PRIVACY POLICY

CLOUDFRESH

Editorial No. 1 of 30.04.2019

This Privacy Policy (used in text as “Policy”) is an integral part of the data use agreement between you and Cloudfresh. This Policy explains who we are, for what purpose and how we process personal data, what rights you have when you provide us with any information about yourself and how to contact us if necessary.

The Privacy Policy has been developed and is in force in accordance with the General Data Protection Regulation (GDPR), the Ukrainian Personal Data Protection Act, and other personal data protection regulations and practices.

We reserve the right to change the Privacy Policy at any time and for any reason. The date of updating the Policy will be shown in the “Last Updated” line at the top of this page.

Who are we? 

We are Cloudfresh LLC (“Cloudfresh” LLC) (hereinafter referred to as “Cloudfresh”). We strive to do everything we can to justify our customers’ trust in our brand, and to treat your personal information, including personal data, responsibly. We carefully safeguard and protect the personal information of visitors to our website, including the mobile adapted website (“Sites”), information obtained from our social media pages on LinkedIn, Facebook and Instagram (“Social Media”). For the avoidance of any doubt, hereinafter in the text of this Privacy Policy, the phrase “personal information” will also include personal data as defined by the Law of Ukraine “On Protection of Personal Data”.

Content of the Policy

1. The types of information we receive and why we need it.
2. Dissemination of personal information.
3. Access.
4. Cookies.
5. Consumer-oriented advertising.
6. Links to other websites.
7. Other Cloudfresh online services.
8. Data retention period.
9. Cross-border data transfer.
10. Special categories of data
11. Making changes to our Privacy Policy.
12. Our contacts.

1. The types of information we receive and what we need it for. The information you give us.

Cloudfresh collects personal information such as your first, middle and last name, email address and telephone number only when you voluntarily provide it. For example, we may collect personal information in order to obtain your feedback about our work and/or Social Media. You have the right not to provide us with this information, but if you do, the Sites may not work to its full potential or the response to your question may not be comprehensive. Some parts of this Site may ask you to provide personal information in order for you to take advantage of certain features (such as a feedback form or consultant assistance) or to participate in a particular activity (such as a contest or other promotion). You will be alerted to what information is mandatory and what information is not.

In addition, when you visit our website or social media, we may receive certain information automatically. Such information may include your IP address, your computer/mobile device operating system and browser type, your mobile device type, your mobile device unique identifier (UDID) or mobile equipment identifier (MEID), the website address where you linked to us (if any), and the pages you visited on our Sites. We may use this information to administer, maintain and configure Social Media and to provide technical support services. This Privacy Policy goes on to provide further information about how we use cookies.

Our websites may receive information about the location of your mobile device using location technologies such as GPS, Wi-Fi, Bluetooth or the distance to the nearest cell tower. Cloudfresh uses this information to provide services that depend on your location, such as when you search for Cloudfresh offices near you, identify specialists, or personalize your interaction with Cloudfresh. On most mobile devices, you can revoke the permission granted by Cloudfresh to receive your location information via your device settings.

We may combine the information you provide with other information we have collected about you (online or offline). We may also combine it with information about you obtained from other sources, such as Cloudfresh partners, publicly available information sources (including information from your publicly available social media profiles) and other third parties.

If you are wondering how to disable the location service on your mobile device, we recommend contacting your service provider or the manufacturer of your device. If you would like to delete the location information you have received, please e-mail us or postal mail to the address below. Please note that social media information may not display correctly after deletion, and that we may have to retain some information due to legal requirements.

We use and disclose information provided to us by you for the purpose you determined at the time it was collected.

We also use information from or about you:

• To respond to your queries and requests, such as sending you requested documents or emails;
• To send you important information about our important events or the Site, including changes to our terms, conditions and policies and/or other information of an administrative nature;
• For business purposes, such as analyzing data, auditing us, developing new products, enhancing our Website features, improving our services, identifying usage trends on the Website, personalizing your experience on the Website by providing products and offers tailored to you, and determining the effectiveness of our advertising campaigns.

Whose personal data are we processing?

We may process your personal data if:

– you are a customer or supplier to us (or are interested in becoming one);

– you use our services or products that we have supplied;

– you work for our customer or supplier or for someone who uses our services or products that we supply;

– you are a customer (or you work for a customer) whom we want to tell about or offer our services;

– you are an employee, contractor or are interested in working with us.

We do not gather personal data from children. 

We do not specifically require online data from children under the age of 14, nor do we offer our services to them. If we learn that a child under the age of 14 has provided us with personal information without parental consent, we will take steps to delete such information.

– your name;

– information about whom you work for, your department and your job description;

– your address, telephone number, email address or other contact details (your personal or work details, depending on the nature of our relationship with you or the person for whom you work);

– personal information obtained through communications with you by telephone, email, our website, social media or other means.

Such information also includes data we receive or you provide to us while using the Sites: registering to receive our news, providing us with goods or services, inquiring about our services, placing orders, participating in a contest, advertisement or survey, contacting us to report a problem or undertaking the above activities on behalf of the person for whom you work;

• information relating to transactions involving us and you or the person for whom you work (for example, details of products we have supplied or services we have provided to you or received from you or the person for whom you work);
• other personal information about you that we need to process in order to enter into or carry out a contract with you or the person for whom you work (for example, the right to process work information and information obtained from credit reference agencies where this is necessary to perform relevant checks on contracts with you or another person for whom you work or are in any way related)
• information about events to which you or someone associated with you has been invited, and your personal information and preferences if such information is necessary to organize and manage those events (for example, your refreshment preferences);
• your personal information that you provide to us or that we obtain in any way during your visits (for example, if you are caught on CCTV footage, or you provide us with the registration details of your vehicle);
• personal information you provide to us when you use the website, in particular:

 technical information, including the internet protocol (IP) address used to connect your computer to the internet, your registration information, browser type and version, time zone, browser plug-in types and versions, operating system and platform;

• information about your visit, including full unique resource locators (URLs), a history of visits to and navigating through our Website, navigational history (including date and time), services you viewed or searched for, page response times, errors during loading, dwell time on particular pages, page activity information (such as scrolling, clicking and hovering), how you move from the page, and the phone number or social media icon you used to contact us. 

What do we do with your personal data?

We process your personal data for the following purposes:

• Entering into and executing a contract with you or someone you work for in order to
  * provide services to clients or other users of those services;
  * obtain goods and services from suppliers;
  * manage our relationships with customers, suppliers and other users of our services. Where you or the person you work for may be a customer, user or supplier of goods, or services for the above purposes.
• Advertising and sales and providing information about our services;
• Administering our website in accordance with the terms of the agreement and for internal operations, including correcting defects, analysing data, testing, researching, collecting statistics;
• Improving our website to ensure we present content in the most effective way for you and your computer;
• Ensuring the security of your stay on our website and other systems;
• Evaluating and understanding the effectiveness of the advertising we show you and others, and for placing relevant advertising;
• Providing advice and guidance on services that may interest you or the person you work for that meet your preferences, where needed.

12. Spreading personal information

Cloudfresh may distribute personal information within Cloudfresh. The Cloudfresh group includes our representative office in the Czech Republic, Poland, the Netherlands, the USA and Ukraine, as well as our partners. Of course, any use of such information within Cloudfresh takes place in accordance with this Policy. From time to time, with your permission, we will send you marketing information such as information about our new services, products and related news. 

If you do not indicate a wish to receive such material, we will not send it to you.

Cloudfresh may engage other companies to perform various functions, such as fulfilling orders, assisting with promotional campaigns, technical services for our Sites or Social Media. These companies may have access to personal information if required to perform these functions. However, these companies may use such personal information solely to fulfil those functions and may not use it for any other purpose.

We also disclose information collected through the Site:

– to our affiliates for the purposes described in this Privacy Policy;

– to our partners, with whom we market under a common brand name;

– to our third party service providers such as, for example, website hosting and administration, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, services that are delivered by email and traditional mail, audit services and other services to enable them to provide their services;

– to a third party in the event of a reorganization, merger, sale, joint venture, transfer or liquidation of the company, assets or shares in whole or in part (including all of the above in connection with bankruptcy or similar legal proceedings).

In addition, we use and disclose information collected through the Site that we believe is necessary or appropriate:

– in accordance with applicable law, including laws outside your country of residence;

– in order to facilitate legal proceedings;

– as a response to requests from public authorities, including public authorities outside your country of residence;

– to enforce our terms and conditions;

– to protect our operations and those of our affiliates; to protect our and your rights, privacy, security or property and/or the rights, privacy, security or property of our affiliates and others;

– to allow us to pursue available legal remedies or limit the amount of damage we may suffer. We may also use and disclose information collected through the Site in other ways with your consent.

Cloudfresh does not sell, transfer or communicate personal information to third parties outside the Cloudfresh group, unless this is covered by the purpose of the provision and your consent.

Cloudfresh reserves the right to use or share any information as required by any law, regulation or legal requirement to protect the integrity of the Sites, Social Media, to fulfill your requests or to facilitate any law enforcement or public safety investigation.

We can share your personal data with:

– any members of our association, which includes our subsidiaries and their subsidiaries;

• selected third parties, including our business partners, customers, suppliers and sub-contractors, to carry out any contract that we enter into or other arrangements that arise typically in the course of working for you or someone you work for;

our auditors, legal advisers and other professional advisers or service providers;

We may share data obtained through our website with:

• Our advertisers and ad networks who need the data to select and place ads that are relevant to you and other users. We do not disclose personally identifiable information to our advertisers, but we do provide them with aggregate information about our users. We may also use such aggregate information to help advertisers show advertisements to their target audiences. Furthermore, we may use your personal information to serve our advertisers’ advertisements to their intended recipients, subject to the cookie clause of this Policy;
• Analytics and search engine providers that help us improve and optimize our website in accordance with the cookie clause of this Policy.

When processing your personal data, we rely on your prior consent to the relevant processing, which applies to individual cases (e.g. direct marketing). In this case, we obtain and rely on your consent to the relevant processing (see below for a point on how to withdraw your consent to processing).

In the absence of consent, we will only process your personal data where necessary:

• to perform the contract to which you are a party or to take the steps required by you to enter into such a contract;
• to comply with legal obligations that we have undertaken; 
• for legitimate interests pursued by us or another person, only in circumstances where those legitimate interests do not conflict with your interests or the fundamental rights and freedoms that require protection of personal data (most circumstances where we process your personal data in accordance with the nature of the relationship we have with the person for whom you work will fall into this category).

How long do we process personal data for?

We only process personal data for as long as necessary for the purposes for which it was first collected, after which the data will be deleted or archived, unless it is necessary to continue processing to comply with the legal obligations we have undertaken or for other lawful and legitimate purposes. If you are a customer or potential customer of ours, we will process personal data for up to three years from the date of collection, unless a different period is derived from the purpose of the data processing.

Where do we process personal data?

Your personal data that we process may be transferred and stored outside the European Economic Area (EEA), such data may not be subject to any other data protection law. Such data may also be processed by employees outside the EEA working for us or one of our suppliers. This includes employees who, among other things, deal with the fulfilment of orders, processing of payment details and the provision of support services.

Where we receive personal information in the course of providing services, we will take all reasonable steps to ensure that all relevant security measures are implemented and that it is securely protected in accordance with this Privacy Policy.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. All processed personal data is stored on secure servers. Any payment transactions are encrypted using appropriate technology. Where we have given you (or where you have set) a password which gives you access to certain parts of our website or systems, you are responsible for keeping this password confidential. We ask you not to share this password with anyone else.

You should be aware that other Internet sites linked to our website(s) or from company emails may have different privacy policies than this Privacy Policy. We encourage you to read the privacy statements of those websites, applications or other digital resources to ensure that your privacy is protected.

3. Access

You have full control over all personal information provided to us through our Social Media accounts. At any time, when you choose to edit your personal information that we have received or if you wish to change your settings regarding the information you receive from us, you can let us know by emailing us or postal mail at the address below.

What are your rights?

When you submit personal data to us for processing, you have the following rights:

• you can request access to relevant personal data (see the point about gaining access to your personal data below);
• you can request that any personal data about you that is incorrect be corrected;
• in certain circumstances (for example, where it is no longer necessary to process individual personal data that you have provided), you may demand that we delete the relevant personal data;
• if we process your personal data on the basis of your prior consent to such processing, you may withdraw your consent to the processing of the data and such processing will stop;
• if you have a complaint about the processing of your personal data, you can contact us or, if you are in the EU, your local representative.

You can withdraw your consent to any processing of personal data by emailing us to gdpr_comliance@cloudfresh.com 

You can exercise your right to access your personal data by emailing us at gdpr_comliance@cloudfresh.com  

Please note that before providing information as per your request, we may ask you for additional details to confirm your identity.

4. Cookies

A cookie is a text file that websites send to a visitor’s computer or other Internet-connected device solely to identify the user’s browser or to store information or settings in the browser.

Like most websites, Cloudfresh uses cookies for various purposes to improve your online experience. For example, we track the total number of visitors to our Sites and Social Media on an aggregate, anonymous basis. We may also use cookies to remember you when you return to our Site to help improve your experience with Cloudfresh. In such cases, we may link personal information to cookies. We, like other organizations (such as advertising networks), may collect personal information about our visitors’ internet activity over time, including through third party websites, when using our Social Media sites.

Customize your browser settings if you do not wish to receive cookies or if you wish to set the cookie notification function. Select the “Help” section of your browser to find out how to change your cookie settings. If you disable all cookies, you will not be able to use all the functions on this Site.

We use the services of Google Inc. in our work, if you share our choice, instructions for setting up the Chrome web browser can be found at https://policies.google.com/technologies/managing 

5. Consumer-targeted advertising

We use cookies and other advertising technologies in our social media to send you advertisements tailored to your individual interests. This section of our Privacy Policy provides more information and explains how to make your choices.

You can see Cloudfresh personalized advertising on the Internet based on your interests as indicated on the Cloudfresh website. This data allows Cloudfresh to customize appeals to the user through various demographic, contextual and personalization tools. Cloudfresh uses this information to display advertisements that may be of interest to you. This process also helps Cloudfresh evaluate its marketing efforts. You can opt out of receiving promotional emails by emailing us to: gdpr_compliance@cloudfresh.com 

Please note that even if you deactivate this option, you will still see ads, only they will not be tailored to your individual interests.

6. Links to other websites

We may link to websites not operated by Cloudfresh. If you visit linked sites, you should review their privacy terms and their policies. We are not responsible for the policies and practices of other companies, and any information you provide to such companies is subject to their privacy policies.

7. Other Cloudfresh online services

All Cloudfresh Social Networks are subject to this Privacy Policy. The policies of some Sites or Social Networks served by Cloudfresh may differ due to local practices, legislation, or unique conditions specific to a particular region. However, in all cases, all Cloudfresh Social Networks will comply with the obligations to our users set forth in this Policy regarding the collection and use of personal information.

8. Data retention period

We will retain your personal information for the period necessary for the purposes set out in this Privacy Policy, unless a longer retention period is necessary or prohibited by applicable law.

9. Cross-border data transfers

Your personal information may be stored and processed in the country where we have facilities or service providers, and by using our Site or providing your consent to us (where required by law), you consent to the transfer of information outside your country of residence to another country, including countries in the European Union and other countries where data protection laws may differ from those in your country.

10. Special categories of data

Except where we specifically request it, we ask that you do not send us or disclose any personal information (such as information relating to matters of racial or ethnic origin, political opinions, religious or philosophical beliefs, health, intimate life, criminal record or trade union membership) on or through the Site or otherwise to us. Where we may request information containing special categories of data, we will do so with your explicit written consent.

11. Changes to the Privacy Policy

This Privacy Policy is effective as of “__”____ 2019. Cloudfresh may change this Privacy Policy from time to time. If there are changes to our policy, we will post the new version here, so we encourage you to periodically review this page to review the most current version of our Privacy Policy. However, we assure you that no changes will apply retroactively and will not affect the way we handle information we have previously obtained.

12. our contacts

      Head office:

Cloudfresh Limited Liability Company

USREO code: 43424671

Location: Goloseevskaya 17, Kiev, 03039, Ukraine

Tel./fax: +38 044 33 444 33

E-mail: go@cloudfresh.com

As a reminder, under the GDPR a user has the right to

• to make a request as to what data is stored;
• to know what data is stored about him or her;
• to know how long the data is stored;;
• to request that the data be redacted;
• at any time, withdraw consent to the processing of personal data (“right to be forgotten”).

For all questions concerning the collection, processing and protection of your personal data, as well as for requests to delete data, send an email with the relevant subject and request to gdpr_compliance@cloudfresh.com