Date Last Updated: September 27, 2016
COLLECTION OF PERSONAL INFORMATION
We collect Personal Information in connection with our Services. When we use the term “Personal Information” we mean information about an identified or identifiable individual. “Personal Information” may include, but is not limited to, your full or partial name, user ID, password, postal address, email address, phone number, and any profile information you choose to submit through our website, application or other Services, as well as (if applicable) your company name and contact information. “Personal Information” also includes any credit card or debit card or other financial account information you may provide to us or to our third-party payment application provider for billing purposes. However, information you submit solely through a third-party payment application provider for billing purposes, including credit and debit card or bank account information, will not be stored on our servers. If you are a Developer or Reseller, “Personal Information” also includes information that we collect, with your enablement and consent, about your End Users, including the people who use your CloudMine-enabled mobile app(s), and may include whatever information you agree to provide to us, including, but not limited to, your End Users’ e-mail addresses, passwords, and data generated from CloudMine-enabled apps on their mobile devices, to the extent such data contains Personal Information. It is each Developer’s and each Reseller’s responsibility to obtain permission from its End Users to collect any Personal Information pertaining to them that you elect to share with us, and we will not collect any more information than you specifically request that we collect through the Services. It is also each Developer’s and each Reseller’s responsibility to make the appropriate privacy disclosures to its End Users, including disclosures to the effect that a Developer or a Reseller is collecting the Personal Information from them, disclosures to the effect that a Developer or a Reseller may share the information with us, and any other disclosures required under the law that relate to the collection and use of your End Users’ Personal Information and sharing of same with third parties. You may always choose not to provide Personal Information, but this may prevent you from receiving certain Services. CloudMine may also collect “Non-Personal Information” about you, including each End User of each Developer or Reseller. “Non-Personal Information” means information that is not Personal Information, such as aggregated, anonymized information, information about devices, and demographic information that does not identify any particular person. Some examples of Non-Personal Information that we may collect include the device name and model used to connect to the Services, the operating system of the device, the Internet Protocol (“IP”) address, use information, including anonymized statistics about data usage per app and per Developer or per Reseller, unique device identifiers for each device that runs a CloudMine-enabled mobile app, browser and browser speed, the carrier or other provider of the device’s Internet connection, the amount of bandwidth of the Internet connection, the location of the server each carrier uses, and the CloudMine service endpoints that were accessed during a visit. Please note that we are not responsible for the privacy policies, practices, or the content of websites owned by others that you may link to or that may be linked from the Services. Accordingly, we encourage you to review the privacy policies and terms of service of those websites so that you understand how those websites collect, use and share any Personal Information.
USE OF PERSONAL INFORMATION
CloudMine uses Personal Information to assist us in setting up accounts; improving online operations; processing transactions; providing customer service; providing newsletters, RSS feeds, and/or other communications or services which you have signed up for or otherwise agreed to receive; displaying content that is customized to your interests or preferences; sending account- or transaction-related communications such as welcome letters and transaction confirmations; performing research and analysis aimed at improving our products, services and technologies; and managing our systems. We may also use this information for internal purposes to help us diagnose problems, monitor traffic patterns and otherwise continually improve our Services.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose Personal Information and Non-Personal Information about Developers, Resellers and End Users to other users of the Services and to companies, agents, contractors, service providers or others engaged to perform functions on our behalf (such as processing payments, providing data storage, hosting our website, conducting audits and performing web analytics). We may also disclose Personal Information and Non-Personal Information about Developers and Resellers to companies, agents, contractors, service providers or others engaged to perform functions on our behalf to market CloudMine products and services to Developers and Resellers (for example, to send Developers and Resellers messages concerning new CloudMine features or products or CloudMine special offers). We may also disclose your Personal Information to third parties, in our sole discretion, to (a) enforce or apply the terms and conditions of the Services, including investigations of potential violations thereof, (b) comply with legal or regulatory requirements or a governmental request including to meet national security or law enforcement requirements, (c) protect the rights, property or safety of CloudMine, our Developers, Resellers, the End Users and other users or other third parties, (d) to any authority, such as a police department or regulatory authority, or (e) detect, prevent or otherwise address fraud, security or technical issues. We may also disclose Non-Personal Information to our clients, developers, business partners, merchants, advertisers, investors, potential buyers and other third parties in our sole discretion. CloudMine reserves the right to transfer information (including your Personal Information and Non-Personal Information) to a third party in the event of a reorganization, spin-out, sale, merger, or transfer of some or all of the assets of our company, or in the unlikely event of a bankruptcy, liquidation or receivership of our business. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield (see section below), CloudMine is potentially liable. We only share your personal information with third parties who are acting as our agents to complete tasks necessary to the functioning of the business and therefore we do not currently offer an opt-out choice for this shared data. If our policy should change in the future, we will notify you and give you an opt-in or opt-out choice.
ACCESSING AND UPDATING PERSONAL INFORMATION
CloudMine acknowledges the individual’s right to access their personal data. When you use our Services, we make reasonable good faith efforts to provide you with access to your Personal Information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Please e-mail us at firstname.lastname@example.org or contact us at the address stated below with any questions, if you need assistance accessing or changing your Personal Information, or if you would like to have your Personal Information deleted. Please be aware that if you delete your Personal Information, you may not be able to continue to use our website or other Services. Please note that if you request that we delete your Personal Information, we may in our sole discretion retain certain information, including your Personal Information, for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements. We may also retain your Non-Personal information.
COOKIES AND AUTOMATIC INFORMATION GATHERING TECHNOLOGIES
We do not knowingly collect Personal Information from users under 13 years of age. While we permit Developers to use CloudMine with apps intended for use by End Users under the age of 13, we do not permit or knowingly allow the Services to be used to collect Personal Information from such End Users. If we learn that we have inadvertently collected Personal Information from a child under the age of 13, whether that child is a Developer, End User, or other user of the website or Services, upon receipt of notice from the child or a parent or guardian we will delete that child’s Personal Information from our systems.
We utilize a number of information security measures to safeguard your Personal Information. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we do not guarantee its security.
YOUR CALIFORNIA PRIVACY RIGHTS
MESSAGE BOARDS AND OTHER ONLINE FORUMS
Please note that when you choose to post messages and/or profile content on messages boards and other online forums we may make available to you on our website or other Services, such content is viewable by third parties and, in the case of public online forums, is publicly viewable. Accordingly, you should exercise discretion with regard to what Personal Information you post on our Services and on third party web sites, and should not post highly confidential or sensitive information. CloudMine is not responsible for how third parties who view your Personal Information may use this information (such as to send you unsolicited messages).
EU-US PRIVACY SHIELD
US-SWISS SAFE HARBOR
CHANGES TO THIS POLICY
CLOUDMINE, INC. ATTN: PRIVACY MATTERS
1217 SANSOM STREET, FLOOR 6
PHILADELPHIA, PA 19107