Privacy Statement

Effective: May 7, 2024

Cloud Software Group, Inc. and its subsidiaries (“Cloud Software Group”, “we”, “us”, and “our”) places importance on privacy and data protection.

This Privacy Statement describes our personal information processing practices, including the types of personal information we obtain, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of that information. The Privacy Statement also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

This Privacy Statement applies to the personal information we obtain through Cloud Software Group properties on which this Privacy Statement is posted, including websites, products, services, desktop and mobile apps, and other tools offered by Cloud Software Group that reference this Privacy Statement (“Online Channels”); offline collection, including Cloud Software Group events, surveys, questionnaires, customer user research and evaluations (“Offline Channels”); and third-party sources, including business partners, ad networks and vendors (collectively, the “Offerings”).

The Online Channels may provide links to other third-party websites and features. Some of these third-party websites may be co-branded with Cloud Software Group even though they are not owned, controlled, operated, or maintained by Cloud Software Group. Unless otherwise disclosed in this Privacy Statement or other supplementary privacy notice provided to you, Cloud Software Group does not automatically share your personal information with those third-party websites and is not responsible for their privacy practices. These websites are subject to their respective privacy policies. In some cases, we may provide the Offerings jointly with other businesses. For these co-branded offerings in which a third party is involved in your transactions, we will sometimes share or jointly collect customer data–which may include personal information–related to those transactions with that third party.

References in this Privacy Statement to “Cloud Software Group” are references to the Cloud Software Group entity responsible for the processing of your personal information, which generally is the Cloud Software Group entity that collects your personal information.

This Privacy Statement does not apply to personal information:

our employees provide us in connection with their employment, which is covered by our Internal Privacy Notice.
an individual makes available to us in connection with the recruitment process, which is addressed separately by our Candidate Privacy Notice.
processed on behalf of our customers when providing Cloud, technical support, and consulting services, which is described in the Cloud Software Group Data Processing Addendum and related product documentation. Customer end-users should direct any questions about our customers’ privacy practices to our customer who collected their information.

What Personal Information We Collect

The data we obtain varies based on the Offerings you use. We obtain personal information through your interaction with the Offerings, such as when you:

browse our website;
create an account in an Online Channel;
sign up for an online program, event, seminar, promotion or sweepstakes;
request products (including product evaluations, trials, tech preview and beta downloads), services or information;
participate in Cloud Software Group events including conferences, webinars, surveys, questionnaires, research or evaluations; or correspond with us or request information from us.

In addition to personal information you directly provide, we collect personal information from the following categories of sources:

third parties such as your employer, company administrator or business partner, through their use of the Offerings;
our affiliates;
social media networks;
personal information contained in forums, blogs, and testimonials you provide or that we obtain from publicly available sources (such as social media channels);
marketing and business information enrichment sources; and
advertising networks.

The types of personal information we obtain include:

contact information (such as name, email address, telephone number, postal, or other physical address) for you or for others (e.g., principals in your business or billing contacts);
identifiers (such as a real name, alias, postal address, unique personal identifier (e.g. device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name);
information used to create and administer your online account (such as username and password);
business profile and practices information used to evaluate you as a partner;
photographs, video images, voice recordings, or transcripts;
billing and financial information (such as name,signature, billing address, payment card details and bank account information and purchase history);
location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your device;
Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements information about your devices, files viewed, and other usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons, pixels, tags, and similar technologies (see our description of Cookies and Similar Technologies below);
time and date related access to events, offices, or facilities;
information collected in forms that may be required on-site to access Cloud Software Group facilities;
personal information contained in forums, blogs, and testimonials you provide or that we obtain from publicly available sources (such as social media channels);
information related to participation in classroom or online training, including programs completed and certifications achieved;
information necessary to provide support or other paid consulting services (such as contact details, chat services, support details, and event history);
commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
personal information contained in content you submit to us (such as through our “Contact” feature or other in-product or in-service messaging);
contact information we obtain from third-party information brokers and event organizers to enrich our sales & marketing database;
in addition to your contact information, if you’re submitting a report to the Cloud Software Group Integrity HelpLine, we also collect the contact information of the persons you name in your report if you provide such information, and a description of the alleged misconduct as well as a description of the surrounding circumstances;
other personal information we obtain through our Offerings; and
inferences drawn from any of the information identified above to create a profile about you reflecting your preferences.

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

How We Use Personal Information

We use the information we collect for the following business or commercial purposes:

to provide and administer our products and services (including websites and apps for which you have registered, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services);
to process and fulfill orders in connection with our products and services and keep you informed about the status of your order;
to help you complete a transaction or order and provide customer support;
to bill you for products and services you purchased;
to provide training, support, and consulting services;
to create and manage your account with Cloud Software Group;
to operate, evaluate and improve our business (such as by administering, developing, enhancing and improving our products and services; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
to perform data analytics (such as research, trend analysis, financial analysis, and customer segmentation);
to communicate with you about your account and orders (including sending emails relating to your registration, account status, order confirmations, renewal or expiration notices, and other important information);
to conduct advertising, marketing, and sales activities (including sending you promotional materials, generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns, and managing our brand);
to audit audit a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
to conduct short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
to communicate with you about, and administer your participation in, events, programs, promotions, and surveys;
to connect customer employees with their enterprise account administrator;
to verify your identity and protect your account against unauthorized use or abuse of our services;
to protect against, identify, and prevent fraud and other unlawful activity, claims, and other liabilities;
to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for such activity;
to protect the health, safety, and security of our employees;
to debug to identify and repair errors that impair existing intended functionality;
to undertake internal research for technological development and demonstration;
to undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
to comply with and enforce relevant laws, regulations, industry standards, contractual obligations, and our policies;
to maintain and enhance the security of our Online Channels, products, services, network services, information resources, and employees; and
to respond to your inquiries.

Depending on the purposes for which personal information is processed, and the context in which the data is obtained, we may rely on one or more of the following legal bases:

performance of a contract with you or other relevant individual data subject;
our legitimate business interests;
compliance with a legal obligation, a court order, or to exercise or defend legal claims; or
your consent, which you can revoke at any time.

We may combine data collected from you with other sources to help us improve the accuracy of our marketing and communications as well as to help expand or tailor our interactions with you. This includes combining personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information (such as referral programs), for the purposes described above. We may anonymize, pseudonymize, de-identify, and/or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we specify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

Cookies and Other Similar Technologies

Cloud Software Group uses cookies, web beacons (including pixels and tags), and similar technologies on our Online Channels which may read or write information on your device in order to collect certain information about you by automated means. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We use these automated technologies to collect information about your device or equipment, browsing actions, and usage patterns. The information we obtain in this manner includes IP addresses and other identifiers associated with your devices including Apple Advertising Identifier or Android Advertising ID, types of devices connected to our Offerings, device characteristics (such as operating system), language preferences, referring/exit pages, navigation paths, access times, email open rates, browser preferences and characteristics, installed plugins, local time zones, local storage preferences, clickstream data, and other information about your online activities.

We use on our Online Channels both first-party cookies (served directly by our website domain when you visit our Online Channels) and third-party cookies (served by a third-party website when you visit our Online Channels and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).

The cookies we use on our Online Channels include: strictly necessary cookies, functional cookies, analytics cookies, and targeting/advertising cookies, as described below.

Strictly Necessary Cookies

We use strictly necessary cookies on our Online Channels that are necessary for us to provide you with our products and services. These include cookies used to securely authenticate you to our website and identify you after you have logged in and user-centric security cookies used to increase the security of the products and services we provide to you (such as to detect authentication abuses). Given the necessary functionality of these cookies, they typically do not require consent.

Functional Cookies

These cookies allow us to analyze your use of the Online Channels to evaluate and improve our performance. They may also be used to provide a better customer experience on the Online Channels. For example, remembering your log-in details, saving what is in your shopping cart, or providing us information about how our site is used.

Analytics Cookies

We use analytics cookies to collect information on how users navigate and use our Online Channels, such as how the users traverse our Online Channels, the pages they view, how long they stay on a page and whether the page is displayed correctly or whether errors occur. Such cookies help us to improve the performance of our Online Channels and make the Online Channels more user-friendly. These cookies are provided by third-party analytics providers, including Google Analytics. To learn more about Google Analytics and how to opt out, please visit Google Analytics. To learn more about these analytics services and how to opt out, please view the Cookie Preferences link in the bottom of the page for the Cloud Software Group business you are interested in managing analytics cookies for.

Advertising Cookies

Advertising cookies are used to control and manage online advertisements. These cookies may collect information on whether a user has reacted to an advertisement and visited another website. Such cookies help us offer you content and provide targeted information that is more relevant to your interests. They also help us to measure the effectiveness of our advertisements and communications. In the EU, we deploy analytics and advertising cookies on our websites only when users have opted-in as required by applicable law.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Online Channels. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

Additional information about our cookie practices and how to manage your cookie preferences is available in the Cookie Preferences link in the bottom of the page for the Cloud Software Group business you are interested in managing cookie preferences for. To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.

The providers of third-party apps, tools, widgets, and plug-ins on our Online Channels (such as Twitter, LinkedIn and Facebook) also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, Cloud Software Group is not responsible for these providers’ information practices.

Interest-Based Advertising

When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners and social media platforms) collect information about your online activities, over time and across third-party websites (such as on websites that serve our ads). We may use such information to provide you with advertising about products and services tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our ads are served. You may see certain ads on other websites because we engage third-party ad buying networks. Through such buying networks, we can target our messaging to users through demographic, interest-based and contextual means.

The information our ad networks may collect on our behalf includes data about your visits to websites that serve Cloud Software Group advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third-party websites that participate in these ad networks. This process helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, click the Cookie Preferences link in the footer at the bottom of the page for the Cloud Software Group business you are interested in managing cookie preferences for. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.

Our Cookie Preferences link in the bottom of the page for the Cloud Software Group business you are interested in provides details about how to exercise your choices (such as changing your cookie preferences).

App Marketplaces

This Privacy Statement is not applicable to any additional data that may be collected by an online App Marketplace (e.g., Google Play Store, Apple App Store). App Marketplaces may collect and use other data about you. Please refer to the Privacy Policies of the App Marketplaces for more information.

ShareFile for Google Workspace: This app’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Why & With Whom We Disclose or Share Personal Information

We do not share or otherwise disclose personal information about you except as described here or at the time of collection. Cloud Software Group may share personal data in the following reasons:

if sharing your data is necessary to provide a product, service, or information you have requested;
as part of a joint sales promotion or to pass sales leads to our business partners;
to keep you up to date on the latest product announcements, software updates, special offers, or other information we think you would like to hear from our business partners;
within Cloud Software Group (including among affiliates and subsidiaries) for the purposes described in this Privacy Statement; and
to connect employees with their company administrator(s).

We share your personal information with the following entities:

with our affiliates and subsidiaries;
with our customers to report and help manage issues requiring support or as part of consulting services;
with our customers and partners to inform them about their users’ use of our services (such as when a user has obtained credentials or completed a course);
with persons connected to your business, such as your employer, company administrator or business partner;
with our vendors and service providers we have engaged to perform services on our behalf (such as payment processing, order fulfillment, customer support, customer relations management, and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements;
with approved Cloud Software Group Partners, to offer and provide our products and services to you;
with our joint marketing and sales partners and other business partners who help us with our business operations or other aspects of our business and for the purposes described in this Privacy Statement; and
with third-party marketers (who may combine your personal information with their own records, and records available from other sources), for their own direct marketing purposes, and the direct marketing purposes of other third-party marketers.

We also may disclose personal information about you for the following legal and public policy reasons:

if we are required or permitted to do so by applicable law, regulation or legal process (such as a court order or subpoena),
to law enforcement authorities or other government officials to comply with a legitimate legal request,
when we believe disclosure is necessary to prevent physical harm or financial loss to Cloud Software Group, its users or the public as required or permitted by law,
to establish, exercise or defend our legal rights, and
in connection with an investigation of suspected or actual fraud, illegal activity, security or technical issues.

In addition, we reserve the right to transfer to relevant third parties information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation) or other business transaction.

We also may share the information in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.

International Data Transfers

We transfer the personal information we collect through the Channels to, and store such data in, other countries in which Cloud Software Group and its service providers operate, including the United States, which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Statement. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information including, as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses pursuant to article 46 of the General Data Protection Regulation (GDPR) or by putting in place other appropriate data transfer mechanism(s).

Your Privacy Rights and Choices

To the extent provided by the law of your jurisdiction, you may have privacy rights to access, correct, update, amend, delete, restrict the processing of your personal information, or object to automated decision-making based on your personal information.

When Cloud Software Group is acting as a “data controller” under applicable law, you may exercise such rights by completing a Privacy Request form or by contacting us using the information under the How To Contact Us section of this Privacy Statement, or, where applicable, by accessing your Cloud Software Group account. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

When Cloud Software group is acting as a “data processor” and you wish to exercise your privacy rights of access and request corrections, suppression, or deletion, we will direct you to the data controller under the applicable data protection laws. Alternatively, to exercise any rights relating to personal information processed on behalf of our customers in connection with the use of our products and services, end users may directly contact the relevant customer, not Cloud Software Group. If you are a customer account administrator or customer account owner and require assistance with this process, such as if you want to make a request with respect to your own user data, you may contact us as described below.

Communication Preferences

We also offer choices in connection with the personal information we use to communicate with you, such as via email or telephone. To update your email and telephone communication preferences, limit the communications you receive from us, or submit a related request, please contact us as specified in the How to Contact Us section of this Privacy Statement. You can also unsubscribe from our email marketing by following the “Unsubscribe” link in our marketing emails. Please note that unsubscribing from marketing communications does not affect your receipt of operational communications that are important to your interaction with us or our services, such as communications about the status of your subscription, service changes, support communications, security updates, event registration updates or account management communications.

Interest-Based Advertising Choices

We support the Self-Regulatory Principles for Online Behavioral Advertising ("Principles") of the Digital Advertising Alliance in the U.S., the Digital Advertising Alliance of Canada, and the European Interactive Digital Advertising Alliance in the EU. If you live in the United States, Canada, or the European Union, you can visit Ad Choices, Ad Choices Canada or Your Online Choices to find a convenient place to indicate your preferences, including the option to make one "universal" opt-out of interest-based advertising with participating entities.

These websites also provide detailed information about interest-based advertising and tips for managing your privacy online and in applications. Opting out of interest-based advertising does not mean you will no longer see advertisements from us or on the Online Channels; rather, opting out means that the online ads that you do see will not be based on your interests. When you opt out of receiving interest-based advertisements through the links above, cookies and other technologies on the Online Channels may still collect information about your use of the Online Channels, including for analytics, fraud prevention, and any other purpose permitted under the Self- Regulatory Principles.

Global Privacy Control (GPC)

Cloud Software Group recognizes Global Privacy Control (“GPC”) signals where legally required. GPC is a browser setting that a user can set in order to send a signal to websites visited regarding the user’s cookie preferences. If your browser or browser extension has GPC enabled, we will recognize that signal and opt you out of non-essential cookies. For more information about GPC and how to implement GPC opt-out preference signals, please visit globalprivacycontrol.org.

Other Online Preferences

When you use our Online Channels, both we and certain third parties (such as our advertising networks, digital advertising partners, and social media platforms) may collect personal information about your online activities, over time and across third-party websites. Certain web browsers allow you to instruct your browser to send Do Not Track (“DNT”) signals to websites you visit, informing those sites that you do not want your online activities to be tracked. Our Online Channels are not designed to respond to “do not track” signals received from web browsers. However, you can manage your cookie preferences in connection with the personal information we collect about you by clicking on the Cookie Preferences link in the bottom of the page for the Cloud Software Group business you are interested in managing cookie preferences for.

Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal. You may also have a right to lodge a complaint with the supervisory authority or other data protection regulator in your jurisdiction.

Some of the rights described above may be subject to limitations under applicable law.

How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of Personal Information.

How Long We Retain Personal Information

To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it, in accordance with the terms of this Privacy Statement, which generally means that we will keep your personal information for the duration of our relationship or as long as you keep your account open with us; (2) only for as long as we have a legitimate business need; and/or (3) for complying with legal requirements, taking into account applicable statute of limitation periods and complying with applicable laws, resolve disputes, and enforce our agreements. As described in the “Your Privacy Rights and Choices” section above, to the extent provided by the law of your jurisdiction, you may request that we delete your information or restrict the processing of such information by contacting us as indicated below.

Children’s Personal Information

The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Privacy Statement.

Supplemental Notice to California Residents

This section applies solely to California consumers and is intended to address the relevant notice requirements of the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 et seq. (the “CCPA”). Certain terms used herein have the meaning given to them in the CCPA.

Collection, Use, and Sharing

During the prior 12-month period, we may have collected, used, and shared your personal information as described in this Privacy Statement. Each category of personal information we may use or share with third parties is outlined in this Privacy Statement.

We Do Not Sell Your Personal Information

California residents have the right to know whether your personal information is being sold. Your personal information is “sold” when it is provided to a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA. We do not sell your personal information.

Your California Privacy Rights

California residents have the privacy right to:

Know what specific pieces of personal information we have collected and retained about you over the previous 12 months;
Correct inaccurate personal information we may have retained;
Receive a copy of your personal information;
Delete your personal information;
Limit our use of your sensitive personal information; and
Opt out of our sharing of your personal information.

To opt out of our sharing of your personal information through cookies and other similar technologies, click the Cookie Preferences link in the footer at the bottom of the page for the Cloud Software Group business you are interested in managing cookie preferences for.

To submit a request related to your other California privacy rights, you may complete a Privacy Request form or contact us as specified in the How To Contact Us section below. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. We will not deny, charge different prices for, or provide a different level or quality of goods or services if you choose to exercise these rights.

Changes to Our Privacy Statement

This Privacy Statement may be updated periodically to reflect changes in our privacy practices. We will indicate at the top of this Privacy Statement when it was most recently updated. However, if we make any material change, we will notify you by means of a notice on this website or by other means prior to the change becoming effective. By continuing to use our Offerings after such revisions are in effect, you accept and agree to our revised Privacy Statement. We encourage you to periodically review this Privacy Statement for the latest information on our privacy practices.

How to Contact Us

If you have questions, requests or concerns relating to one of our customer’s handling of your personal information, please contact the relevant customer. If you have any questions or comments about our privacy practices, this Privacy Statement, or your privacy rights and preferences, you may contact us at:

Cloud Software Group
Attn: Chief Privacy Officer (CPO)
4980 Great America Parkway
Santa Clara, CA 95054
United States
privacy@cloud.com

In addition to our above internal contact information, we have appointed a Data Protection Officer (DPO) for the EU, UK, Germany, and Singapore. If you wish to contact them, their details are as follows:

Bird & Bird Privacy Solutions
Bird & Bird DPO Services SRL
Avenue Louise 235 Box 1
1050 Brussels
Belgium
DPO.Cloud@twobirds.com