Effective Date: July 11, 2023
Crossbow Therapeutics, Inc. (“Crossbow”, “us”, or “we”) respects the privacy of visitors to this website, www.crossbowtx.com, and is committed to the protection of their personal information. This Privacy Policy explains data collection and use practices of Crossbow’s website.
Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING OUR WEBSITE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.
This Privacy Policy may be subject to the provisions of the EU General Data Protection Regulation ("EU GDPR"), the UK General Data Protection Regulation (“UK-GDPR”, and together with the EU GDPR, the “GDPR”), and other applicable privacy laws. Under the GDPR, Crossbow is a data “Controller”. If you are an individual who resides in the United Kingdom the European Union, or Switzerland (collectively, and for the purposes of this Privacy Policy, the “EEA”), you are a “Data Subject” with certain protected privacy rights concerning your “Personal Data.” We will take commercially reasonable steps to maintain compliance with GDPR. Your Personal Data, combined with any other information that may identify you as a person, may be referred to in this Privacy Policy as Personally Identifiable Information (collectively, "PII").
Description of the information Crossbow may collect on this website:
1. Personally Identifiable Information
Crossbow collects PII (i.e., information from which you can be identified, such as name, address, telephone number or e-mail address) only when it is asked for and/or you voluntarily submit it to us on this website. The extent of the PII that we collect is your name, employer, and email address. We may use the information to respond to your requests, improve our level of service and the content of our website; provide you with tips, helpful information, product news and updates; notify you of new Crossbow products and services; and for our own internal purposes.
2. Non-Personally Identifiable Information
Crossbow also collects non-personally identifiable information in aggregate form to track data such as the total number of visits to our website, the number of visitors to each page of our website and the domain names of our visitors’ internet service providers. We use this information, which remains in aggregate, non-personally identifiable form, to understand how our visitors use our website so that we may improve our website and the services we offer. If non-personally identifiable information is paired to any of your PII, we will treat the non-personally identifiable information as if it were also PII.
3. Use of IP Addresses
An Internet Protocol (IP) address is a set of numbers that is automatically assigned to your computer whenever you log on to your internet service provider or through your organization’s local area network (LAN) or wide area network (WAN). Web servers automatically identify your computer by the IP address assigned to it during your session online.
Crossbow or third-party companies acting on behalf of Crossbow may collect IP addresses for the purposes of systems administration and to audit the use of our website. We do not ordinarily link a user’s IP address to personally identifiable information of that user, which means each user’s session will be logged, but the user remains anonymous to us. However, we may use IP addresses to identify users of our website when we feel it is necessary to enforce compliance with the website’s Terms of Service, available here, www.crossbowtx.com/terms/, as updated from time to time (“Terms”), or to protect our company, website or other users.
4. California Law
California law allows California residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. To make such a request, please contact us at contact@crossbowtx.com with “Request for Privacy Information” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.
5. Nevada Law
If you are a Nevada resident, we do not “sell” personal information as defined in the Nevada Privacy of Information Collected on the Internet from Consumers Act as amended by Nevada Senate Bill 220. Nonetheless, you may submit a request to prohibit such sales by contacting us at contact@crossbowtx.com. Additional information on the categories of personal information collected and categories of personal information shared with third parties can be found in this Privacy Policy. If you would like to tell us not to sell your information in the future, please email us at contact@crossbowtx.com with your name, postal address, telephone number, and email address with “Nevada Do Not Sell” in the subject line.
6. Cookies
This website uses a technology called “cookies.” A cookie is a small text file that is placed on your hard disk by a web page server. Cookies help provide additional functionality to the website or help us analyze usage of the website more accurately. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to the website. In all cases in which cookies are used, we will not collect personally identifiable information without your explicit permission. The only PII Crossbow collects is the information you voluntarily provide.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies, or receive a warning before a cookie is stored, if you prefer. Please refer to your internet browser’s instructions or help screen to learn more about these functions. If you choose to decline cookies, you may not be able to fully experience the interactive features of this website or any other websites that you visit.
We also use Wix Analytics and Reports, provided by Visitor Analytics SRL, Cluj-Napoca, Str. Alexandru Vaida Voevod nr. 35, et. 5, Cluj County, Romania, registered under the Trade Registry Number J12/3835/2016 and sole identification number RO36665706, (“Wix”). Without the use of cookies, Wix measures traffic on our website and may collect personal information from our website visitors. We create statistics to improve the experience of our website visitors from these statistics. As a website operator using Wix to conduct reach measurement, depending on the level of data protection we have activated, we may process information about the device you are using and its characteristics, information about technical characteristics of the website visit, the number of page visits and statistically relevant behavior of our website visitors. The technology does not use the collected data to identify individual visitors or to match the data with additional information about an individual user. Depending on the location from which you access our website, Wix may not collect any information about the device you are using due to our technical settings. For more information on Wix’s practices, please see their privacy policy here, https://www.visitor-analytics.io/en/support/legal-data-privacy-certificates/homepage/privacy-policy/.
At present, Crossbow’s website does not specifically respond to browser do-not-track signals.
7. Sharing Personally Identifiable Information with Third Parties
Except as provided in this Privacy Policy, Crossbow will not sell or rent PII to any third party for any purpose. Crossbow will share your PII: (a) as necessary for the purposes for which you provided it; (b) with your consent; (c) as required by law or as we believe necessary to protect Crossbow or others from injury; and (d) with selected third parties are used by Crossbow to provide us with support services in connection with our website and such parties may, from time to time, have access to your information to enable them to provide those services to Crossbow. Please rest assured that all companies providing such support services are required by Crossbow to meet certain standards of data protection and are prohibited from using the information for their own marketing purposes.
We may also share non-personally identifiable information with others, including affiliated and non-affiliated organizations.
We may also transfer your PII to a third party, or an actual or potential successor-in-interest, in relation to, or in the event of, an actual or potential merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control. After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.
8. Storing and Protecting Your PII
After receiving your PII, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect including, but not limited to, strong encryption, firewall protection, and industry best practice authentication. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information, we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers' systems.
If you are visiting the website from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.
We retain and store your PII until you request us to remove it from our servers. We store our logs and other technical records indefinitely.
9. ‘EEA’ Privacy Rights
If you currently reside in the EEA, the GDPR applies to your PII and you are a Data Subject. The GDPR requires that we, in our capacity as a Controller, have a legal basis to process your PII.
We process your PII under one or more of the following legal bases:
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Processing is necessary for our legitimate interests;
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To perform the contract that we are about to enter with you (e.g., our Terms, available here, www.crossbowtx.com/terms/);
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To comply with a legal obligation; and/or
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With your consent to do so, which may be revoked at any time.
Under the GDPR, as a Data Subject you have certain rights. They are:
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The right to be informed. This is your right to be informed about what we are processing, why, and who else the data may be passed to.
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The right of access. This is your right to see what data about you is held by us.
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The right to rectification. This is the right to have your data corrected or amended if what is held is incorrect in some way.
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The right to be forgotten. This is the right to have your personal data to be deleted in the event that such data is no longer required for the purposes it was collected for, your consent for the processing of the data is withdrawn, or the data is being unlawfully processed.
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The right to restrict processing. This is the right to ask for a temporary halt to processing of your personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
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The right to data portability. This is the right to ask for your personal data to be provided to you in a structured, commonly used, and machine-readable format.
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The right to object. This is the right to object to further processing your personal data if such processing is inconsistent with the primary purposes for which it was collected.
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Right in relation to automated decision making and profiling. This is the right to not be subject to a decision based solely on automated processing. The Service does not engage in automated decision making or profiling.
You can find instructions for enforcing some of these rights elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about these rights, please contact us at contact@crossbowtx.com.
10. Children and Young People’s Information
We do not knowingly collect any information from any minors, and we comply with all applicable United States privacy laws including the GDPR, the USA’s Children's Online Privacy Protection Act (“COPPA”), and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC's website (www.ftc.gov) for more information. If you have concerns about our website, wish to find out if your child has accessed our services, or wish to remove your child's personal information from our servers, please contact us at contact@crossbowtx.com. Our website will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with COPPA. If you believe that your child under 13 has gained access to our website without your permission, please contact us at contact@crossbowtx.com.
11. Links to Other Websites
This website may provide links to other Crossbow and third-party websites as a service to our users. This Privacy Policy does not apply to those websites. Please check the privacy policies of these other websites to learn how they collect, use, store and share information that you may submit to them or that they collect.
12. Changes
We may occasionally update this Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about how we are helping to protect the personal information we collect. Your continued use of our website after the Effective Date, or any other form of legal acceptance, after an update to this Privacy Policy constitutes your agreement the updated terms of our Privacy Policy.
13. Contact Information
If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at contact@crossbowtx.com.
Copyright © Crossbow Therapeutics, Inc. All Rights Reserved. The Service is the property of Crossbow, and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.