Privacy Policy

Last Updated: December 2024

This Privacy Policy applies when you use services provided by CrickBuster USA Inc. and outlines:

• How and why we collect and store your personal data
• How we use and disclose your personal data
• Your rights and choices regarding your data

This Privacy Policy is issued by CrickBuster USA Inc., on behalf of itself, its subsidiaries, and affiliates (collectively, "CrickBuster", "we", "us", or "our"). It is directed to individuals outside our organization, including customers, visitors to our websites, and users of our services (collectively, "you").

We may update this Policy from time to time to reflect changes in our practices or legal obligations. We encourage you to review this page regularly for any updates. Continued use of our services after such updates constitutes your agreement to the changes.

If you do not agree with how CrickBuster collects, stores, uses, or shares your data as described in this Privacy Policy, please do not use our services.

1. The Data We Collect About You

"Personal Data" refers to any information that can identify an individual, directly or indirectly. This does not include anonymized data.

We may collect, use, store, and transfer the following categories of personal data:

• Identity Data - includes your first name, last name, maiden name, username, title, and gender
• Contact Data - includes your email address(es), telephone number(s), and mailing address(es)
• Financial Data - includes your bank account or payment information
• Transaction Data - includes details of your interactions and transactions with us
• Technical Data - includes your IP address, browser type and version, login data, time zone, location, and operating system
• Profile Data - includes your CV, career history, and professional background
• Usage Data - includes information on how you use our websites, products, and services
• Marketing and Communication Data - includes your preferences in receiving marketing communications from us and our third-party partners
• Health Data (if applicable) - includes health, genetic, or biometric data only if explicitly provided or legally required (we do not intentionally collect this data)

We may also use aggregated data, such as demographic or statistical data. While this data may be derived from your personal data, it is not considered personal under the law if it does not directly or indirectly identify you. If we ever combine this with data that could identify you, we will treat it as personal data and handle it accordingly.

Note: We do not intentionally collect sensitive personal data such as your race, ethnicity, religious beliefs, sexual orientation, political opinions, or trade union membership unless required by law or with your explicit consent.

If You Fail to Provide Personal Data: Where the provision of Personal Data is required by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may be unable to perform the contract or deliver services. In such cases, we may be required to cancel a service you receive from us. If this occurs, we will notify you at the time.

2. How We Collect Your Personal Data: We collect Personal Data using various methods, including:

• Direct Interactions: You may provide Identity, Contact, and Financial Data by filling in forms or by communicating with us via post, phone, email, or otherwise.
• Automated Technologies: As you interact with our websites, we may automatically collect Technical Data about your device and browsing behavior. This data is gathered through cookies, server logs, and other similar technologies.
• Third Parties or Public Sources: We may receive your Personal Data from third-party sources such as:
• Analytics providers
• Technology and hosting providers
• Business networks
• Data brokers or aggregators
• Publicly available sources
• Relationship Data: We may collect Personal Data in the ordinary course of our relationship with you (e.g., as a customer or partner).

Note: We do not collect or store any payment-related data on our website or servers. All payment processing is handled by secure third-party payment providers, and your data is subject to their terms and privacy policies.

3. How We Use Your Personal Data: We will only use your Personal Data where legally permitted. The most common legal bases include:

• To perform a contract we have entered into or are about to enter into with you
• Where necessary for our legitimate interests (provided they do not override your rights and freedoms)
• To comply with a legal or regulatory obligation
• With your explicit consent (you may withdraw your consent at any time by contacting us)
• To protect the vital interests of an individual
• Where we have a legitimate interest, subject to a balancing test ensuring:
  • Processing is lawful, necessary, and proportionate
  • We have a valid business reason
  • There is minimal risk to your rights and freedoms

4. Purposes for Which We Use Personal Data: We may process your Personal Data for the following purposes:

• Provision of Services: To deliver services you request, communicate service-related information, and manage our relationship with you.
• Site Operations: To operate, maintain, and enhance our websites, including content delivery, user interaction, and display of advertising.
• Membership Services: To manage current or prospective memberships and keep members informed about CrickBuster developments.
• Marketing & Communications: To contact you (via email, phone, SMS, social media, or post) with information about products, services, events, or updates relevant to you, in compliance with applicable laws and with your consent when required.
• IT & Communications Systems: For the management, monitoring, and auditing of our IT and communication infrastructure, including cybersecurity operations.
• Financial & Administrative Management: For billing, invoicing, auditing, and vendor relationship management.
• Surveys & Feedback: To gather feedback on services and customer experiences.
• Security: To ensure physical and digital security, including access logs, visitor records, and CCTV (where applicable).
• Investigations: To detect and prevent fraud, policy breaches, and legal violations.
• Legal Proceedings: To establish, exercise, or defend legal rights.
• Regulatory Compliance: To comply with legal and regulatory obligations.
• Improvement & Innovation: To improve and develop our websites and services based on user interaction and behavior.
• Recruitment: For hiring activities, including screening, interviews, decisions, and onboarding.

5. Disclosure of Personal Data to Third Parties: We may share your Personal Data with selected third parties where it is necessary, lawful, and consistent with the purposes outlined in this Privacy Policy. These third parties may include:

A. Service Providers: We may share your data with trusted third-party service providers who support the operation of our business and services, including:

• Payment processing providers
• IT and system administration services
• Data analytics and marketing platforms
• Web hosting and infrastructure providers
• Customer service support platforms

All such providers are contractually bound to process your Personal Data only on our instructions and in compliance with applicable data protection laws.

B. Business Partners: We may share data with business partners or sponsors where services are jointly provided, co-branded, or collaboratively offered. We will only do this with your consent, where required.

C. Legal and Regulatory Authorities: We may disclose your Personal Data:
To comply with legal obligations or lawful requests from regulatory authorities, law enforcement, or courts
Where required to investigate fraud, abuse, or other violations of the law or our Terms of Service

D. Corporate Transactions: In the event of a business transaction such as a merger, acquisition, reorganization, or sale of all or part of our assets, your Personal Data may be transferred as part of that transaction. Any such transfer will be in accordance with applicable data protection laws and, where required, we will notify you before your Personal Data is transferred and becomes subject to a different privacy policy.

E. Affiliates and Subsidiaries: We may share your Personal Data within the CrickBuster group (i.e., with our affiliates and subsidiaries) for internal business and operational purposes, including service delivery, support, compliance, and reporting.

6. Data Retention Policy

We retain your Personal Data only for as long as necessary to fulfill the purposes for which we collected it, including to satisfy legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider:

• The amount, nature, and sensitivity of the data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for processing and whether those purposes can be achieved through other means
• Applicable legal, regulatory, tax, accounting, or other requirements

When we no longer need to retain your Personal Data, we will securely delete, anonymize, or isolate it.

7. International Data Transfers

Due to the global nature of our operations, your Personal Data may be transferred to-and processed in-countries outside of your country of residence. These countries may not have the same level of data protection laws as your own.

Whenever we transfer your data internationally, we ensure:

• The destination country is deemed to provide an adequate level of protection, or
• We use legally approved standard contractual clauses or other valid legal mechanisms to safeguard your data
• By using our services, you acknowledge that your data may be transferred, processed, and stored outside your home jurisdiction.

8. Data Security

We are committed to protecting your Personal Data. We implement appropriate technical and organizational security measures to prevent your data from being accidentally lost, misused, accessed without authorization, altered, or disclosed.

Key security practices include:

• HTTPS SSL encryption for all site traffic
• Encryption-at-rest for sensitive data
• Password encryption and hashing
• Regular system monitoring and vulnerability assessments

Access to your Personal Data is strictly limited to employees, contractors, agents, and other authorized third parties who need access for business purposes. These individuals are bound by confidentiality obligations and are trained in data protection.

We also maintain a formal data breach response plan. If a data breach occurs that may pose a risk to your rights or freedoms, we will notify you and relevant authorities as required by law.

9. Data Accuracy

We take reasonable steps to ensure that the Personal Data we collect and process is:

• Accurate and up to date
• Relevant and limited to what is necessary for the purposes for which it is processed
• Corrected or erased promptly if inaccurate

From time to time, we may contact you to verify or update your Personal Data. We encourage you to notify us of any changes to your personal details to help us maintain accuracy.

10. Your Rights

Depending on your location and applicable laws (such as the General Data Protection Regulation (GDPR) or California Consumer Privacy Act (CCPA)), you may have the following rights:

• Access - You have the right to request access to the Personal Data we hold about you.
• Correction - You may request correction of inaccurate or incomplete data.
• Erasure - You can request that we delete your data in certain circumstances.
• Objection to Processing - You may object to our processing where we rely on legitimate interests.
• Data Portability - You may request to receive your data in a structured, commonly used format.
• Withdraw Consent - Where we rely on consent, you may withdraw it at any time without affecting prior processing.
• Do Not Sell My Data (CCPA) - You can request that we do not sell your personal information (we do not currently sell data to third parties).

To exercise any of your rights, please contact us using the details provided in the Contact Us section of this Privacy Policy. We may need to verify your identity before processing certain requests.

11. Cookies and Tracking Technologies

Our websites use cookies and similar technologies to distinguish you from other users, improve your browsing experience, and analyze website usage.

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help us:

Remember your preferences Understand how visitors use our site Customize content and ads

Types of Cookies We Use

• Essential Cookies - Necessary for basic site functionality
• Performance Cookies - Help us analyze how the site is used
• Functionality Cookies - Remember your preferences
• Targeting/Advertising Cookies - Deliver relevant advertisements

Managing Cookies: You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our site.

For more information, see our full Cookie Policy (add hyperlink when published).

12. Terms of Use

All use of our websites and services is governed by our Terms of Use. We encourage you to review these terms regularly, as they may be updated from time to time to reflect changes in legal requirements or our service offerings.

13. Children's Privacy (Under 18 Years of Age)

Our services are not directed toward, and we do not knowingly collect Personal Data from, individuals under the age of eighteen (18). We do not intentionally market our services to minors. If you are under 18, you may only use our services with the involvement and consent of a parent or legal guardian.

If we become aware that we have collected Personal Data from a child without appropriate consent, we will take steps to delete such information as soon as reasonably possible.

14. Direct Marketing

We may use your Personal Data to contact you via email, phone, or other methods to inform you about services, promotions, and offers that may be relevant or of interest to you, in accordance with applicable law.

• If you are an existing customer, we may contact you using the contact details you have provided, unless you have opted out.
• You may opt out of promotional emails at any time by clicking the "unsubscribe" link included in each communication.

Even after opting out of marketing communications, we may still contact you for service-related purposes, such as transaction confirmations or important service notifications.

15. Changes to this Privacy Policy

We may update our Privacy Policy from time to time to reflect changes in our practices, legal obligations, or services. We will notify you of significant changes by updating the "Last Updated" date at the top of the policy. For non-material changes, we may not provide direct notice but encourage you to review this policy regularly.

16. Data Subject Rights Under Applicable Laws

If you reside in certain jurisdictions (such as the European Economic Area (EEA) or California), you have specific rights under applicable data protection laws. These rights may include:

• Access: The right to know what data we hold about you.
• Correction: The right to correct inaccurate or incomplete data.
• Erasure: The right to request the deletion of your data under specific conditions.
• Restriction: The right to request restrictions on data processing.
• Portability: The right to receive your data in a structured, commonly used format.
• Objection: The right to object to certain types of data processing (such as direct marketing).

You can exercise these rights by contacting us at inquiry@crickbuster.com

17. Automated Decision-Making

We do not engage in automated decision-making that has a legal or significant effect on you, such as profiling for marketing purposes, unless we have received your explicit consent to do so or unless required by law.

18. Third-Party Websites and Links

Our website(s) may contain links to third-party websites. We are not responsible for the privacy practices or the content of these external sites. We encourage you to read the privacy policies of any third-party sites you visit.

19. Privacy Shield and International Data Transfers

If applicable (for example, if you are a resident of the EU or the US), CrickBuster may comply with relevant frameworks such as the EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield for transferring Personal Data across borders.

We implement safeguards to ensure that all international transfers of Personal Data comply with applicable data protection laws.

20. Consent to Processing (Specific Countries/Regions)

For residents in certain regions (such as the European Union or California), we rely on explicit consent for some forms of data processing. Where applicable, you will be asked to provide your consent before we process certain categories of your Personal Data, such as for direct marketing purposes or the sharing of sensitive data with third parties.

21. Vulnerability Reporting and Data Protection Impact Assessments (DPIA)

We encourage responsible reporting of any security vulnerabilities you may encounter on our website or in relation to our services. If you suspect a data breach or have concerns about our data processing, please report it to us immediately at inquiry@crickbuster.com

For high-risk processing activities, we conduct Data Protection Impact Assessments (DPIAs) to assess and mitigate risks to your Personal Data.

22. Contact Us

For the purposes of this Privacy Policy, CrickBuster USA Inc. is the data controller.

If you have any questions, comments, or concerns regarding this Privacy Policy or how we handle your Personal Data, please contact us:

Email: inquiry@crickbuster.com
Online: www.crickbuster.com/contact

We are committed to responding promptly and respectfully to all inquiries.

Last Updated: December 2024