Privacy Statement

Effective Date: June 2, 2023

At Crownsoft, we are committed to safeguarding your privacy and ensuring the protection of your data. This privacy statement outlines our practices and responsibilities regarding the handling of your personal information. Please note that this statement will be periodically updated to align with any changes in our data handling processes or applicable laws.

This privacy statement applies to all of Crownsoft’s external-facing applications, services, games, tools, websites, and other data processing activities where Crownsoft acts as a data controller. It encompasses our commitment to data privacy across various platforms and services.

For Texas residents, we have a separate privacy statement that addresses your specific privacy rights under Texas law. If you are a Texas resident, you have the option to opt out of the sale of your personal information by following the provided link.

If you require special accessibility accommodations to access the content of this statement, we recommend referring to our Accessibility Statement for detailed guidance and recommendations.

This page, along with its sub-pages, provides comprehensive information on how Crownsoft PLC and its affiliates, subsidiaries, and newly acquired companies protect and control the personal data we process about you. It also outlines your rights concerning the processing of your data.

Please note that any Crownsoft entity located outside the European Union will be represented by Crownsoft PLC for compliance with data privacy laws.

In the following sections, we will provide a general overview of how we protect your data, followed by specific information regarding its usage in various contexts, including:

Personal data usage when visiting Crownsoft’s website
Usage of cookies and other tracking technologies
Personal data usage during visits to our offices
Personal data used for marketing purposes

1. How do We safeguard your personal data?

At Crownsoft, we hold your privacy and the protection of your personal data in high regard. Our utmost priority is ensuring that your personal information is handled securely and in compliance with applicable laws and our robust data privacy policies. To achieve this, we have implemented stringent technical and organizational measures to prevent unauthorized or unlawful processing, accidental loss, alteration, disclosure, access, destruction, or damage to your personal data.

The following sections provide comprehensive insights into how Crownsoft manages and processes your personal data:

Categories of Personal Data and Processing: We detail the specific types of personal data we collect and elaborate on the methods of processing employed.
Purposes and Legal Basis: We clarify the purposes for which we utilize your personal data and the legal basis that justifies our processing activities.
Third-Party Data Sharing: We outline our approach to sharing personal data with trusted third parties.
Handling Sensitive Data: We address our handling of sensitive data, ensuring its utmost protection and confidentiality.
Data Security Measures: We describe the robust measures implemented to secure your personal data.
Data Processing Locations: We specify the locations where your personal data may be processed.
Data Retention Duration: We provide information on the length of time we retain your personal data.
Your Rights: We highlight the rights you possess concerning the processing of your personal data.

At Crownsoft, we strive to empower you by maintaining transparency and respecting your rights throughout the processing of your personal data.

What types of personal data do we collect and how do we process them?

At Crownsoft, we gather personal data from various sources, including our employees, potential employees, clients, their current/former/prospective employees/directors, suppliers, business contacts, shareholders, and website users. While this privacy statement provides an overview of the personal data we collect and process, we ensure individuals receive appropriate notice, as required by law, regarding the collection and use of any additional data.

The personal data we collect align with the categories described in sections such as “How do we use personal data when you visit Crownsoft’s website?”, “How do we use cookies (and other tracking technologies)?”, “How do we use personal data when you visit our offices?”, and “How do we use personal data for marketing purposes?”. Additionally, this privacy statement or other relevant statements you have received may refer to additional categories of personal data.

To provide further clarity, we have included a chart below outlining the categories of personal data we collect:

Classification of Personal Information

Varieties of Personal Data Collected within Each Category

Classification of Personal Information

Full name, preferred pronouns, various identification markers, and comprehensive contact information (including email, telephone numbers, and physical address), occasionally supplemented by additional details such as gender, date of birth, age, and place of birth, as required for specific and legitimate purposes.

Business-related particulars

We maintain a comprehensive record of the products and services you have procured from Crownsoft, including a detailed history. Additionally, any correspondence exchanged between us, whether through a designated mailbox or other electronic communication channels, including those supported by AI for enhanced interaction, is collected and utilized specifically for processing account receivable payments and conducting commercial follow-up activities.

Information about marketing and research activities

1. Identifiers – This category encompasses various forms of identification, including IP addresses, social media handles, online identifiers, email addresses, mobile numbers used for direct marketing, as well as names and physical addresses.

2. Demographic data – This pertains to information related to individuals’ characteristics, such as income level, family status, age group, gender, interests, pet ownership, home ownership, health status, and current service providers.

3. Browser and web history data – This refers to data regarding an individual’s browsing activities, including preferences expressed through the selection, viewing, and purchase of goods, services, and content. It also includes information about the individual’s mobile device, such as device type, identification number, and mobile operating system.

4. Social media content – This category encompasses blogs, posts, and any other content posted by individuals online or content that mentions or references an individual.

5. Analytics and profiles – This involves the creation of profiles and analysis based on the collected data, enabling a deeper understanding of individuals’ preferences and behaviors.

6. Voice-enabled services – This refers to the use of speech-to-text engines for search requests, without the recorded or stored data being retained by the individual’s mobile device.

Confidential and biometric information

Crownsoft acknowledges the significance of privacy and adheres to local laws and regulations when collecting sensitive information. With your explicit consent or in compliance with applicable legislation, we may gather specific types of sensitive data. This may include health and medical information, encompassing disability status, access requirements, dietary restrictions, and allergies, particularly about events we organize or sponsor. Additionally, we may collect biometric information, such as fingerprint data, should you choose to utilize fingerprint authentication methods.

Audiovisual content

Crownsoft may collect and retain various forms of visual content, including photographs and images or video footage obtained through closed-circuit television (CCTV) or other security monitoring systems. Additionally, during marketing campaigns or public filming events, we may capture visual content, including recordings of virtual or live workshops and similar sessions. Furthermore, in mobile applications, we may enable voice search functionality, allowing users to interact with the application through voice commands and receive corresponding results.

Position, professional, or employment- associated data

Crownsoft collects and maintains professional and employment-related information, encompassing details about an individual’s current position, job title, employer, location, and relevant contacts at Crownsoft. This information serves to establish a comprehensive profile of individuals in relation to their professional affiliations and engagements.

Data related to system and application access, internet, and electronic network activities

When individuals are granted access to Crownsoft’s systems, certain information necessary for such access is collected by Crownsoft. This information may include system-specific identifiers such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, as well as system passwords. Additionally, Crownsoft may collect internet or other electronic network activity information related to the use of its systems, including access logs, activity logs, and electronic content generated or accessed through Crownsoft’s systems.

Cookies and geolocation specifics

In certain instances, Crownsoft may also gather geolocation data. For more comprehensive information on our utilization of cookies and related practices, we encourage you to review our Cookies policy.

Information related to Crownsoft alumni

The data you furnish us upon registering as a Crownsoft alumnus/alumna or updating your profile, encompassing your name and email address. If you previously utilized another Crownsoft alumni website, any additional information you provided on that platform may automatically be incorporated into your profile on the Alumni Site. Furthermore, your user profile provides the opportunity to supply a wide array of supplementary data, including postal address, current occupation, industry, education, and personal and professional interests.

• The correspondence exchanged between you and us in connection with the Alumni Site.

• The information you share on the Alumni Site, such as within the chat pages.

• Your responses to online surveys administered for research and quality assurance purposes.

• Particulars concerning (former) compensation and payroll. • Details about the (former) position held.

• Birth year, when deemed necessary for specific objectives.

• Personal data already stored within our Crownsoft systems, such as (former) Enterprise ID, (former) office location, telephone number, home address, and educational or training background. This information is leveraged for identity verification when registering on our Alumni Site.

We may also draw inferences about you based on the aforementioned information and collect additional data as detailed in this privacy statement. If you disclose the personal information of another individual (such as a potential employee or referral), it is your responsibility to ensure that the individual is aware of the contents of this privacy statement and has provided their consent for sharing the information with Crownsoft.

The aforementioned categories of personal data have been obtained either directly from you (e.g., when you provide information for newsletter subscriptions or forum registrations) or indirectly from specific third parties (e.g., through our website’s technology). These third parties include our affiliates, public authorities, public websites, social media platforms, suppliers, clients, and vendors. Except for information required by law or Crownsoft policies (including employment relationship management), your decision to provide personal data to us is voluntary. Please note that failure to provide certain information may result in the inability to fulfill some or all of the purposes outlined in this privacy statement, and may restrict your access to certain tools and systems that rely on such personal data.

For which purposes and on which legal basis do we use your personal data?

Crownsoft uses your personal data for specific purposes based on legal grounds, including providing services, managing customer relationships, processing payments, complying with legal obligations, marketing, enhancing products, conducting research, protecting rights, and handling disputes. We prioritize fair and secure processing in compliance with applicable laws.

Objective

Legal Justification

Managing contractual and employment relationships.

Required for the fulfillment of a contractual agreement in which you are involved.

Recruitment and candidate management.

Supported by our lawful interests in securing suitable personnel for recruitment purposes.

Facilitating communication and providing the requested information.

Founded on the grounds of our lawful interests to facilitate effective communication and emergency response within the organization.

Operating and managing business operations, including data collection for surveys, assessments, and market research.

Supported by the rationale of our lawful interests to ensure the optimal functionality of our business operations.

Compliance with legal requirements.

Required to fulfill our legal obligations as mandated by applicable laws and regulations.

Monitoring system usage and conducting social listening.

Supported by our legitimate interests in maintaining compliance and safeguarding our reputation and Grounded in our legitimate interest to safeguard our brand and protect our assets across social media platforms.

Enhancing website security and functionality.

Supported by our legitimate interests in providing a seamless user experience and safeguarding the security of our networks and information.

Conducting data analytics for business performance improvement.

Based on our legitimate interests, we justify this to ensure the effective functioning of our business operations.

Marketing products and services.

We justify this based on our legitimate interests in conducting and expanding our business.

Recording and sharing audio/video content of events.

This is established based on your prior informed consent.

Recruitment and employment purposes

Legal Justification

Assess your suitability for employment and future roles.

Justified based on Crownsoft’s legitimate interests in hiring suitable employees.

Manage your application and facilitate communication.

Justified based on Crownsoft’s legitimate interests of ensuring that it recruits the appropriate employees and also ensuring effective communication both internally and externally within the organization.

Perform administrative functions and reimburse interview-related expenses.

Based on Crownsoft’s legitimate interests, it is justified to ensure the recruitment of suitable employees.

Conduct data analytics to understand the applicant pool and attract top talent.

To continually enhance its recruitment processes, Crownsoft justifies its actions based on its legitimate interests.

Record online interviews for additional review.

Crownsoft’s pursuit of recruiting suitable employees is justified on the grounds of its legitimate interests.

Provide personalized job recommendations and event notifications.

Crownsoft’s pursuit of recruiting suitable employees is justified on the grounds of its legitimate interests.

Transfer your information to the Crownsoft Talent Connection for new position notifications.

Crownsoft’s pursuit of recruiting suitable employees is justified on the grounds of its legitimate interests.

Administer employee benefits and comply with legal requirements.

Crownsoft’s commitment to providing applicable employee benefits and complying with legal obligations is justified based on its legitimate interests.

Alumni engagement and communication

Legal Justification

Enable alumni to search and locate you through the directory if you are a registered Crownsoft alumnus/alumna

Based on our legitimate interests, we offer users the opportunity to connect with fellow alumni through the Alumni Site.

Provide personalized experiences on the Alumni Site, including customized news, events, and interactive communications

Our legitimate interests drive us to provide users with personalized experiences on the Alumni Site.

Conduct research and analysis of alumni demographics, interests, and behavior in an aggregated manner

With our legitimate interests in mind, we aim to gain a deeper understanding of our users, enhance the Alumni Site, and improve the services we offer.

Periodically communicate with alumni about events, publications, or employment opportunities at Crownsoft, unless otherwise specified. Opt-out options will be provided

We rely on our legitimate interest to ensure effective communication with our alumni and deliver relevant marketing messages.

Share alumni information with internal Crownsoft systems, such as salesforce.com, for industry-relevant communication

In line with our legitimate interest, we prioritize clear communication and targeted marketing for our alumni.

Legitimate interest signifies that Crownsoft possesses justifiable grounds to engage in the processing of your personal information. In instances where the aforementioned table indicates our reliance on legitimate interests for a particular purpose, we firmly believe that these interests do not supersede your rights, interests, or freedoms. This belief is underpinned by several factors, including the transparency we provide regarding our processing activities, our privacy-focused design approach, regular privacy assessments, and the rights you possess about such processing. Should you desire further insight into our approach to conduct this balancing test, kindly reach out to Crownsoft’s Data Privacy Officer.

For the purposes outlined above, we will process your personal information based on your prior consent, to the extent that such consent is obligatory as per applicable laws.

In situations where you are requested to signify your agreement by clicking on “I accept,” “I agree,” or similar buttons/checkboxes/functionalities about a privacy statement, your action will be considered an expression of consent for the processing of your personal information, solely in cases where such consent is mandated by law. Rest assured, we will refrain from utilizing your personal information for purposes that are incompatible with the objectives for which you have been duly informed, unless it is compelled or authorized by law, or is necessary for the protection of your vital interests (e.g., in the event of a medical emergency).

Will we disclose your data to third parties?

Crownsoft may transfer personal data to various parties, such as service providers, professional advisors, public and governmental authorities, Crownsoft companies/affiliates, or third parties, in the course of conducting its business operations. This includes (potential) corporate or commercial transactions and providing client services, which may involve processing data. These third parties may be located in different countries. Before any such transfer, we will take necessary measures to ensure that your data receives adequate protection in compliance with applicable data privacy laws and Crownsoft’s internal policies. Additionally, Crownsoft may transfer your data to its global affiliates/partners to facilitate visits to our Crownsoft locations.

For instance, we may disclose personal information to third-party service providers who assist us in areas such as billing, payment processing, customer service, email communication, advertising and marketing, security and performance monitoring, account maintenance, order processing, verification, research, data hosting, auditing, and data processing. Furthermore, we may share your information to safeguard the legal rights, safety, and security of Crownsoft, our affiliates, users, or the general public, including protection against fraud and malicious activities. These disclosures may also occur for other business purposes as outlined in this privacy statement or as disclosed to you at the time of information collection or with your consent.

In the event of a substantial corporate transaction, such as the sale of a website, merger, consolidation, asset sale, initial public offering, or bankruptcy (in unlikely scenarios), we may also share your information.

Regarding the transfer of your data from the European Economic Area (EEA) to third parties located outside the EEA, we will ensure compliance by relying on adequacy decisions or implementing standard contractual clauses. For non-EEA transfers, appropriate international data transfer mechanisms and standards will be followed.

What about sensitive data?

As a general practice, we do not actively seek to collect sensitive data (also known as special categories within the EEA) through this site or other means. If we do collect such data in limited circumstances, it will be in accordance with data privacy laws and may require your explicit consent. Sensitive data refers to specific categories of personal data, including but not limited to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information related to suspected criminal activities).

What about data security?

At Crownsoft, we prioritize the security of the personal data we hold. We have implemented robust organizational, physical, and technical security measures to safeguard your information. Our comprehensive security arrangements are tailored to the specific categories of personal data we handle and the processing activities we undertake.

Our commitment to data security is exemplified by:

Holding an ISO27001 certification, demonstrating our adherence to the highest international information security standards. This certification, awarded by the British Standards Institution (BSI), validates our rigorous security practices and serves as a testament to our dedication.
Implementing a global Client Data Protection (CDP) program that governs the responsible management of client information and systems entrusted to us.
Conducting regular penetration testing, performed by reputable third-party providers, to evaluate the strength of our technical defenses and ensure the continuous protection of data.

Where will your personal data be processed?

As a global organization, Crownsoft operates across multiple countries and jurisdictions. This means that the personal data we collect may be transferred or accessed internationally within our global business network, including our entities and affiliates.

These international data transfers are conducted in compliance with applicable data privacy laws and are governed by our Binding Corporate Rules (BCR). Our BCR aligns with the standards outlined in European data privacy laws, including the General Data Protection Regulation (GDPR). By adhering to our BCR, all entities within our group uphold consistent internal rules for data processing. Rest assured, your rights concerning the processing of your personal data remain consistent regardless of where Crownsoft processes your information.

What are the sources from which we collect your personal information?

If we do not directly collect your personal information from you, we may obtain it from various sources, including publicly available sources, Crownsoft employees, contractors, board members, shareholders, affiliates, subsidiaries, acquired businesses, employers of our contractors, clients, public authorities, websites, social media, previous employers, educational institutions, suppliers, and third-party data providers. For more information on the sources of your personal information for marketing purposes, please refer to section 5.

How long will your personal data be retained by us?

We retain your personal data only for as long as necessary. Our records management and retention policies ensure that personal data are deleted after a reasonable time, based on the following criteria:

Personal data are retained for the duration of our ongoing relationship with you, particularly if you have an active account with us.
Data are kept as long as needed to provide services to you.
Personal data are retained in compliance with global legal and contractual obligations.

What are your rights regarding the processing of your personal data?

You have certain rights regarding the processing of your personal data, subject to applicable law. These rights include:

The right to access your personal data and obtain information about its processing.
The right to rectify inaccurate or incomplete personal data.
The right to object to the processing of your personal data.
The right to request the erasure of your personal data. The right to request the restriction of the processing of your personal data.
The right to data portability, allowing you to receive a copy of your personal data or have it transmitted to another data controller.

If our processing of your personal data is governed by our Binding Corporate Rules (BCR), you may also have additional rights under our BCR. If the processing is based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing before the withdrawal.

If you have any concerns or complaints regarding the protection of your personal data, we encourage you to contact Crownsoft first to seek a resolution. You also have the right to lodge a complaint with the supervisory authority or take legal action against Crownsoft in the relevant jurisdiction. To exercise any of your rights or for further information, please contact Crownsoft’s Data Privacy Officer.

2. How do we utilize personal data during your visit to Crownsoft's website?

In addition to the information provided earlier, the following sections outline the usage of personal data when you browse Crownsoft’s website:

What types of personal data do we collect?

Crownsoft collects personal data through two channels: direct and indirect. Direct collection occurs when you voluntarily provide personal data through forms on our website, such as registering for services or subscribing to newsletters. Indirect collection involves data collected through our website’s technology.

The personal data we may collect and process include:

Information provided through website forms, which may require further details on why the data is needed and its purpose.
Records of correspondence when you contact us.
Surveys conducted for research purposes.
User-generated content posted on Crownsoft’s website.
Computer or mobile device information, such as IP address, operating system, device identification number, and browser type, collected for system administration and traffic analysis.
Website usage details, including page views, accessed resources, and downloaded materials, to enhance our website’s effectiveness.

Are third-party websites and programs included?

Our website may feature links to partner networks, advertisers, and affiliates’ websites, as well as certain programs provided by third parties. It’s important to note that these third parties may process the personal data collected through their programs for their own purposes. Crownsoft does not assume responsibility or liability for the activities of these third-party websites and programs. We recommend reviewing their terms of use and privacy statements before engaging with them.

How do we use the collected personal data?

We utilize personal data for the purposes mentioned in the section “For which purposes and on which legal basis do we use your personal data?” above. Additionally, we use the data to fulfill information requests, process online job applications, and other purposes that will be communicated to you during data collection. For instance:

Including links to partner networks, advertisers, and affiliates’ websites.
Incorporating third-party programs (widgets and apps) that may process personal data for their purposes.
Analyzing IP and browser information to enhance website effectiveness. Please refer to the Cookies section below for more details.

3. How do we utilize cookies and tracking technologies?

In addition to the aforementioned details, this section outlines our use of cookies and other tracking technologies.

We analyze your IP and browser information to assess the effectiveness of our website and identify areas for improvement. We aim to tailor the website to provide a positive and relevant user experience.

For comprehensive information about our use of cookies, including advertising and social media cookies, as well as access to our cookie consent manager, please refer to our Cookies policy. By using our website, you agree to the placement of cookies and similar technologies on your device as explained in the Cookies policy.

4. How do we handle personal data during office visits?

When you visit our offices, we process your personal data in accordance with this privacy statement. Specific information about visitor data usage and potential CCTV use within our offices is provided in the reception area.

5. How do we utilize personal data for marketing purposes?

In addition to the previously provided information, the following sections elaborate on our usage of personal data for marketing purposes:

Targeted e-mails

We send commercial e-mails to individuals at our clients or other companies with whom we seek to develop or maintain business relationships, adhering to applicable marketing laws. Our targeted e-mails often incorporate web beacons, cookies, and similar technologies to track interactions such as message opens, reads, deletions, and link clicks. Clicking a link in a marketing e-mail from Crownsoft may also result in the use of cookies to log page views and content downloads, even if you are not registered or signed in to our site.

Targeted e-mails from Crownsoft may include additional data privacy information as required by applicable laws. You can manage your contact, content, and data preferences in the Crownsoft Preference Center at any time.

Push notifications

If you use our mobile applications, you may receive push notifications related to industry topics you select to follow within the app or live event information. With your consent, granted through app permissions/settings, we may send push notifications or alerts to your mobile device even when you are not logged in. You can manage to push notification preferences or deactivate them by adjusting notification settings within the app or in the device settings/app permissions.

Customer Relationship Management (CRM) databases

Crownsoft employs customer relationship management (CRM) database technology, as is common among companies, to manage and track our marketing efforts. Our CRM databases contain the personal data of individuals at clients and other companies with whom we already have or aim to establish a business relationship. The personal data used in these databases include pertinent business information such as contact details, publicly available information (e.g., board memberships, published articles, press releases, relevant public social media posts), responses to targeted e-mails (including web activity following e-mail links), website activity of registered users, and additional business information provided by Crownsoft professionals based on their interactions with you.

Combination and analysis of personal data

We may combine data from publicly available sources, different e-mail communications, website interactions, and personal interactions with you (including data collected across our various websites, such as careers and corporate sites, and information obtained when signing up or logging in using social media credentials like LinkedIn and Xing). This data is combined to enhance our understanding of your Crownsoft experience and to facilitate the activities described throughout our privacy policy.

You can manage your contact, content, and data preferences in the Crownsoft Preference Center at any time.

6. Additional Utilization of Your Personal Data

In addition to the information provided above, the subsequent sections outline specific ways in which certain Crownsoft affiliates may employ your personal data.

Here, we present further details regarding the processing of your personal data for content creation and production purposes.

What Personal Data is Processed for Production Activities?

The personal data processed for production purposes encompasses images and footage of individuals, which may include location information during filming.
If you are a member of the public, we strive to inform you in advance about our filming activities and location, allowing you the opportunity to choose not to enter the filming area or participate.
If you are a focal point of our filming activities, such as a contributor, talent (interviewee, extra, or actor), rather than a member of the public, we also collect and process your name, contact information, and any details provided in pre-filming questionnaires and release forms, including next of kin information.
To the extent necessary, we may also collect and process special categories of data, such as health or disability information, to ensure appropriate adjustments are made to our filming arrangements for your assistance or support.

Should you have any inquiries concerning data privacy aspects related to our production activities, please reach out to us.

7. Get in Touch

Feel free to contact us through this platform if:

You have general inquiries regarding how Crownsoft safeguards your personal data.
You wish to exercise your rights pertaining to your personal data (as outlined in the sections “Which rights do you have concerning the processing of your personal data?” and “Your rights regarding marketing communications”).
You would like to obtain a full version of our Binding Corporate Rules (BCR).
You intend to file a complaint regarding Crownsoft’s use of your data.

You can also reach Crownsoft, as the data controller of your personal data, through our Data Privacy Officer. We encourage electronic communication; alternatively, you may send a letter, clearly marked for the attention of the Data Privacy Officer, to the following address: 701 Tillery Street, Unit 12 – 1567, Austin, Texas. 78702 United States or Email us at [email protected]

Crownsoft Privacy Statement for
Texas Residents

For individuals with special accessibility needs, we recommend referring to our Accessibility Statement and recommendations for better access to the content of this statement.

This privacy statement is effective as of June 2, 2023. Please note that it will be regularly updated to reflect any changes in our handling of personal information or relevant laws. If you are not an Austin resident, this privacy statement does not apply to you. For more information, please consult the Crownsoft Privacy Statement.

The Crownsoft Privacy Statement for Austin Residents is intended for individuals residing in Austin whose personal information is processed by Crownsoft PLC and/or its affiliates, subsidiaries, and recently acquired companies (“Crownsoft”; “we”) in accordance with the Austin Consumer Privacy Act. It outlines how we protect and control your personal information (“your personal information”; “your information”) and details your rights regarding its processing.

Any Crownsoft entity located outside the United States will be represented by Crownsoft PLC for the purpose of complying with data privacy laws.

Firstly, we provide a general description of how Crownsoft safeguards your personal information. Subsequently, we provide specific information on the following:

How we utilize personal data when you visit Crownsoft’s website.
Our use of cookies and other tracking technologies.
How we handle personal information when you visit our offices.
Our use of personal information for marketing purposes.
Content Creation and Production endeavors.
Contact Us.

1. What measures does Crownsoft employ to safeguard your personal information?

Crownsoft places paramount importance on safeguarding your privacy and ensuring the utmost protection of your personal information. We are committed to upholding applicable laws and adhering to stringent data privacy policies to ensure that your personal information is handled with the utmost care and security.

To fortify the security of your personal information, Crownsoft maintains comprehensive technical and organizational measures. These measures are designed to prevent unauthorized or unlawful processing of your personal information, as well as to safeguard against accidental loss, alteration, disclosure, or access. We also take precautions to prevent any accidental or unlawful destruction or damage to your personal information.

The following sections provide a detailed overview of how Crownsoft processes your personal information:

Which specific categories of personal information do we collect, and how do we process this information?
For what purposes and on what legal basis do we utilize your personal information?
Will we share your personal data with any third parties?
How do we handle sensitive data?
What measures do we have in place to ensure the security of your data?
Where will your personal information be processed?
How long will we retain your personal information?
What rights do you possess concerning the processing of your personal information?

At Crownsoft, we strive to provide you with the transparency and control you deserve when it comes to your personal information. We respect your rights and are committed to upholding them throughout our data processing practices.

Which specific categories of personal information do we collect, and how do we process this information?

Crownsoft gathers personal information from various sources, including employees, potential employees, clients, suppliers, business contacts, shareholders, and users of our website. If there is any information collected that is not explicitly mentioned in this privacy statement, we will duly inform individuals, as required by law, about the specific details of such information and how it will be utilized.

The personal information we collect encompasses the categories outlined in the sections titled “How do we utilize personal data when individuals visit Crownsoft’s website?”, “How do we employ cookies (and other tracking technologies)?”, “How do we employ personal data when individuals visit our offices?”, and “How do we employ personal data for marketing purposes?”

The following table offers a comprehensive overview of the personal information categories that Crownsoft processes or may process within the framework of the processing activities outlined in this privacy statement.

Personal Information Categories

Types of personal information collected within each category

Personal Identification and Contact Details

Personal Identifiers and Contact Details; Includes names, pronouns, identifiers, contact information, and relevant details such as gender, date of birth, and age.

Commercial Information

Product and Service History; Records of the products and services obtained from Crownsoft, along with correspondence related to account receivable payments and commercial follow-up.

Marketing and Research Information

Demographic and Browser/Web History Data; Information about income, family status, age bracket, gender, interests, browsing history, and preferences expressed through selection and engagement with goods, services, and content.

Sensitive Data and Biometric Information

• Social Media Content; Blogs, posts, and online mentions or references to individuals.

• Permitted collection of sensitive data, such as health/medical information or biometric data with consent.

• Images, footage, and recordings captured through CCTV, marketing events, or voice search functionalities.

• Details regarding current positions, job titles, employers, locations, and Crownsoft contacts.

• Information required for accessing Crownsoft systems, including system IDs, LAN IDs, email accounts, passwords, and electronic network activity logs.

Audiovisual Materials

Images, footage, and recordings captured through CCTV, marketing events, or voice search functionalities.

Position and Professional/Employment-Related Information

Details regarding current positions, job titles, employers, locations, and Crownsoft contacts.

System and Application Access Data, and Internet/Electronic Network Activity Information

Information required for accessing Crownsoft systems, including system IDs, LAN IDs, email accounts, passwords, and electronic network activity logs.

Cookies and Geolocation Data

Data collected in certain circumstances. Refer to our Cookies policy for more information.

Crownsoft Alumni Related Information

Information provided during alumni registration or profile updates, correspondence, chat page posts, survey responses, details related to compensation, position, birth year, and existing personal information in Crownsoft systems for verification purposes.

Furthermore, to fulfill our recruitment and employment obligations, as well as to deliver comprehensive assessment and HR consultancy solutions to our clients, Crownsoft undertakes the processing of personal information as delineated in the following table.

Personal Identification and Cont+act Details

Personal Identifiers and Contact Details; Includes names, pronouns, identifiers, contact information, and relevant details such as gender, date of birth, and age.

Additional personal information, such as details related to personal identification, contact information, and demographic data.

Furthermore, in the context of recruitment and employment, Crownsoft may gather supplementary personal information, including but not limited to the national identification number, social security number, insurance details, marital or civil partnership status, domestic partnership information, dependent information, emergency contact details, and military background. Additionally, professional and personal calendar availability and scheduling information may be collected for effective communication and meeting coordination.

Educational background and professional employment details.

Crownsoft has the potential to acquire data pertaining to your educational background and professional or employment-related details, including your previous work experiences.

Sensitive information collected for recruitment purposes and the provision of assessment and HR consultancy services.

Crownsoft may gather sensitive information, subject to local laws and your consent. This may include health/medical information, trade union membership, religion, race or ethnicity, minority status, and details regarding criminal convictions. The collection of such information serves specific purposes, such as accommodating disabilities or illnesses (within legal constraints), providing benefits, conducting background checks, and ensuring compliance with diversity and anti-discrimination policies.

Documentation is necessary to comply with immigration laws.

Crownsoft may gather information pertaining to citizenship, passport details, and residency or work permit information (either in physical or electronic form).

Financial information pertaining to payroll and employee benefits.

The banking and pertinent financial information necessary for payroll and benefits administration.

Data related to talent management.

The information required for conducting background checks, performance-related decisions and outcomes, performance feedback and warnings, e-learning and training programs, performance and development reviews (including feedback, priority setting, and input updates in relevant tools), driver’s license details, car ownership information, and data used to populate biographies.

Specific information requested during the recruitment process.

The information solicited during the recruitment process, within the permissible bounds of applicable law.

Information provided by you during the recruitment process.

The data furnished by individuals in their resumes/CVs, cover letters, writing samples, or any other written materials (including photographs).

Data generated by Crownsoft throughout the recruitment and assessment processes.

Data produced by interviewers and recruiters pertaining to you, derived from their interactions with you or lawful basic Internet searches.

Information obtained from third parties during the recruitment process.

Data concerning you that is supplied by third-party placement agencies, recruiters, or job-search platforms, as well as relevant clients.

Audiovisual information is utilized during recruitment activities.

Photographs and visual/audio recordings taken through closed-circuit television (CCTV) or other video systems during office visits, recruitment events, or video-based recruitment interviews.

Recommendations provided by relevant parties.

Information pertaining to recommendations provided on your behalf by third parties.

Employment history and background checks.

Details regarding your previous employment, educational background, and, where applicable and in compliance with applicable laws, records of credit history, criminal background checks, or any other pertinent information discovered during the process of conducting background screenings.

Information related to diversity and inclusion.

Data pertaining to race, ethnicity, religion, disability, and gender is collected for government reporting obligations as mandated by law. Additionally, this information is utilized to assess the diverse composition of the workforce, within the boundaries set by legal requirements and consent where applicable.

Data collected during assessments.

Data resulting from your involvement in psychological, technical, or behavioral evaluations will be generated. Detailed information regarding the nature of these assessments will be provided before you participate in any of them.

In addition, we may conclude you based on the aforementioned information and gather further data as outlined in this privacy statement. If you furnish us with personal information pertaining to another individual (such as a potential employee or referral), it is your responsibility to ensure that the individual is informed about the content of this privacy statement and has granted you consent to share the information with Crownsoft.

The aforementioned categories of personal data have been obtained either directly from you (e.g., when you provide information to subscribe to a newsletter or register for a forum website) or indirectly from select third parties (e.g., through the technology employed on our website). These third parties may include our affiliates, public authorities, public websites, social media platforms, suppliers, clients, and vendors. With the exception of information mandated by law or Crownsoft policies (including employment relationship management with Crownsoft), the decision to provide us with personal data is voluntary. Please note that failing to provide certain information may impede our ability to fulfill some or all of the purposes stated in this privacy statement, and it may limit your access to certain tools and systems that necessitate the use of said personal data.

For what purposes and on what legal basis do we utilize your personal information?

Crownsoft utilizes your personal information exclusively for specific purposes, in accordance with legal requirements. Refer to the following table for (i) a comprehensive list of the business purposes for which Crownsoft employs your personal information and (ii) an outline of the legal basis underlying each respective business purpose.

Objective

Legal Justification

Managing our contractual and/or employment relationship with you.

Required for 1) fulfilling a contract or similar agreement in which you are involved or 2) overseeing your employment association with Crownsoft.

Facilitating communication with you (including arranging meetings, emergency communication, and providing requested information).

Supported by our lawful interests to guarantee effective communication and prompt emergency management within the company.

Operating and managing our business operations, including providing services to clients and their employees/contractors and collecting data for surveys, assessments, data analytics, and market research.

Supported by our lawful interests in maintaining the optimal functionality of our business operations.

Ensuring compliance with legal requirements.

Required to fulfill our legal obligations as imposed upon us by applicable laws and regulations.

Monitoring your use of our systems, including our website and associated tools.

Supported by our legitimate interests in preventing non-compliance and safeguarding our reputation.

Conducting research and market analysis.

Based on our legitimate interest in obtaining market insights and insights into business and society, or with the necessary consent from the relevant individuals.

Engaging in social listening to understand the sentiment, market trends, and stakeholder needs.

Based on our legitimate interest in safeguarding our assets and brand on social media platforms.

Using ethnographic videography to observe and understand behavior in natural environments.

Based on the voluntary consent provided by the relevant individuals.

Enhancing the security and functionality of our website, networks, and information.

Based on our legitimate interests to deliver a seamless user experience and maintain the security of our networks and information.

Applying data analytics to improve business performance and user experience, including the use of AI and machine learning.

Based on our legitimate interests to ensure the effective operation of our business activities.

Marketing our products and services to you, unless you have opted out.

Justified based on our legitimate interests for ensuring that we can conduct and increase our business.

Using audio/video captured during live or recorded events for promotional purposes and informing stakeholders about event content.

In accordance with the consent you have provided prior to the event, as per your informed decision.

Grounds for Specific Recruitment/ Employment

Legal Objective

Evaluate your eligibility for employment in the position you have applied for, as well as any potential future opportunities that may arise.

Supported by Crownsoft’s legitimate interests in recruiting suitable employees.

Manage and oversee the processing of your job application.

Justified based on Crownsoft’s legitimate interests in facilitating effective communication internally and with candidates.

Facilitate effective communication with you throughout the recruitment process.

Supported by Crownsoft’s legitimate interests in continuously enhancing its recruitment processes.

Handle administrative tasks such as reimbursing interview-related expenses.

Justified by Crownsoft’s legitimate interests in recruiting the right talent for its organization.

Conduct data analysis to gain insights into our applicant pool and enhance our talent acquisition strategies.

Justified based on Crownsoft’s legitimate interests in improving its recruitment processes.

In certain cases, record online interviews for review by additional recruiters and hiring managers.

Supported by Crownsoft’s legitimate interests in recruiting suitable employees.

Registering on our Careers website will enroll you in our database to receive future communications about Crownsoft positions and events. Additionally, personalized job recommendations may be provided while browsing the website.

Justified by Crownsoft’s legitimate interest in recruiting the right talent for its organization.

Transfer your contact details, education and employment information, application data, and CV from our recruitment system to the Crownsoft Talent Connection platform. This platform informs you about new positions that align with your interests.

Supported by Crownsoft’s legitimate interests in recruiting suitable employees.

Administer employee benefits in compliance with relevant regulations.

Supported by Crownsoft’s legitimate interests in providing eligible employees with the relevant benefits they are entitled to.

Fulfill any legally-required reporting obligations and respond to legal requests as necessary.

Compliance with a legal obligation.

Purposes related to specific alumni information

Legal grounds

Enabling alumni to search and locate you through the directory if you are registered as a Crownsoft alumnus/alumna.

Justified on the basis of Crownsoft’s legitimate interests in offering users the opportunity to utilize the Alumni Site for contacting fellow alumni.

Providing users of the Alumni Site with a personalized experience, including tailored services such as News and Events and interactive communications.

Justified on the basis of Crownsoft’s legitimate interests in providing users with a personalized experience.

Conducting research and analysis on aggregated alumni demographics, interests, and behavior.

Justified on the basis of Crownsoft’s legitimate interests in gaining a deeper understanding of our users, enhancing the Alumni Site, and improving its offerings.

Periodically contacting alumni with communications about events, publications, or employment opportunities at Crownsoft that may be of interest, unless you choose not to be contacted. You will have the option to opt out of receiving further messages.

Justified on the basis of Crownsoft’s legitimate interests in maintaining effective communication with our alumni and conducting marketing activities.

Sharing alumni information with other internal systems at Crownsoft, specifically our internal sales tool (salesforce.com), to contact you with industry-relevant information.

Justified based on Crownsoft’s legitimate interests in maintaining effective communication with our alumni and conducting marketing activities.

Crownsoft relies on legitimate interests as the basis for processing your personal information, meaning that we have reasonable grounds to do so. When we state that we rely on legitimate interests in the above table, it is because we believe that our interests do not outweigh your rights, interests, and freedoms. This belief is supported by our commitment to transparency, privacy by design, regular privacy reviews, and the rights you have in relation to your personal data. If you require further information about our approach to balancing these interests, please reach out to Crownsoft’s Data Privacy Officer.

In certain cases, we may process your personal data based on your prior consent, particularly when it is mandatory under applicable laws.

When you are asked to indicate your acceptance, agreement, or similar actions in relation to a privacy statement by clicking “I accept,” “I agree,” or similar buttons/checkboxes/functionalities, it will be considered as your consent to process your personal data in countries where such consent is required by law. In other countries, this action will be seen as an acknowledgment, and the legal basis for processing your personal data will be based on other applicable grounds, not your consent.

We will not use your personal data for purposes that are incompatible with the ones we have informed you about, unless it is required or authorized by law, or if it is in your vital interest (such as in a medical emergency) to do so.

In cases where we utilize de-identified information, we will continue to maintain and use that information in its de-identified form and will not attempt to reidentify it.

Will we share your personal data with any third parties?

In certain cases, we may process your personal data based on your prior consent, particularly when it is mandatory under applicable laws.

In cases where we utilize de-identified information, we will continue to maintain and use that information in its de-identified form and will not attempt to reidentify it.

How do we handle sensitive data?

At Crownsoft, our general approach is to refrain from collecting sensitive data, as defined in the subsequent paragraph (commonly known as special categories within the EEA), both through our website and other means. However, in exceptional circumstances where we may need to collect such data, we ensure strict compliance with data privacy laws and regulations and may seek your explicit consent.

The term “sensitive data” pertains to specific categories of personal information that data privacy laws recognize as requiring special handling, which may involve obtaining explicit consent. These categories encompass factors such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health details, biometric or genetic data, sexual life or orientation, financial information, geolocation data, the content of private communications, sensitive information associated with government identification (such as social security or driver’s license numbers), and criminal convictions or offenses (including information about suspected criminal activities).

What measures do we have in place to ensure the security of your data?

At Crownsoft, we prioritize the security of the personal information under our care. We have implemented robust organizational, physical, and technical security measures to safeguard this information. Our protocols, controls, policies, procedures, and guidance are designed to address the risks associated with different categories of personal information and the processing activities we undertake.

To ensure the utmost protection of your personal information, we employ state-of-the-art security measures. These measures include, but are not limited to:

1. Holding an ISO27001 certification:

This prestigious certification, awarded by the British Standards Institution (BSI), signifies our adherence to rigorous information security standards. It serves as an internationally recognized validation of Crownsoft’s commitment to maintaining the highest level of security. The certification confirms that our processes and security controls are designed to effectively safeguard both our clients and our information.

2. Global Client Data Protection (CDP) program:

We have established a comprehensive program that governs the responsible handling of client information and the secure management of client systems entrusted to us.

3. Regular third-party penetration testing:

We engage reputable third-party providers to conduct thorough penetration testing, ensuring the ongoing evaluation and fortification of our technical defenses.

These measures reflect our unwavering dedication to protecting your personal information and maintaining the highest standards of security.

Where will your personal information be processed?

As a globally operating organization with offices and activities spanning across different regions, Crownsoft may transfer and access personal data internationally within its extensive business network and among its entities and affiliates.

Such transfers within Crownsoft’s global operations adhere to the applicable data privacy laws and are conducted in compliance with our Binding Corporate Rules (BCR).

Our BCR aligns with the standards established by European data privacy laws, including the General Data Protection Regulation (GDPR). By implementing our BCR, all entities within our group that have adopted these rules are bound by the same internal regulations. This ensures consistent protection of your rights (as outlined in “Which rights do you have with respect to the processing of your personal information?”) regardless of the location where your data is processed by Crownsoft.

For a detailed understanding of Crownsoft’s BCR, you can download a copy from our website.

From which sources do we collect your personal information?

If we do not directly collect your personal information from you, we may acquire it from the following sources: publicly accessible sources such as registers or the internet, individuals associated with Crownsoft including employees and contractors, prospective members of the board of directors, shareholders, Crownsoft’s affiliated companies, subsidiaries, and newly acquired businesses, employers of our contractors, our clients, public authorities, public websites, and social media platforms, your previous employers, educational institutions, suppliers, vendors, and third-party data providers.

In section 5, you can discover additional details regarding the sources of your personal information for marketing purposes.

How long will we retain your personal information?

We will uphold a policy of preserving your personal data for the necessary duration. Within Crownsoft, we adhere to meticulous records management and retention policies and procedures, ensuring that personal data is expunged after a reasonable period based on the following retention criteria:

Your data will be retained as long as an ongoing relationship exists between us, particularly if you hold an account with us.
We will only retain your data as long as your account remains active or for the duration necessary to provide services to you.
Your data will be retained for the required duration to ensure compliance with our legal and contractual obligations on a global scale.

What rights do you possess concerning the processing of your personal information?

Crownsoft recognizes your entitlement, as provided by applicable law, to exercise the following rights:

Request access to the personal information we process about you: This right empowers you to ascertain whether we hold personal information about you and, if so, to obtain information on and a copy of the specific pieces and categories of personal information.
Request rectification of your personal information: This right empowers you to have your personal information corrected if it is inaccurate or incomplete.
Object to the processing of your personal information:
This right empowers you to request that Crownsoft no longer processes your personal information.
Request the erasure or deletion of your personal information: This right empowers you to request the erasure or deletion of your personal information, including situations where such information is no longer necessary for the intended purposes.
Request the restriction of the processing of your personal information: This right empowers you to request that Crownsoft only processes your personal information in limited circumstances, including situations where you provide consent.
Request portability of your personal information: This right empowers you to receive a copy (in a portable and, if technically feasible, readily usable format) of your personal information or request Crownsoft to transmit such information to another data controller.

Texas law provides Texas residents with the right to receive a privacy notice containing information about the personal information we have collected, disclosed for business purposes, and sold during the preceding 12 months. This Crownsoft Privacy Statement for Texas Residents provides details about the categories of information collected, the sources of that information, the purposes for which it has been used, and the categories of third parties with whom it has been shared for business purposes. Texas law also grants Texas residents the right to opt out of the “sale” of their personal information. This right applies to instances where Crownsoft engages in the “sale” of personal information, as defined under applicable law. While Crownsoft generally does not engage in selling information, there may be limited circumstances where we share personal information with clients, third-party partners, or others that qualify as a sale, allowing Texas residents to opt out. We do not sell the personal information of individuals under 16 years of age without affirmative authorization. If you choose to exercise your rights, we will not discriminate against you by offering different prices or providing a different quality of services, unless such differences are related to your personal information or permitted by law. Please click here to opt out of the “sale” of your personal information. If you wish to opt back in and allow Crownsoft to sell your personal information, please click here. To exercise any other rights available to you under Texas law, please contact Crownsoft’s Data Privacy Officer. Additionally, you can call 1-833-226-2351 during regular office hours in the Central Standard Time (CST) zone (only available in English). Upon receiving your request, we may verify your identity by requesting information that sufficiently confirms your identity. If necessary, this may involve requesting a copy of your valid government-issued identification, such as your passport or driver’s license (with the option to redact your driver’s license number or social security number). If you prefer to use an authorized agent registered with the Texas Secretary of State to exercise your rights, we may request evidence that you have granted such agent power of attorney or that the agent possesses the valid written authority to submit requests on your behalf, which we can directly confirm with the agent. We reserve the right to deny requests from authorized agents in certain circumstances, such as when there is a reasonable belief that the request is fraudulent. Crownsoft may offer certain financial incentives for the collection, sale, or deletion of personal information

2. How we utilize personal data when you visit Crownsoft’s website

In addition to the preceding information, the following sections provide an overview of how Crownsoft utilizes personal information when individuals visit its website:

What types of personal information do we collect?
Are we affiliated with or have links to third party websites and programs?
How do we utilize the personal information we collect from our websites?

What types of personal information do we collect

Crownsoft gathers personal information from its websites through two main channels: (1) direct interaction (such as when individuals provide personal information to subscribe to newsletters or register for forum websites), and (2) indirect means facilitated by the website’s technology. We may collect and process the following types of personal information:

Information is provided by individuals through online forms on our website. This includes registration for website usage, subscription to services, newsletters, alerts, conference registration, or requests for white papers or additional information. Pages collecting this personal information may offer further details on the purpose and use of the information, and the decision to provide it is entirely voluntary.
Records of correspondence if individuals contact us.
Optional surveys are conducted for research purposes, with no obligation for individuals to participate.
Content such as postings, comments, or uploads to Crownsoft website.

Our website or mobile applications may collect personal information related to users’ devices, such as IP address, operating system, device type, identification number, mobile operating system, and browser type, for system administration, traffic filtering, domain lookup, and statistical reporting. Details of website visits, including pages viewed, resources accessed or downloaded, traffic data, geolocation data, weblogs, and other communication data. Further information on this can be found in the Cookies section below.

Are we affiliated with or have links to third-party websites and programs?

Our websites may contain:

Links to and from partner networks, advertisers, and affiliates.
Certain third-party programs (widgets and apps). In such cases, it is important to note that these third parties may process personal information collected through their programs for their own purposes.

We assume no responsibility or liability for the websites or programs of these third parties. It is advisable to review their terms of use and privacy statements before providing any information or using their websites and programs.

How do we utilize the personal information we collect from our websites?

We utilize personal information for the purposes outlined in the section “For what purposes and on what legal basis do we use your personal information?” above. Additionally, we employ personal information to fulfill information requests, process online job applications, and for other purposes that will be clearly communicated to individuals at the point of data collection. For example: We analyze IP and browser information to assess the effectiveness of our website, identify areas for improvement, and enhance its overall performance. More information on this can be found in the Cookies section below.

3. Our use of cookies and other tracking technologies

In addition to the aforementioned details, this section elucidates our utilization of cookies and other tracking technologies. We analyze the data derived from your IP address and browser information to discern the most effective aspects of our website. This analysis aids us in identifying opportunities for enhancement and enables us to tailor the website to deliver a more engaging and personalized user experience. For comprehensive information, including details on your choices pertaining to Advertising and Social Media Cookies, as well as access to our cookie consent manager, please refer to our Cookies policy. By accessing our website, you acknowledge and consent to the placement of cookies and similar technologies on your device by us and third parties, as explained in our Cookies policy.