Crossfuze respects the confidentiality and privacy of our clients, our people and others with whom we do business. Inergex Holdings, LLC doing business as Crossfuze, and its affiliated US subsidiaries (“CF,” “we,” “us,” or “our”) complies with the requirements of the EU‐U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Principles”). Crossfuze certifies that it adheres to the Principles with respect to personal information (as described below) that is transferred from the European Union and its Member States, the European Economic Area, the United Kingdom to the United States. If there is any conflict between the terms in this Privacy Shield Policy and the Principles, the Principles shall govern. Crossfuze U.S. is subject to investigatory and enforcement powers of the U.S. Federal Trade
Commission. The Federal Trade Commission has jurisdiction over Crossfuze U. S’s compliance with the Privacy Shield. If there is any conflict between the terms in this Privacy Shield Policy and the Privacy Shield Principles as concerns the Personal Data received under the Privacy Shield, the Privacy Shield Principles shall govern to the extent of the conflict.
Purposed of Collection and Use
This Privacy Shield Policy applies to personal information within the scope of CF’s Privacy Shield certification, which covers the following categories of information:
- Personal information regarding current, former and prospective employees for the purposes of operating and managing CF, performing human resource administration and maintaining contact with individuals.
- Personal information regarding current, former and prospective clients and their personnel or others for the purposes of delivering CF services, maintaining ongoing relationships and performing business development activities.
- Personal information regarding our third parties (e.g., vendors, service providers, etc.) and their personnel for the purposes of managing and administering CF’s business relationships with such third parties.
Additionally, CF may, from time to time, collect personal information from the general public in order to answer inquiries or provide information requested.
For the purposes of this Privacy Shield Policy, “personal information” means information that is about, or pertains to a specific individual and can be linked either directly or indirectly to that individual. In addition, certain personal information covered by CF’s Privacy Shield certification may be subject to more specific privacy policies of CF, which are also consistent with the requirements of the Principles, and in the case of any conflict between these policies and the Principles, the Principles will control.
Personal information obtained from or relating to clients or former clients is further subject to the terms of any specific privacy notice provided to the client, any contractual arrangements with the client and applicable laws and professional standards.
Individual Notice and Choice
CF collects and processes personal information from certain individuals and for the purposes described in this Privacy Shield Policy. Personal information covered by this Privacy Shield Policy is collected and processed only as permitted by the Principles.
Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Policy, other CF website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements. Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt‐in consent for sensitive personal information).
Disclosures and Accountability for Onward Transfers
Consistent with the Principles, CF may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individual’s non‐public personal information to third parties under one or more of the following conditions:
- To our subsidiaries and affiliates;
- The disclosure is to a third‐party providing services to CF, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, CF remains responsible and liable under the Privacy Shield Principles if a third‐party that it
engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless CF proves that it is not responsible for the matter giving rise to the damage;
- With the individual’s permission to make the disclosure;
- Where required to the extent necessary to meet a legal obligation to which CF is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.
- In the event CF sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation), in which case Personal Data held by CF will be among the assets transferred to the buyer or acquirer;
- Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.
- In the event we are unable to resolve your concern, Persona commits to cooperate with the relevant EU Data Protection Authority and comply with their advice regarding personal and human resource data transfers and the Privacy Shield Principles. Per the terms of the frameworks and under certain circumstances, you may invoke binding arbitration.
Individuals whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that CF maintains about them as specified in the Principles. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated). Requests for access, correction, amendment or deletion should be sent to: mailto:[email protected].
CF takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures address the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.
Data Integrity and Purpose Limitation
CF collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject. CF does not retain personal information after it no longer serves the purposes for which it was collected or subsequently authorized. CF takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use.
You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. In compliance with the Principles, CF commits to resolve complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact CF at: mailto:[email protected]. CF has a policy of responding to individuals within forty‐five (45) days of an inquiry or complaint. If an individual has an unresolved complaint or concern that is not addressed satisfactorily, that individual may contact our U.S. based third party dispute resolution provider (free of charge).
Inergex, LLC; Private
Virteva, LLC; Private
Crossfuze Federal Services, LLC; Private
Trec Global, LLC; Private
If you have any questions regarding this Privacy Shield Policy, please contact us by email at [email protected], or please write to the following address:
6110 Golden Hills Drive
Minneapolis, MN 55116
Attention: Dan Rosedahl, Chief Privacy Officer
Changes to the Privacy Shield Policy
CF may update this Policy at any time by publishing an updated version. We will not update this Privacy Shield Policy in contravention to the Principles so long as we remain certified to the Privacy Shield.
Application: All CF subsidiaries
Effective date: May 5, 2023
Approved By: Chief Privacy Officer
Next Review Date: April 1, 2024