This Privacy Policy describes how Crafting Inc. (“Crafting”) collects, uses and discloses information, and what choices you have with respect to the information.

Scope of this Privacy Policy

This Privacy Policy applies to Crafting’s products and services, including applicable mobile and desktop applications (collectively, the “Services”), crafting.dev and other Crafting websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with Crafting. If you do not agree with the terms, do not access or use the Services, Websites, or any other aspect of Crafting’s business.

This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the Crafting platform (“Third-Party Services”), or any other third-party products, services or businesses. In addition, a separate agreement governs delivery, access, and use of the Services (the “Service Agreement”), including the processing of any data submitted through the Services (“Service Data”). The organization (e.g., your employer or another entity or person) that agreed to the Service Agreement (“Customer”) controls its instance of the Services and any associated Service Data (the “Customer Instance”).

Information Crafting Collects and Receives

Crafting may collect, generate, and receive Service Data and other information and data (“Other Information”; Service Data and Other Information collectively “Information”)) in a variety of ways:

• Service data. Customers and individuals granted access to a Customer Instance by a Customer (“Authorized Users”) may submit Service Data to Crafting when using the Services.

• Other information.
  • Account information.
  • To create or update a Crafting account, you or a Customer (e.g., your employer) supply Crafting with an email address, phone number, password, domain and/or similar account details. In addition, Customers that purchase a paid version of the Services provide Crafting (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
• Usage information.
  • Services metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users interact with the Services. For example, Crafting logs what Third Party Services are connected with the Services (if any).‍
  • Log data. As with most technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.‍
  • Device information. Crafting collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether Crafting collects some or all of this information often depends on the type of device used and its settings.‍
  • Location information. Crafting receives information from you, your Customer and other third parties that may help Crafting approximate your location. Crafting may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. Crafting may also collect location information from devices in accordance with the consent process provided by your device.

• Cookie information. Crafting uses cookies and similar technologies in our Websites and Services to help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how Crafting uses these technologies, and your opt-out opportunities and other options, please see Crafting’s Cookie Policy .
• Contact information. An Authorized User is required to provide some contact information (e.g., an email address) when making an account on the Services.
• Additional information provided to Crafting. Crafting receives Other Information when submitted to our Websites or in other ways, such as if you participate in a focus group, contest, activity or event, apply for a job, enroll in a certification program or other educational program hosted by Crafting or a vendor, request support, interact with our social media accounts or otherwise communicate with Crafting.

How Crafting Uses Information

Service Data will be used by Crafting in accordance with the applicable Service Agreement, Customer’s use of Services functionality, and as required by applicable law. Crafting is a processor of Service Data and Customer is the controller.

In addition, Crafting uses Information in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Crafting uses Information:

• To provide, update, maintain and protect our Services, Websites, and business. This includes use of Service Data and Other Information to support delivery of the Services under an Service Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities, or at an Authorized User’s request.

If Information is aggregated or de-identified so that it is no longer reasonably associated with an identified or identifiable natural person, Crafting may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

• As required by applicable law, legal process, or regulation.
• To communicate with you by responding to your requests, comments, and questions. If you contact us, Crafting may use Information to respond.

Data Retention

• To develop and provide additional features. Crafting tries to make the Services as useful as possible for Customers and Authorized Users, and Crafting may use aggregated and anonymized Services Data and Other Information to develop new Services or improve existing Services.

Crafting will retain Service Data in accordance with the applicable Service Agreement, Customer’s use of Services functionality, and as required by applicable law.

• To send emails and other communications. Crafting may send you service, technical and other administrative emails, messages, and other types of communications. Crafting may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, Crafting sometimes sends emails about new product features, promotional communications, or other news about Crafting. These are marketing messages so you can control whether you receive them. If you have additional questions about a message you have received from Crafting please reach out through the contact mechanisms described below.

Crafting may retain Other Information for as long as necessary for the purposes described in this Privacy Policy. This may include keeping Other Information for the period of time needed for Crafting to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

• For billing, account management, and other administrative matters. Crafting may need to contact you for invoicing, account management, and similar reasons and Crafting uses account data to administer accounts and keep track of billing and payments.

How Crafting Shares and Discloses Information

• To investigate and help prevent security issues and abuse.

This section describes how Crafting may share and disclose Information.

• Displaying and operating the Services. Because of the nature and functionality of the Services, Information will be displayed as part of the Services to Authorized Users in a Customer Instance.

Security

Security is critical to Crafting’s mission, and Crafting takes security of data very seriously. Crafting works hard to protect Information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Information Crafting collects, processes, and store, and the current state of technology. Given the nature of communications and information processing technology, Crafting cannot guarantee that Information during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and Crafting doesn’t control or endorse what is on third-party sites.

Age Limitations

To the extent prohibited by applicable law, Crafting does not allow use of our Services and Websites by anyone younger than 16 years old. If Crafting learns that anyone younger than 16 has unlawfully provided Personal Data, Crafting will take steps to delete such information.

Changes to This Privacy Policy

Crafting may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or Crafting may make changes to our services or business. Crafting will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If Crafting makes changes that materially alter your privacy rights, Crafting will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should cease interacting with the Services. Contact the applicable Customer if you wish to request the removal of Personal Data under their control.

• Third-party service providers and partners. Crafting may engage third parties as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services. To the extent necessary and applicable, these third-party service providers and partners will be bound by appropriate and commercially reasonable confidentiality obligations.

International Data Transfers

• Third-Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. Crafting require each Third-Party Service to disclose all permissions for information access in the Services, but Crafting do not guarantee that they do so. When enabled and as requested by Customer, Crafting may share Information with Third-Party Services. Third-Party Services are not owned or controlled by Crafting and third parties that have been granted access to Information may have their own policies and practices for its collection, use, and sharing. Please check the permissions, privacy settings, and notices for these Third-Party Services or contact the service provider for any questions.

Crafting may transfer your Personal Data to countries other than the one in which you live - generally, from locations outside the United States to the United States. Crafting deploys the following safeguards if Crafting transfers Personal Data from jurisdictions with differing data protection laws:

• Corporate affiliates. Crafting may share Information with its corporate affiliates, parents, and/or subsidiaries.

‍

• During a change to Crafting’s business. If Crafting engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Crafting’s assets or stock, financing, public offering of securities, acquisition of all or a portion of Crafting’s business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all Information may be shared or transferred, subject to appropriate and commercially reasonable confidentiality arrangements.

• Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System and Privacy Recognition For Processors. Crafting’s privacy practices, described in this Privacy Policy, comply with the Asia-Pacific Economic Cooperation (“APEC”) Cross Border Privacy Rules (“CBPR”) system and the Privacy Recognition for Processors (“PRP”). The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies and the PRP demonstrates an organization’s ability to provide effective implementation of a personal information controller’s privacy obligations related to the processing of personal information.

• Aggregated or de-identified data. Crafting may disclose or use aggregated or de-identified Information for any purpose. For example, Crafting may share aggregated or de-identified Information with prospects or partners for business or research purposes.

‍‍

• To Comply with Laws. If Crafting receive a request for information, Crafting may disclose Other Information if Crafting reasonably believe disclosure is in accordance with or required by any applicable law, regulation, or legal process. Please see the Data Request Policy to understand how Crafting responds to requests to disclose data from government agencies and other sources.

Data Protection Officer

• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of Crafting or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

To communicate with our Data Protection Officer, please email privacy@crafting.dev.

• With consent. Crafting may share Information with third parties when Crafting has consent to do so.

Identifying the Data Controller and Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Service Data. In general, Crafting is the processor of Service Data and the controller of Other Information.

Your Rights

Individuals located in certain countries, including the European Economic Area and the United Kingdom, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. Contact us for additional access and assistance.

To the extent that Crafting’s processing of your Personal Data is subject to the General Data Protection Regulation (or applicable laws covering the processing of Personal Data in the United Kingdom), Crafting relies on its legitimate interests, described above, to process your data. Crafting may also process Other Information that constitutes your Personal Data for direct marketing purposes, and you have a right to object to Crafting’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information Crafting collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information Crafting has collected over the last 12 months, including the categories of sources, please see the Information Crafting Collects and Receives section above. Crafting collect this information for the business and commercial purposes described in the How Crafting Uses Information section above. Crafting shares this information with the categories of third parties described in the How Crafting Shares and Disclose Information section above. Crafting does not sell (as such term is defined in the CCPA) the personal information Crafting collects. Please note that Crafting may use third-party cookies for our advertising purposes as further described in our Cookie Policy .

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information Crafting collects (including how Crafting uses and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@crafting.dev. Crafting will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict Crafting’s use of Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority.

If you are a resident of the European Economic Area and believe Crafting maintains your Personal Data within the scope of the General Data Protection Regulation (GDPR), please direct questions to privacy@crafting.dev.

Once the United Kingdom is no longer a Member State of the European Union, if you are a resident of the United Kingdom and believe Crafting maintains your Personal Data within the scope of the applicable laws relating to personal data in the United Kingdom, you may direct questions or complaints to the UK supervisory authority, the Information Commissioner’s Office.

Contacting Crafting

Please also feel free to contact Crafting if you have any questions about this Privacy Policy or Crafting’s practices, or if you are seeking to exercise any of your statutory rights. Crafting will respond within a reasonable timeframe.

You may contact us at privacy@crafting.dev or at our mailing address below:

‍

Crafting Inc.
2625 Middlefield Rd. #561
Palo Alto, CA 94306

‍