Privacy Policy

Last updated March 11, 2022

This privacy policy (“Policy”) describes how CloudThread, Inc. (“Company”, “CloudThread”, “we”, “us”) collects, uses, and shares personal information of consumer users of this website, http://www.cloudthread.io (the “Site”), as well as associated products and services, including mobile applications (together, the “Services”), and applies to personal information that we collect through the Site and our Services as well as personal information you provide to us directly.  This Policy also applies to any of our other websites that post this Policy.  Please note that by using the Site or the Services, you accept the practices and policies described in this Policy and you consent that we will collect, use, and share your personal information as described below.  If you do not agree to this Policy, please do not use the Site or the Services.

Index

Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children
Notice to European Users
Changes to this Privacy Policy
How to contact us

Personal information we collect

Personal information you provide to us. Personal information that you may provide to us through the Services or otherwise includes:

   • Contact information, such as your first and last name, email and mailing addresses and phone number.
   • Business information, such as the name of your business, your job title and business contact information.
   • Communications information based on exchanges with you, including when you contact us with questions, feedback, request customer support or otherwise.
   • Marketing information, such as your preferences for receiving our marketing communications and details about your engagement with them.
   • Social media information, such as information you use to login to, and posts you make on, our social media accounts.  
   • Payment information, such as the billing details and credit card information we use to bill you for our Services, your billing and payment history, and any records of personal property that we collect in connection with providing our Services to you.
   • Transaction information, such as the purchase price and date and location of the transaction.
   • Government-issued identification numbers such as your tax identification number to facilitate monetary payments to/from you.
   • Information from job application materials or recruiters, such as your job application, resume or CV, cover letter, writing samples, references, work history, information for checking conflicts of interest (such as your work with specific clients and on specific matters), education transcripts, whether you are subject to prior employer obligations, and information that referrers provide about you.
   • Cloud account information, such information about your Amazon Web Services account, settings in your cloud accounts, usage information and information regarding the costs of cloud-based services to you.
   • Other information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as social media platforms.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services, such as:

   • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
   • Location information that we may derive from your IP address.
   • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Like many online services, we may use the following technologies:

   • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns and facilitating analytics.
   • Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
   • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Services delivery. We may use your personal information to:

   • Provide, operate and improve the Services and our business;
   • Personalize and improve your experience on our Services;
   • Process your payments and complete transactions with you;
   • Communicate with you about the Services, including notifications about changes in the Services, provide expiration and renewal notices, technical notices, security alerts, support and administrative messages and marketing messages, including newsletters and emails;
   • Understand your needs and interests, and personalize your experience with the Services and our communications; and
   • Provide support for the Services, respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

Marketing. We may send you CloudThread-related direct marketing communications as permitted by law, including by email. We may also use your personal information to deliver personalized advertisements that you may see on third-party platforms and websites. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

   • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
   • Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
   • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
   • Enforce the terms and conditions that govern the Services; and
   • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

We may use your personal information for other purposes that we describe to you at the time that we collect the personal information from you.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Service providers. Third parties and vendors that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, payment processors, customer support, email delivery, and website analytics services).

Payment processing. We utilize Stripe, Inc. (“Stripe”) to process credit card payments. Stripe may receive and process personal information about you in connection with processing payments on our behalf. You can view Stripe’s privacy policy by visiting https://stripe.com/us/privacy.  

Advertising and analytics. We allow others to provide analytics services and serve personalized advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes by certain companies, please visit www.aboutads.info/choices. To view a list of companies that we utilize to serve interest-based advertising about the Services online, and to exercise choices regarding the use of your personal information in interest-based advertising, visit the Your Choices section below.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, CloudThread or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our Services, including our social media accounts, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

Your choices

You have the following choices with respect to your personal information.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email. You may also contact us below. You may continue to receive service-related and other non-marketing emails.

Cookies. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Services and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Local storage. You may be able to limit use of HTML5 cookies in your browser settings. Unlike other cookies, Flash-based local storage cannot be removed or rejected via your browser settings, but you can adjust the settings of your Flash player to block it. Blocking Flash storage may impede the functionality of Flash applications, including those employed by the Services. For more information on Flash local storage visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Analytics. We use Google Analytics to help us understand user activity on the Services. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Interest-based advertising. We use remarketing services to advertise the Services on third-party websites. We use cookies to inform, optimize and serve ads based on your past visits to the Site and use of the Services. Specifically, we use the following advertising services in order to promote our business and the Services through interest-based advertising online:

   • Google Ads (AdWords). You can opt-out of the use of Google, Inc. Ads by visiting http://www.google.com/settings/ads. You can view Google’s privacy policy by visiting https://policies.google.com/privacy?hl=en.
   • Microsoft Bing Ads. You can opt-out of the use of Bing ads by Microsoft, Inc. visiting https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads. You can view Microsoft’s privacy policy by visiting https://privacy.microsoft.com/en-us/PrivacyStatement.
   • Twitter Ads. You can opt-out of the use of Twitter Inc.’s interest-based ads by visiting https://support.twitter.com/articles/20170405. You can view Twitter’s privacy policy by visiting https://twitter.com/privacy.
   • Facebook Remarketing. You can opt-out of the use of Facebook, Inc.’s interest-based ads by visiting https://www.facebook.com/help/568137493302217. You can view Facebook’s privacy policy by visiting https://www.facebook.com/privacy/explanation.
   • Pinterest Remarketing. You can opt-out of the use of Pinterest, Inc.’s interest-based ads by visiting http://help.pinterest.com/en/articles/personalization-and-data. You can view Pinterest privacy policy by visiting https://about.pinterest.com/en/privacy-policy.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

European users. If you are a resident of the European Economic Area (“Europe”), you may have additional choices with respect to your personal data. See the “Notice to European Users” section below.

Other sites and services

The Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.

Notice to European Users

The information provided in this “Notice to European Users” section applies only to individuals in Europe.  

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller. CloudThread, Inc. is the controller of your personal information covered by this Privacy Policy for the purposes of European data protection legislation, except to the extent that we process your personal information on behalf of our customer, in which case our customer is the controller of your personal information, and CloudThread, Inc. is the processor.

We have appointed a Data Protection Officer, whose contact information is:  Thomas Yopes, Chief Technology Officer, Cloudthread, Inc., 2810 N Church St PMB 65058 Wilmington, Delaware 19802-4447, thomas@cloudthread.io.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Processing Purpose
Legal Basis
To operate the Services
Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the Services you access and request.
For research and development
To send you marketing communications
To display advertisements
For compliance, fraud prevention and safety
To create anonymous data
These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise permitted to by law).
To comply with law
Processing is necessary to comply with our legal obligations.
With your consent
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it at any time in the manner indicated when you consent or in the Services.

Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.
If you provide us with any sensitive personal information when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Services.

Automated Decision-Making and Profiling. We do not use automated decision-making and/or profiling in regard to your personal information in connection with the Services.

Retention. We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Your rights.  

European data protection laws give you certain rights regarding your personal information. If you are located within the European Economic Area or Switzerland, you may ask us to take the following actions in relation to your personal information that we hold:

   • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
   • Correct. Update or correct inaccuracies in your personal information.
   • Delete. Delete your personal information.
   • Transfer. Transfer a machine-readable copy of your personal information to a third party of your choice.
   • Restrict. Restrict processing of your personal information.
   • Object. Object to our reliance on our legitimate interests as a legal basis of our processing of your personal information that impacts your rights.

You may submit these requests by email to privacy@cloudthread.io or our postal address provided below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer.

If we transfer your personal information out of Europe to a country not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be performed:

   • Pursuant to the recipient’s compliance with standard contractual clauses or Binding Corporate Rules;
   • Pursuant to the consent of the individual to whom the personal information pertains; or
   • As otherwise permitted by applicable European requirements.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

You can reach us by email at privacy@cloudthread.io or at the following mailing address:

CloudThread, Inc.
2810 N. Church St. PMB
65058 Wilmington, Delaware  19802-4447
Phone:  (415) 520-3270