What this Policy Covers

The data controller is Cros Audio sp. z o.o (referred to in this document as “Cros Audio”, “we” or “us”).

Cros Audio is committed to doing the right thing when it comes to how we collect, use and protect information that identifies or is associated with you as a real person (“personal data”). This is why we have developed this privacy and cookie policy (“policy”), which:

• Outlines the types of personal data that we collect;
• Explains how and why we collect and use your personal data;
• Explains why and when we will share personal data within Cros Audio and with other organisations (suppliers and manufacturers);
• Explains the rights and choices you have when it comes to your personal data.

This policy applies to our website www.crosaudio.com, and our mobile apps for iOS or Android mobile devices (collectively, our “service”). Using our service means: this policy also applies when you shop with us over the phone, and also if you contact us or any time we contact you.

Personal Data We Collect

This section describes the personal data we may collect from you when you use our service, and what other personal data we may receive from other sources.

Data you provide to us directly.

When you register on our site or purchase products, you provide us with the following:

• Your name, profile information, shipping address and billing addresses, payment information, email address, phone numbers, and business name.
• When you create an account, you are prompted to create a username and a password. Cros Audio maintains your username and password (in an encrypted format) inside our secure environment and only uses your information to welcome you back and to personalise your experience.
• The shipping and billing addresses you provided for convenience during future purchases.
• The products and other information in your basket, project, BOM, or contained in your order history.

When you contact us, any time Cros Audio contacts you, or whenever you take part in any promotions, competitions, surveys or questionnaires from Cros Audio, or whenever you post or speak with us through social media, we may collect the following information:

• Personal data you provide any time you contact us (for example: your name and contact details, including phone and email);
• Details of the emails and other digital communications, including any links in them that you access, and whether you have opened the communications;
• Email headers, source IP information, sending email server hostnames and ISP information;
• Your feedback and contributions to customer surveys and questionnaires.

You are free to choose which information you want to provide to us, or whether you want to provide us with information at all. However, some information, such as your name, address and payment information, is necessary to process your transaction. By not providing this information, you will not be able to use our website, order products or use some of our service.

When purchasing Cros Audio products, you should know:

• Cros Audio does not keep credit card numbers. Your credit card information is tokenised the first time it is processed. Should you elect to save a credit card to your account for future use, only the encrypted token is stored and used to charge your credit card account;
• Cros Audio deploys technologies that detect and remove credit card information sent through unapproved channels via email or fax; and
• Cros Audio integrates with regional payment processors globally. Third-party payment processors (WeChat, Alipay, PayPal, etc.) process payment data through their sites and not through Cros Audio’s website.

Cookies and other tracking technology

Cros Audio and our third-party partners automatically collect certain types of usage information when you use our service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology (collectively, “tracking technologies”).

Cros Audio collects information about your device and its software, such as your IP address, browser type, internet service provider, platform type, device type, operating system, date and time stamp (a unique ID that allows us to identify your browser, mobile device, or your account). We also collect information about the way you use our website. When you access our website from a mobile device, we may collect unique identification numbers associated with your device or our mobile application.

We may collect analytical data or use third-party analytics tools to help us measure traffic and usage trends to understand the demographics of our users. We may employ technologies, including the application of statistical modelling tools, which permit us to recognise and contact you across multiple devices.

How We Use and Share Your Personal Data

What does Cros Audio use my data for?

Cros Audio processes your data in accordance with all applicable data protection laws, and to the best of our ability, we adhere to the principles of those complex laws. We process your data for the purposes explained to you in this Data Privacy Policy. These are mainly purchase processing and order fulfilment. Processing may also include such purposes as product development, market research, optimisation of business and website processes, and the needs-based design of our service and personalised advertising.

Purchase processing and provision of online, local and personalised service:

We process your data to fulfil contracts and to provide and execute additional service requested by you, as described in this Data Privacy Policy. The most important purposes are:

• The provision, personalisation and needs-based design of our service, including websites, apps and cross-device and cross-platform functions.
• The execution of purchase agreements and customer service, including payment processing, claim management as well as the processing of returns, complaints and warranty claims.
• Non-promotional communication with you on technical, security-related and contractually relevant subjects (e.g. fraud warnings, account blocking or product recall).
• The execution of campaigns, competitions and/or newsletters.

Improving the shopping experience:

Cros Audio uses data to enhance the shopping experience.

Cros Audio uses cookies and access data for usage analysis. Cros Audio also uses data received from advertising partners while you visit Cros Audio. When logged into a customer account, we use profile data, interest data and shopping data to personalise the shopping experience. This personalisation allows Cros Audio to present you with suitable search results, product suggestions, technical recommendations and other content corresponding to your interests.

Prevention of fraud:

Cros Audio uses collected data to verify identity and secure against fraud and protect against potential security issues. This applies both to ordering and to registering for a customer account. Cros Audio uses encryption and security technologies to protect our network and data. Cros Audio also uses technical and organisational measures to secure our systems against loss, destruction, unauthorised access or distribution of customer data by unauthorised persons. Protection of personal data is our top priority.

Advertising and market research, data analysis:

Cros Audio uses your data, also within the framework of data analysis, for advertising and market research, in particular for the following purposes:

• Classification into various target and user groups within the framework of market research (user segmentation).
• Findings on various target groups and their respective usage habits and shopping interests.
• The production of findings on demography, interests, our users’ shopping and usage habits as well as the marketing based on these findings within the framework of advertising service provided to third parties.
• The early identification of trends in the areas of technology and online shopping.
• The execution of advertising to existing customers.
• The execution of direct marketing, e.g. in the form of newsletters.
• The planning, execution and success monitoring of advertising corresponding to the interests of target groups.
• Findings as to how our service are used (usage analysis).

Product and technology development:

Cros Audio uses your data for product and technology development, including the development and improvement of personalised service. In doing this, we use aggregated, pseudonymised or anonymised data and machine learning algorithms for the analysis in the interests of our users. Data is processed in relation to product and technology development particularly for the following purposes:

• The development and improvement of personalised service and technologies for data analysis, advertising and more relevant product searching.
• The development of technologies and concepts to improve IT security, prevent fraud and improve data protection e.g. by using pseudonymisation, encryption and anonymisation technologies.

Business management and business optimisation:

Cros Audio transmits and processes data necessary for administrative and logistical processes.

Data processing for business management and business optimisation also allows us to improve customer service, manage fraud and security. At no time does Cros Audio sell customer information. Cros Audio does not share information without your knowledge and consent.

On the basis of your consent:

If you have given Cros Audio consent for the processing of personal data, your consent is the primary basis of our data processing. Typical purposes include:

• Subscription to a newsletter
• Participation in surveys and market research studies
• Customer Service Support documentation
• The execution of a credit check (if it is not necessary for contractual fulfilment)

Your Rights

Your privacy rights are important to Cros Audio. New privacy laws and requirements are constantly being implemented around the globe, Cros Audio works to ensure that your privacy is protected regardless of who you are and where you are from. We respect your privacy rights and manage your data according to your wishes.

Right of access

• Manual right of access request

If you would like a copy of the personal data we hold about you, and you do not have an email address, please write to:

Cros Audio sp.z o.o.

ul. Zwierzyniecka 10 lok 1

15-333 Bialystok, Poland

• Email a right of access request to:

office@crosaudio.com

Cros Audio will perform the following process.

• Cros Audio will erase your account (your personal data).
• Cros Audio will remove your data from our marketing database.
• Cros Audio deletes information on transactional records only after statutory retention requirements have been met (a transactional record is the record of a purchase, invoice, refund, return, credit or payment).
• Cros Audio will keep a record of your “request to be erased” and a log of when your data was erased from our systems.
• Cros Audio will provide you with a verification email that personal data has been erased from our systems.

Other Rights

• Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete;
• Right to restriction. The right to obtain restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period of time enabling us to verify the accuracy of that personal information;
• Right to portability. The right to portability allows you to move, copy or transfer personal information easily from one organisation to another; and
• Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. You can object to marketing activities for any reason.
• Right to submit a complaint. You also have the right to lodge a complaint with your local data protection authority.

If you wish to exercise any other of your rights, please write to us at:

Cros Audio sp.z o.o.

ul. Zwierzyniecka 10 lok 1

15-333 Bialystok, Poland

You can also email us at office@crosaudio.com

Marketing and Market Research

Cros Audio will send you relevant news, offers and surveys about our products and service in a number of ways including by email, but only if you have previously agreed to receive these marketing communications. Your email preferences can be managed on our websites or through Cros Audio’s customer service.

We also like to hear your views to help us to improve our service, so we may contact you for market research purposes. You always have the choice whether or not to take part in our market research.

We want you to understand your rights and choices regarding how we may use your personal information. Depending on how you choose to manage your information, these rights and choices may include the following:

• Profile and Data Sharing Settings: You may update your username and password, and may change some of your data sharing preferences;
• How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in our communications. We make every effort to promptly process all unsubscribe requests; and
• Modifying or deleting your information: If you have any questions about reviewing, modifying or deleting your information, you can contact us directly at office@crosaudio.com
• Non-Discrimination: Cros Audio provides equal service to all our customers. The exercise of your privacy rights in no way changes our service to you, our customer
• Sale of customer data: We want you to be confident that your data is safe and secure. Cros Audio does not sell customer information. Cros Audio does not share or sell distribution lists, marketing lists, or customer lists. Cros Audio values your privacy and only uses your information for the purposes of fulfilling orders and providing the superior customer service you

Retention and Protection of your Data

We care about the security of your information and employ physical, administrative and technological safeguards designed to preserve the integrity and security of information collected through transactions on our website and customer service. We have in place secure servers, firewalls and encryption to safeguard all our information.

We will store personal information for as long as necessary to fulfil the business purposes fully outlined in this policy, in accordance with our legal obligations and the performance of contracts. In general, transactional records are deleted after statutory retention requirements have been met (a transactional record is the record of a purchase, invoice, refund, return, credit or payment).

International Transfer of Data

As we are located in Poland, any information you provide will be processed and stored in Poland. Cros Audio ensures appropriate (adequate) safeguards for all customer data based on internationally recognised data protection standards.

If you wish to inquire further about the safeguards we use, please contact us using the details set out at the end of this policy.

Third Party Tracking and Online Advertising

Interest-Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. Typically, though not always, the information we share is provided through cookies or similar tracking technologies. Cookies and tracking technologies are able to recognise the device you are using and collect information, including click stream information, browser type, time and date you visited the site, and other information. Our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related service such as reporting, attribution, analytics and market research.

Social Media Widgets and Advertising. Our website may include social media features, such as the Facebook “Like” button, LinkedIn, Snapchat, Instagram, Twitter, or other widgets. These social media companies may recognise you and collect information about your visit to our site, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, and others. These companies have interest-based advertising programmes that allow us to direct advertisements to users who have shown an interest in our service while those users are on the social media platform or to groups of other users who share similar traits. These advertisements are governed by the privacy policies of those social media companies that provide them.

Cross-Device Linking. We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you log into our website. This allows us to provide interest-based advertising and other personalised content across your devices, perform analytics, and measure the performance of our advertising campaigns.

Your Choices:

• Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices. If you are located in the EEA, you may also manage certain advertising cookies by visiting Your Online Choices at www.youronlinechoices.eu;
• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app; plus
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

Google Analytics and Advertising. We use Google Analytics to recognise you and link the devices you use when you visit our website on your browser or mobile device, log in to your account on our site, or engage with us. Google Analytics allows us to understand how you interact with our site and tailor our advertisements and content to you.

You can learn more about Google’s practices at www.google.com/policies/privacy/partners/.

For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, see Google’s site https://tools.google.com/dlpage/gaoptout/.

Links to Other Websites and Service

Our service may contain links to and from third-party websites related directly to our business partners, advertisers and social media sites. In addition, our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and we do not accept any responsibility or liability for their policies or websites. We strongly recommend that you read their privacy policies, terms, and conditions of use to understand how they collect, use and share information.

How to contact us

If you have any questions about this policy, the Cros Audio website, or Cros Audio’s service, please contact us by email at: office@crosaudio.com or by post at:

Cros Audio Cros Audio sp.z o.o.

ul. Zwierzyniecka 10 lok 1

15-333 Bialystok, Poland

Changes to this Policy

We may modify or update this policy from time to time to reflect the changes in our business and international compliance requirements. When any changes in the policy occur, we will update the ‘last modified’ date at the top of this page.