Effective Date of Privacy Policy: May 1, 2020

This CrossLink Publishing LLC (“CP”, “we”, “us”, or “our”) Privacy Policy describes our privacy practices with respect to information we collect through the Permissions Portal website (the “Site”) or other information you deliver to us which we maintain in our possession. It does not apply to information collected from you through third parties such as other websites or online services operated by CP’s affiliates or partners. If you use or link to any of those websites or services, please take a moment to review their privacy policies.

By using the Site or submitting information to us, you are accepting the terms described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Site or submit information to CP. We reserve the right to modify or amend the terms of our Privacy Policy from time. Your continued use of our Site following the posting of changes to these terms will mean you accept those changes.

What Information We Collect

Information You Provide Directly To Us:

You provide personal and non-personal information directly to us in several situations, including when you register for a Permissions Portal account or contact us through the Site. Such information includes, but is not limited to, your name, address, email address, phone number and account login name and password.

Information Collected Using Technology:

When you visit the Site, or otherwise communicate with us, we may collect certain non-personally identifiable information about your usage or device by automated means or by using the following technologies:

• Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer or other Internet-connected device that uniquely identifies your browser to store information or settings in your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to use all of the features of the Site.
• Web Server Logs. In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs also may record information such as the address of the web page that linked you to our site and the IP address of the device you use to connect to the Internet.
• Web Beacons. Pages of the Site and our communications to you may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count how many times those pages have been visited and for other related Site statistics.

Third Party Web Analytics Services

We may use third party web analytics services on the Site and in communications we send to you. The service providers that administer these services also use technologies such as cookies, web server logs, web beacons and similar technologies to help us analyze how you use the Site and our emails.

How We Use Your Information

We may use the information that we collect for a variety of purposes, including to:

• Fulfill your order or provide you with the services you request
• Communicate with you about your account with us and send you information about features on the Site
• Communicate with you about CP products and services
• Communicate with you about changes to our policies
• Maintain or administer the Site, perform business analyses, or for other internal purposes to optimize or improve the quality of our business, the Site, and the products and services we offer
• Detect, investigate, and prevent activities that may violate our policies, be illegal, or damage our business or others’ businesses
• As otherwise described to you at the point of collection or pursuant to your consent

Who We Share Your Information With

Except as described below, we do not disclose your personal information to any person or entity outside CP.

Third Party Service Providers

We may share your personal information with third party service providers that perform functions on our behalf. These entities have access to your personal information only as needed to perform their functions. These may be organizations such as Stripe for payment processing or common carriers such as UPS and Federal Express.

Corporate Parents and Affiliates

We may share your personal information with our corporate parents and other affiliated entities for a variety of purposes, including business, operational and marketing purposes.

Other Third Parties When Required By Law or In Emergency Situations

We may also use or disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to applicable law or comply with legal process or discovery request served on us or the Site; (b) protect and defend our rights or property, the Site or our users; or (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Site or the public.

Other Parties In Connection With a Transaction

We may change our ownership or corporate organization while providing the Site. We may also sell certain assets associated with the Site. In such event, we may transfer some or all of your personal information to a company acquiring all or part of our assets or to another company with which we have merged or that has otherwise acquired our business. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time.

Other Parties With Your Consent

We may share personal information about you with other third parties when you consent to such sharing. In addition to the disclosures above, we may disclose non-personal information to third parties, such as aggregate website usage data or demographic reports that do not describe or identify individual users.

Security of Your Personal Information

CP takes reasonable steps to help protect and secure your personal information. However, please remember that no data storage or data transmission over the Internet, or by other means, can be guaranteed to be 100% secure. Thus, CP cannot ensure or warrant the security of any information you transmit to us. Therefore, you understand, acknowledge and agree that you transmit your personal information to the Site at your own risk.

Retention of Personal Information

We may retain personal information for as long as needed or permitted by applicable law.  The criteria used to determine our retention periods include:

1. An ongoing relationship with you as a customer of CP (e.g. you maintain an account with us or are in an ongoing contractual relationship) or user of the Site;
2. If there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
3. Whether retention is advisable when considering our legal position or the legal position of a relevant third party (such as in regard to applicable statutes of limitations, litigation or regulatory investigations, discovery requests from third parties, etc.).

Third Party Content and Links to Third Party Websites

The Site may contain content hosted or served by third parties or link to websites operated by third parties. Please be advised that the practices described in this Privacy Policy for CP do not apply to information gathered by these third parties. We are not responsible for the actions and privacy policies employed by any third party, and our hosting of third party content or linking to third party websites does not constitute an endorsement of the content or business practices of those third parties.

Children’s Privacy

We are committed to complying with the guidelines set forth by the Children’s Online Privacy Protection Act.  The Site is not directed to children under the age of 13. We do not knowingly collect or maintain information on children under the age of 13. If you are the parent or guardian of a child age 13 or under who has provided us with personal information and you would like that information removed, please contact us at publisher@crosslink.org.

Governing Law

The Site is published in the United States. We attempt to protect the personal information of all users of the Site and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to CP’s services, but the Site is primarily targeted to United States citizens and our policies are directed at compliance with those laws.

If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your personal information to CP. This Privacy Policy and its terms shall be governed and construed in accordance with the laws of the United States and the State of South Dakota without regard to the conflicts of laws provisions therein. Any claim or dispute related to this Privacy Policy or the privacy practices of CP must be brought in the federal or state courts of Pennington County, South Dakota, USA, and the parties each hereby submit to the personal jurisdiction thereof.

Notice to Non-US Users

If you are located outside the United States of America, you should be aware that your personally identifiable information will be transferred to the United States of America, the laws of which may be deemed by the your country to have inadequate data protection. If you are located in a country outside the United States of America and voluntarily submit personally identifiable information to us on the Site, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States of America. Depending on the nation of you citizenship or residence, you may be entitled to certain other privacy rights.

Changes to This Privacy Policy

As the Site continues to develop, we may add new services and features to them. In the event that these additions affect our Privacy Policy, or if other changes in our privacy practices or applicable laws necessitate changes to the Privacy Policy, this document will be updated accordingly. If we make a material change in the way we use your personal information, we will provide prominent notice of the change on the Site or notify you of such change.

How To Opt-Out or Correct Your Information

You may always opt-out of receiving future commercial emails and newsletters from CP. We provide you with the opportunity to opt-out of receiving such communications from us by clicking on the “unsubscribe” link within the email you receive. Please note that your request not to receive unsolicited commercial emails from us will not apply to messages that you request or that are not commercial in nature.

Do Not Track

The Site may not respond to the Do Not Track setting of your web browser.

California Privacy Rights for California Residents

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared personal information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities).

To obtain this information from CP, please send an email message to publisher@crosslink.org with “Request for California Privacy Information” on the subject line and in the body of your message. The requested information, if required by law, will be provided to you at your email inbox.

Rights of European Union Residents.

The European Union’s General Data Protection Regulation (GDPR) applies to the processing of personal data of E.U. citizens and residents. This section provides information regarding the rights GDPR grants to E.U. users and the responsibilities of CP under such regulations.

1. E.U. User Rights

If you are an E.U. resident and submit your personal information to us or we otherwise collect personal information about you as defined by GDPR, you have the following rights regarding how we manage your personal information. For purposes of this “EU User Rights” section, “personal information” means personal information, as the term means above in this Privacy Policy, as well as any information which CP may link or otherwise connect with your account or identity. To exercise the rights provided below, please submit your request to publisher@crosslink.org with the subject EU Privacy Request.

Explanation and access to your personal information: You have the right to be informed about your personal information CP has in its possession. You also have the right to request a copy of all personal information in CP’s possession if CP collected such personal information based on consent or because it is required to provide a service that you requested from Organization.

Data Deletion: You may request the deletion of your account and all personal information in our possession. CP may retain certain personal information if required by law or for legitimate business purposes as permitted by GDPR.

Data Correction: If you believe in personal information in CP’s possession is inaccurate, you may request correction of such personal information.

Objections: You may object to CP’s processing of your personal information (including for marketing purposes), based on profiling or automated decision-making. However, CP may continue to process your personal information if it is doing so in accordance with GDPR regulations. You may file a complaint with the appropriate European governmental agency if you believe CP’s management of your personal information is not in accordance with GDPR.

1. Grounds for Processing Personal Data.
   1. Consent

1. CP may collect and use your personal information based on your consent. You may revoke your consent at any time but doing so will prevent you from accessing any service or feature that requires collection or use of the personal information CP collected or used based on consent.
2. CP relies on consent in connection with data collections or uses of personal information that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you.

1. 1. To provide certain services you request. To provide you with certain services that you request from CP, we may collect and use personal information such as:

1. Information necessary for your account or user profile, for communicating with you, for verifying your identity, to fulfill orders for products or services, or to make or receive payments;
2. Transaction information about a specific transaction you have initiated with CP; or

• Usage information, which is necessary to maintain, optimize, and enhance Organization’s services, such as products or features on our website which generate greater traffic.

1. 1. Compliance with legal obligations, protecting the vital interests of a third party or general public.

1. CP may process or disclose personal information to comply with a legal investigation, at the request or law enforcement, if there is a threat to the safety or property of another person, or a substantial public interest.

1. 1. Necessary for CP’s legitimate interests.

1. To prevent, detect and combat fraud in connection with the use of our services.
2. To provide customer support.

• To optimize our service and develop new services.

1. For research and analytical purposes. This includes, for example, analyzing usage trends to improve the user experience.
2. For direct marketing purposes. This includes, for example, analyzing data to identify trends and tailor marketing messages to user needs.
3. To enforce CP’s Terms of Use.

How To Contact Us

If you have any questions about this Privacy Policy, you may contact us as follows:

By mail:
CrossLink Publishing
1601 Mt. Rushmore Rd, Ste 3288
Rapid City, SD 57701

Phone:
(888) 697-4851

Email:
publisher@crosslink.org