Borderless Incorporated respects your privacy. Borderless Incorporated and its affiliates (“CrossHelmet” or the “Company”) offer a fully-featured motorcycle helmet, as well as through its software, mapping, GPS navigation, and community based services to users of www.crosshelmet.com (the “Website”) and/or users of CrossHelmet’s mobile applications (the “Application”) (collectively referred to as the “Services”). When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
User Accounts & Accessing the Services
Information that is being collected
Why CrossHelmet collects data
Sharing your information
Integration with social networks
Integration with other third party services
Controlling your personal information
How CrossHelmet retains data we collect
How does CrossHelmet use aggregated information
Compliance & cooperation with regulators
To use our Services you must be 16 years of age or older. If you are under 16, you may not download or use the Services.
Contact CrossHelmet – Privacy concerns reports
User Accounts & Accessing the Services
When you set up a CrossHelmet username and password in the Application:
CrossHelmet will link all of your information with your Account and that username. This includes information received from all mobile devices running the Application on which you have chosen to sign in using your username and password;
With the exception described in the bullet below and as explained in the section “Visibility” below, your Account and information associated
with your Account will be visible only to CrossHelmet; and When using the Application, your approximate location and other information you
may choose to contribute will be visible to other users associated with that username.
CrossHelmet may also establish and require from time to time additional or different means of identification and authentication for logging in
and accessing the Services or for accessing certain features or designated sections of the Services.
Your login details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your login details to someone else. You must maintain your login details in absolute confidentiality and avoid disclosing them to others. Make sure that you change your password frequently and at least once every six months.
Information that is being collected
We want you to understand the types of information we collect as you use our services.
CrossHelmet collects information to provide better services to all its users – from figuring out optimal routing and showing you relevant riding information while using CrossHelmet. The information CrossHelmet collects, and how that information is used, depends on how you choose to use our services.
Information you create or provide to us:
Account Information: information required when setting up a username you have chosen, such as your name and gender. Bear in mind that false, incorrect, or out-dated information may impair CrossHelmet’s ability to provide you with the Services and to contact you when necessary. CrossHelmet will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to set up a username; and/or
Information that you choose to share with CrossHelmet: information that you choose to share with CrossHelmet, including a username you have chosen, reports associated with your username, phone number, “home” or “work”, destinations you may travel to, search queries, and files you have uploaded to the service, including voice and audio files, if applicable.
Communication which you choose to conduct through the CrossHelmet Services: if you choose to use CrossHelmet to communicate with other CrossHelmet users or third parties through the CrossHelmet Services, such as chat messages or group talk on the CrossHelmet platform. We may also collect information when you exchange communication with CrossHelmet, for example, if you submit a request, contact CrossHelmet’s support team, or report a violation to the abuse team.
Information from your social networks which you choose to connect to your CrossHelmet Account: you may choose to connect your CrossHelmet Account to your social network account(s). If you choose to do so, you may choose to share with CrossHelmet and/or other users information from your social network accounts, such as your Facebook profile photo or other personal information shared by you. For more information see Integration with social networks, below.
“Add Contacts feature”: if you use the “Add Contacts” feature, CrossHelmet will collect: _ Periodically, CrossHelmet will collect all of the phone numbers which are stored on your device’s phone contacts book. With regards to the “suggested friends” feature we only collect numbers in a form which is anonymous to CrossHelmet; This information will be used to help us find and create a list of other CrossHelmet users who you may know and with whom you may wish to connect. Note that we will not collect names, addresses or other information from your device’s phone contacts book, however some of this information may be saved locally on your device and may be used within searches for your friend’s name or address within the Services. and/or _ Your phone number. Your phone number will be used to verify your account and as part of the “find friends” feature , if applicable, to help find and create a list of other CrossHelmet users who you may know and with whom you may wish to connect.
You may also provide additional information that will be used to personalize the Services and enhance your experience with the Services. For example, if you provide us with your “home” and “work” information, we may provide you with what we think is the preferred route between those locations.
Information we collect as you use our services
We collect information about your activity in the Services, which we use to provide you with the Services of CrossHelmet, including features which are meant to personalize your experience. This includes things like notifying you about weather and riding conditions to improve your riding experience. The activity information we collect may include:
-Detailed location, travel and route information. Location and route information is collected for example in the form of GPS signals (combined with a time-stamp) and other information sent by your mobile device on which the Application is installed and activated. This location and route information is saved to a route history of all of the journeys you have made while using the Application. We may collect information about your location and travel (or lack thereof) also while you are not using the app, in order to be able to tell you when to leave for planned ride, notify you about bad traffic in your area, analyze how effective our guidances are and more;
-Terms or venues you searched;
-Your views and interactions with content and ads;
-Your voice and audio information when you use voice and audio features;
-Communication or other content you chose to share with any third party, including CrossHelmet users through the Services;
-Your activity on third-party sites and apps that you chose to link to your CrossHelmet account or that you interact with through the Service.
Meta-data (information about your device, browser and app use):
Once you install the Application, CrossHelmet collects information about the use of the Services and information from the device you have CrossHelmet installed on. For example:
– CrossHelmet may collect and record how often you use the app and for how long, your device type, unique identifiers, operating system type & version, battery usage, the third party web pages or applications you visit or use or interact with via the Application, information that you viewed on our Services, advertisements that are shown to you or that you view or click on, the fact that you used the Services to communicate with other users and the fact that you used third parties application/services via CrossHelmet to communicate with third parties, and the duration of such communications, the Internet Protocol (IP) address and the name of the domain that serves you to access the Services, and the geographic location of the device that you are using to log in and use CrossHelmet on.
– CrossHelmet may also collect information about apps installed on your device that CrossHelmet can link with – such as third party music or media audio service apps (e.g. Spotify).
– We also collect information about the interaction of your devices with our Services, including, noise cancellation settings, system activity, and the date, time, and referrer URL of your request.
Information we collect about you from our partners
We work with ad partners, including entities that belong to the Google group of companies, in order to show you more relevant and useful ads based on your CrossHelmet activity and information associated with your device’s identifier (i.e, Advertising identifiers or similar technologies) shared with us by our ad partners.
We may also receive aggregated, non-personally identifiable information and analysis from third parties measurement services which help us understand how our users interact with our ads. We may also receive information from third party services about how CrossHelmet’s own marketing efforts performed on third party sites or platforms.
We use various technologies to collect and store information, including, cookies, Advertising ID available on Android mobile devices or similar technologies, local storage, browser web storage, application data caches, databases, and server logs.
Why CrossHelmet collects data
CrossHelmet may use information collected from or provided by you for the following purposes:
Provide our services
We use your information to deliver our services. For example:
– Use your location and route information and/or search query history to provide navigation services, best routing choices,
traffic alerts and to provide information about sites, shops and other places and attractions in your close vicinity; and
– (If you have opted in to the “find friends” feature), use your phone number and the phone numbers which are stored in your device’s
phone book to find and create a list of other CrossHelmet users who you may know and with whom you may wish to connect.
– To provide advertising services, including personalized ads, in accordance with the section titled ‘Advertising campaigns’
– To share your submissions with other users of the Services and to facilitate communication between you, CrossHelmet and other users.
Maintain & improve our services
We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues you report to us. And we use your information to improve the service or to develop new features or services. For example, CrossHelmet may use your route information to improve the accuracy of its mapping and navigation data.
Provide personalized services, including content and ads
We use the information we collect to operate the Services and to customize your experience with the Services. For example, CrossHelmet may use your “home” and “work” and other “favorites” information (if you choose to provide such information) or route history to offer routes based on how you’ve chosen to travel between favorite destinations in the past.
We may also use the information to provide you with support and handle requests and complaints.
We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your usage of the Services to do things like optimize product design. We also use the data we collected about the ads you view or interact with (e.g. click on) to help advertisers understand the performance of their ad campaigns and to provide them with aggregated reports. We may also use data to measure the usability and effectiveness of CrossHelmet’s own marketing efforts on third party sites or platforms.
Communicate with you
We also use your information to send you updates, notices, announcements, and additional information related to the Services;
We may also use your information to conduct surveys and questionnaires; And if you contact CrossHelmet we may keep a record of your request in order to help solve any issues you might be facing.
Subject to your prior indication of consent (to the extent required under applicable law), we may also use the email address that you provided to send you promotional and/or marketing materials. At any time you may choose not to receive such materials by clicking on the “Unsubscribe” link in the email messages that we may send to you. In any case, CrossHelmet will not share your contact details with any advertiser, unless explicitly permitted or required by law.
To protect CrossHelmet, our users, the public and for Legal reasons
We may also use and process your information and content, using different technologies to the following purposes:
– To contact you when CrossHelmet believes it to be necessary;
– To comply with any applicable law and assist law enforcement agencies under any applicable law, when CrossHelmet has a good faith belief that CrossHelmet’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
– To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
– To handle breakdowns and malfunctions;
– To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services;
– To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm crosshelmet, our users, or the public;
– To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does CrossHelmet use aggregated information”, below;
Sharing your information
Personal information that you share
The Services are based on a community of users publicly sharing information with CrossHelmet and with other members of that community.
In particular, users may choose to share personal information such as name, age, gender, picture, their location information, reports and other files. This information may be shared directly to the Services to your friends on CrossHelmet. This information may also be shared via third party services (such as social networks) which interact with the Services upon such users’ choice.
You can decide whether or not to upload content to the Services. However any content that you choose to share and submit for posting is neither private nor confidential and you should expect that it may be made public and known to others. Information you choose to upload will be posted along with your user name and other information including personal information you attached to your publicly available user profile.
Except as detailed below with respect to information shared from your social network accounts (according to your privacy settings for such social network accounts), your email address will not be visible to others through any reports or user posts that you share or upload.
We, at CrossHelmet, take great measures to provide you with the best experience you can have while using the Services. However, CrossHelmet has no control over the conduct of any user and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.
Participating in any user’s activities as a result, directly or indirectly, from using CrossHelmet, is entirely at your own risk. CrossHelmet is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.
When CrossHelmet shares your information
CrossHelmet does not sell, rent or lease your personal information to third parties.
CrossHelmet will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in CrossHelmet’s good-faith discretion:
As necessary for the facilitation and operation of the Services.
If CrossHelmet is required, or reasonably believes that it is required by law to share or disclose your information;
In any case of dispute, or legal proceeding of any kind between you and CrossHelmet, or between you and other users with respect to, or in relation with the Services;
In any case where CrossHelmet reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of CrossHelmet, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property;
To detect, prevent, or otherwise address fraud, security, or technical issues;
To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to CrossHelmet, as reasonable for business purposes, which may be located in Japan, or the U.S.A., potentially countries outside of your jurisdiction;
CrossHelmet may also share personal information with companies or organizations connected or affiliated with CrossHelmet, such as subsidiaries, sister-companies and parent companies;
We also work with selected measurement services which help us understand how our users interact with our ads and in order to measure CrossHelmet’s own marketing efforts, by using and sharing the device’s identifier (i.e, Advertising ID or similar technologies).
Personal information may also be shared with CrossHelmet’s trusted partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer services.
Please note that your username and some other information will be visible to others. Note that your username will be included along with any information you submit. It will therefore be visible to others. Also – your friends on CrossHelmet will see your name & profile photo and any other information you chose to share.
Integration with social networks
You may choose to share information between your CrossHelmet account and your social network account (such as Facebook). Through this option, you may choose to have personal information and other content about you available from social networks, transmitted and shared through the Services. Similarly, you may choose to have personal information and other content about you available from CrossHelmet, including your location and route information, transmitted to and shared through your social network account.
When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked by the social network to permit the social network to share your personal information stored on such social network with CrossHelmet. We collect your information from your social network account only in accordance with the permissions granted by you (such as your name, email address, list of friends, profile picture and other information available via the applicable social network).
You understand and agree that the Services may access, make available and store such information so that it is available on and through your CrossHelmet Account, until your CrossHelmet Account is deleted.
Please note that certain information which you have defined as private on your third party social network accounts may become public to other CrossHelmet Users through the Services once you have allowed the social network to share such information with CrossHelmet.
Integration with other third party services
CrossHelmet may offer you the option to link CrossHelmet to third party services that may be useful to you (like, Spotify). Where CrossHelmet detects an integration may be available (either because a third party service attempts to link to CrossHelmet, or CrossHelmet detects an installed service on the device which has an integration option, or you request a particular integration), CrossHelmet will ask for confirmation to connect the accounts. If you choose to connect the accounts, CrossHelmet will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts and CrossHelmet is not responsible for the third party service’s use of data. You can disconnect CrossHelmet and the third party service at any time and CrossHelmet will cease sharing data with that service from the point of disconnection onwards.
Controlling your personal information
You can always review and update certain information by visiting your Profile settings (such as your phone, email and more).
If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up a username and impair the ability to provide you with Services.
Deleting your information
If you would like us to delete your Account, please send a “Delete Account” request email to our support at [email protected]. On receiving such a request, CrossHelmet will use reasonable efforts to delete such information, however please note that information may not be deleted immediately from our back-up systems. We aim to initiate the deletion process immediately after your request. Once we receive your request, we then begin a process designed to safely and completely delete the data from our storage systems. This process generally takes around 2 months from the time of deletion. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and time frames defined in this policy. We maintain systems designed to detect and remediate such issues.
How CrossHelmet retains data we collect
Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.
Information retained until you remove it – such as your “Home, “work”, favorites, email address and other account related information. We’ll keep this data in your CrossHelmet Account until you choose to remove it and/or update it.
Data that expires after a specific period of time – in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. For example, if you choose to connect your calendar to your CrossHelmet Account, we extract your calendar events for several days in advance and delete them after their occurrence. We may also take steps to anonymize certain data within set timeperiods. Information retained until your CrossHelmet Account is deleted – we may keep some data for the life of your CrossHelmet Account if it’s useful for helping us understand how users interact with our features and how we can improve our services. For example, if you made an incident report, we will keep information about how many reports you have submitted, even after the event is removed. When you delete your CrossHelmet Account, the information about how many reports you have submitted is also removed.
Information retained for extended time periods for limited purposes – sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when CrossHelmet processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include: _ Security, fraud & abuse prevention _ Financial record-keeping _ Complying with legal or regulatory requirements _ Ensuring the continuity of our services * Direct communications with CrossHelmet How does CrossHelmet use aggregated information?
CrossHelmet may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).
CrossHelmet may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/or anonymous form to help improve the map and solve map problems, traffic data may be provided to cities, and aggregated ads analysis may be provided to advertisers.
Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.
CrossHelmet allows advertisers to run ad campaigns on the Services.
The information and advertisements that you see when accessing the Services may be targeted on the basis of your current CrossHelmet activity, such as your current location, your destination or contextual information based on your current drive session.
Depending on your settings, you may also see ads personalized to you based on:
Information we received from you (for example, your saved “Home” & “Work” addresses)
Past activity and search query history (for example, rides that appear in your trip list)
Information from our ad partners.
We don’t knowingly collect nor do we show you personalized ads based on sensitive categories, such as race, religion, sexual orientation, or health.
We don’t share information that personally identifies you with advertisers, such as your name or email.
As described under “When CrossHelmet shares your information” section above, we may work with other services for advertising and ad measurement purposes. In order to help advertisers decide what ads to show on CrossHelmet, and sites such as Google and Facebook, CrossHelmet may share information with these services such as a unique identifier for advertising (Advertising ID available on Android mobile devices or similar technologies).
The Services may include an internal messaging system which provides you the ability to send and receive messages to and from other users, and to receive marketing messages from us. You hereby agree that we may use the internal messaging system for the purpose of informing you regarding products or services, which may interest you.
Please note however that other CrossHelmet users are not allowed to use your contact details or our internal messaging account for commercial advertising purposes. If you have encountered any user generated advertising material, please inform us through the channels listed on the “Contact Us” page in the Settings menu in the Software or through the “About us” page on the Site link here.
It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable for any loss, damage, cost or expense that you may suffer or incur as a result or in connection thereof.
CrossHelmet considers information security to be a top priority. CrossHelmet services are built with strong security features that continuously protect your information. CrossHelmet implements systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to CrossHelmet employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.
However, these measures are unable to provide absolute assurance. Therefore, although CrossHelmet takes great efforts to protect your personal information, CrossHelmet cannot guarantee and you cannot reasonably expect that CrossHelmet’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
Compliance & cooperation with regulators
We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.
When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.
If the European Union (EU) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information.
You have the right to object to the processing of your information.
We process your information for the purposes described in this policy, based on the following legal grounds:
With your consent
We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time.
When we’re pursuing legitimate interests
We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:
Providing, maintaining, and improving our services to meet the needs of our users
Developing new services and features that are useful for our users
Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services
Customizing our services to provide you with a better user experience
Marketing to inform users about our services
Providing advertising to make our services freely available for users
Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services
Protecting against harm to the rights, property or safety of CrossHelmet, our users, or the public as required or permitted by law
Performing research that improves our services for our users and benefits the public
Fulfilling obligations to our partners like developers and rights holders
Enforcing legal claims, including investigation of potential violations of applicable Terms of Service
When we’re providing a service
When we’re complying with legal obligations
We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process.
If you have questions, you can contact CrossHelmet at: [email protected]. And you can contact your local data protection authority if you have concerns regarding your rights under local law.
Last modified: September 3 2019