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 Information from HoneyTrap Pro^™ Appliances

Data Category	Examples	Purpose
Appliance Telemetry	Serial number, IP address, software version, uptime, health metrics	Device management, monitoring
Security Events	Attacker IP addresses, attack types, timestamps, protocols, ports	Threat detection, analysis, reporting
Session Data	Commands executed by attackers, session recordings	Forensic analysis, AI threat analysis
Configuration Data	Enabled services, alert settings, integration credentials	Service delivery, customization

2. How We Use Your Information

2.1 Service Delivery

• Providing, operating, and maintaining the HoneyCloud^™ platform
• Managing HoneyTrap Pro^™ appliances and delivering security alerts
• Processing transactions and managing subscriptions
• Generating reports and security analytics
• Providing AI-powered threat analysis via Claude API

2.2 Service Improvement

• Analyzing usage patterns to enhance features
• Developing new products and services
• Conducting research and analysis
• Troubleshooting and resolving technical issues

2.3 Security and Compliance

• Detecting and preventing fraud, abuse, and security incidents
• Monitoring for unauthorized access or use
• Complying with legal obligations
• Enforcing our Terms of Service

2.4 Communications

• Sending administrative information, updates, and security alerts
• Responding to your comments, questions, and requests
• Sending promotional communications (with your consent, where required)
• Providing information about new features, products, and services

3. Legal Basis for Processing (GDPR)

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

• Contract Performance: Processing necessary to provide the Service as agreed in our Terms of Service
• Legitimate Interests: Processing necessary for our legitimate business interests, such as improving the Service, ensuring security, and preventing fraud
• Consent: Where you have given explicit consent for specific processing activities
• Legal Obligation: Processing necessary to comply with applicable laws and regulations

4. Threat Intelligence Sharing

4.1 What Data May Be Shared

• Attacker IP addresses
• Attack types and signatures
• Timestamps and frequency data
• Protocols and ports targeted
• Malicious payload hashes (not the payloads themselves)

4.2 What Data Is Never Shared

• Your company name or identifying information
• Your End Customers' identities or information
• Your internal network information
• Your account credentials or configuration details

4.3 Your Control

Participation in threat sharing is entirely optional. You can enable or disable this feature at any time in your account settings. By default, threat sharing is disabled for new accounts.

5. Data Sharing and Disclosure

We may share your information in the following circumstances:

5.1 Service Providers

We use trusted third-party service providers to help us operate our business:

• Stripe: Payment processing
• Amazon Web Services: Cloud infrastructure
• Anthropic: AI-powered threat analysis (Claude API)
• SendGrid/SMTP Providers: Email delivery

5.2 Legal Requirements

We may disclose your information if required by law, subpoena, court order, or governmental request, or when we believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

5.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

6. Data Retention

Data Type	Retention Period
Account Information	Duration of account + 7 years (tax/legal compliance)
Security Event Data (Basic tier)	30 days
Security Event Data (Professional tier)	60 days
Security Event Data (Enterprise tier)	90 days
Session Recordings	Same as Security Event Data per tier
Audit Logs	1 year
Billing Records	7 years (tax compliance)

7. Data Security

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

• Encryption in transit (TLS 1.2+) and at rest (AES-256)
• Regular security assessments and penetration testing
• Access controls and authentication requirements
• Employee security training and background checks
• Incident response procedures
• Regular backups with secure storage

8. Your Rights and Choices

To exercise any of these rights, contact us at privacy@honeycloud.co.

9. Cookies and Tracking

We use cookies and similar technologies for:

• Essential cookies: Required for platform functionality (authentication, session management)
• Analytics cookies: Help us understand how you use the Service
• Preference cookies: Remember your settings and preferences

You can control cookies through your browser settings. Note that disabling certain cookies may impact functionality.

10. International Data Transfers

Your information may be transferred to and processed in the United States where our servers are located. If you are located outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States.

For EEA residents, we rely on Standard Contractual Clauses approved by the European Commission to ensure adequate protection for transferred data.

11. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email to the address associated with your account or through prominent notice on the Platform at least thirty (30) days prior to the changes taking effect. Your continued use of the Service after such modifications constitutes acceptance of the updated Privacy Policy.

13. Contact Information

For questions about this Privacy Policy or to exercise your rights, please contact us:

Cross Country Communications Corp.
402 Church Street
Sulphur Springs, TX 75482
United States

Email: privacy@honeycloud.co
Phone: (903) 438-9104
Website: www.honeycloud.co