De-identified data
Last updated: 28 August 2026
This page is Crosswalk Technologies, Inc.'s public commitment about aggregated dashboard products.
We do not sell raw clickstream. Clients receive group statistics only. Those files are not a list of people.
US comprehensive privacy laws exclude de-identified data from "personal information" and "personal data." Several states also exclude aggregate consumer information in express terms. A business that holds de-identified data must:
Take reasonable measures so the data cannot reasonably be associated with a natural person.
Publicly commit not to re-identify it.
Contractually bind recipients to the same.
This page is item 2.
The commitment
Crosswalk Technologies, Inc. publicly commits to maintain and use aggregated dashboard products in de-identified form, and not to attempt to re-identify any natural person, household, or device from those products.
We take reasonable administrative, technical, and physical measures so that those products cannot reasonably be associated with a natural person.
We contractually obligate recipients not to re-identify, and we exercise reasonable oversight of those commitments.
We will not re-identify de-identified or aggregated data in order to respond to a consumer rights request. We will not keep data in identifiable form solely so that such a request could be fulfilled from a client file.
What a client file is
The product a client holds is an audience, not a person. We do not sell raw clickstream. Clients receive aggregated dashboard products only: group statistics, not a stack of individual rows.
A shipped file does not include:
Name, email, phone, or postal address
IP address, cookie, advertising ID, or device ID
Panel ID, unique user ID, hash, or token
Precise geolocation
A row that is one person
It includes group statistics such as penetration, index versus US Gen Pop, projected US counts, ranked brands, and demographic composition of a cohort.
What we will not do
We will not:
Attempt to re-identify any person, household, or device from a shipped aggregated product
Combine a shipped product with other data in order to single out a person
Re-identify a client file in order to pull one person out of it, including in response to a rights request
Sell Layer A personal information as individual records or as raw clickstream
Rights requests run on Layer A, the consented panel and account records Crosswalk holds. Later product builds inherit a valid deletion. The person is not in the client file.
Recipients
If you receive a Crosswalk aggregated product, you agree:
Not to attempt to re-identify any person, household, or device from the file, alone or combined with other data
Not to commingle it with individual-level data in a way that would reasonably link a cell back to a person
Not to reverse-engineer small cells to isolate an individual
To flow the same prohibitions to any permitted sub-recipient
Notify privacy@crosswalknyc.com of any attempt, demand, or incident that would breach those terms.
Rights requests
If you want to know, delete, correct, opt out, or withdraw panel consent, that request is about Layer A.
Submit it at privacy@crosswalknyc.com, +1 (818) 231-2610, Your Privacy Choices, or by mail to Crosswalk Technologies, Inc., Attn: Privacy, 23465 Civic Center Way Bldg 9, Malibu, CA 90265.
We respond within 45 days.
Full consumer notice: Privacy Policy. How to leave the panel: Opt-Out.