Cloudacio LLC, and our subsidiaries and affiliates, (“Cloudacio” or “We“) respect your privacy and commit to protecting it through our compliance with the practices described in this Privacy Policy (“Policy”).

This Policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website(s) or other digital properties, communications, or forms that link or refer to this notice (our “Website“).  This Policy also describes our data collection, use, protection and disclosure practices for customers that we provide our services to under a Master Services Agreement (“MSA”), or similar agreement.   For purposes of this Policy, Website visitors shall be referred to as “Site Visitors” and customers that we provide services to under an MSA shall be referred to as “Customers.”

This Policy applies to the personal data collected through our Website, regardless of the country where you are located.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.

Please read this notice carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Website, you accept and consent to the practices described in this notice. This notice may change from time to time (see Changes to Our Privacy Policy). Your continued engagement with our Website after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.

 

Data We May Collect About You

 

We collect and use different types of data from and about you including

If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

 

How We Collect Data About You

 

We use different methods to collect data from and about you including through

 

Cookies and Automatic Data Collection Technologies

 

Our Website uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Website users (a complete list of cookies that we use on the Website can be found at cloudacio.com by clicking on ‘Cookie Settings’). Cookies help us deliver a better and more personalized service when Site Visitors browse our Website. It also allows us to improve our Website by enabling us to:

Site Visitors may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Website may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

Certain features of our Website may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies and browser cookies use different management tools and you must manage their settings separately. For information about managing your Flash cookie privacy and security settings, see Your Personal Data Use Choices.

Our Website pages and emails may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Website content popularity or verifying system and server integrity.

 

Third-Party Use of Cookies and Other Tracking Technologies

 

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Your Personal Data Use Choices.

 

How We Use Your Personal Data

 

We use your personal data to provide you with products, offer and provide you services, communicate with you, deliver advertising and marketing, fulfill business obligations, or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

We may use non-personal data for any business purpose.

 

Disclosure of Your Personal Data

 

We may share your personal data:


We may also disclose your personal data to third parties:


We may share non-personal data without restriction.

 

Consent to Personal Data Transfer

 

We are based in the United States. We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own, including Canada, Argentina, and Brazil.

If you are based in the European Economic Area, the European Commission has not approved an adequate level of protection for the transfer of data to the countries named above.  As a result, we have, in accordance with European Union law, entered into a special agreement with our subsidiaries, affiliates, and service providers in those countries in order to maintain an adequate level of data protection in situations when the processing may occur overseas. The above-mentioned agreements are based on the standard contractual clauses approved by the European Commission, the use of which is governed by Article 46 GDPR. 

You can find more information at the following link:

https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en

By submitting your personal data or engaging with our Websites, or as a Customer, you consent to this transfer, storing, or processing.

 

Your Personal Data Use Choices

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

 

Accessing and Correcting Your Personal Data

 

You can access, review, and change your personal data by logging into the Website and visiting your account profile page.

You may also send us an email at privacy@cloudacio.com to request access to, correct, or delete the personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information’s accuracy.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or because other Website users may have copied or stored them. Our terms of use govern proper access and use of information provided on the Website, including User Contributions.

 

Data Security

 

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers employing security protections. We encrypt any payment transactions.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of the Website like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.

 

Children’s Online Privacy

We do not direct our Website to minors and we do not knowingly collect personal data from children under 18, or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at privacy@cloudacio.com.

 

Changes to Our Privacy Policy

 

We will post any changes we may make to our privacy policy on this page. If the changes materially alter how we use or treat your personal data we will notify you. Please check back frequently to see any updates or changes to our privacy policy.

 

Contact Information

 

Please address questions, comments, and requests regarding this privacy policy and our privacy practices to privacy@cloudacio.com.

Our corporate headquarters are located at 459 Columbus Ave #4003, New York, NY 10024, USA.

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@cloudacio.com.

 

Privacy Notice for California Residents

 

This Privacy Policy for California Residents supplements the information contained in the Cloudacio Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some of its requirements.


Information We Collect

 

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:


In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

CategoryExamplesCollected
A. Identifiers.A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.YES
C. Protected classification characteristics under California or federal law.Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).NO
D. Commercial information.Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.NO
E. Biometric information.Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.NO
F. Internet or other similar network activity.Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.YES
G. Geolocation data.Physical location or movements.YES
H. Sensory data.Audio, electronic, visual, thermal, olfactory, or similar information.NO
I. Professional or employment-related information.Current or past job history or performance evaluations.NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NO
K. Inferences drawn from other personal information.Profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO


We obtain the categories of personal information listed above from the following categories of sources:

 

Use of Personal Information


We may use or disclose the personal information we collect for one or more of the following purposes:


We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

 

We may share your personal information by disclosing it to a third party for business purposes.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated at www.cloudacio.com/subprocessors.

We do not sell personal information.

 

Your Rights and Choices

 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Right to Know and Data Portability

 

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:


We do not provide a right-to-know or data portability disclosure for B2B personal information.

 

Right to Delete

 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

 

Exercising Your Rights to Know or Delete

 

To exercise your rights to know or delete described above, please submit a request by emailing us at privacy@cloudacio.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

 

Response Timing and Format

 

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@cloudacio.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Non-Discrimination

 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

 

Other California Privacy Rights

 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@cloudacio.com.

 

Changes to Our Privacy Policy

 

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

 

Contact Information

 

If you have any questions or comments about this notice, the ways in which Cloudacio collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at privacy@cloudacio.com.

If you need to access this Policy in an alternative format due to having a disability, please contact privacy@cloudacio.com.