WhiteClouds Privacy Notice
WhiteClouds is committed to protecting and respecting your privacy.
Before you submit any information on or through the Services, please carefully review this Policy and any other documents referred to therein to understand our views and practices regarding your information and how we will treat it. By using any part of the Services, you consent to the collection, use, and disclosure of your information as further outlined in this Policy. We will continue to evaluate this Policy as we update and expand the Services and our offerings, and we may make changes to the Policy accordingly. Any changes will be posted here, and you should check this page periodically for updates. Your continued use of the Services signifies acceptance of the terms of the updated Policy.
For the purpose of data protection laws applicable from time to time to you in the location that you provide your information (“Applicable Law”), WhiteClouds will be the ‘data controller’ (or such equivalent or replacement terminology as appropriate).
INFORMATION WE COLLECT
We collect information in multiple ways, including when you provide information directly to us, when third parties transfer information to us, and when we passively collect information from you, such as from your browser or device. The information we process may include that which relates to you and could be used to identify you (“Personal Information”). We process your Personal Information based on your consent, to fulfill contracts with you, and for our legitimate interests.
1. Information You Provide Directly to Us
We may collect information from you during your use of or access to the Services, such as when you:
- Search for a product,
- Complete a bid request form or provide us with feedback;
- Subscribe to a service or request certain features (e.g., newsletters, updates, and other products);
- Communicate with us by phone, e-mail or otherwise;
- Report a problem with our website; or
- Post user-generated content, including comments, to or on any of our Services, including on discussion boards, community forums, blogs or other social media functions on our website.
2. Information that is Passively or Automatically Collected
a. Device/Usage Information
We may automatically collect certain information about the computer or devices (including mobile devices or tablets) you use to access the Services. As described further below, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers, IMEI and TCP/IP address, and other information about your computer or device(s), browser types, browser language, operating system, mobile device carrier information, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit web pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content (such as advertisements) viewed and the order of those pages, statistical information about the use of the Services (such as barcodes scanned through certain of our mobile apps), the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.
b. Location Information
We and our service providers may automatically collect location information, including general information (e.g., IP address, zip code) from your computer or mobile device. If you access the Services through a mobile device, we may also ask you to share your specific geo-location information with us. The Services use this location information to provide customized location-based services, content, promotional offers and other information that may be of interest to you. We may also use location information to improve the functionality of the Services and our other products services. We and our service providers may also collect other information based on your location and your device’s proximity to “beacons” and other similar indoor proximity systems, including, for example, the strength of the signal between the “beacon” and your device and the duration that your device is near the “beacon.” If you do not wish to have this location information collected and used by us and our service providers, you may disable the location features on your device. Please note that if you disable such features, you will not be able to access or receive some or all of the services, content, features and/or products made available via the Services. Also see the “Tailored Advertising” section below for more choices regarding the delivery of interest-based content and advertising.
c. Cookies and Other Electronic Technologies
We may also collect data about your use of the Services through the use of Internet server logs, cookies and/or tracking pixels. A web server log is a file where website activity is stored to distinguish you from other users of our website. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering content specific to your interests; (v) perform searches and analytics; and (vi) assist with security administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, measure popularity of the Services and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather additional information through other methods. We also gather information and identify users through the fingerprinting methods described in Section 2(a) above.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Except for essential cookies, all cookies will expire after one year.
Your usage of the website without changing your browser cookies settings will indicate your consent to usage of cookies in accordance with this section of this Policy. You can change your cookie settings at any time. Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Please also see below the section entitled ‘Tailored Online and Mobile Advertising’ which contains further information on how cookies are used for advertising purposes by WhiteClouds and by associated third parties.
3. Information Collected By and From Social Media and Other Content Platforms
When you “like” or “follow” us on Facebook, Instagram, Pinterest, Twitter or other social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We may also collect your information if you sign up for one of our promotions or submit information to us through social media sites.
4. Information from Affiliates and Non-Affiliated Third Parties
We may also obtain information about you if you use any other websites that we operate or may operate from time to time or other services we provide. We may share information amongst members of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries. We may also obtain information, such as demographic information, from our affiliates or from third parties, such as marketers, partners, researchers, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies and others.
HOW WE USE YOUR INFORMATION
We may use your information for the following purposes:
- For the purposes for which you provided it;
- To carry out our obligations arising from contracts between you and us including to provide you with information, products and services that you request from us, online content and dealing with your requests and enquiries;
- To process a transaction you initiate or to provide the features, services and products available through the Services;
- To send you information about your relationship or transactions with us, account alerts, or other communications, such as newsletters to which you have subscribed;
- With your consent, to send you SMS messages;
- With your consent (or provided you have not objected, or opted-out, as may be appropriate under applicable law), to provide you with marketing communications;
- To notify you about new features, changes and/or offerings of the Services, including, but not limited to, updates, discounts, events, shows news about our Services, products, and/or special offers;
- To contact you with information, surveys, or advertising that we believe may be of interest to you both regarding our products and Services and those of third parties;
- To process and respond to your inquiries or to request your feedback;
- For internal research and reporting;
- To analyze and improve the content and features of the Services or develop new Services;
- To ensure that content from our website is presented in the most effective manner for you and on the device or browser from which you are accessing our Services;
- To personalize the content and advertising that you see on the Services or on other websites, including across difference devices and browsers (see “Personalized Content and Advertising” section below);
- To measure or understand the effectiveness of advertising we serve to you and others;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To enforce the legal terms that govern your use of the Services;
- To keep our website safe and secure;
- To use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine the jurisdiction in which you are accessing the Services; and to administer and troubleshoot the Services.
Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
If you ever provide to us any information that classifies as ‘sensitive Personal Information’ (for example racial or ethnical origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences), we will only use this information to provide the Service you require in accordance with this Policy, and we will ask for your explicit consent to such processing.
WHEN WE DISCLOSE INFORMATION
WhiteClouds may disclose and/or share your information between members of the WhiteClouds corporate group, and to or with any non-affiliated third parties under the following circumstances:
Consent. We may disclose your information to any third parties based on your consent to do so.
Service Providers. We may provide access to or share your information with select third parties who perform services on our behalf and for any other legitimate business purpose. These third parties provide a variety of services to us, including without limitation billing, sales, marketing, advertising, market research, customer support, fulfillment, data storage, analysis and processing, and legal services.
Business Partners. We may provide your information to individuals and companies with whom we have business relationships to provide you with special coupons, discounts, or promotions, or to offer products and services to you for purchase. We encourage these partners to adopt and post privacy policies. However, the use of your Information by such parties is governed by the privacy policies of such parties and is not subject to our control.
Protection of WhiteClouds and Others. By using the Services, you acknowledge, consent and agree that we may access, preserve and disclose your information, including, but not limited to, any user content, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce our contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of WhiteClouds, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Business Transfers. As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of WhiteClouds’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets.
Public Forums. Our Services offer publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Please also remember that if you choose to provide information on public features of the Services, individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about what you choose to disclose publicly and make sure it’s information you want to share with the public.
PERSONALIZED CONTENT, ADVERTISING, AND YOUR CHOICES
1. Online and Email Analytics
If you receive email from us, we may use certain tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
2. Tailored Online and Mobile Advertising
We may personalize the content and advertising that you see when using the Services or when visiting third-party websites that have contracted with us. In such cases, we may employ third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you provide such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored.
When using a mobile application, you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to opt-out of tailored in-app advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. We also may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. You can opt-out from third-party interest-based advertising on some Android devices and Google apps by visiting Google Settings, Ads and then clicking on ‘Disable ads based on interests.’
Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Notice Concerning Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform online services that they do not want certain information about their page visits collected over time and across websites or services. We are committed to providing you with meaningful choices about the information collected on the Services for third party purposes, and that is why we provide links to the Network Advertising Initiative and the Digital Advertising Alliance opt-out pages, as well as choices provided by Google Ads, Google Analytics, and TrustArc. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. To learn more about Do Not Track, you can do so here.
RIGHTS TO YOUR PERSONAL INFORMATION AND DATA RETENTION
Depending on the Applicable Law, you may have the right to copy, access, delete, correct, or modify the personal data that we possess, which may be done through your relevant account settings on the Services or by contacting us directly using any of the methods listed below.
Your right of access can be exercised in accordance with the provisions of Applicable Law. Any access request will be subject to the maximum fee permissible under Applicable Law to meet our costs in providing you with details of the information we hold about you.
You also have the right to withdraw your consent to, object to and to restrict the processing of your Personal Information. For additional assistance with any of these rights, contact us by clicking HERE.
We will keep your information only for as long as is reasonably necessary for the purpose that it has been processed, taking into account any legal requirements under Applicable Law. For the avoidance of doubt, we will retain your information to continue offering the Services to you. If you terminate your account, any association between your account and information we store will no longer be accessible through your account. Personal Information from a terminated account will be deleted unless required or allowed by Applicable Law. However, if you have engaged in any public sharing prior to termination, that information will remain indefinitely on our services and accessible to the public. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you wish to verify the details that we hold about you, you may do so by contacting us via e-mail by clicking HERE. Our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will typically take the form of your e-mail address and any password submitted upon registration.
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot and do not guarantee that the measures we take will prevent every unauthorized attempt to access, use, or disclose your information. As no Internet and/or other electronic transmissions can be completely secure despite our efforts, any transmission is at your own risk.
It is important for you to protect against unauthorized access to your password and to your computer. So, we advise that you sign out after using a shared computer. We also strongly recommend not using a browser’s password memory function, which would permit others who use your device to access your information. Change your password periodically. You are responsible for maintaining the security of your account username and password. You should not provide account credentials to any third party. If you believe that your account username and/or password have been compromised, change your password immediately and contact us. To the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorized access, misuse or alterations of any information you submit to the Service or that we process.
If you have provided contact information through the Services and decide that you do not want WhiteClouds to use that information for marketing purposes in accordance with this Policy, you can opt-out of future use at any time by: (i) going to the link provided at the bottom of any email you receive and opting out of receiving future information; or (ii) by sending us an email by clicking HERE. Please note that you may not be able to opt out of emails about your transactions and relationship with us, such as emails regarding your account, requests or inquiries, and purchases of products and/or services.
INTERNATIONAL USERS — CONSENT TO TRANSFER
Your Personal Information may be transferred to, stored at, or processed in the United States. WhiteClouds generally uses approved Standard Contractual Clauses to assure that Personal Information is adequately protected when it is transferred out of the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland to the United States. We may also make transfers out of other jurisdictions on contractual bases when allowed under Applicable Law. WhiteClouds will assure that any transfer of Personal Information from the EEA, Switzerland, and/or the UK continues to be safeguarded as described in this section and in accordance with Applicable Law. Please contact us using the Contact Information included in this Policy if you would like to learn more about cross-border transfers or to obtain a copy of the Standard Contractual Clauses. By using the Services, you consent to the transfer of your personal information and to the use of the information as described herein.
THIRD PARTY LINKS AND SERVICES
The Services may also include widgets and social media features such as the Facebook “Like” button, which are interactive mini-programs that provide specific services from another company (e.g., displaying the news, opinions, music, etc.). Information such as your email address may be collected through these features. These features may collect your IP address and set cookies to enable them to function properly. We are not responsible for, nor do we endorse, the privacy practices or the content of such third-party services. Any information you provide via those services is subject to their applicable privacy policies and is not covered by this Policy.
YOUR CALIFORNIA PRIVACY RIGHTS
California Law permits visitors who are California residents to request a list of the third parties to which we have disclosed “Personal Information” (as that term is defined under applicable California law) for such third parties’ direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information by email by clicking HERE.
INFORMATION FROM CHILDREN
The Services are not directed to children under the age of 13 and such children are not permitted to use the Services. If we discover we have received any “Personal Information” (as defined under the Children’s Online Privacy Protection Act) from a child under the age of 13 in violation of this Policy, we will take reasonable steps to delete that information as quickly as possible. If you believe we have any information from or about anyone under the age of 13, please contact us by email by clicking HERE.
WhiteClouds GDPR DECLARATION
The EU General Data Protection Regulation (GDPR) is a privacy and data protection regulation that imposes obligations on organizations that control or process the “personal data,” as that term is defined under GDPR, of individuals located in the EEA (“Data Subjects”), and provides rights and protections to such Data Subjects.
Although WhiteClouds Inc. does not collect data directly from any consumer, we are committed to ensuring that your privacy is protected and we strictly adhere to the provisions of all relevant Applicable Laws, including GDPR, ensuring all personal data that we process is handled in accordance with Applicable Law.
PERSONAL DATA SHALL BE:
- Processed lawfully, fairly and in a transparent manner in relation to the Data Subject;
- Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date;
- Kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data are processed; and
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
WhiteClouds respects your rights to data privacy and protection and are committed to maintaining internal policies, procedures, working practices that meet the requirements of the GDPR. WhiteClouds is committed to compliance with the GDPR as a controller of personal data and has appointed a data protection officer (“DPO”) to ensure compliance on an ongoing basis.
We place a high priority on protecting and managing data in accordance with accepted standards and helping our customers utilize our products and services to the same end.
QUESTIONS ABOUT THIS POLICY
If you have any questions about our Policy, you can contact us by clicking HERE.
CHANGES TO THIS POLICY
We may update this Policy from time to time. When we make changes to this Policy, we will post a notification on the main page of the website and revise the “last updated” date at the top of this Policy. We encourage you to frequently review this Policy for any changes to stay informed about how we are helping to protect the Personal Information we process.