Privacy Policy

Cloud Generation, LLC (“Cloud Generation”) is committed to protecting your privacy.

This Privacy Policy explains our data practices for subscribers to our Software Services (“Subscribers”) and visitors to our Website, choices available to you regarding the use of, your access to, how to update and correct your Personal Data (as defined below) and other information that we collect in connection with:

(i) your visit to our Website www.cloudgeneration.com (where you can learn more about the Cloud Generation’s products and services, and request information and content);

(ii) your use of our mobile applications (together, the “Apps”);

(iii) events you may attend to (for example, trade shows).

Our use of information on behalf of Subscribers who have registered to use Cloud Generation applications (pursuant to which our Subscribers offer access to a Website for their employees, customers and other authorized individuals) is governed by our contract with that Subscriber and the Subscriber’s own privacy policies. We are not responsible for the privacy policies or privacy practices of Subscribers or other entities.

By using our Website and/or the Apps, you consent to policies and practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use our Website or Apps.

Our Collection of Your Personal Data

Cloud Generation collects and uses information that, alone or in combination with other information, could be used to identify you (“Personal Data”) in order to deliver our products and services, process applications to join programs, inform you of various opportunities, and provide support, as described below (please also see the “How We Use Information” section below).

The following table describes (1) the categories of Personal Data we collect, (2) examples of the types of information that fall within each category of Personal Data collected, (3) how we use each category of Personal Data, and (4) how we disclose Personal Information.

Categories of Personal Information	Examples	Sources of Personal Information	Use of Personal Information	Disclosure Of Personal Information
Identification Information	Your name, email address, postal address, telephone number, and your company name, size, and job title.	We collect Identification Information from you voluntarily when you interact with our products, services, and customer service. We may also receive information about you from publicly available and third-party databases or services that provide information about business people and companies, or from entities from whom we have purchased information.	We use Identification Information to (1) provide you support or other services you have ordered from us, as well as product updates, product patches and fixes and other similar operational communications; (2) respond directly to your information requests (including registrations or other specific requests) or other inquiries; and (3) facilitate your engagement in the Cloud Generation User Group. For EU Data Subjects, these uses are necessary for the performance of the contract between you and us. We also use Identification Information to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.	We disclose Identification Information to (1) service providers who provide certain services to us to assist us in meeting business operation needs, including: Providers of payment processing and accounting, as necessary to process payment from our subscribers, Learning management systems that integrate with our platform, Customer service providers, Providers helping us fulfill subscription services (such as Salesforce), Providers of research and analytics services, including Google Analytics, Providers of cloud computing infrastructure services.
Interaction Information	Your name and contact information and information that you elect to upload to your profile, such as a biography, your education and job history, company information.	We collect Interaction Information when you interact with our products, services, and customer service, when you create a profile in the Cloud Generation Apps.	We use Interaction Information to (1) provide you support or other services you have ordered from us, as well as product updates, product patches and fixes and other similar operational communications; (2) respond directly to your information requests (including registrations or other specific requests) or other inquiries; and (3) facilitate your engagement in the Cloud Generation Apps. For EU Data Subjects, these uses are necessary for the performance of the contract between you and us. We also use Identification Information to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.	We disclose Interaction Information to (1) service providers who provide certain services to us to assist us in meeting business operation needs, including: Providers of payment processing and accounting, as necessary to process payment from our subscribers, Learning management systems that integrate with our platform, Customer service providers, Providers helping us fulfill subscription services (such as Salesforce), Providers of research and analytics services, including Google Analytics, Providers of cloud computing infrastructure services.
Automatically-Collected Data	When you visit the Websites we may collect your IP address, browser type/settings, search terms used, and the data and time of your visit, ISP, site usage data, referring/exit pages, clicks, and ads viewed, among other things.	We collect Automatically-Collected Data through cookies, web beacons and other technologies (“Tracking Technologies”).	We use Automatically-Collected Data for system administration, technology management, including optimizing our websites and applications, information security and cybersecurity purposes, including detecting threats, for recordkeeping purposes, to better understand our customers and prospective customers and to enhance our services, for online targeting and advertising purposes, and for our everyday business purposes.	We may disclose Automatically-Collected Data Information to (1) service providers who provide certain services to us to assist us in meeting business operation needs, including: Providers of research and analytics services, including Google Analytics, Providers of cloud computing infrastructure services.

Other Disclosures. We may also disclose Personal Data: (1) if you request or authorize (2) to comply with law, including responding to a warrant or subpoena or other government requests, (3) to protect the rights, property, or safety of us or others, (4) to investigate fraud, (5) for law enforcement purposes, (5) if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, in which case your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets or as part of the diligence process.

Service Data. In providing our services to Subscribers through the Platforms, we also process on behalf of Subscribers information, including Personal Data, that Subscribers upload to, integrate with or otherwise submit to our services. Our Subscribers decide what data to submit (this typically includes information about their customers, prospects, employees, consultants or independent contractors, suppliers and other individuals or entities). We only collect such information under the direction of Subscribers and have no direct relationship with the individuals whose Personal Data we process.

Our use of information collected through the Platforms on behalf of our Subscribers is limited to the purpose of providing the service for which the Subscriber has engaged Cloud Generation and is governed by our contract with that Subscribers and the Subscriber’s own privacy policies.

Social Media

The Websites use interfaces with social media websites or platforms that are owned and/or controlled by other entities, such as Facebook, LinkedIn, Twitter and others (“Social Media Sites”). If you choose to “like” or share information from a Website through any Social Media Sites, if you are a member of a Social Media Site the interfaces on our Websites may allow the Social Media Site to connect your Website visit to your Personal Data. The information that you share with the Social Media Sites will be governed by the specific privacy policies and terms of service of the Social Media Sites and not by this Privacy Policy. You should review the privacy policy of that Social Media Site before choosing to access and use any Social Media Sites, including interacting with our pages on those sites.

How You Can Access and Change Information

Cloud Generation acknowledges that you may have the right to access your Personal Data. Our Website and Apps allow you to access, correct, amend, or delete inaccurate data. In case you request us to remove data, we will respond within a reasonable timeframe.

Upon request, Cloud Generation will provide you with information about whether we hold any of your Personal Data. You may access, update or correct your Personal Data or remove it from our system by making a request to us at the contact information provided below. Requests typically receive a response within thirty (30) days. If access cannot be provided within that time frame, we will provide the requesting party with an estimated date by which the information will be provided. If for some reason access is denied, we will provide an explanation of why access has been denied.

Cloud Generation has no direct relationship with the individuals whose personal data it processes on behalf of Subscribers. An individual who seeks to access, correct, amend, or delete inaccurate data should direct the query to the Cloud Generation Subscriber (the data controller). If requested to remove data, we will respond within a reasonable timeframe.

If you are an EU Data Subject, please see the “EU Data Subject” section below for information on your rights in relation to the Personal Data we hold about you.

EU and UK Data Subjects

Scope. This section applies if you are an individual located in the European Union (“EU”) (“EU Data Subject”) or in the United Kingdom (“UK”) (“UK Data Subject”). For these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland.

Data Controller. Cloud Generation, LLC is the data controller for the processing of your Personal Data, but we act as data processor on behalf of Subscribers for Personal Data that we process through the Cloud Generation Apps.

Consent. Where required by the applicable law (for example, if you are an EU Data Subject or UK Data Subject), we will send you marketing information or notifications only with your consent, which was given at the time you provided us with the Personal Data. In such case, if you do not provide us with your consent to the processing of your Personal Data for this purpose, we will not send you this information. With your permission, we may also use information you provide to us as a testimonial posted on the Websites.

Your Rights. Subject to applicable law, you have the following rights in relation to your Personal Data:

• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to data portability: Effective 25 May 2018, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
  • If we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
  • If we are processing your Personal Data for direct marketing.
• Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, that affect you, unless such processing is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent to such processing.
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

You may exercise your rights by contacting us as indicated under “Contact Us” section below.

Legitimate Interest. “Legitimate interests” means the interests of Cloud Generation in conducting and managing our organization. For example, we have a legitimate interest in processing your Personal Data to analyze how the Websites, Apps and our products and services are being used by you, and to ensure network and information security, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your Personal Data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.

Our Security Measures to Protect Your Personal Data

We are committed to taking reasonable efforts to secure the information that you choose to provide us, and we use a variety of security technologies and procedures to help protect against unauthorized access to or alteration, disclosure, or destruction of Personal Data. We restrict access to Personal Data to our employees, contractors and service providers (described in the “Disclosure of Information” section above) who need to know the information in order to operate, develop, or improve our services.

Unfortunately, no transmission of Personal Data over the Internet can be guaranteed to be 100% secure. Accordingly, and despite our efforts, Cloud Generation cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services. Cloud Generation has no responsibility or liability for the security of information transmitted via the Internet. If you have questions about this Privacy Policy or the security of your Personal Data, please contact us as indicated under the “Contact Us” section below.

We retain your Personal Data for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. We retain Personal Data collected through the Platforms we process on behalf of our Subscribers for as long as needed to provide services to our Subscriber and pursuant to our contract with that Subscriber.

Tracking Technologies

Cloud Generation and its partners use cookies and other technologies to analyze trends, administer the Websites, track users’ movements around the Websites, to gather demographic information about our visitors and user base as a whole and to collect information about your browsing habits in order to make advertising relevant to you and your interests, as described below.

When you first visit the Websites, you will be asked to consent to the use of cookies and similar technologies on the Websites in accordance with this Policy, and if you accept we will store cookies and similar technologies on your computer.

I. What Are Cookies
Cookies are pieces of data sent to your browser when you visit a website and stored on your computer’s hard drive. Cookies may store user preferences and other information. For example, cookies can store your session information for easy log-in to a website or platform, or your language or user interface customization preferences or may allow websites to record your browsing activities (for example, number of page views, number of visitors, and time spent on each page).

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for a set period of time or until you delete it.

II. How We Use Cookies
We classify cookies in the following categories:

Categories of Use	Purpose
Strictly Necessary	These cookies allow to link the actions of a user during a browser session in order to allow navigation around web pages, access to secure areas of the Websites or Platforms and help make the services available through our Websites and Platforms work. Without these cookies, basic functions of the Websites and Platforms would not work.	Because these cookies are strictly necessary to deliver our services, users cannot refuse them.You can block or delete these cookies by changing the browser settings as explained below.
Preferences	These cookies are used to store choices you make and your preferences regarding our services (such as your user name, language or the region you are in, enable user interface customization). These cookies allow us to provide enhanced, more personal features (such as enabling customer support for users). These cookies are not essential for using our services. However, without these cookies, certain functionality may become unavailable or may not function properly.	You can block or delete these cookies by changing the browser settings as explained below.
Analytics	These cookies allow us to recognize and count the number of visitors and to see how visitors move around the Websites and Platforms when they are using it. This helps us to improve the way the Websites and Platforms work, for example by making sure visitors are finding what they need easily. The information collected through these cookies include anonymous traffic statistics, like number of page views, number of visitors, and time spent on each page. In particular, we use cookies from Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your internet protocol (IP) address) will be transmitted to and stored by Google on servers in the United States. Google will use this information on our behalf for the purpose of evaluating your use of the Websites, compiling reports on the Websites activity and providing further services to us relating to the Websites usage. Learn more about Google Analytics’ privacy practices, and see a copy of Google’s privacy policy, at the following link: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631. We use Analytics cookies from HubSpot, Inc. on the www.cloudgeneration.com Website to analyze and evaluate the use of our site and improve our services and features. Learn more about HubSpot’s privacy practices here. If a user is logged in to HubSpot, the application also sets the additional authentication cookies listed here.	You can block or delete these cookies by changing the browser settings as explained below.You can also prevent your data from being collected by Google Analytics on the Websites by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

In their use of our services, Subscribers’ may enable various integrations which may set additional cookies. These cookies are set and controlled by Subscribers for various purposes such as website usage tracking and analytics and enabling social media features. Cloud Generation does not control the placement of such cookies. Use of these cookies is governed by Subscriber’s own privacy and cookie policies.

III.  Other Technologies

Cloud Generation may use a tracking technique that employs embedded URLs to allow use of the Websites without cookies. Embedded URLs allow limited information to follow you as you navigate the Websites, but are not associated with Personal Data and are not used beyond the session.

Cloud Generation and its service providers may use embedded pixel technologies (or pixel tags) for the purposes of identifying unique user visits (as opposed to aggregate hits) and for advertising purposes. In addition, embedded pixels or other technologies may be used in e-mails and our online display advertising to provide information on when the e-mail or ad was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient’s e-mail address.

We may use widgets, which are interactive mini-programs that run on our site to provide specific services from another company (e.g., links to bookmarked sites), along with buttons or other tools that link to other companies’ services (e.g., a “Like” button or another entity’s map). The widget, button or tool may collect and automatically send Personal Data, such as your e-mail address, or other Information (such as your browser information, or IP address), to another entity. Cookies may also be set or used by the widgets, buttons or tools to enable them to function properly or for other purposes, which may include advertising. Information collected or used by a widget, button or tool, including cookie settings and preferences, is governed by the privacy policy of the company that created it.

We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the Apps, the events that occur within the Apps, aggregated usage, performance data, and where the Apps was downloaded from. We do not link the information we store within the analytics software to any Personal Data you submit within the Apps.

IV. Your Choices

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Apple Safari

Please note that if you reject cookies or disable cookies, your use of certain features or functions on our Website or Platforms or service may be limited.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit  www.allaboutcookies.org and/or or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org, and follow the opt-out instructions there. If you access the Websites on your mobile device, you may not be able to control tracking technologies through the settings. If you wish to not have your information used for the purpose of serving you targeted ads, you may opt-out by visiting the Network Advertising Initiative’s online resources available here and following the opt-out instructions there, or if located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here. By opting out of targeted advertisements you will no longer see advertisements on our Websites from third-party partners that participate in the Digital Advertising Alliance; however, you may still continue to see other non-targeted advertisements on our Websites.

If you do not wish to receive marketing materials, brochures, push notifications, or emails from Cloud Generation, you may inform us of your preference by contacting Cloud Generation at the contact information below, submitting a contact form electronically through the Websites and unsubscribing from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails.

We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level.

Inapplicability of Privacy Policies of Any Linked Websites or Other Entities

This Privacy Policy only addresses Cloud Generation’s use and disclosure of your Personal Data. The Websites and Apps may contain links to other websites, so please be aware that we are not responsible for the privacy practices of other websites, and we are not liable for their misuse of Personal Data. We encourage you to be aware that when you go to another website you should carefully read their privacy policy.

California Privacy Rights

I. California Consumer Privacy Act (“CCPA”)
To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Data we collect:

• The right to know what Personal Data we have collected and how we have used and disclosed that Personal Data;
• The right to request deletion of your Personal Information;
• The right to be free from discrimination relating to the exercise of any of your privacy rights.

We will acknowledge any request to know or to delete within 10 days of receipt, and aim to respond to such requests with 45 days. If we need more than 45 days to respond to your request to know or delete, we will inform you accordingly.

Cloud Generation does not sell your Personal Data. However, we may share your Personal Data (including your contact information and your browsing activity) with social media platforms, including Facebook, that will use that information to serve targeted advertisements on the social media platforms and third-party websites. We do not control and are not responsible for the social media platform’s processing of your Personal Data. You can opt out of such marketing through Facebook here.

Exercising Your Rights: California residents can exercise the above privacy rights as described here by contacting Cloud Generation here.

Verification: in order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Data. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Data for verification. If we cannot verify your identity, we will not provide or delete your Personal Data.

Authorized Agents: you may submit a request to know or a request to delete your Personal Data through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.

II. Do Not Track
Cloud Generation does not currently respond to “Do Not Track” signals sent by your browser or mobile application and operate as described in this Privacy Policy whether or not a “Do Not Track” signal is received. If we change our practices in the future and begin to respond to “Do Not Track” signals, we will update this Privacy Policy accordingly.

III.  Shine The Light Law

In addition to the information provided in this Privacy Policy, under California’s “Shine the Light” law, California residents who provide “personal information” (as defined in the statute) in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year. To obtain this information, please contact us here.

Children

The Websites and Apps are not intended for use by or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13.

Conditions of Use

By using the Websites, our Apps and our services, you agree to the terms and conditions contained in this Privacy Policy and Conditions of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use the Websites, Apps and/or any Cloud Generation benefits or services. You agree that any dispute over privacy or the terms contained in this Privacy Policy and Conditions of Use and any other agreement we have with you will be governed by the laws of Maryland. You also agree to arbitrate any such dispute in Maryland, and to abide by any limitation on damages contained in any agreement we may have with you.

Changes to the Privacy Policy

As Cloud Generation, its products, and its services change from time to time, we may update this Privacy Policy to reflect changes to our information practices. We reserve the right to amend the Privacy Policy at any time, for any reason, and may do so by posting a new version online. Your continued use of the Websites, the Apps and/or continued provision of Personal Data to us will be subject to the terms of the then-current Privacy Policy. If we make any material changes or if otherwise required by the applicable law, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us here.

Last updated June 11, 2021