Cloudsway Privacy Policy

This Privacy Policy (this “Policy”) explains how Cloudsway (as used in this Policy, “Cloudsway”, “we” or “us” refer to Cloudsway Pte. Ltd. and its affiliates) collects, uses, discloses, and otherwise processes personal data in connection with our Websites （together with our portals that post a link to this Policy, collectively, the “Websites”）and any content, services, products, and other functionalities offered by Cloudsway which contain or refer to this Policy (collectively, the “Services”). Please carefully read this Policy before providing your personal data to Cloudsway. By browsing our Websites or using our Services, you agree Cloudsway processing your personal data in accordance with this Policy.

In certain situations, Cloudsway may function as a service provider for other businesses. In the course of providing services for other businesses, we may collect your personal data on behalf of our business customers who are the data “controllers” (i.e., they determine the purposes and means of the processing of your personal data). This Privacy Policy does not apply to such processing, and we recommend you read the privacy policy of the respective customer if their processing concerns your personal data.

1.WHAT IS PERSONAL DATA

When we use the term “personal data” in this Privacy Policy, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household, or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information.”

2.HOW WE COLLECT PERSONAL DATA

Personal Data Collected from You

• Account Information

  including first and last name, company name, position, business contact details, user ID and password, and any other information you provide to us. We use this information to administer your account, provide you with the relevant Services, communicate with you regarding your account and the service use, and provide customer support.

• Payment Information

  If you sign up for one of our Services requiring payment (i.e., Cloudsway subscription), we collect the information provided in connection with such payment, including your account name, credit card number and other similar payment-related information.

• Inquiry and Communications Information

  such as your name, company name, or contact details, and any information provided through forms, our “Contact Us” feature, chat messages, emails, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the Services and to develop our organization.

• Newsletter, Marketing Emails, and Blog Information

  including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you.

• Services Usage Information

  including any files, documents, videos, images, data, or information you choose to upload or transmit to us, such as user content and any information contained in the user content. This information is stored and collected as part of the Service, and is used for the provision of Services.

• Feedback Information

  We may collect feedback and ratings you provide relating to our Services. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve our business operations.

• Business Representative Contact Information

  If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g. email, phone, address), job title, and any other information related to the performance of the agreement with us.

• Employment Application Information

  If you apply a job with us, we collect your contact and demographic information, educational and work history, employment interests, interview details and any other additional information you provide.

Personal Data Obtained from Third Parties

We may also obtain personal data from third parties, which we often combine with personal data we collect automatically or directly. We may receive the same categories of personal data as described above from the following sources:

• Authentication Services Providers

  Some parts of our Services may allow you to login through third party authentication services. These services authenticate your identity and may share certain personal data with us, such as your name, email address, address book and contacts, depending on their policies and your privacy settings. We use this information to operate and provide the Services, and may send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, updates on Services features, or technical and security notices).

• Your Employer / Company

  If you interact with our Services through your employer or company, we may receive your information from them or their representatives. We use this information to operate and maintain the features and functionality of the Services.

• Data Providers

  To provide our direct mail marketing services, we may acquire personal data, such as name and mailing addresses, from data providers. We use this information to send Cloudsway mailings with information on new products and services offered by Cloudsway or our business partners. We may combine this information with other information we collect from or about you. In these cases, our Privacy Policy governs the handling of the combined information.。

• Service Providers

  Our service providers that perform services solely on our behalf, such as survey and marketing providers and payment processors, collect personal data and often share some or all this information with us. The information may include contact information, demographic information, payment and purchase history information, communications records, and orders details.

• Business Partners

  We may receive your personal data from our business partners, such as companies that offer their products and/or services on our platform. We may use this information to manage and enhance our services, orders, and marketing activities.

• Other Sources

  We may also obtain your personal data that we do not otherwise have from, for example, publicly available sources, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Cloudsway will maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Cloudsway satisfies the requirements under applicable laws.

3.HOW WE USE PERSONAL DATA

We may use personal data we collect for the following purposes:

• To provide you with products or services that you request or in which you express interest;

• To communicate with you;

• To customize the advertising and content you see based on your preferences and interests;

• For marketing and advertising purposes, including to market to you or offer you through email, direct mail, phone or text message, information and updates on products or services you may find interesting (where applicable, we may send you marketing messages if you have given us your consent to do so or where we have relied on the soft opt-in rule);

• To process payment for our Services;

• To respond to your emails, comments, questions, or requests for client services;

• To improve and customize our Services, and to address the needs and interests of our user base and other individuals we interact with;

• To test, enhance, update and monitor the Services, or diagnose or fix technology problems;

• To enforce our Terms of Use to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;

• To prevent and investigate fraud, unlawful behaviour or criminal activity;

• For any other purposes we may describe when you provide your information;

• For any other lawful purposes, or other purposes that you consent to.

4.HOW WE SHARE PERSONAL DATA

We may also share, transmit, disclose, grant access to, make available, and provide personal data with and to third parties, as follows:

• Cloudsway Entities

  We may share personal data with other companies owned or controlled by Cloudsway, and other companies owned by or under common ownership as Cloudsway, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.

• Your Employer / Company

  If you interact with our Services through your employer or company, we may disclose your information to them and their representatives.

• Customer Service and Communication Providers

  We may share personal data with third parties who assist us in providing our customer services and facilitating our communications with individuals who submit inquiries.

• Other Service Providers

  In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.

• Ad Networks and Advertising Partners

  We may work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device via cookies or other data collection technologies when an individual visits our Services. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

• Business Partners

  We may share personal data with our business partners at your direction or we may allow our business partners to collect your personal data. Our business partners may use your personal data for their own business and commercial purposes, and they may have their own separate privacy policies, which are not governed by this Policy.

• Business Transaction or Reorganization

  We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.

• Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:

  • in connection with the establishment, exercise, or defence of legal claims;

  • to comply with laws or to respond to lawful requests and legal process;

  • to protect our rights and property, and the rights and property of others, including to enforce our agreements and policies;

  • to detect, suppress, or prevent fraud;

  • to protect the health and safety of us and others;

  • as otherwise required by applicable laws.

• With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your consent or direction we may post your testimonial on our Sites or service-related publications.

5. HOW WE CONDUCT ONLINE ADVERTISING

We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. These companies, including online advertising networks, social media platforms and other third-party services, collect information about your use of our Services over time to play or display ads on our Services, on other websites or services, and across your devices. Typically, though not always, interest-based advertising is facilitated through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technologies. These tools recognize the device you are using and collect information, including clickstream, browser type, time and date of visit and other information. To be specific, we may engage in the following:

• Social Media Platforms

  We may display targeted advertising to you through social media platforms, such as Twitter, Instagram, LinkedIn, Facebook, TikTok, and other social media forums. These platforms have their own interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services or those users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platforms or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you. These social media platforms may have their own separate privacy policies. If you do not want to receive targeted ads on your social networks, you shall adjust your advertising preferences settings in accordance with the policies or directions of those platforms.

• Third Party Partners

  We may work with third-party partners to provide advertising services. For example, we may utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies and third-party cookies to optimize and deliver ads based on your past interactions with our Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.

In addition, some advertising networks we use may be members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the DAA resources and/or the NAI resources, at www.aboutads.info/choices or https://thenai.org/. Please note that when you opt out of receiving interest-based advertisements, this does not opt you out of being served non-targeted advertising and you may continue to receive generic, non-targeted ads.

6. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES

We use tracking technologies, including (i) cookies or small data files that are stored on your device and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”), to collect information about how you access and use our Websites and Services when you visit our services, read our emails, or otherwise engage with us. We may use third-party partners or technologies to collect these information and these information may be combined with other personal data we collect directly from you or receive from other sources. We and our third-party partners may use tracking technologies to collect the following types of information:

• Device and Usage Information

  such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modelling tools, which permit us to recognize and contact you across multiple devices.

• Service Interaction Information

  for example, the site from which you came and the site to which you are going when you leave our services, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other browsing behaviour and actions you take on the Sites.

• Activity Information

  such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks and keystroke activity on the Services and other browsing, search or purchasing behaviour. These tools may also record information you enter when you interact with our Services or engage in chat features through our Service.

• Analytics Information

  We may collect analytics data or use third-party analytics tools to help us measure traffic and usage trends for the services and to understand more about the demographics of our users.

All of the information collected automatically through these tools allows us to improve your customer experience. Specifically, we use this data to: - Improve User Experience: Customize and personalize your experience by remembering your preferences and past interactions. - Enhance Services: Monitor and improve our Websites and Services, including the effectiveness of our offers, advertising, communications, and customer service. - Personalize Content: Provide tailored content and targeted advertising based on your interests and usage patterns. - Cross-Device Identification: Recognize and identify you across multiple devices for a more seamless experience. - Measure Effectiveness: Assess the performance of our services and monitor metrics such as visitor counts, traffic, usage, and demographic patterns. - Troubleshoot Issues: Diagnose and resolve technology problems to ensure smooth operation. - Plan and Enhance Services: Use insights to plan improvements and future enhancements to our services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Services, as some features and services may not work properly.

7.HOW WE PROTECT DATA SUBJECT RIGHTS

Cloudsway fully respects individual’s privacy and recognizes individual’s data protection rights. Depending on your jurisdiction or on where you live, you may have the right to request access to and correction or erasure of personal data, or restriction of processing and to object to processing as well as the right to data portability or other rights as provided by applicable laws. You also have the right to withdraw your consent previously given for the processing of your personal data.

From time to time, we may send you emails regarding updates to our Service, notices about our organization, or information we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from essential services-related emails (e.g., account verification, confirmations of transactions, technical or legal notices).

In addition to unsubscribe option, as indicated above, you may also at any time request for modifying, or deleting your information by contacting us directly using the information provided in the Contact Us section below. We will respond within 30 days upon our receipt of your request. Before we are able to provide you with any access to information, correct any inaccuracies, or delete your personal data, we may ask you to verify your identity and may seek other details from you to help us to respond to your request. Please note that we may not be able to fulfil all modification or deletion requests, for example where we are obligated to retain your personal data under regulatory requirements.

8.PERSONAL DATA OF CHILDREN AND MINORS

Cloudsway’s Websites and Services are not intended for children or minors. The definition and minimum age of children and minors is set forth in relevant applicable laws. Children and minors should not use our Services or otherwise provide us with any personal data either directly or by other means. In very rare cases, our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children and minors, however, they may actively interact with us. If we learn that any personal data we have collected has been provided by a child or minor, we will promptly delete that personal data.

9.LINKS TO THIRD-PARTY WEBSITES AND SERVICES

Our Services may include links to third-party websites, plug-ins and applications that we do not own or operate. If you are using a third-party website or service, you do so at your own risk. We are not responsible for the practices or content of these external websites which are not governed by this Policy. Activities on third party websites or services are subject to that applicable third party’s rules and policies. We encourage you to review the privacy policies of any site or service before providing any personal data.

10.CHANGES TO THIS PRIVACY Policy

Cloudsway reserves the right to update or modify this Privacy Policy from time to time at our sole discretion, with changes taking effect immediately upon posting on our Websites. We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your Cloudsway account and/or by placing a prominent notice on our Websites. We recommend that you check this Policy regularly to familiarize yourself with Cloudsway’s privacy practice. When we do change this Privacy Policy, we will also revise the “Last Updated” date.

11.CONTACT US

If you have any questions regarding this Privacy Policy or any of our Services, or you wish to exercise your rights, please send an email to: info@cloudsway.ai