CruxOCM, Inc. Privacy Policy

This Privacy Policy will change periodically to comply with privacy law requirements. If the changes are significant, we will provide notice.

We at CruxOCM, Inc. (“Crux”, “us,” “our”, or “we”) are committed to protecting the privacy of individuals who visit our website(s) (“visitors”), and individuals who subscribe to use our services (“clients”). This Privacy Policy describes our practices related to the foregoing personal data.

We recommend that you read this Privacy Policy to ensure you are fully informed about the types of personal data we collect, why and how we collect, use, and protect it, how it is disclosed, where it is stored, and to ensure you are fully informed about your rights relating to any of your data. Residents of California, Nevada, and Canada, please also refer to the specific sections directed to you in this Privacy Policy to learn more about your privacy rights.

How We Collect

Crux collects personal data from you directly when you express an interest in obtaining additional information about our services, register to use the services, register or log in to your account, create or edit your user profile, contact Crux’s customer support team, comment on our blogs or in community forums, or when you interact with us in any form.

What We Collect

• Personal Information. When you register an account with us, we may collect personal information from you, such as your first and last name, title, name of business and address. If you are seeking customer support, you will also be asked to create a login as well as a password for your account.
• Business Contacts. When you access and use our services, we may also collect information about the business contacts that you upload into your account.
• IP Address. We may collect the IP address of your computer in order to enable us to detect unauthorized transactions, better manage website traffic, and to gather other analytics on our website.

How We Use Your Personal Data

We use your personal data to:

• respond to your inquiries about our services,
• maintain a commercial relationship with you and to communicate with you (which communication may include account verification, and discussions pertaining to your needs and preferences),
• market features and products and provide you with newsletters, promotional materials and information about events, and other information that may be of interest to you, including to deliver tailored content and targeted advertising,
• generate analytics for the improvement of the website and services,
• administer, maintain, manage and improve our website, services and products, and internal operations, including to fix problems individuals may have with our services, such as answering support questions and resolving technical issues,
• manage the services platform (including support systems and security),
• analyze, research and improve our products, business, services, and websites including to create and review data about our users and how they use our services,
• test changes in our services and develop new features and products,
• comply with our legal obligations to establish, exercise, or defend legal claims, and to monitoring, and reporting compliance issues, records retention periods,
• prevent, investigate and respond to fraud, unauthorized access to or use of our services, breaches of terms and policies, or other wrongful behavior, and
• disclose as permitted or required by law, or as otherwise specified at the time of collection.

Cookies and Related Technologies

We and our vendors, including service providers and third parties, use, or intend to use, cookies, which are text files containing small amounts of information that are downloaded on your device, and related technologies such as web beacons, local shared objects, and tracking pixels to store or collect information for the purposes mentioned in this Privacy Policy including targeted advertising, monitoring performance, analytics, and improving our services and website.

Our website uses both session cookies (used to maintain authentication while clients are using our products) and advertising cookies (that help us serve you tailored ads). For more information on cookies, click here: www.allaboutcookies.org.

Ads for Our Products and services

We may also use third party services, such as Google, to serve tailored ads about our products and services to you on our services and elsewhere. We allow these third parties to use and access their own cookies on your computer or other device(s) you use to access our services. We do not have access to these cookies or related technologies, and this Privacy Policy does not govern the use of those cookies and related technologies.

How You Can Opt-Out of Cookies and Related Technology

You may opt out of our use of cookies and other related technology as follows:

• Cookies and Other Related Technology. You can decline cookies through your browser settings. However, if you decline cookies, you may not be able to use some parts of our services.
• Geolocation Information. If you do not want us to see your device location, you can turn off location sharing on your device, change your device privacy settings, or decline to share location on your browser.
• Google Opt-Out – To opt out of Google Analytics, please see https://tools.google.com/dlpage/gaoptout/. To opt out of Google Ads, please see https://safety.google/intl/en/privacy/ads-and-data/.
• Digital Advertising Alliance — You can also opt out from companies like Google and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/. You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: https://youradchoices.ca/ or opt out using your mobile device settings.

In addition, all marketing messages we send contain an “unsubscribe” link in the email message. You may opt-out of receiving any or all of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contact us at the contact information at the bottom of this Privacy Policy. Please note that we may send one message to confirm your opt out request. Transactional or business relationship messages may continue after you opt out of marketing messages.

Circumstances in Which We Share Personal Data

We do not rent, trade, or share personal information with third parties, except to provide our services, which you requested, when we have your permission, or under the following circumstances:

• We use third parties for credit card processing, which parties are prohibited from using your personally identifiable information for promotional purposes.
• We may export data at your request to our third-party integration partners.
• We may share your aggregate anonymous information with third parties (such as Hubspot) to improve the website and services or for marketing purposes.
• We may share your information with third party contractors such as developers, support administrators, designers, data analysts, and network technicians to maintain and improve the services.
• We may share your information with third party vendors, who help to manage and store data uploaded to Crux, or to support and improve the services.
• We may share your personal information if required by law and if we believe that the disclosure is required or necessary to protect our rights and/or comply with a judicial processing or legal process served on us.
• We may share personal information if we believe that it is required to investigate, prevent, or take action regarding illegal activities, suspected fraud, a potential threat to the physical safety of a third party, or as otherwise required by law.
• We may transfer personal information to a third-party entity in the event of an assignment of this website or an acquisition of Crux, for any reason. You will be notified via email of any such change in ownership or control of personal information.
  We may share personal information with our legal, financial, and other professional advisors.

We may share personal information with third parties upon receiving your consent, as required by law.

How Long We Keep Personal Data

For visitors to our websites, we retain your personal data to allow you to return to our websites and be recognized. For “clients”, we retain personal data for as long as the account is open, unless a longer retention period is required by law.

You have the following rights with respect to your personal information:

• Right to Access – You may request to have access to the personal data we have relating to you. We will reply within 30 days either to provide you your information if we have it, or let you know we do not, or if we have it but are not allowed to provide you access, for example if doing so would violate the privacy of another individual, we will provide you with justification.
• Right to Correct – If you find your information is inaccurate, you may have it corrected.
• Right to Withdraw Consent – If consent was a basis of collection of your personal information and you no longer consent to us retaining and using your personal data, you may request to have it deleted. We will do so immediately, unless legal requirements (for example, tax law in relation to clients) impose retention periods.

To keep your personal data safe, we use appropriate security safeguards to provide necessary protection. These include physical measures (e.g., restricting access to offices, and alarm systems), up-to-date technological tools (e.g., passwords, encryption, firewalls and security patches), and organizational controls (e.g., security clearances, limiting access, staff training, and agreements). We apply these measures, tools, and controls based on the sensitivity of the information we collect, use, and store, and the current state of technology. While we make considerable efforts to protect our information systems, no data security measures can guarantee 100% security.

We will never initiate a request for personal information by email or pop-up window. If you receive a request by email or pop-up window that appears to be originating from Crux, please do not respond and notify us at the contact information under “QUESTIONS?” below.

If you are located outside the United States, please be aware that information we collect or obtain about you may be transferred to and processed in the United States or other jurisdictions outside your own. By interacting with our websites, applications and using our services, you consent to such transfers and acknowledge that the data protection laws and regulations that may apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence including such that the governments, courts, law enforcement or regulatory agencies of the other countries may be able to obtain access to your personal information through the laws of that country.

As a supplement to other information provided throughout this Privacy Policy, we provide the following additional information as a notice to residents of California (“California consumers”) in accordance with the California Consumer Privacy Act (“CCPA”). Please note this section may not apply to you if you are a Crux client.

California Consumer Privacy Rights:

• Right to Know – You have the right to request that we disclose to you the following information about Personal Information we collect from you:
  • categories of personal information collected,
  • categories of sources of personal information collected,
  • the business or commercial purpose for collecting or selling personal information,
  • the categories of third parties with whom we share personal information, and
  • the specific pieces of personal information we have collected about you over the past 12 months.
    In the preceding 12 months,
• Crux has disclosed the following categories of personal data for a business purpose:

We do not knowingly sell the personal data of consumers under 16 years of age.

• Right to Delete — You have the right to request the deletion of your personal data collected or maintained by us subject to certain exceptions permitted by law.
• Right to Opt-Out of Sale of Personal Information — You have the right to opt out of the sale of your personal data.
• Right to Non-Discrimination — You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.

Making a CCPA Request

You may make a CCPA request by email to [email protected]. Once we receive your request, we are required to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. Upon making a request, you will be asked to provide certain information to identify you and verify your information which may include your first and last name, full mailing address, email address, phone number, and possibly other request details. If we cannot verify your identity, we will not be able to respond to your request. Information collected through verification will only be used for verification purposes.

Authorized Agent

You may designate an authorized agent to exercise any of the above California privacy rights on your behalf, subject to the agent request requirements of the CCPA. Authorized Agents may make requests under the CCPA on behalf of California Consumers by contacting us at [email protected].

California’s Shine the Light Law. We do not share personal data with third parties for their own direct marketing purposes without your consent. Under California Law, you provide consent when you accept Cookies. We only share personal data when there is evidence of that consent.

Once a year, free of charge, you are entitled to request and obtain certain information regarding Crux’s disclosure of your personal data to third parties for their direct marketing purposes. This right only applies to activities within California. To make any request to exercise your California privacy rights please contact [email protected] or write to us at CruxOCM Inc., 12436 FM 1960 Rd. W PMB 1025 Houston Texas 77065, with a reference to “CA Shine the Light Disclosure”.

Do Not Track Signals — California law requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals. Because there currently are no industry or legal standards for recognizing or honoring DNT signals, we do not respond to them at this time.

All the personal data we collect directly from consumers, whether on our websites, apps or through our services, is through consent. All the personal data that we collect from other sources as disclosed in this Privacy Policy is with the assurance that the individuals have provided consent for that sharing of their personal data.

Your Privacy Rights. You may ask us to take the following actions with respect to your personal information:

• access your personal information;
• verify or correct inaccuracies in your personal information;
• where you have provided your consent to the collection, use and transfer of your personal information, withdraw your consent under certain circumstances.

You may submit these requests by email to [email protected] may require specific information from you to help us verify your identity prior to processing your request.

Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to any legal or regulatory restrictions on disclosing this information. Please note, if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

If you are accessing our website or the services from the European Union, Asia, South America, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States or Canadian laws (such as the General Data Protection Regulation, or “GDPR”), please be advised that through your continued use of our website and services, you will be transferring your personal information into the United States and you consent to that transfer.

If you have a complaint against us relating to our use of personal information and you are accessing the website or our services from the EU, you may lodge a complaint with a supervisory authority competent for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at:

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

This Privacy Policy does not apply to any third-party websites and apps that you may use, including any linked to our services and website. Please note that such websites have their own privacy policies that are different from ours, and you should review their privacy policies to understand the privacy practices of their services before clicking on any links or submitting any personal data to such third parties. We are not responsible for any transactions that occur between you and a third-party website.

Our website, apps and services are not designed for and are not marketed to people under the age of 16 (“minors”). We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our services. If you are a minor, please do not use our services or send us your information. We delete information that we learn is collected from a minor without verified parental consent. Please contact us at [email protected] if you believe we might have information from or about a minor.

We reserve the right to update or modify this Privacy Policy from time to time at our discretion. We will indicate changes to this Privacy Policy by updating the “Effective Date” at the beginning of the Privacy Policy. Please review this Privacy Policy periodically and especially before you provide any personal information to us. Your continued use of our Services after any update will constitute your acceptance of our changes.

For questions, concerns, or complaints regarding our data handling practices, compliance with laws or this Privacy Policy, please contact us via [email protected] or by writing to us at:

CruxOCM Inc.
12436 FM 1960 Rd. W
PMB 1025
Houston, Texas 77065
Attention: Privacy Team