Last Revised: May 25, 2018
INFORMATION COLLECTION AND USE
We collect and use the following information to provide, improve, and protect our Services:
1. Information You Provide:
- Account Information. You can browse our site without providing personal information, but you must register in order to access most of the features of the Service. We ask for certain information such as your company name, your name, email address, and password when you create an account on the Service.
- Additional User Content. After you setup your account, you may choose to provide additional information such as the names and email addresses of additional members of your team or an additional phone number. You may also test the Service by uploading your own team members’ name and email address to your account from your address book using the Service. Providing this information is optional.
- Communications. At times, you may choose to send us messages. We may retain any messages you send to us. You may also provide us information when you respond to surveys, communicate with our engineering, sales, or support teams about a question regarding the Services, or post a question or comment in our public forums.
- Payment and Billing Information. We also collect credit card or payment information for paid subscriptions. This information will be securely stored with a third party specialized in the handling of such information, such as a credit card payment gateway or other payment vendors.
- Telephone Information. If we telephone you, or you telephone us, to discuss our Services, we may collect personal information from you, including your name, company name, business address, phone number, job title, email address, whether you use the Services, information about your business needs, the number of users of our Services you require, and, if you telephoned us, how you heard about us, and any other information you choose to share with us by telephone.
2. Information We Collect Automatically:
- Device Information. Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. Your devices (depending on their settings) may also transmit location information to the Services. We collect log information when you use our Services–for example, when you create or make changes to your account on the Services.
- Usage Information. We collect information related to how you use the Services, including actions you take in your account (like viewing reports and configuring the service). We use this information to improve our Services, develop new services and features, and protect our Users.
- Location Information. We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
- Cookies and Similar Technologies. We use technologies like cookies and pixel tags to provide, improve, protect, and promote our Services. A cookie is a small text file containing a string of alphanumeric characters that may uniquely identify your browser that lets us help you log in faster and enhance your navigation through the Services. A cookie may also convey information to us about how you use the Services (e.g., the pages you view, the links you click, how frequently you access the Services, and other actions you take on the Services), and allow us to track your usage of the Services over time. You can set your browser to not accept cookies, but this may limit your ability to use the Services. Similarly, we may employ clear gifs (also known as web beacons) which are used to anonymously track your usage patterns on the Services, or place clear gifs in HTML-based emails we send you to track which emails are opened and which links you click. This information allows for more accurate reporting and improvement of the Services.
3. Information We Receive from Other Sources:
- Authentication Services. We allow End Users with certain third-party accounts to authenticate on the Services using those third-party accounts. We support the OAuth standard and will use the OAuth standard to facilitate End Users’ use of the Services to upload their data from their respective contact management provider whenever possible. Use of the Service with respect to third-party contact management providers that support the OAuth standard does not require Cloud Copy to have access to, and Cloud Copy will not in fact have access to, your End Users’ passwords in such instances. Cloud Copy may request End Users’ credentials for certain third party contact management providers in order to complete the upload of their address book information from any source that does not support the OAuth standard. When we request this information from a third party contact management service or use the OAuth standard to facilitate authentication with a third party contact management service, we receive certain End User Content, namely registration or basic profile information from that third party service and other information that your End Users may authorize. This information enables us to authenticate the End User on that third party service and improve the Services. The information we receive depends on which contact management services the End User authorizes and any options that are available. End Users should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Services.
- Third Party Analytics Services. We may also receive information from third party services to help us better understand you and how you use our Services.
- End Users. We also process information about our End Users, on behalf of our Users and in accordance with our user agreements. Typically, the information we receive from an End User may include the End User’s address books information, namely contact lists, contact notes, and any images associated with an End User’s address book. For clarity, Cloud Copy only collects the minimum amount of personal data necessary for it to perform its obligations under its Terms of Service with its respective User Accordingly, any personal data about an End User is only stored in the random access memory of Cloud Copy’s servers and never written to a physical disc. The pseudoanonymous data about an End User that remains with Cloud Copy, is limited to a hash of each End User’s email address, the End User’s IP address, the source of the address book, and the number of contacts in the address book.
4. Information Collected by Third Parties:
5. Purpose for Collection:
We use information about you as mentioned above and for the purposes listed below:
- To provide you the Services, including for example, reporting errors and bugs in your Products and billing you for the Services;
- To maintain, monitor, and improve the Services by adding new features, sharing new use cases, or making the Services easier to use;
- To monitor and analyze trends and better understand how you interact with our Services;
- For our own internal benchmarking, for example, to measure, and gauge the effectiveness of the Services, our advertising of the Services, and to better understand user retention and attrition–for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
- To prevent problems with our Services, protect the security of our Services, detect fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Cloud Copy and others, which may result in us declining a transaction or the use of our Services;
- To personalize your experience using our Services, remember your preferences on the Services so that you will not have to re-enter it during your visit or the next time you use the Services, target our marketing messages to groups of our Users (for example, those who have a particular plan with us or have been our user for a certain length of time), to serve relevant advertisements; and
- To communicate with you, for example through an email, about offers and promotions offered by Cloud Copy and others we think will be of interest to you, solicit your feedback, or keep you up to date on what we’re up to and our products. We give users the option to use some of our Services free of charge. These free Services are made possible by the fact that some users upgrade to one of our paid Services. If you register for our free Services, we will, from time to time, send you information about upgrades when permissible. For further information on your choices regarding your choices with regard to the use of your information for marketing purposes, see “Your Choices Regarding Your Information” below.
LEGAL BASIS FOR COLLECTING AND USING INFORMATION
We collect and use the personal data described above based on the following grounds:
- The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our Services on your device or charge you for a paid subscription; or
- Compliance with a legal obligation necessitates the use; or
- The protection of your vital interests or those of another person require the use; or
- We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
- You have given us your consent.
INFORMATION SHARING AND DISCLOSURE
We collect and use the personal data described above based on the following grounds:
- Account Administrators. If your use of the Services is pursuant to an agreement entered into by your employer or other organization to which you belong, your administrator may have the ability to access and control your Cloud Copy team account. Please refer to your organization’s internal policies if you have questions about this.
- Law & Order and the Public Interest. Third parties as required to (a) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (b) enforce our Terms of Service or other agreements with you, including the investigation of potential violations thereof, (c) investigate and defend ourselves against any third party claims or allegations, (d) protect against harm to the rights, property or safety of Cloud Copy, its users or the public as required or permitted by law and (e) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
- Aggregated and De-Identified Information. We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
YOUR CHOICES REGARDING YOUR INFORMATION
- Account Data. All Cloud Copy account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. Cloud Copy account holders may also contact us at email@example.com to accomplish the foregoing or if you have additional requests or questions.
- Access to Data Controlled by Our Users. Cloud Copy has no direct relationship with End Users whose personal information is contained within the personal data processed by our Services. An individual who seeks access, or who seeks to correct, amend, or delete personal information provided by our Users should direct their request to the specific User. End Users may also contact us at firstname.lastname@example.org if you have additional questions or concerns.
- Marketing Communications. If you do not wish to receive promotional emails, you can click the “unsubscribe” button on promotional email communications. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices. We sometimes contact people who do not have a Cloud Copy account. For recipients in the EU, we or a third party will obtain consent before contacting you. If you receive an email and no longer wish to be contacted by Cloud Copy, you can unsubscribe and remove yourself from our contact list via the message itself.
- Analytics Services. As noted above, analytics providers may set tracking technologies (like cookies) to collect information about your use of the Services, and potentially your use of other websites and online services. For more information about how to manage and delete cookies, visit aboutcookies.org. For further information on what information is collected by analytics service providers and why, see the section Information Collection and Use above. You may also use the controls made available directly by our analytics providers to opt-out or opt-in to the tracking by certain analytics providers across all websites enabled with their services, subject to the user’s settings or practices regarding third party cookies, as more fully described the specific opt out instructions for each service, accessed below:
- Set Your Browser to Reject Cookies. At this time, Cloud Copy does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using the Services, with the drawback that certain features of the Services may not function properly without the aid of cookies.
- Close Your Account. Of course, while it’s hard to say goodbye, we understand that sometimes you just need to move on. You can delete your information from within your account or close your account and keep in mind that we may continue to retain your information after closing your account, as described in How We Store Your Information below–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests. We immediately begin the process of deleting your account from our systems upon your request, but it can take up to a month to complete.
- Access and Take Your Data. You can request a copy of the personal data you provided to us by sending a request to email@example.com.
HOW WE STORE YOUR INFORMATION
- Security. We use commercially reasonable physical, electronic, and administrative safeguards to protect the information we collect from loss, misuse and unauthorized access, disclosure, alteration, destruction, and to ensure that the information we process is reliable for its intended use, accurate, complete, and current to the extent necessary for the purposes for which we use the information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Please contact us immediately if you have reason to believe that your interaction with us is no longer secure. Our Security and Compliance page describes the measures we take to secure the Services and your data.
- Location of Storage. To provide you with the Services, we may store, process, and transmit information in the United States and locations around the world—including those outside your country. Information may also be stored locally on the devices you use to access the Services.
- Retention. When you sign up for an account with us, we’ll retain information you store on our Services for as long as your account is in existence or as long as we need it to provide you the Services or maintain records of our processing pursuant to applicable laws. If you delete your account, we will immediately initiate deletion of your information. Deletion of your information, including deletion of your information from our backup storage, will be completed within 30 days of your request. But please note we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
TRANSFERRING YOUR DATA
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield or Swiss-US Privacy Shield, as applicable; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
Your personal information is controlled by Cloud Copy, Inc. Have questions or concerns about the Services or your privacy? Contact our Data Protection Officer at firstname.lastname@example.org. If they can’t answer your question, you have the right to contact your local data protection supervisory authority.
See the Revision archive.