CloudOn complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. CloudOn has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement with respect to the information collected through the Services. To learn more about the Safe Harbor program, and to view CloudOn’s certification, please visit http://www.export.gov/safeharbor/.
Information Collection and Use
CloudOn believes in transparently providing users, customers and clients with information on how we treat information that we receive from you. We collect information to provide and improve the Services, and any features and/or content offered therein, and to enable users to enjoy and easily navigate the Services.
In the course of using the Services, you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”).
The Personal Information we collect is described below:
Registration Information. When you register to use the Services directly or through a Third Party Account, or contact us for more information regarding our products or services, we may collect certain Personal Information, such as your name and email address. Once you have registered for an Account we will provide you with the opportunity to connect the Services with External Storage Systems that you use. When you choose to do so, we may collect information from you, including your login credentials for your third party service in order for you to access your documents or contact lists. In some cases, the specific information that we extract may depend on the privacy settings you have with the External Storage Systems or Third Party Account. You hereby consent to our access to and collection of such Personal Information about you. You agree to provide and maintain accurate and complete registration data.
This Personal Information will be used to authenticate and identify you for the use of the Services and to provide Services features that will benefit you. We may also contact you regarding the Services and any important changes made to them as may be required. In some cases, if we want to send you communications about new features to the Services, you will have the option to opt-in to such communications. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications.
Location Information. We do not ask you for, access or track any geo-location information from your mobile device at any time using our Services. We may determine your city and country through your IP address.
Payment Information. Our payment service providers may collect the following information from you if you pay for a subscription: credit card information, billing information, and other related payment information. This information will only be used to process payment for the subscription based on the service level you choose. We receive information related to confirmation of payment from our payment service providers, but we do not receive any credit card or other payment information.
In addition to the above, we may also use Personal Information:
- To help us develop, deliver, and improve the Services, content and advertising;
- To provide Services updates or product announcements;
- For internal purposes such as auditing, data analysis, and research to improve the Services and customer communications; and
- To contact you with CloudOn newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Control of Personal Information” below.)
Non-Identifying or Non-Personal Information
We also collect other information that you provide as you use the Services (“Non-Identifying Information”).
- We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Services and administer your inquiries.
- When you download and use the Services, we and our third-party service providers, such as ad networks and analytics service providers, may collect the following Non-Identifying Information with your permission: (i) mobile device type, device identification code and device properties; and (ii) regional geographical data.
- Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how the Services are used.
Cookies and Other Technologies
Like many services, we and our third-party service providers, such as ad networks, email service providers, and analytics service providers, may use “cookies” and other technologies such as log files, pixel tags, and web beacons. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. First, we utilize certain technology to save your login information for future logins into the Services. Second, we use other technology to enable certain features of the Services, to better understand how you interact with the Services, and to monitor aggregate usage by CloudOn users and web traffic routing on or through the Services. If you do not want this information collected, you may cease using the Services and delete the Application from your device.
When you access or otherwise use the Services, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your device’s Internet protocol (IP) addresses, information about your usage of the Services, the type of device you are using the access the Services, the time spent on various features of the Services (e.g. time spent using certain Third Party Software or features of certain Third Party Software you utilize), information you search for through the Services, access time and dates, and other statistics. We use Log Data collected through the Site and Application to understand and analyze trends, to administer the Services, to learn about user behavior on or through the Services, to increase the functionality and user-friendliness of the Services, to better tailor it to our visitors’ needs, for troubleshooting purposes and to gather demographic information about our user base as a whole. CloudOn may also use this information in connection with marketing our Services.
We and our email service providers also use pixel tags to enable us to send email messages in a format that customers can read. These pixel tags also enable us to tell whether mail has been delivered and opened. We may use this information to reduce or eliminate messages sent to customers.
Information Sharing and Disclosure
We will share your personal information with third parties only in the ways that are described in this privacy statement.
Files. We will share access to any content you make available via the Services only in accordance with the selections you make via the Services. For example, if you choose to invite a third party to access and edit your content via the Services, we will provide such third party with access to the applicable content. Accordingly, please carefully consider inviting any third party to access your content via the Services.
Compliance with Laws and Law Enforcement. CloudOn cooperates with government and law enforcement officials and private parties to enforce and comply with the law. Thus, it may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for CloudOn to disclose your Personal Information and Non-Identifying Information to respond to claims and legal process (including but not limited to subpoenas) and to protect the property and rights of CloudOn or a third party. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
Protection of our Operations and Users. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our Terms of Service, or protect our operations or users.
Business Transfers. In the event of a reorganization, merger, or sale of assets of CloudOn, or in the event of bankruptcy, we may sell, transfer or otherwise share some or all of our assets, including any and all Personal Information we collect, to the relevant third party.
Service Providers. We may also employ third party companies and individuals to provide and facilitate our Services and to perform Services-related services (e.g., without limitation, maintenance services, database management, web analytics, and email service provider to send emails on our behalf, and improvement of the Services’ features) or to assist us in analyzing and improving how our Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
If you choose to use our referral service to tell an individual about one of our blog posts or send them a document, we will ask you for your friend’s email address. We will automatically send your friend a one-time email inviting him or her to view the post or document. CloudOn does not store this information.
Social Media Features
Links to Other Sites
Our Services may include links to other websites whose privacy practices may differ from those of CloudOn. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
Our Services may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. When we collect sensitive information such as billing information we protect it using SSL encryption. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Services, you can contact us at email@example.com.
Control of Personal Information
You may review, update or correct or delete your Personal Information at any time by contacting us or logging into your Account and making the applicable changes. If you completely delete all such information, then your Account may become deactivated. If you would like us to delete your Account in our system, please contact us at firstname.lastname@example.org with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. We will respond to requests for access within 30 days.
Third Party Services
We may make our Services available to you through third party stores like Apple App Store or the Android Store. We do not exercise control over these third party websites or services. These other websites and services may place their own cookies or other files on your computer and collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
The Services are not directed to persons under 13. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com. If we learn that we have collected the personal information of a child under 13 we will take steps to delete the information as soon as possible.
Questions or Complaints
If you are located in the EU and you have concerns about our privacy practices, we ask that you first submit any such questions or concerns directly to us via firstname.lastname@example.org. If you aren't satisfied with our response, please contact JAMS at http://www.jamsadr.com/file-safe-harbor-claim/. JAMS is an independent organization responsible for reviewing and resolving complaints about our Safe Harbor compliance.
Effective Date: January 1 2012
Last Updated Date: January 16, 2015