PRIVACY POLICY

Last modified: January 24, 2019

PRIVACY NOTICE

Toaster LLC d/b/a Crosswalk (“Crosswalk”, the “Company”, “We” or “Our” is committed to taking reasonable steps towards protecting your privacy and managing your information responsibly. This Privacy Notice is intended to notify you of our online privacy practices, the types of information that may be collected and stored, how information may be used and shared, what choices are available to you regarding the collection, use and distribution of information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, and who to contact with questions or concerns. Crosswalk is committed to full compliance with applicable privacy laws otherwise using data in a responsible and ethical manner.

This Privacy Notice applies to the website located at www.crosswalknyc.com (the “Website”), to the Company’s marketing contacts with you, as well as to any phone, email, or mail communications concerning our operations, products, advertisements, communications or services. This Privacy Notice also applies to the market research services that we provide to our clients. This Privacy Notice does not apply to other websites to which we may link, or to other companies or persons with whom we may interact or do business.

Why We Collect Information:

We collect information for several reasons. We collect information to help us design, improve and deliver our products and services. We also collect information that you choose to share with us in order to assist our clients in their marketing activities. In addition, we collect information in order to respond to inquiries, and communicate opportunities, news, special offers, and other information and events.

We also obtain aggregated, non-personally identifiable consumer and market information in order to provide market research services to our clients, and to help provide interesting and relevant targeted marketing and recommendations to our clients based on consumer interests and engagement.

What Information We Collect:

This section includes a general description of the types of personally identifiable information we may collect (“Personal Information”). If you provide us with personally identifiable information, you consent to our use of it in accordance with this Privacy Notice.

We do not automatically collect personal information from you unless you voluntarily input or submit such information, such as during a registration, submitting questions or comments, requesting information, or otherwise interacting with us. If you voluntarily provide us with personally identifiable information, you consent to our use of it in accordance with this Privacy Notice.

Even if you do not submit personal information to us directly, we also collect and may maintain aggregated data from third-party service providers including advertisers, brands, and social media services about groups or segments of consumers. This information is primarily used to assess target demographics for advertisements and campaigns, and to determine appropriate audiences for marketing activities. This data does not contain personally identifiable information about any individual, and we cannot identify any of the underlying individuals from this information. For example, we may combine aggregated demographic information such as age, gender, income, residence, education, and ethnicity, with lifestyle behavior, such as social activities, consumer preferences and media engagement, in order to derive meaningful and accurate market segment measurements and insights that are not associated with any particular household or individual. In certain instances, our clients may temporarily entrust us with information, including Personal Information, so that we can perform our services on their behalf. Such information is retained only as long as necessary to provide the services on behalf of such client and is promptly and securely disposed of thereafter.

While using the Website, we may gather navigational information about where visitors go on the Website and information about the technical efficiencies of our Website and services (such as time to connect to the Website or time to download pages). This information may allow us to see which areas of our Website are most visited and helps us better understand the user experience, in order to improve the features and quality of the Website. In this process of gathering information, we may collect technical information (such as domain type, browser type and version, service provider and IP address, referring/exit pages, operating system, date/time stamp, and click-stream data), and we may create and use electronic records from this data.

How We Collect Information:

We generally receive information in three primary ways:

1. You Give Us Information: We collect information from you when you submit it to us directly.

2. We Collect Information Automatically: We automatically collect certain types of information when you use our products and services.

3. We Collect Information from Other Sources: We may obtain aggregated, non-personally identifiable information from outside sources. For example, we may obtain information from social media services such as Facebook, Instagram, Twitter, and LinkedIn pertaining to user engagement with certain types of online content. We may also receive information from third-parties who provide services for us through web-beacons and other technologies.

Use of Cookies:

The Website uses a common browser feature known as a cookie, which assigns a unique identification to your computer browser and session. Cookies are typically stored on your computer’s hard drive and are used to help maintain an expected user experience by tracking clicks as you go through the pages within our Website and informing the Website that each of your clicks comes from you individually when needed. We may use cookies to tell us whether you have previously visited the Website. We may also use cookies that can be set by third-parties with whom we have entered into agreements that may enable us to obtain analytic information about the use of our Website. You can set your browser not to accept cookies or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. You may also use commonly available tools in your browser to remove cookies that may have been placed onto your computer. However, you should be aware that all features of the Website may not operate correctly if cookies are rejected or disabled.

Types of Cookies Utilized:

1. Strictly necessary cookies. These are cookies which are strictly necessary for us to provide a service requested by you, or to comply with legal requirements. We use a number of these 'strictly necessary' cookies. For example, these types of cookies provide the necessary security that your visit to the Website requires, help ensuring the content of the pages you request load quickly and remember which of our client's products you wish to buy when you put them in your 'Shopping Bag'. Without these cookies, some of the services that you have asked for cannot be provided.

We want you to understand these types of cookies, and why we use them, but we don't need to get your consent to use them on the Website, because we use these cookies only to provide you with services that you have requested.

2. Performance cookies. These cookies collect anonymous information about the web pages you visit. We use these cookies to collect information about how visitors use the Website. For example, which pages our visitors go to most often, and if they get error messages on those pages. These performance cookies don't collect personal data – all information they collect is aggregated and anonymous.

3. Functionality cookies. These cookies remember your choices to improve your experience of the Website. We use these cookies to allow the Website to remember choices you make. For example, remembering your username, your language, the region you are in, and changes you make to various other parts of the Website which you can customize. The aim of these cookies is to provide you with a more personal experience so that you don't have to reset your preferences each time you visit.

4. Targeting, advertising and third party cookies and similar technologies. We allow third party cookies, web beacons and similar technologies, placed by our re-targeting and advertising partners, to track your browsing habits on our Website (and also elsewhere on the internet and other apps) so that we can later show you targeted ads on other websites (including on social media sites) which we hope are relevant to your interests. For example, if you viewed pages on our Website relating to a particular client's product, you may be later be shown one of our advertisements relating to these or similar products when you are viewing pages on another website (including on social media sites) or app. These types of cookies, web beacons and similar technologies and the information they collect are also used to limit the number of times you see these advertisements, as well as to help measure the effectiveness of our advertising campaigns and to provide other measurement services.

We also allow third party cookies, placed by our affiliate network partner(s), to record information about third party links or adverts that you may have clicked on directly before browsing on our Website and then making a purchase. These partners have advised us that they do not collect any personal data from which they would be able to identify you.

Which specific cookies do we use?

The table below explains what cookies we use on the Website, and the reasons why we use them:

Cookie Name

Purpose

__atuvc

The __atuvc cookie is created and read by JavaScript on the client side in order to make sure the user sees the updated count if they share a page and return to it before our share count cache is updated.

__utma

A ‘persistent’ cookie. This cookie keeps track of the number of times a visitor has been to the site pertaining to the cookie, when their first visit was, and when their last visit occurred.

__utmb and __utmc

These cookies work together to calculate how long a visit takes. __utmb takes a timestamp of the exact moment in time when a visitor enters a site, while __utmc takes a timestamp of the exact moment in time when a visitor leaves a site.

__utmv

The __utmv cookie gets set on your computer, so that Google Analytics knows how to classify that visitor. The __utmv cookie is a persistent, lifetime cookie.

__utmz

__utmz keeps track of where the visitor came from, what search engine was used, what link was clicked on, what keyword you used, and where they were in the world the website was accessed.

_ga

The _ga cookie is a first-party cookie that can only be accessed by the domain on which the JavaScript is run.

AcceleratorSecureGUID

This is a session identifier.

mlbrSecureGUID

This is a secure session token.

NRAGENT

Stores a 16 character token identifier. This cookie is used to communicate between the New Relic server aggregating end user metrics and the agent(s) running in the associated web application.

ROUTEID

Apache Load Balancer cookie.

AcceleratorSecureGUID

This is a secure session token.

mlbrSecureGUID

This is a secure session token.

__atuvc

mt_misc and uuid

This is a third party re-targeting cookie placed by our partner MediaMath.

LinkSynergy

This is a third party re-targeting cookie plaved by our affiliate network partner LinkShare.

_cs_id

This is a third party cookie placed by our partner ContentSquare.

_cs_s

This is a third party cookie that contains the number of pageviews within the running session for our partner ContentSquare Solution.

_cs_vars

This is a third party cookies used by our partner ContentSquare to record custom variables

_cs_ex

This is a third party cookies used by our partner ContentSquare to exclude some visitors from the collection.

_cs_c

This is a third party cookie used by our partner ContentSquare to save the user consent to be tracked.

_cs_output

This is a third party cookie used by our partner ContentSquare to exclude some visitors from the collection

As earlier indicated, you can disable and/or delete all types of cookies, including the above cookies by using your browser settings. Cookies are generally easy to disable and/or delete but how you do so varies from browser to browser. The "help" function within your browser should tell you how to do it. The best way may be to close your browser and then search for "cookie folder" or "cookie manager" or simply "cookie". Further information on deleting or controlling cookies is also available on www.allaboutcookies.org and www.aboutads.info/choices.

Use of Web Beacons, Clear GIFs, Pixel Tags and JavaScript:

We also may use web beacons (also called “Internet tags,” "pixel tags," or "clear GIFs") and/or JavaScript plug-ins, placed on our Website and in our emails to you. These web beacons and plug-ins are small graphic images (typically that you cannot see) or code on a website or in an email message that are used to transmit information to web servers, for example, to record web pages and advertisements clicked on by a user, or to track the performance of email marketing campaigns. These files may help us analyze our users' online behavior and measure the effectiveness of our Website and our communications. We may also work with third-party service providers that help us track, collect, and analyze this information. Third-party entities with whom we have agreements may place these files on the Website and/or in e-mails to use information obtained from them such as pages viewed, items purchased, e-mails opened, and items clicked on in e-mails. These third-party providers may also place cookies onto your computer. Those third-party cookies may enable us to obtain aggregate demographic information and user statistics about you and your preferences from these third-party sources as well as our information we have about you.

Search Queries, Server Logs and Widgets:

A web “server log” is a record of activity created by a computer that delivers certain web pages to your browser. Certain activities that you perform on our Website may record information in server logs, such as if you enter a search term into a search box located on the Website. The server log may record, for example, the search terms or the link you clicked on to bring you to our Website. The server log may also record information about your browser, such as your IP address and the cookies set on your browser and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.

A “widget” is generally an application that can be embedded in a webpage. Widgets can provide real-time information to the webpage. Widgets are often provided by third-parties; we may provide widgets on our website. Widgets may enable the third-parties that provide them to collect data about users visiting the Website.

How We Use the Information We Collect:

We generally use information to assess target demographics for advertisements and campaigns, to determine appropriate audiences for marketing activities, and to derive meaningful and accurate market segment measurements and insights to increase relevant consumer interactions. We also may use information to (i) analyze trends and conduct research (including market and consumer research, trend analysis, and financial analysis) in order to improve our (and/or our clients’) products and services; (ii) interact with social media services on behalf of our clients (iii) provide support to and communicate with clients and other individuals who may contact us; (iv) track online traffic patterns and consumer engagement; (v) enable online registration, and identify and authenticate access to our products and services; (vi) correlate information with other commercially available information to identify demographics and preferences to assist us in our marketing efforts; (vii) address information security and/or privacy practices, systems control, network functioning, engineering, and troubleshooting issues; (viii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (ix) comply with law, or based on our good-faith belief that it is necessary to comply with the law, cooperate with police or other governmental authorities, or to protect our rights, property or safety (or that of others); and, (ix) process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.

We may also share any of our information collected externally with clients and other third-party service providers who provide services for us or on our behalf. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of such service providers may include companies that host our software or computer systems, provide network equipment and application management, or allow us to connect to or communicate via the internet. If we share Personal Information received from a client with a social network, that information is configured to automatically be deleted from that social network after a set period of time (generally around thirty (30) days) to ensure that it is not inadvertently retained.

Retention of Personal Information:

To the extent that we receive any Personal Information, we retain such information for only as long as: (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Notice and any of our contractual obligations; or (2) we are obligated by operation of law, compliance obligations or risk management to retain such data.

You can control the information that we are able to access and retain by deciding whether to engage with us and through the use of privacy settings in the social networks or other third-party services in which you participate.

Business Transfers

We reserve the right to transfer any information we have in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

Your Choices About the Information We Collect

If you do not consent to the ways in which we may use your personal information, please do not submit any personal information to us. If you do not wish to receive emails containing information, special offers, or other promotions from us, our clients, or our partners, please click the relevant unsubscribe link located in those emails. If you do not wish to receive other marketing materials from us or if you do not want us to share your personally identifiable information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out from information sharing or receiving information, or both, as the case may be, using the contact information specified in the How to Contact Us section of this Privacy Notice.

To the extent required by law, you may (1) have the right to access certain personal information we maintain about you; (2) request that we update or correct your personal information; (3) object to the processing of your personal information or withdraw your prior consent, if applicable; and (4) ask us to block or delete your personal information from our database. To exercise these rights, please contact us as indicated in the How To Contact Us section of this Privacy Notice. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.

Notice to California Residents

Subject to certain limits under California law, California residents may ask us to provide them with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (2) the identity of those third parties. To make this request, California residents may contact us as specified in the How to Contact Us section below.

Privacy of Children

We recognize the importance of children's safety and privacy. In accordance with the Children’s Online Privacy Protection Act, Crosswalk does not request, or knowingly collect, any data from children under the age of 13. If we become aware of any collection of Personal Information from a child under the age of 13, we will take all necessary measures to promptly delete such information from our records.

Data Transfers

All information that we receive may be maintained on web servers and systems located within the United States. Please note that the data protection laws in the United States may be different from the data protection laws in other countries.

Security

We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to the information that we maintain.

Updates to our Privacy Notice

This Privacy Notice may be updated periodically to reflect changes in our privacy practices. We will indicate at the top of the Privacy Notice when it was most recently updated.

How to Contact Us

If you have questions or concerns with respect to our Privacy Notice, or if you would like to exercise other applicable data protection rights, please contact us by email at privacy@crosswalknyc.com or write to us at:

Crosswalk

404 5th Avenue

3rd Floor

New York, NY 10018