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Privacy Policy



LEARN MORE ABOUT CRYSTAL'S PRIVACY POLICY BELOW.


OVERVIEW

Your privacy and security are important to Crystal Project, Inc. (“Crystal”). As
a result, we have developed strict internal processes developed to maintain your
data in a secure environment.

For purposes of this Privacy Policy, “Personal Data” means any information
relating to an identified or identifiable natural person including name,
identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, cultural or social identity of
that natural person. Personal Data may include Sensitive Information; and
“Subscription Service” means the particular edition and elements of Crystal
Project's Crystal applications, tools and platform subscribed to by Customer
under an Order Form, and developed, operated, and maintained by Crystal Project,
accessible via www.crystalknows.com or another designated URL, and any ancillary
online or offline products and services provided to Customer by Crystal Project,
to which Customer is being granted access pursuant to this Agreement and an
Order Form. The Subscription Service includes the Crystal Project Content, and
does not include training services, consulting services, and Third-Party
Products. All other terms used in this Privacy Policy that are not otherwise
defined in this Privacy Policy have the meanings ascribed to them in the Terms
of Service (available here: https://www.crystalknows.com/tos).

Crystal is a platform where people can fill out personality tests and share
their personality profile. We also offer tools that analyze public data to
provide personality predictions, based on the person's writing style, job
experience, and other publicly available data.

The purpose of this Privacy Policy is to explain (1) what data we collect from
you, (2) how we collect, use, process, store, and share your data, and (3) who
we share your data with.


DATA COLLECTED

We collect and use the following information to provide, improve and protect our
Services:


PERSONAL INFORMATION

We may collect, and associate with your account, information like your name,
email address, phone number, and billing and payment information.


CONNECTED ACCOUNTS

When you use Crystal and the Subscription Services, you may grant us access to
third-party applications like Gmail or LinkedIn (such applications, the
“Connected Accounts”). We query, store, process, and transmit information
related to your Connected Accounts in connection with providing the Subscription
Services. If you decide to connect your Google Calendar or Outlook Calendar to
receive meeting insights, you grant Crystal permission to read your calendar
events for the purpose of generating one-time or recurring meeting reports, with
personalized insights for communicating effectively with each attendee. We do
not store past meetings on our servers.


USAGE

We collect information from and about the devices you use to access the
Subscription Services. This includes things like IP addresses, the type of
browser and device you use, the languages used by your browser or device, the
web page you visited before coming to our sites, and identifiers associated with
your devices, such as location. Your devices (depending on their settings) may
also transmit location information to the Subscription Services. Most mobile
devices allow you to turn off location services.


COOKIES

We use cookies and similar technology to automatically collect data from you to
provide, improve, protect and promote our Subscription Services. For example,
cookies help us with things like remembering your username for your next visit,
understanding how you are interacting with our Subscription Services, and
improving them based on that information. You can set your browser to not accept
cookies, but this may limit your ability to use the Subscription Services.


PUBLICLY AVAILABLE INFORMATION

The Subscription Services may allow you to connect and share your actions,
comments, contacts, and information publicly with friends, relatives, and
members of your professional network. Please be mindful of your personal privacy
needs and the privacy needs of others as you choose whom to connect with and
what to share and make public. We cannot control the privacy or security of
information you choose to make public or share with others. Please contact those
sites and services directly if you want to learn about their privacy practices.

Additionally, certain Subscription Services utilize publicly available sources
of information to provide assumptions and determinations about third parties.
Because certain of our Subscription Services provide predictive insights to
Customers or Users about third parties who may be unaware that our Subscription
Service is analyzing publicly available information about them, it is of utmost
importance that we take appropriate measures to protect such third parties’
rights and freedoms. To that end, we ensure that our Services only utilize
information that such third party has made publicly available and for which such
third party does not have a reasonable expectation of privacy, that only
information is stored that is necessary to provide the Subscription Services to
our Customers and Users, that and that only our assumptions and determinations
based on that data, as opposed to the specific data itself, is disclosed to our
Customers and Users.


DELETION/CHANGES/UPDATES

If you delete your Crystal account, we will delete all of your personal
information and private data. Please note: (1) there might be some latency in
deleting this information from our servers and back-up storage; and (2) we may
retain this information if necessary to comply with our legal obligations,
resolve disputes, or enforce our agreements. You have the right to request, at
any time, Crystal to delete, update, change, or alter your Crystal account and
any other information Crystal may have collected from or about you. To delete,
update, change, or alter your account or any information that Crystal may have
collected from or about you, contact us at hello@crystalknows.com.


HOW WE USE THE DATA AND INFORMATION WE COLLECT

We use your data collected through the Subscription Services for the purposes
described in this Privacy Policy. For example, we may use your data to:

 * Offer you or provide you with other products and services through the
   Subscription Services;
 * Operate and improve our Subscription Services, our applications, and other
   products and services;
 * Make assumptions and/or determinations about you or members of your network.
   In connection with such collection we may use automated processing
   techniques, in combination with manual decision making, to make certain
   determinations about you and your preferences. If you have any questions
   pertaining to our use of automated processing techniques, please contact us
   at hello@crystalknows.com.
 * Display relevant advertising;
 * Respond to your comments and questions and to provide customer service
 * Send you information relating to our products and services, including
   technical notices, updates, security alerts, and support and administrative
   messages;
 * Communicate with you about products and services offered by us, our
   affiliates, and certain of our select partners;
 * Authenticate credit care or debit card account information; and
 * Protect, investigate, and deter against fraudulent, unauthorized, or illegal
   activity.

By providing you mobile phone number and/or email address, you expressly consent
to receive direct dial calls, autodialed and prerecorded calls, text messages,
and or email messages from us regarding our products and services.


SECURITY

We employ appropriate technical and organizational measures to help protect your
Personal Data and any other information that Crystal collects from or about you.
We have team members dedicated to keeping your information secure and testing
for vulnerabilities. We also continue to work on features to keep your
information safe. However, while we attempt to protect all information you send
to us and we maintain to provide Crystal and the Subscription Services to you,
please note that no connection through the Internet and data storage facilities
are entirely immune from unauthorized hacking and access, and so you should use
Crystal and the Subscription Services with discretion. You can help us by
protecting your username and password and using Crystal and the Subscription
Services only through secure networks.


SHARING

Your private data will be kept secure and private as detailed above. It may need
to be processed by other people or third party purposes. We will only share such
information for the following purposes.


OTHERS WORKING FOR CRYSTAL

For quality and technical support purposes, select Crystal employees may review
your data. These employees will access your information only to perform tasks on
behalf of and in compliance with this Privacy Policy. Crystal employees with
access to your data are bound to Crystal by obligations of confidentiality
sufficient to ensure compliance with the requirements set forth in this Privacy
Policy.


SERVICE PROVIDERS

Crystal uses trusted third party cloud service providers to help us provide,
improve, protect, and promote our Subscription Services (for example, Google
Analytics uses cookies to help us understand how users interact with
cyrstalknows.com). These third parties will access your information only to
perform tasks on our behalf and in compliance with this Privacy Policy.


PAYMENT AND BILLING

To use certain Subscription Services, we may require credit or debit card
account information. By submitting your credit or debit card account information
through the Subscription Services, you expressly consent to the sharing of such
information with third-party payment processors for the sole purpose of billing
you for the Subscription Services.


LEGAL

We may disclose your information to third parties if we determine that such
disclosure is reasonably necessary to (a) comply with the law; (b) protect any
person from death or serious bodily injury; (c) prevent fraud or abuse of
Crystal or our users; or (d) protect Crystal’s property rights.


CHANGE OF CONTROL

If we are involved in a reorganization, merger, acquisition or sale of our
assets, your information may be transferred as part of that deal. We will notify
you (for example, via a message to the email address associated with your
account) of any such deal and outline your choices in that event. We may revise
this Privacy Policy from time to time, and will post the most current version on
our website. If a revision meaningfully reduces your rights, we will notify you.
We will comply with applicable laws and regulations to the extent changes to
this Privacy Policy require your consent.



PRIVACY POLICY FOR UK AND EUROPEAN RESIDENTS




1.    INTRODUCTION  

WHO WE ARE

This is the Privacy Policy of Crystal Project, Inc. incorporated in Oregon,
United States of America and having its principal place of business at 9450 SW
Gemini Dr PMB 72836, Beaverton 97008, Oregon and any entity which directly or
indirectly controls, is controlled by, or is under common control with Crystal
Project, Inc.

Purpose of this Privacy Policy

The Privacy Policy will inform you as to how we look after your Personal Data
and tell you about your privacy rights and how the law protects you. Please also
use the Glossary to understand the meaning of some of the terms used in this
Privacy Policy.

It is important that you read this Privacy Policy together with any other
privacy notice or fair processing notice we may provide on specific occasions
when we are collecting or processing Personal Data about you so that you are
fully aware of how and why we are using your Personal Data. This Privacy Policy
supplements the other notices and is not intended to override them.

WHEN THIS PRIVACY POLICY APPLIES

This Privacy Policy applies if you are a resident in the UK or Europe and we are
acting as a controller of your Personal Data as determined by the EU & UK Data
Protection Legislation.

WHEN WE ACT AS A CONTROLLER

Controllers determine how and why Personal Data is processed, whereas processors
process Personal Data on behalf of, and under the instructions of, the
controller. In most instances, our Customers are controllers of the Personal
Data processed by our Crystal platform for assessments and predictions and we
act as a processor on behalf of our Customers in providing the Subscription
Services. When we collect and use your Personal Data in the ways set out in this
Privacy Policy, we are the controller.  

OUR CONTACT DETAILS

If you have any queries in relation to this Privacy Policy or how we use your
Personal Data then please feel free to contact us at: hello@crystalknows.com.

HOW TO USE THIS PRIVACY POLICY

The General Section (section 2) of the Privacy Policy applies to the use of all
Personal Data processed by us in our capacity as a controller. There are then
specific section(s) (sections 3 to 7) that will or will not apply to you
depending on how you interact with us. Please read the relevant sections that
apply to you:

•    Section 3: Customer Section: When our Customers are individuals (rather
than corporate bodies).  

•    Section 4: User Section: If you have a User account for Crystal.

•    Section 5: Personality Profile Section: If Crystal Project has collected a
personality profile for you via the Crystal platform for its own purposes. 

•    Section 6: Website Section: If you visit our website and/or contact us
through our website. 

•    Section 7: Marketing Section: If you receive marketing communications or
updates from us.

GLOSSARY

References to Personal Data means any information about an individual from which
that person can be identified. It does not include data where the identity has
been removed (anonymous data). 

controller, processor, data subject, supervisory authority and processing and
appropriate technical and organisational measures have the meanings given to
them in the EU & UK Data Protection Legislation.

EU & UK Data Protection Legislation means (i) Regulation 2016/679 of the
European Parliament and of the Council on the protection of natural persons with
regard to the Processing of Personal Data and on the free movement of such data
(General Data Protection Regulation) ("GDPR") and (ii) the United Kingdom’s Data
Protection Act 2018 and the GDPR as it forms part of the law of the United
Kingdom (“UK GDPR”), including by virtue of Section 3 of the European Union
(withdrawal) Act 2018, as any of the forgoing may be amended from time to time.
 

All other terms used in this Privacy Policy that are not otherwise defined in
this Privacy Policy have the meanings ascribed to them in the Terms of Service
(available here: https://www.crystalknows.com/tos). 

Changes to this Privacy Policy 

We may update this Privacy Policy from time to time. It was last updated on
December 2022. We may revise this Privacy Policy at any time by amending this
page. You are expected to visit this page from time to time to note any changes
we make, as they affect you.


2.    GENERAL SECTION

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights in relation to your Personal Data
under the EU & UK Data Protection Legislation.  

You have the right to: 

•    Request access to your Personal Data (commonly known as a "data subject
access request"). This enables you to receive a copy of Personal Data we hold
about you and to check that we are lawfully processing it. 

•    Request correction of the Personal Data that we hold about you. This
enables you to have any incomplete or inaccurate data we hold about you
corrected, though we may need to verify the accuracy of the new data you provide
to us. 

•    Request erasure of your Personal Data. This enables you to ask us to delete
or remove Personal Data where there is no good reason for us continuing to
process it. You also have the right to ask us to delete or remove your Personal
Data where you have successfully exercised your right to object to processing
(see below), where we may have processed your information unlawfully or where we
are required to erase your Personal Data to comply with local law. Note,
however, that we may not always be able to comply with your request of erasure
for specific legal reasons which will be notified to you, if applicable, at the
time of your request.  

•    Object to processing of your Personal Data where we are relying on a
legitimate interest (or those of a third party) and there is something about
your particular situation which makes you want to object to processing on this
ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your Personal Data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
freedoms. 

•    Request restriction of processing of your Personal Data. This enables you
to ask us to suspend the processing of your Personal Data in the following
scenarios: (a) if you want us to establish the data's accuracy; (b) where our
use of the data is unlawful but you do not want us to erase it; (c) where you
need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims; or (d) you have objected to our use
of your data but we need to verify whether we have overriding legitimate grounds
to use it.  

•    Request the transfer of your Personal Data to you or to a third party. We
will provide to you, or a third party you have chosen, your Personal Data in a
structured, commonly used, machine-readable format. Note that this right only
applies to automated information which you initially provided consent for us to
use or where we used the information to perform a contract with you. 
 
•    Withdraw consent at any time where we are relying on consent to process
your Personal Data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We
will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us at
hello@crystalknows.com.  

You will not usually have to pay a fee to access your Personal Data (or to
exercise any of the other rights). However, we may charge a reasonable fee if
your request is clearly unfounded, repetitive or excessive or if you ask for
multiple copies of your Personal Data. Alternatively, we may refuse to comply
with your request in these circumstances. 

We may need to request specific information from you to help us confirm your
identity and ensure your right to access your Personal Data (or to exercise any
of your other rights). This is a security measure to ensure that Personal Data
is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to
speed up our response. 

We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.  

COMPLAINTS

You have the right to make a complaint at any time to your relevant supervisory
authority. We would, however, appreciate the chance to deal with your concerns
before you approach the supervisory authority so please contact us in the first
instance.  

SHARING

We share your Personal Data with others in certain circumstances as detailed
below.

We contract with third party service providers and suppliers to deliver certain
services, for example third party payment processors, hosting providers, digital
marketing providers, etc. We only permit them to process your Personal Data for
specified purposes and in accordance with our instructions. Our service
providers change from time to time. If you require any further information on
our service providers, you may request this by contacting us, subject to our
obligations of confidentiality.  

We will also provide your Personal Data to third parties where there is a legal
obligation to do so, for example to regulators, government departments, law
enforcement authorities, tax authorities and any relevant dispute resolution
body or the courts.

We may also provide your Personal Data to third parties to whom we may consider
or choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. 

We will provide information about you to any other person who is authorised to
act on your behalf.

RETENTION

We will only retain Personal Data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.  

To determine the appropriate retention period for Personal Data, we consider the
amount, nature, and sensitivity of the Personal Data, the potential risk of harm
from unauthorised use or disclosure of the Personal Data, the purposes for which
we process the Personal Data and whether we can achieve those purposes through
other means, and the applicable legal requirements. 

In some circumstances we may anonymise Personal Data (so that it can no longer
be associated with you) for research or statistical purposes in which case we
may use this information indefinitely without further notice to you.  

Where applicable, we have discussed specific retention periods under the
specific sections.

INTERNATIONAL TRANSFERS  

We may transfer data outside the UK or the EEA. Crystal Project is a US based
entity and currently uses data centers based out of the UK and the EEA, and
which are located in the US.  We will take reasonable steps to ensure that the
transfer is to a country covered by a decision of the European Commission or the
UK Information Commissioner or is otherwise made in circumstances where we have
put appropriate safeguards in place to protect your Personal Data in accordance
with the EU & UK Data Protection Legislation.

SECURITY

We employ appropriate technical and organizational measures to help protect your
Personal Data. We have team members dedicated to keeping your information secure
and testing for vulnerabilities. We also continue to work on features to keep
your information safe. However, while we attempt to protect all Personal Data,
please note that no connection through the Internet and data storage facilities
are entirely immune from unauthorized hacking and access, and so you should use
Crystal and the Subscription Services with discretion. You can help us by
protecting your username and password and using Crystal and the Subscription
Services only through secure networks.

LAWFUL PROCESSING

We will only use your Personal Data when the law allows us to. Most commonly, we
will use your Personal Data in the following circumstances: 

•    Where we need to perform the Agreement we are about to enter into or have
entered into with you. 
•    Where it is necessary for our legitimate interests (or those of a third
party) and your interests and fundamental rights do not override those
interests. 
•    Where we need to comply with a legal or regulatory obligation. 
•    Where you have consented to us using your Personal Data for specific
purposes.  

In the specific sections we have provide more information about the types of
lawful basis that we will rely on to process your Personal Data.

CHANGE OF PURPOSE  

We will only use your Personal Data for the purposes for which we collected it,
unless we reasonably consider that we need to use it for another reason and that
reason is compatible with the original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please contact us. 

If we need to use your Personal Data for an unrelated purpose, we will notify
you and we will explain the legal basis which allows us to do so. 

Please note that we may process your Personal Data without your knowledge or
consent, in compliance with the above rules, where this is required or permitted
by law.

NOT INTENDED FOR CHILDREN

The Crystal platform and our website is not intended for children and we do not
knowingly collect Personal Data relating to children.

CHANGES TO PERSONAL DATA AND YOUR DUTY TO INFORM US OF CHANGES

It is important that the Personal Data we hold about you is accurate and
current. Please keep us informed if your Personal Data changes during your
relationship with us.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect Personal Data by law, or under the terms of the
Agreement and you fail to provide that Personal Data when requested, we may not
be able to perform the Agreement we have or are trying to enter into with you.

COOKIES AND SIMILAR TECHNOLOGY

In common with many other website operators, we may use standard technology
called 'cookies' on our website and the Crystal platform. Cookies are small text
files that are placed on your devices. They are widely used to make websites and
platforms work, or work more efficiently, as well as to provide information to
the owner of platform.

Generally our cookies do not collect any information which identifies you and
therefore the information collected is not deemed Personal Data. Our cookies do
collect Personal Data in the following specific scenarios
     

Name of cookie

Purpose    

Duration    

Third party provider

Hubspot Tracking Pixel

  User analytics  

[e.g. how long the cookie sits on the users device]

HubSpot – the provider of our marketing automation system 

Rudderstack Tracking Pixel     

User analytics   

[e.g. how long the cookie sits on the users device]    

Rudderstack – the provider of our user analytics platform


3.    CUSTOMER SECTION

If you are a Customer of Crystal Project in your capacity as an individual,
rather than a corporate body, please read this section. Information related to
corporate Customers is not Personal Data and so this Privacy Policy does not
apply to that type of Customer.

HOW IS YOUR PERSONAL DATA COLLECTED?

We generally collect Personal Data directly from our Customer.  

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

In general terms, we use your Personal Data to allow us to perform the
Subscription Services and to comply with the Agreement that we have with you. 

Purpose/Activity

Types of Personal Data

Lawful basis for processing including basis of legitimate interest

To register you as a new Customer

Email address

Necessary for the performance of the Agreement that we have with you 

Respond to your comments and questions and to provide customer service

Email address

(a) Necessary for the performance of the Agreement that we have with you (b)
Necessary for our legitimate interests (to respond to enquiries)

To improve our Subscription Services, our applications, and other products and
services

Email address

Necessary for our legitimate interest of improving our business

Correspond with you regarding the Subscription Services, including technical
notices, updates, security alerts, and support and administrative messages this
is necessary to perform the Agreement that we have with you, or is in our and
your legitimate interests to ensure that we have good communication regarding
the Subscription Services

Email address

(a) Necessary for the performance of the Agreement that we have with you (b)
Necessary for our legitimate interests (to ensure that we have good
communication regarding the Subscription Services)

Authenticate credit card or debit card account information

Credit card information

(a) Necessary for the performance of the Agreement that we have with you (b)
Necessary for our legitimate interests (to recover debts due to us)

Protect, investigate, and deter against fraudulent, unauthorized

Email address

(a) Necessary for the performance of the Agreement that we have with you (b)
Necessary for our legitimate interests (to identify fraud and to recover debts
due to us)

When you use Crystal and the Subscription Services, you may grant us access to
third-party applications like Gmail, Outlook or LinkedIn (such applications, the
“Connected Accounts”). 

The Crystal platform does not have access to email content with Connected
Accounts, and the only information that it transmitted from such Connected
Accounts to Crystal Project is the email address of Users for authentication
purposes as required to provide the Subscription Services.

Email address

(a) Necessary for the performance of the Agreement that we have with you (b)
Necessary for our legitimate interests (authentication)

 


4.    USER SECTION

If you have a User account for Crystal please read this section.

HOW IS YOUR PERSONAL DATA COLLECTED?

We generally collect Personal Data of Users directly from the User or indirectly
from our Customer.  

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/Activity

Type of Personal Data

Lawful basis for processing including basis of legitimate interest

To allow us to manage and maintain User accounts

Email address
Name
Company
Job Title

Necessary for our legitimate interests (and the legitimate interests of Users
and Customers to ensure that User accounts are appropriately managed).

When you use Crystal and the Subscription Services, you may grant us access to
third-party applications like Gmail, Outlook or LinkedIn (such applications, the
“Connected Accounts”). 

The Crystal platform does not have access to email content with Connected
Accounts, and the only information that it transmitted from such Connected
Accounts to Crystal Project is the email address of Users for authentication
purposes as required to provide the Subscription Services.  

The Crystal platform's use and transfer to any other app of information received
from Google APIs will adhere to Google API Services User Data Policy, including
the Limited Use requirements. 

 

Email address

Necessary for our legitimate interests (authentication)

RETENTION

If you delete your Crystal User account, we will delete all of your Personal
Data as stored on the account. Please note: (1) there might be some latency in
deleting this information from our servers and back-up storage; and (2) we may
retain this information if necessary to comply with our legal obligations,
resolve disputes, or enforce our agreements. 

To request that we delete, update, change, or alter your account or any
information that Crystal may have collected from or about you, contact us at
hello@crystalknows.com.


5.    PERSONALITY PROFILE SECTION

Please read this section if: (a) you are a User who has chosen to publicly
publish their own ‘verified’ personality profiles, or (b) you have completed a
personality assessment sent to you by a Crystal Project employee, or (c) Crystal
Project has generated a personality prediction for you.

HOW IS YOUR PERSONAL DATA COLLECTED?

The Crystal platform allows our users to run personality assessments by sending
email invitations and unique links to any third party selected by the user. The
assessments generally only process Personal Data provided by the assessment
respondents themselves apart from the email address or other identifier to which
the assessment results are linked.

The Crystal platform also provides functionality for our users to generate
personality predictions for individuals based on text analysis. The predictions
mainly use and analyse Personal Data that is of a corporate, business or
professional nature (e.g. the types of information available on a LinkedIn
profile) rather than Personal Data that is of a sensitive nature or related to
the prediction respondent’s private life outside of their profession, and only
process Personal Data that is publicly available or uploaded by the user:

•    Publicly available text samples - on websites with available text samples
(including job titles, experiences, bios, etc), Crystal uses a predictive model
to immediately generate a predicted profile without sending any of the text
samples to Crystal platform servers. Crystal Project does directly not scrape or
copy profiles from any website or social network

•    Uploaded Text Samples - users may upload a text sample in the form of a raw
text or PDF file in order to generate a predicted profile. In this case, the
text sample is sent to Crystal platform servers for back-end analysis, but none
of the original text sample is.

•    Sometimes we may supplement samples with Back End Data. Back End Data is
aggregated and returned via API by providers like People Data Labs
(https://docs.peopledatalabs.com/docs/data-sources) and CoreSignal
(https://coresignal.com/data-sources). Our current provider used for data
collection is People Data Labs.  You can read more about People Data Labs’ data
sourcing here: https://docs.peopledatalabs.com/docs/data-sources. The link
explains that People Data Labs uses public data sources (e.g. open-sourced
datasets, publicly available data, governmental public records) and validates
the source and accuracy of all data before adding it to its data-sets.  

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/Activity

Type of Personal Data

Lawful basis for processing including basis of legitimate interest

Enhancing the skills and effectiveness of personnel and teams e.g. team
collaboration, leadership development and talent acquisition

Personality profile  

The detail in the personality profiles is a broadly described cohort by
reference to a generic personality type with reference to 16 generic personality
types. 

Necessary for our legitimate interests (to enhance personnel and teams).

Enhancing sales, business opportunities and business growth through more
effective marketing and customer success

Personality profile  

The detail in the personality profiles is a broadly described cohort by
reference to a generic personality type with reference to 16 generic personality
types.

Necessary for our legitimate interests (to develop our business).

Enhancing other key business functions that rely on communication skills

Personality profile  

The detail in the personality profiles is a broadly described cohort by
reference to a generic personality type with reference to 16 generic personality
types.

Necessary for our legitimate interests (to develop our business and increase
communication effectiveness).

 

RETENTION

For as long as the User retains their User account which holds the personality
profile.


6.    WEBSITE SECTION

If you visit our website and/or contact us through our website then please read
this section.

HOW IS YOUR PERSONAL DATA COLLECTED?

We generally collect Personal Data directly from the website user.  

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/Activity

Type of Personal Data

Lawful basis for processing including basis of legitimate interest

To respond to an enquiry made by you or your company

Your identity, your contact information and your query

Necessary for our legitimate interests (to respond to your enquiry)


THIRD-PARTY LINKS

Our website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every
website you visit.


7.    MARKETING SECTION

If you interact with us as a Customer, User or enquirer via our website then you
may receive marketing or advertising materials from us, our affiliates or our
selected partners. This is necessary for our legitimate interest of marketing
and growing our business or we may have obtained your consent.

We may form a view on what we think you may want or need, or what may be of
interest to you. This is how we decide which products, services and offers may
be relevant for you (we call this marketing).  

You can ask us to stop sending you marketing messages by contacting us or by
following any opt-out links on any marketing message sent to you.  

Where you opt out of receiving these marketing messages, this will not apply to
Personal Data provided to us as a result of a service purchase, service
experience or other transactions.



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