must provide contact information (like name and shipping address) and financial information (like credit card number, expiration date). This information is used for billing purposes and to fill the customer’s orders. If we have trouble processing an order, this contact information is used to get in touch with the user.Billing AddressCredit Card Type
4. Third Party Collections
We use Third Parties to collect and store our Account and Payment Information in accordance with this Privacy Policy as well as other information related to volunteer work and customer service.Sripe (this is the platform that technically collects and stores the information for all transactions through our checkout page)
5. Cookies
A cookie is a piece of data stored on the user’s hard drive containing information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. Once the user closes their browser, the cookie simply terminates. For instance, by setting a cookie on our site, the user would not have to log in a password more than once, thereby saving time while on our site. If a user rejects the cookie, they may still use our site. The only drawback to this is that the user will be limited in some areas of our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Some of our business partners use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies.For personal data subject to the European Union’s General Data Protection Regulation (“GDPR”), we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings; when the processing is necessary to perform a contract with you, like the Terms of Service; and our legitimate business interests, such as in improving, personalising, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as in this Privacy Policy.
6. Log Files
We use IP addresses to analyse trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
7. How We Use Your Information
We use the information we collect for the following purposes:To provide Services and ProductsTo improve Services and Products (to the extent applicable)To deliver the Products and Services to you (for example, full name and shipping address)To improve the Services (for example, we use the information to troubleshoot, perform data analysis and testing and to develop new features)To share information about our Company (via our newsletter)To share information about new Products (via our newsletter)To share information about Crossword events (via our newsletter)
8. How Your Information Is Shared
We will share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person.We use an outside shipping company to ship orders and a credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes. We partner with four other third parties, such as SpringBot, CookieBot, Bazaarvoice and Formstack to provide specific services. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services.These parties are not allowed to use personally identifiable information except for the purpose of providing these services.We may also share your information for legal reasons or to prevent harm. We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services.If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice before transferring any personal information to a new entity.
9. Links
This web site contains links to other sites. Please be aware that we (Crossword) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site.
10. Newsletter
If a user wishes to subscribe to our newsletter, we ask for contact information such as name and email address.
11. Surveys & Contests
From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information.Information requested may include contact information (such as name, email address and/or shipping address), and demographic information (such as zip code, gender or age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.
12. Tell-A-Friend
If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Crossword will automatically send the friend a one-time email inviting them to visit the site. Crossword stores this information for the sole purpose of sending this one-time email. The friend may contact us at j.bardiau@skynet.be to request the removal of this information from our database.
13. Security
This website takes every precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected both online and off-line. When our registration/order form asks users to enter sensitive information (such as credit card number and/or social security number), that information is encrypted and is protected with the best encryption software in the industry - SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Google Chrome and Microsoft InternetExplorer becomes locked, as opposed to un-locked, or open, when you are just ‘surfing’. To learn more about SSL, follow this link: https://en.wikipedia.org/wiki/Transport_Layer_Security.While we use SSL encryption to protect sensitive information online, we also do everything in our power to protect user-information off-line. All of our users’ information, not just the sensitive information mentioned above, is restricted in our offices. Only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use password-protected screen-savers when they leave their desk. When they return, they must re-enter their password to re-gain access to your information. Furthermore, ALL employees are kept up-to-date on our security and privacy practices. Every quarter, as well as any time new policies are added, our employees are notified and/or reminded about the importance we place on privacy, and what they can do to ensure our customers’ information is protected.Finally, the servers that we store personally identifiable information on are kept in a secure environment, behind a locked cage. If you have any questions about the security at our website, you can send an email to j.bardiau@skynet.be.
14. Special Offers
New and established members will occasionally receive information on products, services, special deals, and our newsletter. Out of respect for the privacy of our users we present the option to not receive these types of communications.
15. Site and Service Updates
We also send the user site and service announcement updates. Users are not able to un-subscribe from service announcements, which contain important information about the service. We communicate with the user to provide requested services and in regard to issues relating to their account via email or phone.
16. Your Rights to Access and Control Your Personal Data.
We give you access and control of your personal data as described in this Privacy Policy. If you livein the European Economic Area, United Kingdom, and Switzerland (the “Designated Countries”), youhave a number of legal rights with respect to your information,
17. Data Retention
We will retain your data for a period of 6 months from the time we first collect your data if you have no additional activity or until you opt out, whichever comes first.
18. Policies for Children
In order to respect the privacy of minors, Crossword does not knowingly collect, maintain or process Personal Information submitted online via our Internet Services by anyone under the age of 18. To the extent Crossword collects Personal Information on minors in the context of one of the purposes mentioned in the Statement, Crossword will only do so with the appropriate consent or as otherwise permitted under applicable laws.
19. International Data Transfers
We will rely on multiple legal bases to lawfully transfer personal data around the world. These includeyour consent, the EU-US and Swiss-US Privacy Shield, and EU Commission approved model contractual clauses, which require certain privacy and security protections. You may obtain copies of the model contractual clauses by contacting us. Crossword complies with the Privacy Shield principles regarding the collection, use, sharing, and retention of personal information as described in our Privacy Shield certifications.Crossword is subject to the oversight of the US Federal Trade Commission and remains responsible forpersonal information that we transfer to others who process it on our behalf as described in the HowInformation Is Shared section. If you have a complaint about our Privacy Shield compliance,please contact us. You can also refer a complaint to our chosen independent dispute resolutionbody, the International Centre for Dispute Resolution® at http://go.adr.org/privacyshield.html. Please note that the countries where we operate may have privacy and data protection laws thatdiffer from, and are potentially less protective than, the laws of your country. You agree to this riskwhen you create a Crossword's account and click “I agree” to data transfers, irrespective of whichcountry you live in. If you later wish to withdraw your consent, you can delete your information asdescribed in the Privacy Policy.You have the right to lodge a complaint regarding your information with the proper supervising authority.
20. Correction/Updating Personal Information:
If a user’s personally identifiable information changes (such as your zip code), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the user account page or by emailing our Customer Support at j.bardiau@skynet.be.Our users are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our site at the point where we ask for the information. For example, our order form has an ‘opt-out’ mechanism so users who buy a product from us, but don’t want any marketing material, can keep their email address off of our lists.Users who no longer wish to receive our newsletter or promotional materials from our partners may opt-out of receiving these communications by clicking the opt-out, unsubscribe button, or email us at j.bardiau@skynet.be.Users of our site are always notified when their information is being collected by any outside parties. We do this, so our users can make an informed choice as to whether they should proceed with services that require an outside party, or not.
21. Notification of Changes
If we decide to change our privacy policy, we will post those changes on our Website, so our users are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.
22. How to Contact Us
If you have questions, suggestions, or concerns about this policy, or about our use of your information, please contact us at j.bardiau@skynet.be. If you live in the European Economic Area, United Kingdom, or Switzerland and are seeking to exercise any of your statutory rights, please contact our Privacy Officer at :
Crossword
Avenue Louise, 79 - 1050 Brussels
T +32 2 537 42 26 BE 0825.14.12.87