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LAST UPDATED: MARCH 29, 2021

Privacy Statement

Overview

CrossBorder Transactions LLC d/b/a CrossBorder Solutions (“CrossBorder”, “we”, “us”, “our” or the “Company”) is committed to respecting and protecting your privacy. This CrossBorder Privacy Statement (“Privacy Statement”) describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals (“Personal Data”) that we obtain through or in connection with your use of our services and/or in connection with your use of https://xbs.wpengine.com/ (our “Site”), and your rights and choices regarding our processing of your Personal Data.

“Personal Data” is information (including “personal information” as that term may be defined) that, directly or indirectly, identifies you or another individual and which may include: name, title, company name, expertise, postal address, telephone number, email address, browser and device information (including IP Address), and information collected through cookies and other similar technologies. If you submit any Personal Data relating to other people to us or to our service providers in connection with the Site, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.

“Other Information” or “Other Data” is any information or data that does not and cannot be used to reveal your identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Site and for other purposes described below.

For the purposes of the UK Data Protection Act 2018 (the “DPA”) and the EU General Data Protection Regulation 2016/679 (the “GDPR”) and other laws globally, CrossBorder is the “controller” and is responsible for deciding how Personal Data is used, collected, and processed, unless expressly specified otherwise. We are a limited liability company organized under the laws of the State of Delaware, U.S.A., with offices at 520 White Plains Road, Tarrytown, New York 10591 USA. By using or accessing the Site, or by providing Personal Data to us on or through the Site, you acknowledge that you have read and understood the policies and procedures described in this Statement. This Privacy Statement does not apply to the practices of third parties that CrossBorder does not own or control, or to individuals that CrossBorder does not employ or manage.

If you have any questions or concerns about this Privacy Statement, please contact us using the Contact Us button or at info@xbs.ai

 

Personal Data we collect

Personal Data you provide to us

This is information that you choose to provide to us, which may include: your name, job title, company name, contact information including email, postal address and telephone number(s) and your preferences or areas of interest.

If you register to use our services, either as a company or as an individual, we will ask that you provide your name, contact information, company information and title (if applicable) and that you use your email address as user name and select a password which will be used to access your account.  Each user must have a separate user name and password and is responsible for the security of this information.

 

How we process your Personal Data

Where your consent is not mandatory, we may process Personal Data on the following lawful bases:

  • For the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract.
  • As necessary in certain legitimate interests (including our business interests), provided such interests are not overridden by your interests or fundamental rights.

We will process Personal Data for the following purposes as is necessary for the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract:

  • To administer or otherwise carry out our obligations in relation to any agreement to which we are a party;
  • To assist you in completing a transaction or order;
  • To prepare and process invoices;
  • To respond to queries or requests and to provide the services and associated support;
  • To provide customer relationship management;
  • To create and manage our accounts;
  • To notify you about changes to our services;
  • To allow you to subscribe to news, alerts or other publications; and
  • To allow you to sign-up to attend webinars or events.

We will process Personal Data for the following purposes as necessary for certain legitimate interests, or where you have given your informed consent to such processing (such consent may be withdrawn at any time), including:

  • To offer our services to you in a personalized way;
  • To send you personalized marketing communications;
  • To allow you to participate in questionnaires, surveys, contests and surveys and benefit from personalized promotional offers;
  • To monitor quality control and ensure compliance with any and all applicable laws, regulations, codes and ordinances, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law;
  • To resolve any disputes;
  • As part of our efforts to keep our Site, services and premises safe and secure;
  • To ensure the security of your account and our business, preventing or detecting fraud, malicious activity or abuses of our Site and services, for example, by requesting verification information in order to reset your account password (if applicable);
  • To administer our Site and services, and for internal business administration and operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • To create products or services that may meet your needs; and
  • To develop and improve our products and services.

 

Subscribing to news, alerts or other publications

You can use the Site to subscribe to CrossBorder news, alerts or other publications. We will ask you to provide Personal Data such as your name, contact details and topics of interest. We will use this information to provide you with the content you have requested and to tailor this content to your preferences and areas of interest. 

We may use your Personal Data to communicate with you about other topics that we believe may be of interest provided you have given your consent. You can unsubscribe from this content at any time (please see the “Opting-out of Communications” section below).

You can use the Site to subscribe to CrossBorder news, alerts, or other publications. We will ask you to provide Personal Data such as your name, contact details and topics of interest. We will use this information to provide you with the content you have requested and to tailor this content to your preferences and areas of interest.

We may use your Personal Data to communicate with you about other topics that we believe may be of interest provided you have given your consent. You can unsubscribe from this content at any time (please see the “Opting-out of Communications” section below).

Save for where we seek your consent for marketing purposes, we will process such Personal Data as is necessary for performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract.

 

Webinars or Events

You may provide your Personal Data, including your name and contact details, through our Site to register for CrossBorder events and webinars. We will use this information to process the registration and contact you about any changes or updates regarding the event or webinar.  We will process such Personal Data as is necessary for performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract.

We may share your Personal Data with speakers or event sponsors, provided you have given your consent. We may also contact you with information about other events and other CrossBorder activities and services provided you have consented to receiving such information. You can unsubscribe from this information at any time (please see the “Opting-out of Communications” section below).

 

Blogs

In some cases, our Site allows you to comment on CrossBorder blog posts and to share content with third parties via email or social media. These comments are visible to the general public.  Personal Data may be shared in any comment you post and you may submit your name or email address with the comment. Please take care to limit the amount of Personal Data you include in your comments to information that you are comfortable sharing with the general public. By sharing content on social media, you will provide Social Networks with information about your use of our Site.

You can use our Site to subscribe to an RSS feed or to receive email updates of our blogs by submitting your name and email address. We use this information to send you the content you request and to communicate with you in connection with our blogs. You can unsubscribe from this content at any time (please see the “Opting-out of Communications” section below).

 

Careers

You can use the careers section of our site, to learn about our company and apply for open positions by submitting a resume and other Personal Data via email or through our Site. We may also receive resumes from recruitment consultants, CrossBorder employees or other third parties. Information we collect will typically include identifiers (name, contact details, location, references), professional and employment related information (academic and professional qualifications and experiences), protected classification information (information protected by state, local and federal law which we use only to ensure we comply with our anti-discrimination obligations), your interests, and the position at CrossBorder for which you are applying. We will process this Personal Data for the following purposes as necessary for certain legitimate interests, or where you have given your informed consent to such processing (such consent may be withdrawn at any time) to:

  • Assess your suitability for the position for which you are applying.
  • Contact you in relation to your application.
  • Manage and administer our recruitment processes; and
  • Provide updates on vacancies at CrossBorder which might be suitable for you, provided you have given your consent.

In the event you are not hired by our company, we will permanently delete your resume and any other  information you submitted to us or which we held about you in connection with your application within one year (as required by law) after receiving your application, unless you have given us your consent to keep this information for a longer period in order to inform you about future vacancies which may be of interest.

 

Contacting us by phone, e-mail or otherwise

When you communicate with us via our Contact Us page, you are asked to provide your name, email address, phone number and company name. We will use this information to respond to your questions and comments. We will request similar Personal Data to confirm your identity when you contact us by phone, email or otherwise.  We will process such Personal Data as is necessary for the performance of a contract between you and us or to answer questions or take steps at your request prior to entering into a contract, or as is necessary for certain legitimate interests.

 

Generally

We collect log files and Other Information about your device and your usage of our Site through cookies, web beacons or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data (view the “Device and usage data we process” section below)

In some cases, if you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, photo identification, company name and time and date of arrival.  We will process such Personal Data as is necessary for certain legitimate interests.

 

Where we act as a processor

In some situations when providing our services, we process Personal Data on behalf and under the instructions of our customers.  We process such Personal Data as a “service provider” or “processor” (as defined by applicable law), on the behalf of our customers. 

 

Personal Data we collect from other sources

We may also collect information about you from other sources, including third parties from whom we have purchased Personal Data, and combine this information with Personal Data provided by you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. We collect Personal Data from the following sources:

Business contact information, including mailing address, job title, email address, phone number, ‘intent data’ which is web user behavior data, IP addresses, social handles, LinkedIn URL and custom profiles from third party data providers for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling.

 

Device and usage data we process

We use common information-gathering tools, such as log files, cookies, web beacons and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our website or interact with emails we have sent you.

 

Log Files

As is true of most websites, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your general location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our website and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Company’s security features.

 

Cookies, web beacons and other tracking technologies

We use cookies and similar technologies such as web beacons, tags and JavaScript alone or in conjunction with cookies to compile information about usage of our website and interaction with emails from us.  Please read our Cookies Notice for more information.  We will use your Personal Data to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you, provided you have given your consent, which can be withdrawn at any time.

 

Site use information

Our web servers may collect information including the IP address of visitors to our Site, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

We use this information for the following purposes:

  • To measure the use of our Site, including number of visits, average time spent on a Site, pages viewed, page interaction information (such as scrolling, clicks, and mouse-overs), etc., and to improve the content we offer;
  • To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  • As part of our efforts to keep the Site safe and secure.

We may share with third parties this information or Other Data on an aggregated basis without the use of any personal information.

 

Web Beacons

As well as cookies, we use other technologies to recognize and track visitors to our Site. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie.

Web beacons allows us, for example, to monitor how users move from one page within our Site to another, to track access to our communications, to understand whether users have come to our Site from an online advertisement displayed on a third-party website, to measure how ads have been viewed, and to improve Site performance.

 

“Do Not Track” Browser Settings

We do not use technology that recognizes a “do-not-track” signal from your web browser, because we do not track users other than for aggregate statistical purposes.

 

Opting out of communications

If you have subscribed to or are otherwise receiving CrossBorder news, alerts, blog posts, or similar information from us by email and no longer want to receive such information in the future, you may opt-out of receiving these emails by clicking the “unsubscribe” link at the bottom of those emails you receive. Please allow ample time for us to process your request. If you are having difficulty unsubscribing, please contact us using the Contact Us page or at info@xbs.ai.

Please note that even if you opt-out of receiving emails, you may still receive communications related to your interaction with us (such as confirmation of a registration or form submission) or otherwise as required by law. Also note that we may need to keep Personal Data we have collected about you to respect your decision to opt-out, for record-keeping, research, and other purposes.

 

Accessing your information

You may contact us to update or correct information that you have provided to us by contacting us using the Contact Us page or at info@xbs.ai.

 

Disclosing information to third parties

We will not share, rent, sell, or otherwise disclose any Personal Data that we collect about you through our Site, except as provided in this Privacy Statement and in any of the following situations:

  • You request or consent to the release of your Personal Data;
  • We will disclose your Personal Data to service providers, suppliers, third-party contractors and payment processors who perform services for us in connection with the Site, where the disclosure will enable that party to perform business, professional or technical support for us, or to complete or confirm a transaction or series of transactions that you conduct with us. When we share your Personal Data with third parties that we engage to process data on our behalf we will ensure that those third parties are contractually bound to guarantee the same levels of privacy protection and confidentiality observed by us when handling your Personal Data;
  • Where you have provided your consent, which can be withdrawn at any time, we will provide your Personal Data to other select third parties approved by CrossBorder as offering products or services relevant and useful to you. The use by and/or content of communications from any third party will be pre-approved by CrossBorder;
  • We may disclose Personal Data about you as part of a merger, acquisition or other sale or transfer of the assets or business of CrossBorder. In such circumstances, we will take steps to inform you of the transfer either directly or indirectly through publishing news of the transaction; and
  • We may disclose Personal Data you have provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, or to enforce our Terms of Use or other agreements; or to protect our rights, property or safety or the rights, property or safety of our users or others. We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.

We will also share Other Information that cannot identify you with third parties. For example, we disclose the number of visitors to the Site or the number of people who have downloaded a particular document.

Where we transfer UK and European Economic Area Personal Data to a third party located in a country not recognized by the UK Government, European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps, such as implementing Standard Contractual Clauses recognized by the UK Government and EU Commission, to safeguard such Personal Data.

If you want further information on the specific mechanism used by us when transferring your Personal Data out of the UK or the EEA, please contact us using the contact details set out above.

 

Security

We have implemented appropriate organizational, technical, and administrative measures to protect Personal Data within our organization, including security controls to prevent unauthorized access to our systems. While we take reasonable steps to secure your Personal Data from loss, misuse, interference and unauthorized access, modification and disclosure you should keep in mind that the Site is run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. You also play a role in protecting your information. You must maintain the security of your online transactions by not sharing your passwords and account information with any unauthorized parties. Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Statement, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure. We cannot guarantee the security of any information you transmit to us or from our Site, and therefore you use our Site at your own risk.  Please also take care when sending us Personal Data by email as email communications are not secure.

 

Breach Notification

We will promptly notify affected individuals and companies if a data compromise is detected and verified as required by applicable laws.

 

Communications with CrossBorder

Telephone calls to CrossBorder, including to the Customer Services or Professional Services teams, may be recorded, and monitored subject to applicable law.

 

Retention

We will store your Personal Data, in a form which permits us to identify you, for no longer than is necessary for the purpose for which the Personal Data is processed. We may retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. Consistent with these requirements, we will try to delete your Personal Data quickly upon request.

Where we process your Personal Data on behalf of a CrossBorder customer as a service provider or processor, we will retain such data in line with the customer’s instructions and our contractual obligations.  You may have the right to ask the controller of your Personal Data to delete, block or correct such Personal Data in line with applicable data protection law.

 

Links to other websites

Our Site may contain links to other websites. This Privacy Statement only addresses the use and disclosure of your Personal Data collected through our Site and services, if any. If you choose to visit an external website linked from a Site, you will leave our Site. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the privacy practices of any third parties or the content of linked websites. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

 

Child Privacy

If you are under the age of majority in your home jurisdiction, please do not use or access the Site. It is not our intention to collect or use Personal Data from anyone under the age of majority, and we will not knowingly do so. If we are made aware that we have collected any Personal Data from minors and are asked to delete such information from our databases, we will promptly do so.

 

Access from outside the United States

If you access our Site from outside of the United States, information that we collect about you will be transferred to servers inside the United States, which may involve the transfer of information out of your country of origin. By accessing our Site and/or using our services, you acknowledge our practices regarding such transfer and processing of your Personal Data.

 

Data Privacy Rights

In certain situations, and subject to applicable law, you may have certain rights in relation to your Personal Data.

For Personal Data that we process on behalf of our customers, we are not responsible for and have no control over the privacy and data security practices of those customers, which may differ from those explained in this Statement.  The data protection rights listed below do not apply to CrossBorder where we process Personal Data as a processor or service provider on behalf of a customer.  If we process your Personal Data as a processor on behalf of a customer, and you wish to exercise any data subject rights you may have under the DPA, the GDPR, the CCPA or other applicable data protection laws, please inquire with the controller directly.

 

Your European and United Kingdom Privacy Rights

For European and United Kingdom residents only. Under European and United Kingdom data protection law, in certain circumstances, you have the right to:

  • Request access to any Personal Data we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the Personal Data, the recipients or categories of recipients with whom the Personal Data has been shared, where possible, the period for which the Personal Data will be stored, the source of the Personal Data, and the existence of any automated decision making;
  • Obtain without undue delay the rectification of any inaccurate Personal Data we hold about you;
  • Request that Personal Data held about you is deleted;
  • Prevent or restrict processing of your Personal Data; and
  • Request transfer of Personal Data directly to a third party where this is technically feasible.

Also, where you believe that CrossBorder has not complied with its obligation under this Privacy Statement or UK or European law, you have the right to make a complaint to a UK or an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting us using the Contact Us page or at info@xbs.ai.

We aim to respond to requests made by you within one (1) month, but may extend that period by two (2) further months where necessary. 

 

Notice to California Residents

Your California Privacy Rights.

CrossBorder may share your Personal Data with third parties for their use to market their products or services to you only when we have your consent.  You may withdraw your consent at any time by contacting us at using the Contact Us page or at info@xbs.ai.

 

California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) provides “consumers” (California residents) with specific rights regarding their Personal Data (referred to as “personal information” under the CCPA”).  This section describes your CCPA rights and explains how to exercise those rights. The CCPA rights described below do not apply to information collected in the employment context about our current, former or prospective employees or contractors (who receive separate disclosures under the CCPA) or to information collected about California business contacts (employees, owners, directors, officers, or contractors of companies, sole proprietorships, and other entities collected in the context of conducting due diligence regarding, or providing or receiving a product or service to or from, such companies, sole proprietorships, or entities).  California business contacts have the right to tell us not to sell their information; please see below for how to exercise this right. For purposes of the CCPA, “personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.

During the past twelve (12) months, we have collected the following categories of Personal Data from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties. Not all information is collected about all individuals.  This list excludes information collected about employees and business contacts in the context of those relationships.

 

Category of information collected 

Source

Business purposes* for use 

Categories of third parties receiving information 

Identifiers

(first name, surname, company name, contact information including email, postal address and telephone number(s), social media account information, content, correspondence, survey and questionnaire responses)

Individuals submitting information to us.

Information we automatically collect from site visitors.

Information we may receive from third-party marketing and data partners.

Performing services for you.

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in above).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

Sensitive information

(name with financial account, medical, health, and health insurance information, user name and password)

Individuals submitting information to us.

Employment applications.

 

 

 

Performing services for you.

Security detection, protection and enforcement.

Service providers (such as those listed in above).

Affiliated companies.

Government regulators.

Law enforcement.

Commercial information

(transaction history, products/services purchased, obtained or considered and product preferences, details of how you like to interact with us)

Third party marketing partners.

Individuals submitting information to us.

Information we automatically collect from Site visitors.

 

Performing services for you.

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in above).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

Internet or other electronic network activity

 

Information we automatically collect from Site visitors.

 

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in above).

Affiliated companies.

Government regulators.

Law enforcement.

 

Audio & visual

(recordings of customer services calls, security monitoring)

Individuals submitting information to us.

Information we collect for security purposes.

Performing services for you.

Internal research and development.

Security detection, protection and enforcement.

 

Service providers (such as those listed in above).

Affiliated companies.

Government regulators.

Law enforcement.

Geolocation

Information we automatically collect from site visitors.

Auditing relating to transactions.

Security detection, protection and enforcement.

Functionality debugging/error repair.

Advertising customization.

Performing services for you.

Internal research and development.

Quality control.

Service providers (such as those listed in above).

Government regulators.

Law enforcement.

 

Biometrics

Not collected

 

 

Inferences from the above

(preferences, characteristics, behaviour, attitudes and abilities, etc.)

Internal analytics

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Service providers (such as those listed in above).

 

*More specifically, the business purposes include those listed throughout this Statement.

Sale of Personal Data

Your rights and choices

If you are a verified California resident, you have the right to obtain certain information about our collection and use of Personal Data over the past twelve (12) months, including:

  • Information Collection Practices: disclosure of the categories of Personal Data we collect, the categories of sources of such information, our business purpose for collecting or sharing such information, and the categories of third parties with whom we share such information;
  • Information Sharing Practices: disclosure of the categories of Personal Data sold with the category of third party recipients and a list of the categories of Personal Data that we disclosed for a business purpose;
  • The specific Personal Data we have collected about you over the past twelve (12) months;

You have the right to request that we do not sell Personal Data about you.

You have the right to request that we delete (and direct our service providers to delete) your Personal Data subject to certain exceptions. 

Personal Data Sales;  opt-out and opt-in rights

We do not sell your Personal Data for monetary consideration but we may transfer your Personal Data to a third party that provides us with services such as helping us with advertising, data analysis and security, which may fall under the definition of for “other valuable consideration” which may be considered a “sale” under the CCPA.

During the past 12 months, we disclosed Identifiers and Electronic Network Activity to third parties, such as advertising and analytics providers for a business purpose which falls within the CCPA’s definition of a “sale”.  If you are sixteen (16) years of age or older, you have the right to direct us to not sell your Personal Data at any time (the “right to opt-out”).  We do not sell the Personal Data of individuals we actually know are less than sixteen (16) years of age.  To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at any time by visiting the following page: Do Not Sell My Personal Information or by calling us toll-free at (727) 350-6377. We will comply with your request within 15 business days.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Data sales.

Exercising your rights for disclosure and deletion

You can exercise your rights to request disclosure of our information collection practices, our information sharing practices, or your specific Personal Data  by contacting us by email at ccpa@xbs.ai.  You may also submit a request to us by visiting our Contact Us page. You may make a request up to twice within a twelve (12) month period. 

You can exercise your right to request deletion of your information by email at ccpa@xbs.ai or by visiting our Contact Us page. You may make a deletion request at any time. Please understand that California law permits us to retain certain information and not to delete it under certain circumstances.  By way of example, we are not required to comply with a request to delete information if the information is necessary for us to complete a transaction for you or otherwise perform a contract; to detect, protect against, or prosecute security incidents, fraud or illegal activity; to use the information only internally in ways reasonably aligned with your expectations as our customer (such as maintaining sales records), and/or to comply with legal obligations. If we receive such a request from you we will notify any service providers we have engaged to delete your information as well.

We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected Personal Data) by matching it against information in our records and we will use that information only for that purpose. We may request that you submit a signed statement under penalty of perjury that you are the individual you claim to be if you request disclosure of Specific Information or deletion.  We cannot respond to your request or provide you with Personal Data if we cannot verify your identity and confirm that the Personal Data relates to you.

We will not discriminate against you as a result of your exercise of any of these rights.

Response timing and format

We will acknowledge receipt of your request within ten (10) days and endeavour to respond within forty-five (45) days of receipt of your request, but if we require more time (up to an additional forty-five (45) days) we will notify you of the reason and extension period in writing.

Where you request a copy of your Personal Data, we will endeavour to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy.  Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of you verified request.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Using an Authorized Agent. 

You may submit a request through someone holding a formal, notarized Power of Attorney.  Otherwise, you may submit a request using an authorized agent only if (1) the person is registered with the Secretary of State to do business in California, (2) you provide the authorized agent with signed written permission to make a request, (3) you verify directly with us that you have authorized the person to make the request on your behalf, (4) you verify your own identity directly with us and (5) your agent provides us with proof that they are so authorized..  We will require the agent to submit proof to us that they have been authorized to make requests on your behalf.

 

Notice to Nevada Residents

We do not transfer Personal Data for monetary consideration.  Nevertheless, if you would like to tell us not to sell your information in the future please email us at info@xbs.ai with your name, postal address, telephone number and email address with “Nevada do not sell” in the subject line.

 

Governing Law

By choosing to visit our Site or provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Statement will be governed by the laws of the State of New York and the United States of America. You also agree to abide by any limitation on damages contained in our Terms of Use, or other agreements that we have with you.

 

Changes to this Privacy Statement

We may occasionally amend this Privacy Statement to reflect our activities and user feedback, and we reserve the right to make changes to this Privacy Statement at any time. The use of your information is subject to the Privacy Statement and Terms of Use in effect at the time of use. The provisions contained in this Privacy Statement supersede all previous notices or policies regarding our privacy practices with respect to the Site. Please check the “Last Updated” legend at the top of this page to see when this Privacy Statement was last revised. In the event we make material changes to this Privacy Statement we will post the revised Privacy Statement here with a current “Last Updated” date.  We encourage you to check frequently to see the current Privacy Statement to be informed of how we are committed to protecting your information and providing you with improved content on our Site in order to enhance your experience.

 

Contact

If you have any questions or comments regarding our Privacy Statement or our Site, please contact us using the Contact Us page or at info@xbs.ai.

You can also write to us at:

CrossBorder Solutions

520 White Plains Road

Tarrytown, New York 10591

USA

Attn: Marketing Compliance Team