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Privacy Notice

This Privacy Notice regulates the use and protection by CrossMoore AI Limited and its group affiliates ('CrossMoore') of personal data you provide to CrossMoore either when using this Website, accessing our AI services, or otherwise in relation to any processing by CrossMoore of personal data for the purposes set out below, unless an alternative separate privacy notice applies to such processing. Personal data is information which identifies (or which could, with other information that we hold or are likely to hold, identify) a living individual.

CrossMoore AI Limited is registered in England and is a 'controller' under the Data Protection Act 2018. We process personal data in accordance with:

  • The Data Protection Act 2018
  • The UK General Data Protection Regulation (UK GDPR)
  • The Privacy and Electronic Communications Regulations 2003 (PECR)
  • The Computer Misuse Act 1990
  • The Network and Information Systems Regulations 2018
    ('Data Protection Laws')

For queries on data protection, please contact CrossMoore's Data Protection Officer at Data Protection Officer, CrossMoore AI Limited, 128 City Road, London, EC1V 2NX or privacy@crossmoore.io.

Personal Data We Collect

We will not collect any personal data about you or individuals accessing this Website, using our AI services, or otherwise communicating or interacting with CrossMoore, except where: it is specifically and knowingly provided, where it is necessary for us to process or hold for the purposes of our services, and where there is a valid legal basis for doing so or an alternative separate privacy notice applies. Examples include:

  • Personal details including: your name, address, email address, telephone number and occupation
  • Service usage details including: API keys, usage patterns, and interaction logs where you have accessed our AI services
  • Employment details including: employment history and curriculum vitae where provided by you in relation to any application made via our careers section and where you have provided explicit consent via a separate consent form referencing this privacy notice
  • Job alert preferences that you have selected regarding roles within CrossMoore where you have subscribed to such features and provided explicit consent via a separate consent form referencing this privacy notice
  • Technical information including: IP address, operating system and browser type, subject to your chosen cookie and privacy settings
  • Business relationship details including: contract information, payment details, and project specifications where necessary for service provision

Where We Store Your Personal Data

All personal data you provide to us is stored on systems with appropriate technical and organisational security measures within either the UK or the European Economic Area (EEA), with the following specific exceptions:

  • Website analytics data processed by Google Analytics
  • Cloud service providers with UK-compliant data processing agreements

These exceptions are covered by appropriate safeguards such as:

  • UK approved standard contractual clauses
  • Adequacy decisions
  • Explicit consent where required

We maintain specific retention periods for different types of data:

  • Account data: Duration of account activity plus 12 months
  • Service usage logs: 90 days
  • Technical logs: 30 days
  • Marketing preferences: Until consent withdrawn or service termination
  • Employment applications: 6 months post-decision
  • Client project data: Duration of contract plus 6 years (as required by UK law)

The accuracy of your personal data is important to us. If any information becomes inaccurate or out of date, please inform us using the contact details above.

Uses of Personal Data

We use your personal data for:

  1. Service Provision
    • Delivering our AI and technology services
    • Managing your account and preferences
    • Processing payments and fulfilling contracts
    • Providing technical support and service updates
    • Maintaining service security and reliability
  2. Communications
    • Sending service updates and notifications
    • Providing information you have requested
    • Marketing communications (only with explicit consent via separate consent form)
    • Processing enquiries and support requests
  3. Business Operations
    • Contract fulfilment and management
    • Legal and regulatory compliance
    • Security and fraud prevention
    • Service improvement and development
    • Analytics and performance monitoring
  4. Employment and Recruitment
    • Processing job applications (with explicit consent)
    • Managing job alerts (with explicit consent)
    • Verification and background checks where legally required
    • Recruitment communication and assessment

Legal Basis for Processing

For personal data which is not 'special category data', we rely on the following legal bases:

Legitimate Interests

We process certain data where necessary for our legitimate interests, including:

  • Providing and improving our AI services
  • Ensuring service security and reliability
  • Managing business relationships
  • Preventing fraud and abuse

We ensure such processing:

  • Is kept to a minimum regarding data collected
  • Will not be overly intrusive
  • Is proportionate to meet our legitimate interests

Contractual Necessity

Processing required to:

  • Deliver our services
  • Fulfil our contractual obligations
  • Process payments
  • Provide technical support

Legal Obligations

Including compliance with:

  • Data Protection Act 2018 and UK GDPR requirements
  • Privacy and Electronic Communications Regulations (PECR)
  • Companies Act 2006 obligations
  • Employment Rights Act 1996
  • Equality Act 2010
  • Finance Act requirements
  • Modern Slavery Act 2015
  • Bribery Act 2010
  • Competition Act 1998
  • Network and Information Systems Regulations 2018
  • Environmental Information Regulations 2004
  • Freedom of Information Act 2000 (where applicable)
  • Industry-specific regulations and standards

Consent

Where required for:

  • Marketing communications
  • Optional cookies
  • Special category data processing
  • Job applications and alerts
  • Certain international transfers

Disclosure of Your Information

We will share your information with CrossMoore group companies and, where relevant, their professional advisers. Where required by law or regulatory requirement, or where necessary to fulfil our contract with you, we may also share your information with:

  • Third-party service providers, including:
    • Cloud infrastructure and hosting providers
    • Payment processing services
    • Analytics services
    • Professional services providers
    • Security and fraud prevention services
    • Our nominated recruitment and talent providers
  • Legal and Regulatory Bodies:
    • Professional advisers and auditors
    • Regulators and government departments
    • Law enforcement authorities
    • Tax and revenue services
    • Information Commissioner's Office
    • Any relevant ombudsman or dispute resolution body
    • Courts and tribunals
  • Business Operations:
    • Persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in CrossMoore's business
    • Our insurers and insurance brokers
    • Third parties in connection with legal proceedings or potential legal proceedings

Personal data shall not be transferred to or stored at a destination outside the UK or EEA unless required for the purposes of:

  • Transfers by CrossMoore to its group companies
  • Service provision by our carefully selected providers
  • Cloud infrastructure services essential to our operations

In such cases, transfers shall be subject to appropriate safeguards such as:

  • UK approved standard contractual clauses
  • UK Government adequacy decisions
  • Explicit consent from you
  • Other alternative safeguards in accordance with Data Protection Laws

The transmission of information via the internet is not completely secure. While we implement appropriate technical and organisational measures to protect your personal data, we cannot guarantee the security of data transmitted to our site; any transmission is at your own risk.

Your Rights Under Data Protection Laws

You have the following rights in relation to your personal data:

  1. Right of Access
    • Request access to your personal data (commonly known as a "data subject access request")
    • Receive a copy of the personal data we hold about you
    • Verify the lawfulness of our processing
  2. Right to Rectification
    • Have inaccurate personal data rectified
    • Have incomplete personal data completed
    • Request updates to your information
  3. Right to Erasure (Right to be Forgotten)
    • Request deletion of your personal data where:
      • It is no longer necessary for the purpose collected
      • You withdraw consent
      • You object and we have no legitimate overriding interest
      • The data was unlawfully processed
  4. Right to Restrict Processing
    • Temporarily halt processing while we verify:
      • The accuracy of your data
      • Our legitimate grounds for processing
      • If you have objected to processing
  5. Right to Data Portability
    • Receive your personal data in a structured, commonly used format
    • Transmit that data to another controller
    • Request direct transmission where technically feasible
  6. Right to Object
    • Object to processing based on legitimate interests
    • Object to direct marketing
    • Object to research/statistical processing
  7. Rights Related to Automated Decision Making
    • Not be subject to decisions based solely on automated processing
    • Obtain human intervention for significant automated decisions
    • Express your point of view and contest automated decisions

To exercise any of these rights, please contact our Data Protection Officer at the address provided above. We will respond to all legitimate requests within one month. We will not charge a fee for processing standard requests. However, we reserve the right to charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

Complaints Procedure

If you are unhappy with how we handle your personal data, we encourage you to contact us first to resolve the issue. Please write to:

Data Protection Officer
CrossMoore AI Limited
128 City Road
London
EC1V 2NX
Email: privacy@crossmoore.io

We will investigate your complaint and aim to respond within 14 working days.

If you are not satisfied with our response, or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk

Changes to this Privacy Notice

This Privacy Notice is effective from 06/11/2024. We keep this Privacy Notice under regular review and reserve the right to change it at any time. We will notify you of significant changes in the following ways:

  1. Direct Communication
    • Email notification if we hold your email address
    • In-app notifications for service users
    • Direct communication to business contacts
  2. Substantial Changes

    3. We will specifically notify you when:

    • We are making substantial changes to how we use your data
    • We are doing something with your personal data that you would not reasonably expect
    • We are changing our core privacy practices
  3. Minor Updates
    • Changes will be posted on our website
    • Updates will be flagged via a banner on our homepage
    • Previous versions will be archived and available on request

Links to Other Websites

This Privacy Notice applies only to CrossMoore's websites and services. Links within our site to other websites are not covered by this Privacy Notice. We encourage you to read the privacy notices on other websites you visit.

Contact Us

For all privacy-related queries:

Data Protection Officer
CrossMoore AI Limited
128 City Road
London
EC1V 2NX

Email: privacy@crossmoore.io

CrossMoore AI Limited
Registered in England and Wales
Company Registration: 15793460
Registered Office: 128 City Road, London, EC1V 2NX

Last Updated: 06/11/2024

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