Cross Country Communications Corp. ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use the HoneyCloud™ platform and related services (collectively, the "Service"). Please read this Privacy Policy carefully. By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

1. INFORMATION WE COLLECT

We collect information in several ways depending on how you interact with our Service:

1.1. Information You Provide Directly

Data Category Examples Purpose
Account Information Name, email address, company name, phone number, billing address Account creation, communication, billing
Payment Information Credit card number, billing address, payment history Payment processing (handled by Stripe)
Company Information Business name, logo, branding preferences, SMTP settings White-label customization, email delivery
User Information Names, email addresses, roles of your team members User management, access control
Communications Support requests, feedback, correspondence Customer support, service improvement

1.2. Information Collected Automatically

Data Category Examples Purpose
Usage Data Features accessed, actions taken, time spent, click patterns Service improvement, analytics
Device Information IP address, browser type, operating system, device identifiers Security, troubleshooting, optimization
Log Data Access times, pages viewed, error logs, referring URLs Security monitoring, debugging
Location Data Approximate location based on IP address Security, compliance, localization

1.3. Security and Threat Data

Data Category Examples Purpose
Attack Data Attacker IP addresses, attack types, timestamps, protocols used Threat detection, alerting, reporting
Appliance Data Serial numbers, IP addresses, software versions, health status Device management, support
Threat Intelligence Aggregated attack patterns, malicious IP lists, threat indicators Security enhancement, optional sharing
Network Data Connection logs, honeytrap interactions, captured credentials (attacker-submitted) Threat analysis, forensics

2. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

2.1. Service Provision and Operations

2.2. Service Improvement

2.3. Security and Protection

2.4. Communications

2.5. Legal Compliance

3. LEGAL BASIS FOR PROCESSING (GDPR)

For users in the European Economic Area (EEA), we process personal data based on the following legal grounds:

4. THREAT INTELLIGENCE SHARING

4.1. How Threat Sharing Works

The HoneyCloud™ platform offers optional threat intelligence sharing features that enable anonymized threat data to be shared among platform participants. This collective intelligence helps all participants improve their security posture.

4.2. What Data May Be Shared

4.3. What Data Is Never Shared

4.4. Your Control

Participation in threat sharing is entirely optional. You can configure your preferences at any time in your account settings:

5. DATA SHARING AND DISCLOSURE

5.1. Service Providers

We may share your information with third-party service providers who perform services on our behalf:

Provider Type Purpose Data Shared
Cloud Infrastructure (AWS) Hosting, storage, compute All platform data (encrypted)
Payment Processor (Stripe) Payment processing Billing information
Email Service Transactional emails, alerts Email addresses, notification content
Analytics Usage analytics, improvement Anonymized usage data

5.2. Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including:

5.3. Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change and any choices you may have regarding your information.

5.4. With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

6. DATA RETENTION

6.1. Retention Periods

Data Type Retention Period
Account Information Duration of account + 30 days after termination
Attack/Threat Data Configurable per plan (default 90 days)
Usage Logs 12 months
Payment Records 7 years (legal requirement)
Support Communications 3 years

6.2. Data Deletion

Upon termination of your account, you may request export of your data within thirty (30) days. After this period, we will delete or anonymize your personal data, except where retention is required by law or for legitimate business purposes.

7. DATA SECURITY

7.1. Security Measures

We implement comprehensive technical and organizational measures to protect your information:

7.2. Security Limitations

While we strive to protect your information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide information at your own risk.

7.3. Breach Notification

In the event of a data breach that affects your personal information, we will notify you and applicable regulatory authorities as required by law, typically within 72 hours of becoming aware of the breach.

8. YOUR RIGHTS AND CHOICES

Access and Portability

You have the right to request a copy of the personal data we hold about you in a structured, commonly used, machine-readable format.

Correction

You have the right to request correction of inaccurate or incomplete personal data.

Deletion

You have the right to request deletion of your personal data, subject to certain legal exceptions.

Restriction

You have the right to request restriction of processing of your personal data in certain circumstances.

Objection

You have the right to object to processing of your personal data based on legitimate interests.

Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time.

To exercise any of these rights, please contact us at support@crosscountrycomm.com. We will respond to your request within thirty (30) days.

9. COOKIES AND TRACKING

9.1. Cookies We Use

Cookie Type Purpose Duration
Essential/Session Authentication, security, session management Session
Preferences Remember your settings and preferences 1 year
Security Fraud prevention, CSRF protection Session

9.2. Third-Party Tracking

We do not use third-party advertising cookies or tracking pixels. We do not sell your data to advertisers or data brokers.

9.3. Do Not Track

We currently do not respond to "Do Not Track" browser signals as there is no industry standard for compliance.

10. INTERNATIONAL DATA TRANSFERS

10.1. Transfer Locations

Your information may be transferred to and processed in the United States, where our servers and company are located. By using the Service, you consent to this transfer.

10.2. Safeguards

For users in the EEA, UK, or other jurisdictions with data transfer restrictions, we implement appropriate safeguards including:

11. CHILDREN'S PRIVACY

The Service is intended for business use and is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately, and we will take steps to delete such information.

12. CALIFORNIA PRIVACY RIGHTS (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

To exercise these rights, contact us at support@crosscountrycomm.com or call (903) 885-2900.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:

Your continued use of the Service after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

14. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Cross Country Communications Corp.
Attn: Privacy Officer
Sulphur Springs, Texas 75482
United States of America

Email: support@crosscountrycomm.com
Phone: (903) 885-2900

For EEA residents, you also have the right to lodge a complaint with your local supervisory authority if you believe your data protection rights have been violated.

© 2025-2040 Cross Country Communications Corp. All rights reserved.
HoneyCloud™ and HoneyTrap Pro™ are trademarks of Cross Country Communications Corp.