Privacy Policy

1. General Provisions

This Privacy Policy is designed in accordance with the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and applicable data protection laws. It describes how Alexey Bezrukov (Individual Entrepreneur) (the "Data Controller" or "we") collects, uses, processes, and protects your personal data when you visit or use our website https://cruxly.tech.

1.1. We are committed to protecting your privacy and ensuring transparency in how we handle your personal data. This policy explains your rights regarding your personal data and how we comply with applicable privacy laws.

1.2. This Privacy Policy applies to all information that we may collect about visitors to the website https://cruxly.tech and users of our services.

2. Definitions

3. Data Controller Rights and Obligations

3.1. The Data Controller has the right to:

• Request accurate information and/or documents containing personal data from Data Subjects;
• Continue processing personal data without consent when there are legal grounds specified in applicable data protection laws, even after consent withdrawal;
• Independently determine the composition and list of measures necessary to ensure compliance with applicable data protection laws and regulations.

3.2. The Data Controller is obligated to:

• Provide Data Subjects with information concerning the processing of their personal data upon request;
• Organize personal data processing in accordance with applicable data protection legislation;
• Respond to inquiries and requests from Data Subjects and their legal representatives within the timeframes required by law;
• Report to supervisory authorities upon their request within prescribed timeframes;
• Publish and ensure unrestricted access to this Privacy Policy;
• Implement appropriate technical, physical, and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction;
• Cease transfer, processing, and destroy personal data in cases provided for by applicable laws;
• Fulfill other obligations provided for by applicable data protection laws.

4. Data Subject Rights and Obligations

4.1. Data Subjects have the following rights:

• Right of Access: Obtain information about the processing of your personal data, including the purposes, categories of data, recipients, and retention periods;
• Right to Rectification: Request correction of inaccurate, incomplete, or outdated personal data;
• Right to Erasure ('Right to be Forgotten'): Request deletion of personal data when it is no longer necessary for the original purposes or when you withdraw consent;
• Right to Restrict Processing: Request limitation of processing under certain circumstances;
• Right to Data Portability: Receive your personal data in a structured, commonly used format and transmit it to another controller;
• Right to Object: Object to processing based on legitimate interests, direct marketing, or profiling;
• Right to Withdraw Consent: Withdraw consent at any time when processing is based on consent;
• Right to Lodge a Complaint: File a complaint with supervisory authorities or seek judicial remedy for unlawful processing.

4.2. Data Subjects are obligated to:

• Provide accurate data about themselves to the Data Controller;
• Notify the Data Controller about updates or changes to their personal data.

4.3. Persons who provide false information about themselves or about another Data Subject without their consent bear responsibility in accordance with applicable law.

5. Data Processing Principles

6. Purposes and Legal Basis for Processing

7. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: When you have given clear consent for specific processing purposes
• Contract Performance: When processing is necessary for performing a contract with you
• Legitimate Interest: When we have legitimate business interests that don't override your rights
• Legal Obligation: When processing is required by applicable laws

8. Data Retention Periods

9. Cookies and Tracking Technologies

9.1. Use of Cookies

Our website uses cookies for the following purposes:

• Essential website functionality
• Remembering your preferences and settings
• Analytics and service improvement (with your consent)
• Content personalization (with your consent)

9.2. Types of Cookies We Use

9.3. Cookie Management

You can manage cookie preferences through our cookie banner or your browser settings. Disabling certain cookies may limit website functionality. You have the right to withdraw consent for non-essential cookies at any time.

10. Data Processing, Storage, and Security

10.1. Security Measures

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption in transit (SSL/TLS) and at rest
• Access controls and authentication systems
• Regular security audits and vulnerability assessments
• Staff training on data protection and security
• Incident response and breach notification procedures
• Regular data backups with secure storage
• Network security monitoring and intrusion detection

10.2. Data Sharing and Third Parties

We do not sell your personal data. We may share your data only in the following circumstances:

• Legal compliance: When required by law, regulation, or valid legal process
• Your explicit consent: When you have specifically agreed to data sharing
• Service providers: With trusted third-party processors who assist us (under strict data processing agreements)
• Business transfers: In case of merger, acquisition, or asset sale (with notice to you)
• Anonymized data: For analytics and research purposes (cannot identify you)

10.3. To update your personal data, contact us at support@cruxly.tech with the subject line 'Personal Data Update'.

11. International Data Transfers

11.1. When we transfer personal data outside your country, we ensure adequate protection through:

• Transfers to countries with adequacy decisions
• Standard Contractual Clauses (SCCs) approved by supervisory authorities
• Binding Corporate Rules or certification schemes
• Your explicit consent for specific transfers

11.2. We will inform you about any international transfers and the safeguards we use to protect your data.

12. Your Privacy Rights

13. California Consumer Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

• Right to Know: Request information about personal data collection, use, and sharing
• Right to Delete: Request deletion of personal data we collected from you
• Right to Opt-Out: Opt-out of the sale of personal data (we do not sell personal data)
• Right to Non-Discrimination: Equal service and pricing regardless of privacy choices

California residents can exercise these rights by contacting us at support@cruxly.tech with 'CCPA Request' in the subject line.

We may need to verify your identity before processing your request.

14. Data Breach Notification

In case of a data breach that poses risks to your rights and freedoms:

• We will notify supervisory authorities within 72 hours when feasible
• We will inform affected individuals without undue delay if high risk is involved
• We will document the breach and our response measures
• We will take steps to mitigate the breach and prevent future incidents

15. Final Provisions

15.1. We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and, where required, seeking your consent.

15.2. For all privacy-related questions, contact us at: support@cruxly.tech

15.3. The current version of this Privacy Policy is available at: https://cruxly.tech/privacy

15.4. You have the right to lodge a complaint with your local data protection supervisory authority.