EFFECTIVE DATE: December 1, 2019
CrossKey (“us”, “we”, or “our”) operates the www.predictablerevenue.com website (the “Website”).
This page informs you of our policies regarding the collection, use, and disclosure of personal data
when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise defined in this
Conditions, accessible from www.predictablerevenue.com.
Cookies means the small pieces of data generated by a website and stored on your device
(computer or mobile device), typically on the browser.
Data Controller means the natural or legal person who (either alone or jointly or in common with
other persons) determines the purposes for which and the manner in which any personal information
are, or are to be, processed.
Data Processors (or Service Providers) means any natural or legal person who processes the data
on behalf of the Data Controller.
Data Subject (or User) means any living individual who is the subject of Personal Data.
Personal Data means any information relating to an identified or identifiable natural person.
Service means the CrossKey software as a service tools and services offered through the
Usage Data means data collected automatically either generated by the use of the Service or from
the Service infrastructure itself (for example, the duration of a page visit).
INFORMATION COLLECTION AND USE
We collect several different types of information for various purposes to provide and improve our
Service to you.
INFORMATION WE COLLECT
Information you provide: When you register an account, we collect some Personal Data, such as
your name, title, email address, phone number, billing information and other similar information.
Content: You also provide Personal Data in content you upload to the Service, or which is uploaded
on your behalf (“Content”). In general, the Content you provide will be viewable and discoverable by
your users. In some cases, where content has been shared with users outside your email domain
extension, your information may be viewed by those additional users. We can, but have no obligation,
to monitor the Content you post on the Service.
Geo-Location Information: Content that you upload or share through the Service may contain
recorded location information. Location data does not collect or share any personally identifiable
information about you. Location data may be used in conjunction with personally identifiable
Device Identifiers: When you access the Service by or through a device, we may access, collect,
monitor and/or remotely store one or more “device identifiers”. Device identifiers allow us to uniquely
identify your device and are used to enhance the Service (including sending updates and information
from the Service). A device identifier does not collect or share any personally identifiable information
about you. A device identifier may be used in conjunction with personally identifiable information.
Analytics: When you access the Service on our website, we may collect information (using third party
services) using logging and cookies which can sometimes be correlated with Personal Information.
We use this information to monitor and analyse use and interest in the Service. See the section on
“Service Providers” for more detail in this respect.
Log data: As with most websites and technology services delivered over the Internet, our servers
automatically collect information when you access or use our Websites or Services and record it in log
files. This log data may include the Internet Protocol (IP) address, the address of the web page visited
before using the Website or Services, browser type and settings, the date and time the Services were
used, information about browser configuration and plugins, language preferences and cookie data.
us collect certain Usage Data about you, which may become Personal Data due to direct association
with your account. The Websites and Services may also include cookies and similar tracking
technologies of third parties, which may collect information about you via the Websites and Services
and across other websites and online services. For more details about how we use these
HOW WE USE INFORMATION
We use information that we collect for the purpose of fulfilling our contractual obligations to you under
our Terms of Service, in furtherance of our legitimate interests in operating our Services, Websites
and business and/or where you have consented to such usage. These are the lawful basis for the
usage of your Personal Data. More specifically, We use Personal Data:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Personal Data to support delivery of the Services under our Terms of Service, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at your request. We may use your email address or phone number to send you
- Service-related notices (including any notices required by law, in lieu of communication by postal mail). If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
- As required by applicable law, legal process or regulation. We may in certain instances be compelled by law to process your Personal Data in order to comply with a binding order. We will only do so to the extent reasonably required by that order.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Personal Data to respond.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications.
- We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about us. These are marketing messages so you can control whether you receive them, and if you are resident in the EEA we will only send you these emails where you have consented to our sending them to you. .
- For billing, account management and other administrative matters. We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
- For marketing purposes. We may also use your contact information to send you marketing messages. If you are in the EEA we will only to do if you have opted in to receive such communications. If you don’t want to receive these messages, you can opt out by following the instructions in the message.
LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GENERAL DATA PROTECTION
If you are from the European Economic Area (EEA), CrossKey ’s legal basis for collecting
collect and the specific context in which we collect it.
CrossKey may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- To comply with the law
We set out a more detailed breakdown of the legal basis for our use in the “How We Use Information”
RETENTION OF DATA
CrossKey will retain your Personal Data only for as long as is necessary for the purposes
comply with our legal obligations (for example, if we are required to retain your data to comply with
applicable laws), resolve disputes, and enforce our legal agreements and policies.
CrossKey will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used to strengthen the
security or to improve the functionality of our Service, or we are legally obligated to retain this data for
longer time periods.
TRANSFER OF DATA
Your information, including Personal Data, may be transferred to — and maintained on — computers
located outside of your state, province, country or other governmental jurisdiction where the data
protection laws may differ than those from your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that
we transfer the data, including Personal Data, to the United States and process it there.
agreement to that transfer.
CrossKey will take all steps reasonably necessary to ensure that your data is treated
place to an organization or a country unless there are adequate controls in place including the
security of your data and other personal information. Without limiting the foregoing, if we transfer
Personal Data originating from the European Union or Switzerland to other countries not deemed
adequate under applicable data protection law, then we ensure that adequate safeguards are in place
including without limitation ensuring that the Service Provider is EU-US Privacy Shield compliant or
requiring them to enter into the European Union Standard Contractual Clauses.
DISCLOSURE OF DATA
Disclosure for Law Enforcement
Under certain circumstances, CrossKey may be required to disclose your Personal Data if
required to do so by law or in response to valid requests by public authorities (e.g. a court or a
CrossKey may disclose your Personal Data in the good faith belief that such action is
- To comply with a legal obligation
- To protect and defend the rights or property of CrossKey
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
- Other lawful basis for disclosure
CrossKey may disclose your Personal Data:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business solely for the purpose of them providing services to us.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
SECURITY OF DATA
The security of your data is important to us, but remember that no method of transmission over the
Internet, or method of electronic storage is 100% secure. While we strive to use commercially
reasonable means to protect your Personal Data in accordance with industry standards, we cannot
guarantee its absolute security.
YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION
If you are a resident of the European Economic Area (EEA), you have certain data protection rights.
CrossKey aims to take reasonable steps to allow you to correct, amend, delete, or limit the
use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed
from our systems, please contact us using the contact information set out below.
In certain circumstances, where we act as Data Controller, you have the following data protection
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you where we are the data controller and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it.
- You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your
Personal Data. For more information, please contact your local data protection authority in the
European Economic Area (EEA).
If you wish to exercise any of the rights set out above, please contact us using the contact details
You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal information (or to exercise any of your other rights). This is a
security measure to ensure that personal information is not disclosed to any person who has no right
to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our
IDENTIFYING THE DATA CONTROLLER AND PROCESSOR
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of
information. In general, We are the controller of information which we request or collect for the
purposes of maintaining the Service. Our customers are the controller of Personal Data which they
enter into the Service which is not requested by us, or which we may enter into the Service on their
behalf. Our Data Processing Addendum applies to the processing of any Customer Data to which the
General Data Protection Regulation (2016/679) applies.
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to
provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how
our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and
are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic.
Google uses the data collected to track and monitor the use of our Service. This data is shared with
other Google services. Google may use the collected data to contextualize and personalize the ads of
its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing
(ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web
CrossKey uses remarketing services to advertise on third party websites to you after you
based on your past visits to our Service.
Google AdWords is a remarketing service provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display
Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on
– https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser
Add-on provides visitors with the ability to prevent their data from being collected and used by Google
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this
To opt-out from Facebook’s interest-based ads follow these instructions from
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by
the Digital Advertising Alliance. You can also opt-out from Facebook and other participating
companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the
Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive
Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile
For more information on the privacy practices of Facebook, please visit Facebook’s Data
AdRoll remarketing service is provided by Semantic Sugar, Inc.
You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web
ADDITIONAL LIMITS ON USE OF YOUR GOOGLE USER DATA
- The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
- The App will not use this Gmail data for serving advertisements.
- The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App’s internal operations and even then only when the data have been aggregated and anonymized.
LINKS TO OTHER SITES
Our Service may contain links to other sites that are not operated by us. If you click on a third party
of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of
any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If
you are a parent or guardian and you are aware that your child has provided us with Personal Data,
please contact us. If we become aware that we have collected Personal Data from children without
verification of parental consent, we take steps to remove that information from our servers.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming
Policy are effective when they are posted on this page.