Last Modified and Effective Date: June 24, 2020
1. Your privacy is important to us
3. Information Collected From and About You
The information we collect from you varies, depending on the way you use our Site, either by filling out a form, uploading information, applying for a specific job position, or otherwise supplying information to us. It is highly possible you may browse our Site without submitting any personal information, but where we require that you provide us with your personal information, we will indicate what information is required in order to provide you with the product or service you have requested. We collect several types of personal information from and about you when you use our Site, which may include your name, address, email address, telephone number, credit or debit card information when you request a product or service. We may also request information from you in order to learn more about and improve our products and services. We collect personal information such as your name, address, e-mail, phone number, demographic information, and military status when you apply for employment with us through this Site. In addition, we may collect information relating to your education and employment history when you submit that information as part of an employment application. Not all requested information is required, however, and we specifically indicate what information is required in order to submit your employment application. 3.1 Other Information We Collect Besides the information you choose to submit, our systems collect certain types of data automatically. This information gives us insight on how our Site is being used, as well as helps us understand how we may improve it in the future and does not necessarily individually identify you. We may collect information about your device, operating system, web browser, ISP, IP address, advertising identifiers, click activity, referring website, or location information, to better serve you as a customer (“Automatic Data Collection Tools”). We may also collect information through cookies or other similar tracking technology to provide you with a personalized buying experience, facilitate our marketing efforts, or analyze how we can best provide you targeted information or promotions. This typically entails automatically gathering data such as any of the content you view on our website.
4. Purposes and legal basis for the processing of personal data
Your Personal Data will be processed by Crown, as controller, provided that at least one legal ground exists for such processing in accordance with the applicable Privacy Laws. The purposes for which Crown will process your Personal Data and the relevant applicable legal bases are the following:
- To fulfill your requests, we may use your Personal Data to respond to your queries and provide you with the services and contents you have requested from us (e.g. through contact forms or application for job positions). This includes sending you administrative messages and other non-commercial information about Crown and the Site, including critical updates and notifications;
- When you have given your consent, we may use your Personal Data:
- to improve the Site and to enhance, customize, and personalize your experiences and communications with us, including analyzing your behavior and trends, through Automatic Data Collection Tools, to help us in ways that include identifying unused product features and understanding ways to better support the workflow of our users;
- if you are not a customer of Crown, we may deliver you promotional newsletter and commercial communications, e.g. via email, SMS or other automated means, regarding products and services different from those regulated herein;
- Based on our legitimate interest, we may process your Personal Data:
- to maintain the integrity of the Site and our network and address security issues;
- to combine the information collected from any source to create aggregated data (“Aggregated Data”) to provide or improve the Site and services and facilitate a more targeted, tailored user experience. Crown may use Aggregated Data, as long as such data no longer allows the re-identification of any individual, for its internal purposes, including, but not limited to, research and analysis purposes, to ascertain trends and security/privacy patterns, internal record keeping and reporting purposes, to perform statistical analyses, and for our other business purposes;
- if you are already a customer of Crown, we may deliver to you promotional newsletters and commercial communications regarding our Sites and services. You have the right to reject such communications upon the collection of your data or at any time thereafter;
- to investigate or take action regarding violations or suspected violations of applicable laws and to establish, exercise or defend legal claims.
- When it is necessary for us to comply with a legal obligation and in any of the special circumstances described in paragraph 5 below.
Examples of how we may use your information are below.
- Communicate with you about our products or services or respond to your requests for information
- Provide you with information about goods or services that may interest you
- Present more relevant display advertisements, and share promotional events
- Manage our product offerings, and assess the effectiveness of our marketing efforts
- Analyze and improve the functionality of our Site
- Improve our business and/or to better serve you
- Prevent, detect, or investigate security concerns, including fraud
- Comply with applicable laws, regulations, or industry requirements
- Fulfill any other purpose for which you provide it or consent
If you provide us your personal information in connection with an employment opportunity, we use that information to primarily fulfill your request to be considered for employment with us and to improve our Site. We may also use that information to contact you about a position for which you applied or another position which may interest you. We may also contact you about future employment opportunities with us. If you no longer wish to be considered for employment with us, please contact us through one of the methods below.
5. How and With Whom We Share Your Information
We may share your information for our business purposes, examples of which are below.
- We may share information with third parties if you give us consent or permission to share the information.
- We may share information with third parties who perform functions on our behalf, including support service providers, such as Site hosting, marketing analysis, email and postal delivery, product and service delivery, analytics services, or other functions. We share your Personal Data with third parties which provide services on our behalf to help with our business activities and that enter into appropriate data processing agreements with us. These agreements require, among other things, third parties to maintain suitable security measures to safeguard the confidentiality, security, and integrity of your Personal Data.
- We may share information in accordance with a business transaction. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, other business transaction, we may share information subject to confidentiality arrangements.
- We may share information to prevent, detect, or investigate security concerns, including fraud.
- We may share information to comply with applicable laws, regulations, or industry requirements.
- We may share your information with law enforcement if required by law or in order to prevent fraud or other potential wrongdoing.
- We may share your personal information with our business affiliates and/ or business partners so that they may provide you information about products and services that may interest you.
- We do not share your personal information with other non-affiliated third-party companies for those companies to market their services or products to you
- We may disclose or share your personal information in connection with an employment application to verify the information you provide
- We may share de-identified or aggregated information collected from our Site with our affiliates or third parties to improve our products and services or our Site or for any other business purpose.
6. Control Over and Access to Your Personal Information; Your rights
We enable you to have access to and control over the accuracy of your personal information. In relation to the processing of Personal Data covered by this Policy (i.e. when Crown acts as controller), you can at any time exercise your rights in accordance with the Privacy Laws, including:
- the right to access by asking us to provide you with information on how we process your Personal Data and to obtain copies of your Personal Data;
- the right to have incorrect Personal Data duly rectified; You can access and update your personal information at any time by contacting us via a method described under “Contact Us” below.
- provided for by the applicable Privacy Laws;
- the right to restrict the processing of your Personal Data, where applicable;
- the right to withdraw your consent at any time, in the event your Personal Data is processed based on consent, without affecting the lawfulness of processing based on consent before its withdrawal;
- the right to request portability of the data provided to us, i.e. receiving such data in a structured, commonly used and machine-readable format when the specific conditions for exerting such right are fulfilled
- the right to object to processing that we carry out in our legitimate interests (please see our processing activities listed in section 4 – “Purposes and legal bases of the processing of personal data” above);
- the right to lodge a complaint relating to the processing of your Personal Data with the competent data protection authority.
7. International data transfer
Your Personal Data may be transferred from any EU Member States to Crown’s servers located in the US only under the specific guarantees established by the Privacy Laws.
8. Data retention
We may retain and process your Personal Data for as long as you continue to access or use any Site and, in general, for the period necessary to achieve the purposes set out above. Where permitted by applicable laws, we will retain your Personal Data to comply with our legal obligations, resolve legal disputes and for enforcement of our agreements.
9. Use of “Cookies” and Other Technologies
A cookie is an element of data that a website can send to and store on your browser or device. A cookie is useful for having the browser remember specific information across several pages or between visits to a website.
11. Other Tracking Technologies
Other tracking technologies work like cookies by placing small elements of data on your device. Those include: Web Beacons or Clear gifs Web beacons, which are also known as clear gifs, are small graphic images or web programming code that may be included in our Site’s pages and can track the actions of the visitor on that Site page. Embedded Script An embedded script is a programming code that collects information about your interactions with the Site such as the links you click on. It is only active while you are on the Site and is deactivated or deleted thereafter.
13. Cookies used on the Site
14. Consent about cookies
15. Google Analytics
We use a tool called “Google Analytics” to collect information about use of this site across devices. This tool requires the user’s consent that can be collected through different techniques implemented on the Site in accordance with Privacy Laws. We have implemented the Remarketing and AdWords features of Google Analytics. The Remarketing feature allows us to serve you relevant advertising on third party websites if you have visited our Site, however accessed, but does not personally or directly identify you. AdWords allows us to manage our advertising and collect information about your visit to our Site.
16. Do Not Track
Third parties may collect information about you across different websites, including our Site. We do not currently utilize the capability to respond to web browser do not track signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of this information.
17. Will Your Personal Information Be Secure?
Crown recognizes and understands your concerns on the subject of safety and security regarding your personal information. We strive to employ reasonable measures to protect your information as well as the overall security of our Site. We also request that any third parties we are affiliated with, whom we may transfer your information to take the same or comparable steps to protect your information and security. With that said, it should be noted that even with such measures, no website is 100% secure. We cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
18. Leaving our Site and Outside Links
19. For Users in the European Economic Area AND SWITZERLAND
If you are located in the European Economic Area (EEA), we provide you the following information and notification of rights in accordance with the European Union’s General Data Protection Regulation (“GDPR”).
20. Crown as Data Processor
Crown obtains and processes Personal Data (as that term is defined by the GDPR) of those located in the EEA or Switzerland as a data Processor. We process Personal Data on behalf of our European Union business affiliate, and we process any such Personal Data only pursuant to the instructions of the business affiliate who is a data Controller. The data Controller determines how Personal Data will be utilized.
21. Crown’s Obligations as Data Processor
Crown implements appropriate technical and organizational measures to process Personal Data to meet the requirements of GDPR and ensure the protection of the rights of Data Subjects. Crown will not engage another processor in connection with the processing of Personal Data without specific authorization from the Controller and will inform the Controller of any intended changes concerning the addition or replacement of other processors. Crown’s processing of Personal Data will be governed by a contract that is binding on the processor and sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the Controller. The contract will contain all provisions required by the GDPR.
22. Contact Us