Cloud Advisor Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, CloudAdvisor LLC (together, “Cloud Advisor” “we”, “our” or “us”) use, collect and store Personal Data we collect or receive from or about you (“you”) such as in the following use cases:

1. 1. When you browse or visit our website, https://www.cloudadvisor.app/ (“Website”)

2. 2. When you make use of, or interact with, our Website

   1. a. When you subscribe to our distribution list(s) / newsletter(s) / blog (s)

   2. b. When you request a demo

   3. c. When you contact us (e.g. customer support, help, submit a request, chat)

3. 3. When you interact with us on our social media profiles (e.g., Facebook, LinkedIn, Twitter)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

1. 1. What information we collect, why we collect it, and how it is used

2. 2. Period of storage of collected information

3. 3. How we protect and store your personal data

4. 4. How we share your personal data

5. 5. Additional information regarding transfers of personal data

6. 6. Your rights

7. 7. Use by children

8. 8. Public information about your activity on the services

9. 9. Links to and interaction with third party product

10. 10. Log files

11. 11. Cookies and other tracking technologies

12. 12. Analytic tools

13. 13. California privacy rights

14. 14. How to contact us

This Privacy Policy can be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes.

2. PERIOD OF STORAGE OF COLLECTED INFORMATION

2.1. Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

2.2. Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings.

3. HOW WE PROTECT AND STORE YOUR INFORMATION

3.1. Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

3.2. Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

4. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

4.2. We may use third party service providers to process your Personal Data for the purposes outlined above, including, without limitation:

4.2.1. With cloud service providers for hosting purposes;

4.2.2. With service providers in order to help us manage our Website and Platform;

4.2.3. With email providers, marketing, CRM, notification tool, lead tools and other similar tool providers; and

4.2.4. With analytic companies, in order to help us understand and analyze data we collect (which may include Personal Data) in accordance with this policy.

4.3. To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

4.4. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your Personal Data to such third party (whether actual or potential) in connection with the foregoing events;

4.5. In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or

4.6. Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

If you want to receive the list of recipients of your Personal Data, please make your request by contacting us to info@cloudadvisor.app.

5. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

5.1. Storage: We store the Personal Data with the following storing companies: Yandex Cloud with servers located in the Russian Federation.

5.2. External transfers: Where we transfer your Personal Data (for example to third parties who provide us with services), we will generally obtain contractual commitments from them to protect your Personal Data in accordance with the requirements under applicable privacy law.

6. YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

• You have the right to request that we rectify any Personal Data we hold that it is inaccurate or misleading;

• You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;

• The right to object, to or to request restriction, of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;

• The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

• You have the right to object to profiling;

• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;

• The right to withdraw your consent. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations.

• You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.

You can exercise your rights by contacting us at info@cloudadvisor.app. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

7. USE BY CHILDREN

We do not offer our products or services for use by children. If you are under 18, you shall not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

8. PUBLIC INFORMATION ABOUT YOUR ACTIVITY ON THE SERVICES

Some of your activity on and through the Services is public by default. This will include, but not limited to, content you have posted publicly on the Website or otherwise through the Services.

Registered users can have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) can be tracked anonymously through the use of cookies and stored by us.

Please also remember that if you choose to provide Personal Data using certain public features of the Services, then that information is governed by the privacy settings of those particular features and can be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

9. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Website enables you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

10. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

11. COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Website utilizes “cookies”, anonymous identifiers and other tracking technologies in order for us to provide our Website and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Website. Certain cookies and other technologies may serve to recall Personal Data, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

12. ANALYTIC TOOLS

Yandex.Metrica. The Website uses a tool called “Yandex.Metrica” to collect information about use of the Website. Yandex.Metrica collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Yandex.Metrica to maintain and improve the Website and our products. We do not combine the information collected through the use of Yandex.Metrica with personally identifiable information. Yandex’s ability to use and share information collected by Yandex.Metrica about your visits to this Website is restricted by the Yandex.Metrica Terms of Use, available at https://yandex.com/legal/metrica_termsofuse/, and the Yandex Privacy Policy, available at https://yandex.com/legal/confidential/. You may learn more about how Yandex collects and processes data specifically in connection with Yandex.Metrica at https://yandex.com/support/metrica/general/how-it-works.html. You may prevent your data from being used by Yandex.Metrica by downloading and installing the Yandex.Metrica Opt-out Browser Add-on, available at https://yandex.ru/support/metrica/general/opt-out.html?lang=en.

We reserve the right to use other analytic tools.

13. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to info@cloudadvisor.app. Please note that we are only required to respond to one request per customer each year.

14. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@cloudadvisor.app.