Introduction

Your privacy is very important to Kloudless, Inc. ("Kloudless", or "we", "us", or "our"). This privacy policy ("Privacy Policy") applies to the Kloudless Websites (kloudless.com, developers.kloudless.com, api.kloudless.com, and kloudl.es, and any sub-domains), products, and services, and describes how personal information is collected, used, disclosed, and protected by Kloudless. For convenience, the Kloudless Websites and our services are collectively referred to as the "Service". The exception to this is if you are part of an organization that has a separate written agreement with Kloudless covering the use of our Service in which case any terms in that agreement describing how Kloudless handles your personal information take precedence.

Kloudless' Service and Customer Services Data

Customers and registered users of the Service ("Customers") use the Service to connect Customer applications and services ("Customer Services") to their users' third-party accounts ("End-User Accounts") and transfer data ("Customer Services Data") between the Service and End-User Accounts.

Customer Services Data may include, without limitation, personal data and information about the identity of Customer users, such as email addresses, names, phone numbers, postal addresses, IP addresses, age, and actions they take while using Customer Services. In addition to reviewing this Privacy Policy, please refer to our Customers' policies for information regarding their collection, use, and disclosure of your personal information. Our use of Customer Services Data provided by our Customers in connection with our Service is subject to the written agreement between Kloudless and the Customer.

If you are using Kloudless as a sub-processor, please contact us for our Data Processing Agreement to accept it if applicable.

Personal Information Collected

We collect information from you in various ways when you use our Service, including Customer Services Data described above. We may also supplement this information with information from other companies. As used in this Privacy Policy, the term 'personal information' means information that specifically identifies an individual (such as, but not limited to, a name, email address, or IP address), and demographic and other information when directly or indirectly linked to information that can identify an individual.

Information you give us

The following are the specific types of information you give to us. We collect information you give us on our Service and when you register for and use our Service.

Registration information — When you register to use our service, we may collect your name, email address, phone number, postal address, and IP address. You may log into your Kloudless account to access our services using third-party sign-in functionality such as via your Google or GitHub account. This feature uses those services' application programming interfaces (API) to authenticate your identity and automatically share certain personal information with us like your name and email. We use similar methods to connect your cloud service accounts.

Third-party connected accounts — All policies that apply to End-User Accounts also apply to any third-party accounts of your own that you connect to the Service. Please refer to our Data Processing Agreement for more information on how we handle this data.

Payment and Transaction Information — If you choose to use a paid Kloudless account or service, our payment-processing vendor, Stripe, directly collects your credit card information and billing address. We never receive this information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry-standard security. Stripe may use your Payment Information in accordance with its own Privacy Policy here: https://stripe.com/us/privacy. Kloudless also receives transaction information on details of your purchase and billing details such as the last four digits of a credit card number and billing address.

Feedback and correspondence — Information you provide when you respond to surveys, report a problem with the Service, receive customer support, let us know how you use the Service, or otherwise correspond with us.

Marketing information — Your preferences for receiving marketing communications and details on how you interact with this option to choose your preferences.

Information automatically collected

We gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, links clicked on, search terms, and other statistics. We collect this information in server logs, and by using Cookies and similar tracking technologies to analyze trends, administer the website, track users' movements around the website, gather demographic information about our user base as a whole, and deliver advertising.

Kloudless uses Cookies, small text files that store settings, to improve your user experience. Cookies remember your preferences and personalize the content so it is more relevant to you. You can update your Cookie preferences from our main site, or use third-party browser extensions to block Cookies you would not prefer, although it may adversely affect your use of the Service.

Here are the different categories of Cookies we use:

Essential — Kloudless uses browser cookies that are necessary for the site to work as intended. For example, we store your cookie preferences so we can honor them when you return to the site. You can disable these cookies in your browser settings, or as described above, but the Service may not work as intended.

Functional — To monitor our site's performance, provide customer support, and enhance user experience. Examples of tools used include Zendesk.

Marketing and Analytics — To understand user behavior, provide you with more relevant information, and improve our service. Examples of tools used include Google Analytics, Google Tag Manager, and Hubspot.

Sensitive personal information

We ask that you not send or disclose any sensitive personal information to us on or through the Service or otherwise. This includes information such as social security numbers, information related to racial or ethnic origin, religion or other beliefs, political opinions, health, criminal background, union membership, and similar information. If you do, such as when you connect an End-User Account, you must consent to our processing and use of such information in accordance with this Privacy Policy and our Data Processing Agreement as applicable. If you do not consent, you must not provide the information.

Use of Personal Information

In general, we use your personal information to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Service and to otherwise serve you and our users and comply with our Customers' instructions. For example, we may use your personal information:

• to operate, provide, maintain, administer, and improve the Service, and communicate with you in the process of doing so to manage your Service account if you have one or inform you of Service announcements, technical notices, updates, and support or administrative messages;
• to request feedback and to enable us to develop, customize and improve the Service and our publications, products and services;
• to conduct marketing communications which you will have the option to opt out of, such as surveys, newsletters, news about our products, activities, special events or offers from Kloudless or our partners and for other marketing, informational, product development and promotional purposes;
• to send you a welcome email and to contact you about your use of the Website and services; to respond to your emails, submissions, comments, requests or complaints; to perform after-sales services; to anticipate and resolve problems with our service; to respond to customer support inquiries, for assistance with our product and service development; and to inform you of updates to products and services from Kloudless that better meet your needs;
• to create anonymous aggregate data, that is shared with third-parties for our lawful business purposes, by removing information that makes the data personally identifiable to you and aggregating it;
• to investigate or prevent violation of the law or our Terms of Service; secure the Service; protect either our, your, or others' rights to privacy, safety, or property; protect, investigate and discourage fraudulent, harmful, unauthorized, or illegal activity;
• to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, or where permitted by law in connection with a legal investigation; or to prosecute or defend legal claims.
• to share customer stories, case studies, quotes, or other testimonials from you on our Service, with your consent to collect, use, or share this personal information.

Use of Information in End-User Accounts

Kloudless accesses and uses Customer Services Data or any information obtained from End-User Accounts to the extent required to provide the Service as described in this Privacy Policy. Additional connector-specific policies are listed below.

Google — Use of information received from Google APIs will adhere to API Services User Data Policy including the Limited Use requirements, where applicable.

Sharing of Personal Information

We will share your personal information with third-parties only in the ways that are described in this Privacy Policy or as otherwise instructed by our Customers. We do not share or sell your personal information to third-parties except as detailed below or as otherwise instructed by our Customers. We may disclose your personal information to third-parties under the following circumstances:

Subsidiaries — We may disclose your personal information to our subsidiaries for use consistent with this Privacy Policy. Our current sole subsidiary is Kloudless Taiwan, a wholly owned subsidiary headquartered in Taipei, Taiwan.

Service providers — We may use third-party partners to help us operate and maintain our Service and deliver our products and services. We may also share your Personal Information and Website Usage Information with our service providers and other third-parties that provide products or services for or through this Website or for our business (such as website or database hosting companies, address list hosting companies, communications providers, email service providers, analytics companies, distribution companies, fulfillment companies, credit card processing companies and other similar service providers that use such information on our behalf).

Third-party service providers are contractually restricted from using or disclosing the Personal Information and Website Usage Information except as necessary to perform services on our behalf or to comply with legal requirements, or otherwise subject to the terms of this Privacy Policy.

Company account — If you are an individual Kloudless registered user, and the domain of the primary email address associated with your Kloudless account is owned by your employer and that email address was assigned to you as an employee of that organization, and that organization wishes to establishes a Kloudless corporate account and add you to it, then certain information concerning past use of your individual account may become accessible to that organization’s administrator including your email address.

Professional advisors — We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services they render to us.

Payment processors — We may share your payment information to process your payments as described in the Payment and Transaction Information section above.

Aggregate statistics — We may disclose non-personally identifiable aggregate statistics regarding user behavior as a measure of interest in, and use of, our Website and emails to third parties in the form of aggregate data, such as overall patterns or demographic reports, which do not describe or identify any individual user. Information relating to aggregate statistics may be collected through the use of third-party Cookies as described above.

Legally compelled disclosure — We may disclose your Personal Information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law, comply with a judicial or court order or comply with legal process served on us or affiliates; (b) protect and defend our rights and property, the Service, the users of the Service, and/or our affiliates; or (c) act under circumstances to protect the safety of users of our Service, us, or third-parties.

Business transfer — If Kloudless is involved in a merger, acquisition, or sale of all or a portion of its assets to another company, Personal Information collected by Kloudless will by shared with or transferred to the acquiring company and the acquiring company will assume the rights and obligations regarding such information as agreed upon in this Privacy Policy.

User Access and Choice to Opt In/Out

If your personal information changes in any way, we invite you to correct, delete or update your information as soon as possible. You can make updates to your profile information by logging into your account on Kloudless at any time. You can also request changes or access to your information by emailing  support@kloudless.com.

If you no longer desire our service, you may email support@kloudless.com to delete your account. We will respond to your request within 5 business days.

If you gave us permission to quote you on our Service's website or otherwise make your personal data such as full name public, but wish to revoke this permission, please contact us at support@kloudless.com.

Kloudless may send you communications or data regarding our Websites and services, including but not limited to (i) notices about your use of our Service, including any notices concerning violations of use, (ii) updates, and (iii) promotional information and materials regarding our products and services. You may opt-out of receiving promotional emails from Kloudless by following the opt-out instructions provided in those emails. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing support@kloudless.com with your specific request. Opt-out requests will not apply to transactional service messages, such as security alerts and notices about your current account and services. To stop receiving emails you would have to deactivate your account. Please email support@kloudless.com from the email address associated with your kloudless account with a request to deactivate your account and we will respond to your request within 5 business days.

In some of our communications, we track clicks on links or the communication being opened to measure the effectiveness of our communications.

Our Service does not currently respond or acknowledge "Do Not Track" or similar signals sent by some internet browsers.

International Data Use

Kloudless is headquartered in the United States and has affiliates and service providers in other countries. Your personal information may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. European Union users should read the important information provided below on this page under "Information for European Union Users" about transfer of personal information outside of the European Economic Area.

User-Generated Content

Some features of the Service allow you to share information online, such as on comments on our blog, via our community helpdesk and support forum, chat, events, uploaded files, or similar. We have no control over, and take no responsibility for, the use, storage, or distribution of any personal information voluntarily disclosed in these mediums. The information becomes public and can be collected and used by others.

Information Security

Kloudless takes reasonable steps to protect information we collect from you to prevent loss, misuse and unauthorized access, disclosure, alteration, and destruction.

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. While we take reasonable efforts to guard personal information we knowingly collect directly from you, no security system is impenetrable.

Updates to this Privacy Policy

We may change this Privacy Policy from time to time. If we make any changes to this Privacy Policy, we will change the 'effective date' below. If there are material changes to this Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website once you log back in. We encourage you to check this Privacy Policy whenever you use our Websites and services to understand how your personal information is used.

Additional Information

Links to Third Party Sites — Our Website includes links to other websites whose privacy practices may differ from those of Kloudless, Inc. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Blog/Forum — Our Website offers publicly accessible blogs or 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. To request removal of your personal information from our blog or community forum, contact us at support@kloudless.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Social Media Widgets — Our Website includes Social Media Features, such as the Facebook Like button (and Widgets, such as the Share this button or interactive mini-programs that run on our site). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Service. Your interactions with these Features are governed by the privacy policy of the company providing it.

Information for European Union Users

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

Controller — Except with respect to Customer Services Data, Kloudless is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation. Contact us at privacy@kloudless.com. With respect to Customer Services Data, Kloudless is a processor or sub-processor for purposes of European data protection legislation.

EU Representative — Kloudless is a company located outside of the European Union. In order to comply with Article 27 of the EU GDPR, we've nominated GDPR-Rep.eu as our representative in the European Union. If you want to make use of your data privacy rights, please visit our GDPR-Rep.eu landing page. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.

Legal Basis — We need to use your personal information to provide the services you have requested when you entered into a contract with us by signing up to use our services. If you fail to provide this information, we will be unable to register you to use our services. We may also process your data with your consent, which can be withdrawn at any time, or if required to comply with legal obligations. The rest of our processing activity constitute legitimate interest. We make sure to carefully consider your rights before processing your personal information. If you have any other questions about the legal basis of how we process your personal information, please contact us at privacy@kloudless.com.

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

Retention — We will retain your personal information for as long as necessary to fulfill the purposes we collected it for, unless you request deletion of such data or such data is no longer relevant. In some cases, we may have to retain data to comply with legal obligations, including, but not limited to accounting or reporting requirements.

Your rights — You may ask us to provide you with information about our processing of your personal information, opt-out of marketing communication, correct or delete certain personal information, transfer it to you or a third-party of your choice, restrict further processing of your personal information, or object to our need to process that information. Please send these requests to privacy@kloudless.com. We may accept or decline your request, subject to applicable law and legal restrictions. If you would like to file a complaint, you may contact us or submit one to your jurisdiction's data protection regulator (found here).

Cross-Border Data Transfer — If Kloudless transfers your personal information out of the European Economic Area or Switzerland and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so. Such safeguards may include applying the European Commission Model Contracts for the transfer of personal data to third countries described here.

Privacy Shield

Kloudless complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and/or Switzerland to the United States. Kloudless has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield, Kloudless is potentially liable. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Kloudless commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Kloudless at privacy@kloudless.com or the address at the bottom of this Privacy Policy.

Kloudless has further committed to refer unresolved Privacy Shield complaints to the ICDR/AAA Privacy Shield Program, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Kloudless is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Kloudless may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

See the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint for conditions when you may invoke binding arbitration if other dispute resolution procedures have not resolved your complaint.

Data Subprocessors

Kloudless' sub-processors are listed below. If you would like to receive an email when new sub-processors are added, please complete the form here.

• Amazon Web Services — Infrastructure Service Provider (USA): https://aws.amazon.com
• Google — Infrastructure Service Provider (USA): https://gsuite.google.com/, https://cloud.google.com
• SparkPost — Email Service Provider (USA): https://www.sparkpost.com/
• Atlassian — Issue Tracking Service (USA): https://atlassian.com/
• Zendesk — Customer Support Service (USA): https://zendesk.com/
• Elastic — Infrastructure Service Provider (USA): https://elastic.co/
• Salesforce — Customer Relationship Management (USA): https://salesforce.com/
• Stripe — Payments Processor (USA): https://stripe.com/
• Hubspot — Marketing Analytics (USA): https://hubspot.com/

Contact Us

Any questions beyond what this page can answer should be addressed to support@kloudless.com.

Effective date: July 15, 2020