Privacy Policy

Effective date: December 13, 2018

Crossroads Eurasia LLC is a company registered in the United States that operates the https://www.crossroadseurasia.com website (“Website”) and the Crossroads Eurasia internship placement service (“Service”). In this document, Crossroads Eurasia LLC will sometimes be referred to as “we”.

This Privacy Policy is designed to help you understand everything you need to know about the what, why and how’s of our data gathering and processing operations, and what your legal rights are as an individual.

We hope you’ll take some time to read this document. If there’s anything in this policy you don’t understand or if you want to ask any questions, please feel free to contact us using the details below.

By using the Website or Service, you agree to the collection and use of information in accordance with this policy. 

Definitions
  • Personal Data. Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
  • Usage Data. Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Cookies. Cookies are small files stored on your device (computer or mobile device).
  • Data Controller. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
  • Data Processors (or Service Providers). Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
  • Data Subject (or User). Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Data collection and use

We collect several different types of information for various purposes, detailed below, to provide and improve our Website and Service.

Personal Data

We hold Personal Data on individuals who apply for and participate in our program, potential participants who contact us before applying for the program, past participants, and other individuals who have expressed an interest in our program. This Personal Data helps us recognize them when they re-engage with us. 

Personally data may include, but is not limited to: contact details such as name, addresses, telephone numbers, and email addresses. 

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may ask additional information from individuals who apply for and take part in our program. This information is collected for contractual and legal reasons, as well as to matching individuals with the most suitable placement and providing them with a safe and secure experience. It may include, but is not limited to:

  • Date and place of birth
  • Gender
  • Educational details
  • Next of kin and emergency contact information
  • Passport and visa details
  • CV/resume
  • Health information
  • Criminal record check

Usage Data

We may also collect information on how the Website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. 

Use of Data

Crossroads Eurasia LLC uses the collected data for various purposes:

  • To provide and maintain our Website or Service
  • To notify you about changes to our Website or Service
  • To allow you to participate in interactive features of our Website or Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Website or Service
  • To monitor the usage of our Website or Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and updates to our Service. 
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Crossroads Eurasia LLC legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Crossroads Eurasia LLC may process your Personal Data because:

  • We need the information in order to deliver on our contractual obligations to you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • For payment processing purposes
  • To comply with the law
Retention of Data

Crossroads Eurasia LLC will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Crossroads Eurasia LLC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

In order to achieve the above stated purposes for which we will process your personal data, we may need to share this information with various third-party organisations such as placement providers, host families, foreign authorities, accountants, insurance providers, travel agents, and technical resource providers.

In line with the above, your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

We will never share your personal data with third-parties that intend to use it for their own purposes like direct marketing.  

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, Crossroads Eurasia LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Crossroads Eurasia LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Crossroads Eurasia LLC
  • To prevent or investigate possible wrongdoing in connection with the Website or Service
  • To protect the personal safety of users of the Website or Service or the public
  • To protect against legal liability
Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Crossroads Eurasia LLC aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. To do so, please contact us.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Crossroads Eurasia LLC relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Payments

We may use third-party services for payment processing (e.g. payment processors). For this purpose, we work with PayPal / Braintree. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: info@crossroadseurasia.com

Questions?

About us

Address: 15 Guy Court

Rockville, MD 20850, USA

E-mail: info@crossroadseurasia.com

Web: www.CrossroadsEurasia.com

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