We at CrossCountry Consulting (CrossCountry) respect your concerns about privacy and value the relationship that we have with you. This Privacy Statement describes the types of personal information that we collect and use, whether we receive that personal information from and about individuals who visit our website, www.crosscountry-consulting.com and who we interact with in other ways, or we receive that personal information from clients who collected and made it available to us in connection with our provision of services to those clients. Your use of our Site constitutes your consent to this Privacy Statement.
In addition to this Privacy Statement, CrossCountry adheres to the EU-US Privacy Shield Principles with regard to the transfer of Personal Data from the European Union to the United States. For more information, see “Additional Information for Individuals in the European Union,” below.
To contact us with questions about this Privacy Statement, the EU-US Privacy Shield Framework, or any other privacy-related issues, see “How to Contact Us/California Privacy Rights,” below.
This Privacy Statement does not apply to CrossCountry’s human resources information, including information that we collect from prospective job applicants and from employees and contractors.
CrossCountry and its compliance with this Privacy Statement is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Information that We Collect and How We Use It
Personal information that we collect directly from and about you
In general, you can visit our Site without telling us who you are or providing any personal information about yourself, but you may also choose to open a user account on our Site, in which case you will be asked to provide personal information.
CrossCountry may obtain information (primarily name, contact information, area of business, and title) about you in a number of ways:
- Through this Site,
- Through information provided by you at live events, and
- Through other public sources
We may enhance or merge any information that you provide to us online (such as by filling in information on our “contact us” webpage or by registering for a user account on our Site) with any additional information that you provide to us offline (such as by registering for one of our live events) and with public information that we obtain through public sources. If you choose to provide us with your information or we obtain it through public sources, we will use that information to open, maintain, administer, and service your user account; to respond to your inquiries; to customize and improve the content of our Site and other communications; and to provide you with offers and information regarding CrossCountry products and services.
Website Tools and Tracking Technology
We may also use certain automated tools and technologies to collect other information from visitors to our Site, including, but not limited to:
- Traffic Data – When you visit our Site, we may automatically track and collect the following categories of information: (1) your Internet protocol and domain server address; (2) the date and time of your visit to the Site; (3) the type of web browser and operating system you used to access the site; and (4) the web pages that you accessed at the Site (collectively, Traffic Data). Traffic Data is anonymous information that does not identify or track you personally. We use Traffic Data to evaluate and improve the content of our Site and to make our Site more useful to visitors. We also use it to diagnose problems with our server, to keep our server running smoothly, and to monitor the number of visitors to our Site and the type(s) of technology they use. (5) We may also collect other information that is not identified or tracked to you personally, such as search-related information.
- Cookies – A cookie is a small data file placed on your hard drive by an Internet website server. We use temporary session cookies to maintain the functionality of our online services during your visit to our Site, including permitting you to navigate among our webpages and access content. These temporary cookies contain no information that personally identifies you, they are not stored, we do not combine them with other information that we collect, and they only exist until you exit our Site and close your browser. If you register for a user account with us, we may use permanent cookies to identify you as a registered user and remember you and your preferences when you return to our Site. Any such permanent cookies will be encrypted and will only be functional on this Site. You can refuse to accept permanent cookies and you can also choose to delete such cookies from your computer and/or browser by using any of the widely available methods, but if you do so, you may be unable to experience the full benefits of our Site and of your user account, including some of the interactive features of our Site.
- Tracking Code – We may also track the pages you view on our Site, collect information about the links to and from our Site that you click on, and collect information about emails that we may send and you may open, through methods such as tracking codes, web beacons, or pixels. These tools may be used to measure the effectiveness of our Site, marketing, and email campaigns by permitting us to quantify the number of individuals who click on a link to or from our Site; the frequency with which our email messages are opened and the links they contain are clicked on; the extent to which our email messages are forwarded to others; and the type of software, device, operating system and browser used to access our email messages.
- Mobile Devices – If you access our Site from a mobile device, in addition to the types of information described above, we may also collect data about your device, including type of device, browser technology, and device identification information.
At this time, we do not honor “do not track” signals from website browsers. However, you may refuse or delete cookies. If you refuse or delete cookies, some of the functionality of our Site may be impaired. If you turn off cookies, Web beacon and other technologies will still detect visits to our Site, but the information they generate cannot be associated with other non-identifiable cookie information and will be disregarded. Please refer to your browser Help instructions to learn more about how to manage cookies and the use of similar technologies.
Personal information collected by clients that is made available to us in connection with our provision of services to those clients
In addition to collecting personal information directly from and about individuals as described above, CrossCountry provides a range of consulting services to its client companies, including management analyses, financial- and accounting-related services, and system implementation support services. Our clients may make personal information that they have collected available to us to permit us to perform the requested consulting services. In all such instances, CrossCountry’s access to and use of any personal information collected by a client company is limited to the purposes and use(s) specified in the client’s contract with CrossCountry, and CrossCountry’s handling of that information complies with the client contract and with the applicable provisions of this Privacy Statement.
Information We Share
We do not sell, rent, trade, or otherwise disclose personal information except as described in this Privacy Statement. We may share personal information provided to us with service providers that we have retained to perform services on our behalf, such as hosting our Site, managing customer relationships, distributing communication content, and assisting us in providing services to clients to the extent permitted by our contract with the client and, if applicable, the EU-US Privacy Shield Framework. Our service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf and to comply with legal requirements. In addition, we may be required to disclose information about you (i) if we are required to do so by law or pursuant to legal process, (ii) in response to a request from law enforcement authorities or other government officials, (iii) in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information in a manner that is consistent with this Privacy Statement, our contracts with clients, and, if applicable, the EU-US Privacy Shield Principles. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, CrossCountry is potentially liable. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
Apart from the purposes listed above, we will not share your information with other third parties for their independent use without your consent.
Additional Information for Individuals in the European Union
The personal information that we collect directly from individuals and the personal information that clients collect and make available to us to permit us to provide our services is stored on third-party servers currently located in the United States, where data protection laws may not be as stringent as the country in which you reside. The location of such servers may be subject to change.
Individuals in the European Union may file a complaint concerning CrossCountry’s processing of their Personal Data by contacting us using the information shown in “How to Contact Us/California Privacy Rights,” below.
CrossCountry will take steps to address any questions, issues, or concerns relating to its compliance with the EU-US Privacy Shield Principles or its Personal Data practices. CrossCountry has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield panel.
Links to Other Sites
Occasionally we may provide links to third-party websites for your convenience and information. These sites operate independently from CrossCountry and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest that you review if you choose to visit any linked websites. With the exception of any site(s) to which we refer you to apply for a job with CrossCountry or to receive other CrossCountry-specific services, we are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites.
CrossCountry maintains reasonable physical, administrative, and technical safeguards to protect your personal information against unauthorized disclosure, use, alteration, or destruction, and we require the third-party service providers and business partners that we work with to do the same.
CrossCountry’s Site and consulting services are not directed to or intended for use by children under age 13. Accordingly, we do not knowingly collect information directly from anyone under 13 years of age. Where appropriate, CrossCountry will specifically instruct children not to submit such information to our Site. If we become aware that a child has provided us with personal information without parental consent, or a parent or guardian of a child contacts us as shown in “How to Contact Us/California Privacy Rights,” below, we will use reasonable efforts to delete the child’s information from our databases.
Changes or Updates to this Privacy Statement
We may update or change this Privacy Statement from time to time and without prior notice to you. We will post a notice on our Site to notify you of any significant changes to our Privacy Statement and indicate at the bottom of the Statement when it was most recently updated.
Your Right to Access and Choice
If we collected personal information directly from and about you, and you do not want to receive marketing communications from CrossCountry, you may change your contact preferences or unsubscribe by sending an email to email@example.com, by using the link included in each of our emails, or by contacting us as shown in “How to Contact Us/California Privacy Rights,” below.
CrossCountry does not use personal information that our clients collect and make available to us for marketing or other communications from CrossCountry.
You have a right to access your information. If you wish to correct, amend, or delete inaccurate data, please direct your query to:
Amy Bjarnason, Chief Operating Officer
1650 Tysons Blvd, Suite 720
McLean, VA 22102
If requested to remove data, we will respond within a reasonable timeframe.
How to Contact Us/California Privacy Rights
Amy Bjarnason, Chief Operating Officer
1650 Tysons Blvd, Suite 720
McLean, VA 22102
CrossCountry has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
In addition, please use the contact information above if you have any questions, comments, complaints, or concerns about our Privacy Statement, the EU-US Privacy Shield Principles and our Personal Data practices, or other privacy-related practices, or you wish to access or delete your personal data, or provide us with updated or corrected information. We will attempt to respond promptly to your inquiries.
To opt out of CrossCountry marketing and other online communications, you may also send an email to firstname.lastname@example.org.
California residents may have certain additional rights including the right to information about how personal information is shared with third parties for the third parties’ direct marketing purposes during the preceding calendar year. California residents may make such a request by using the contact information shown above.
Effective Date: August 25, 2016