Updated: May 24, 2018
Acrossio is committed to transparency. You, our customer, will know what information we request and how we use it.
Across Lab, Inc. is operating under the dba of Acrossio and will be referred to as "ACROSSIO" is committed to protecting your privacy and ensuring you have a positive and safe experience on our website and even more importantly our cloud-based Platform (referenced as “Solution”). This Privacy Statement describes how we handle personal information and the choices available to you regarding the use of, your access to, and how to update your personal information. It also covers the privacy practices that apply when ACROSSIO customers ("Customers") use the Solution. Additional information on our personal information practices may be provided in the supplements in notices provided at the time of data collection.
The most fundamental privacy principle by which we operate; that anything you discuss and post on Acrossio is private to your team and colleagues. That is, listening to the audio, viewing video and the messages and files shared within a specific team requires authentication as a member of that team. Sessions created in the Solution may be shared only by unanimous consent. In other words nothing is shared without your consent.
We may collect information, including personal information, about you as you use our website and Solution to interact with us. "Personal information" or "Personal Data" is any information that
can be used to identify an individual, and may include name, email address, title, address, phone number(s), login information (account alias, password), social media account information, marketing preferences, or payment method information and other personally identifiable information.
If we link other data with your personal information, we will treat that linked data as personal information. This information may be internally generated or from trusted third-party sources and shall be treated as personal information.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below.
These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
ACROSSIO will be the Data Processor of your Personal Data that is provided, collected and/or processed either by you directly or by your Team or Network Administrator (ACROSSIO's Customer which is considered to be the Data Controller according to GDPR) pursuant to this Service Privacy Policy, except where otherwise expressly stated below.
In the case of you being a member of the "Acrossio Professional Network" or APN (if you are an older Acrossio user or you have been invided by an individual to join the APN) then ACROSSIO is the Data Controller of your Personal Data that is provided, collected and/or processed either by you directly or the person who invited you, pursuant to this Service Privacy Policy, except where otherwise expressly stated below.
If you have any questions about whether any of foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.
This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to the Solution.
We collect personal information for such reasons as:
*where applicable
In some instances, Acrossio and the third parties we engage may automatically collect data through cookies, web logs, web beacons, and other similar applications. This information is used to better understand and improve the usability, performance, and effectiveness of the Website and Solution and to help tailor content or offers for you.
ACROSSIO provides customers and web site visitors with options for how Acrossio collects and uses their personal information. Web site visitors may opt-in to specific marketing communications and opt-out at any time.
Customers (Network Owners/Administrators) can modify their account contact information, configure platform preferences, delete and modify users and request us to terminate their account.
End Users (Team or Network members) can modify their profile and contact information, including skills, social networks and other content and context they have been contributing during their meetings. They can also modify and delete sessions when they are the sole owners of them.
Cookies are small text files sent by us to your computer and from your computer to us, each time you visit ourwebsite. They are unique to your Acrossio account or your browser. Persistent cookies last until you or your browser deletes them or until they expire. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser.
Some cookies are associated with your Acrossio account and personal information in order to remember that you are logged in and which teams you are logged into. Other cookies are not tied to your Acrossio account but are unique and allow us to do among other things site analytics and customization. If you access Acrossio through your browser,you can manage your cookie settings there but if you disable all cookies you may not be able to use Acrossio.
Acrossio uses cookies, or similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies.
Acrossio sets and accesses our own cookies on our company-owned domains. In addition, we use 3rd parties like Google Analytics for website analytics. You may opt-out of third party cookies from Google Analytics on its respective website. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance. Note that third party services you integrate to Acrossio have their own privacy policy. Please review and be aware of these policies.
To modify how our Website and Platform use Cookies please use this link below Acrossio Cookies page
We may use your personal information for the purposes of operating our business, delivering, improving and customizing our Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law. Some of the ways we may use personal information include:
When you use Acrossio, you have control over a number of things with respect to your own privacy and choices about how your content is visible to others or not.
If you are an Acrossio team owner or administrator, you are considered to be the Data Controller and you have additional choices that impact your team’s privacy.
Some members will not have access to all of the same choices that the team owner(s) or administrator(s) do. That is because Acrossio is set up with team orientation, and provides Team Owners with the maximum ability to control their team’s experience and available tools.
We may share your personal information with third parties for the purposes of operating our business, delivering, improving and customizing our Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or with your consent. We may share personal information in the following ways:
Upon request, Acrossio will provide you with information about whether we hold any of your personal information. Acrossio enables customers and web site visitors with the ability to access and correct personal information we have collected.
If you have any concerns or suspect unauthorized activities associated with your account, please contact us at support@acrossio.com. We will respond to your request within a reasonable timeframe.
Acrossio acknowledges that you have the right to access your personal information. If you are a person who uses a Team or Company Network on the Acrossio Platform, then Acrossio has no direct relationship with you and your data that it processes.
In such case, if you seek to access, correct, amend, or delete data, you should direct your query to ACROSSIO’s Client (the data controller).
If you are a person who has signed up directly with ACROSSIO for the use of the Acrossio Professional Network and you seek to access, correct, amend, or delete data, you should direct your query to Acrossio.
If requested to remove data under either scenario, we will respond within a reasonable timeframe.
We intend to protect the personal information entrusted to us and treat it securely in accordance with this Privacy Statement. Acrossio implements physical, administrative, and technical safeguards to help protect your personal information from unauthorized access, use, or disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure. In the case of you being a member of a Company or Team (Acrossio's Customer) Network, it is our customer’s responsibility to ensure authorized access to personal information by selecting and protecting your password appropriately and limiting access to your Acrossio resources. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal information you provide to us.
Personal Data means any information relating to an identified or identifiable natural person. Sensitive Personal Data is Personal Data comprised of an individual's financial account number, social security number, driver's license number or
other government-issued identification number, financial account password or PIN, mother's maiden name, answers to security questions, or other Personal Data that allows access to financial accounts, or that can be used to facilitate identity theft,
as well as any other special category of Personal Data such as biometric, genetic or health data, data concerning sex life or sexual orientation, racial or ethnic origin, data concerning a person’s political opinions, religious beliefs, membership in trade unions or criminal history.
Confidential Data is any proprietary data which is not in the public domain, and/or, data which is controlled by its owner and requires explicit permission to access, store, process, or transfer.
End User Data is data provided by End Users in connection with the Acrossio Services.
Customer Data is data provided by Customer to ACROSSIO in connection with the Acrossio Services. Customer Data may be Personal Data, Sensitive Personal, End User Data or Confidential Data. Agreements between Acrossio and Acrossio customers specify how Customer Data and End User Data is processed, transferred, and stored.
With respect to data protection legislation (including GDPR) Acrossio may be a Data Controller or a Data Processor.
Acrossio is a Data Controller with respect to data provided by website visitors and, customer contact and billing information, and Acrossio employees.
We will retain your personal information as needed to fulfill the purposes for which it was collected. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Since Acrossio Networks operate like a Social Network in certain cases, if you participate in a Team or Network discussion groups, or have connections on an Acrossio Solution, you should be aware that some of the information you provide might be made broadly available to others who are connected with you (your connections),
and could be used to contact you, send you unsolicited messages, or for purposes neither Acrossio nor you have control over.
Also, please recognize that individual groups have different rules and conditions. Acrossio is not responsible for the personal information or any other information you choose to submit to your Acrossio connections and groups.
You can modify the information you display to your connections by modifying your profile or leaving those Groups. If you have any questions, comments or concerns add a request for support.
In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. In any case we might be able to modify your personal information or anonymize it when possible if this is not interfering with existing laws and regulations
It is our customer’s responsibility to obtain the EXPRESS CONSENT of individual Data Subjects (for example, your family members, co-workers, or customers) to transfer their Personal Data to Acrossio as a Data Processor and/or Data Importer.
Acrossio processes all such information in accordance with the terms of applicable law and/or this Privacy Policy.
ACROSSIO's headquarters in the United States is our primary location for business operations. Servers hosting the Acrossio platform are located in the United States and they are hosted in Microsoft Azure Datacenters in US geographic regions.
In order to provide you with the information, products, or services you have requested, Personal Data may be transferred or shared with other companies within our Subprocessors, including those third-party vendors who act on our behalf,
process Personal Data in accordance with the purposes for which the data was originally collected, or for purposes to which Data Subjects have subsequently consented.
Our Privacy Policy, supported by model contract agreements and safeguards for data governance, are designed to provide equivalent data protection for all customers wherever they may reside.
For example, regarding normal business operations, Acrossio may engage a third party to support our video recordings, billing, support services, information technology, or mailings on our behalf.
We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety, or the safety of others,
investigate fraud, or respond to a government request.
Across Lab, Inc. uses certain subprocessors to support delivery of our Services. This page provides important information about the identity, location and role of each Subprocessor.
What is a Subprocessor:
A subprocessor is a third party data processor engaged by Acrossio, who has or potentially will have access to or process customer data.
Due Diligence:
Prior to engaging any third party Subprocessor, Acrossio evaluates their security and privacy posture.
Acrossio Subprocessors
| Subprocessor Identity | Subprocessing Activities | Location |
| Microsoft Azure | Leading Secure Cloud Service Provider https://azure.microsoft.com | United States |
| TokBox | Leading cloud platform for live video, voice and messaging https://www.tokbox.com | United States |
| Twilio | Leading Communication APIs for SMS, Voice, Video and Authentication Platform Provider https://www.twilio.com/ | United States |
| Zoom | Cloud Based enterprise video communications provider https://www.zoom.com | United States |
| Zendesk | Cloud-based customer support services https://www.zendesk.com | United States |
| Intercom | Leading Cloud-based Customer Messaging Platform https://www.intercom.com/ | United States |
| Mouseflow | Website Heatmap and Analytics Provider (only for Website) https://www.mouseflow.com/gdpr | EU and United States |
| Google Analytics | Cloud-based Website Analytics provider | United States |
Updates
As our business grows and evolves, the Subprocessors we utilize may also change. We will provide the owner of Customer’s account with notice of any new Subprocessors to the extent required under contractual agreement, along with posting such updates here.
ACROSSIO protects personal information in accordance with Fair Information Practice Principles, General Data Protection Regulations (GDPR), and applicable law pertaining to residents of any country where personal data is shared.
All personal data received from European Union (EU) member countries are subject to the EU-U.S. Privacy Shield Framework, and to the Framework’s applicable Principles.
For example, when visitors access our public websites from any country outside the United States, personal information will be transferred across national boundaries.
Customers who reside and conduct business outside the United States, enter into contractual agreements with Acrossio to provide products and services which may result in international data transfers.
Acrossio provides an array of product and service offerings designed to support regulatory requirements for the data protection of our customers and their interests.
Acrossio is not directed to children under 16. We encourage parents and guardians to take an active role in their children's online activities. Acrossio does not knowingly collect personal information from children without proper parental or guardian consent.
If you believe that we may have collected personal information from someone under the applicable age of consent in your country without parental or guardian consent or if you have comments or concerns on the policy or a specific incident please contact support and we will take appropriate measures to investigate and address the issue promptly.
Residents of the State of California, under California Civil Code § 1798.83, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed personal information during the preceding year for direct marketing purposes.
Alternatively, the law provides that if the company has a privacy policy that gives either an opt-out or opt-in choice for use of your personal information by third parties (such as advertisers) for marketing purposes, the company may instead provide you with information on how to exercise your disclosure choice options.
Acrossio qualifies for the alternative option. We have a comprehensive privacy statement, and confirm that will not send your personal information to third parties for direct marketing purposes.
If you are a California resident and request information or have questions about your rights, please use our contact form at this website https://www.acrossio.com/contact
We value your opinion. Should you have questions, concerns or coments related to this Privacy Statement, please use our contact form at https://www.acrossio.com/contact.
We may update this Privacy Statement from time to time. If we modify our Privacy Statement, we will post the revised version here. You agree to visit these pages periodically to be aware of and review any such revisions. If we make significant changes to our Privacy Statement, we may also notify you to the changes prior taking effect. This may be done using actions such as by posting a notice on our website or sending you a notification. By continuing to use our website after such revisions are in effect, you accept and agree to the revisions and to abide by them.
Copyright (C) 2012-2018 ACROSS LAB, INC. All rights reserved. ACROSSIO is a registered trademark of ACROSS LAB, INC.
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© 2019 Across Lab Inc.