Corporate Value Limited
2nd July 2018
Corporate Value Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions And Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site.
means this website, cloudlysuites.net.
India And EU Cookie Law
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
means Corporate Value Limited, a limited company registered in HK, whose registered address is RM 607, 64 Hoi Yuen Road, Yen Sheng Centre, Kwun Tong, Kowloon, HK.
2. Information About Us
1. Our Site, cloudlysuites.net, is [owned and] operated by Corporate Value Limited, in HK, whose registered address is RM 607, 64 Hoi Yuen Road, Yen Sheng Centre, Kwun Tong, Kowloon, HK.
2. Our data protection officer is Harshal Jadhav who can be contacted at [email protected]
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:
2. Contact information such as email addresses
3. IP address (automatically collected)
4. Web browser type and version (automatically collected)
5. Operating system (automatically collected)
5. How Do We Use Your Data?
1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
We use your data to provide the best possible software and trading recommendation services to you. This includes:
[Providing and managing your Account;]
[Providing and managing your access to Our Site;]
[Personalising and tailoring your experience on Our Site;]
[Supplying Our Products and services to you;]
[Personalising and tailoring Our Products and services for you;]
[Responding to communications from you;]
[Supplying you with email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the unsubscribe link located at the bottom of each email).
[Analysing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience;]
2. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data.
3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by Email with information, news and offers on Our Products AND Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
4. [Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.]
5. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
you have given consent to the processing of your personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which we are subject;
processing is necessary to protect the vital interests of you or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
How And Where Do We Store Your Data?
1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
2. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
Keeping a Backup of all the unsubscribers.
Protecting the login information of the database which holds all the subscribers and customers.
Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
Do We Share Your Data?
1. We may contract with third parties to supply [products and] services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
2. [We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.]
3. In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
What Happens If Our Business Changes Hands?
2. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
How Can You Control Your Data?
1. When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.
Your Right To Withhold Information And Your Right To Withdraw Information After You Have Given It
1. You may access [certain areas of] Our Site without providing any data at all. [However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.]
3. You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible [products and] services to you.
How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at [email protected], or using the contact details below in section 14.
What Cookies Do We Use And What For?
2. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for advertising services.
3. All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
4. The following first party Cookies may be placed on your computer or device:
Social Website Cookies
So you can easily “Like” or share our content on the likes of Facebook and Twitter we have included sharing buttons on our site.
The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.
Site Improvement Cookies
We regularly test new designs or site features on our site. We do this by showing slightly different versions of our website to different people and anonymously monitoring how our site visitors respond to these different versions. Ultimately this helps us to offer you a better website.
Visitor Statistics Cookies
You may notice that sometimes after visiting a site you see increased numbers of adverts from the site you visited. This is because advertisers, including ourselves pay for these adverts. The technology to do this is made possible by cookies and as such we may place a so called “remarketing cookie” during your visit. We use these adverts to offer special offers etc to encourage you to come back to our site. Don’t worry we are unable to proactively reach out to you as the whole process is entirely anonymised. You can opt out of these cookies at anytime.
We have a number of partners who promote our service on a success-only basis (i.e. instead of paying for advertising, we pay them commissions on sales). Cookies are required to allow us to reward these partners and these cookies are usually provided by specialist companies (known as affiliate networks). Neither us, the networks, or the partner advertising or recommending our services are able to identify you personally. We ask you to support us by allowing these cookies which ultimately help us to offer you the service we do at the price we do.
Email Newsletter Cookies
This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
We use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Facebook Ads Conversion Tracking
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Website.
WickedReports is an analytics service provided by Wicked Reports LLC.
The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.
Visual Website Optimizer (Wingify)
We use Visual Website Optimizer as an A/B testing service.
Pingdom is a monitoring service provided by Pingdom AB.
Google AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Website with the Adwords advertising network and the Doubleclick Cookie.
Twitter Remarketing (Twitter, Inc.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Website with the Twitter advertising network.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.
Hosting And Backend Infrastructure
A hosting service provided by INMOTION HOSTING, INC.
Amazon Web Services
Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Stripe is a payment service provided by Stripe Inc.
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Disqus is a content commenting service provided by Big Heads Labs Inc.
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Interaction And Customer Support
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.
Freshdesk is a support and contact request management service provided by Freshworks, Inc.
ManyChat is a platform to send and receive messages on Facebook Messenger.
User Database Management
ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.
Convertfox is a User database management service provided by ConvertFox, Inc. Convertfox can also be used as a medium for communications, either through email, or through messages within this Website.
Amazon Simple Email Services
Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.
PostMark is a service to send out email messages.
Google reCAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc.
Jvzoo is a check-out system to handle payments and affiliate tracking.
Gravatar is an image visualization service provided by Automattic Inc. that allows this Website to incorporate content of this kind on its pages.
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Website to incorporate content of this kind on its pages.
YouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.
CloudFlare is a traffic optimization and distribution service provided by CloudFlare Inc.
The way CloudFlare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User’s browser, while also allowing analytical data from this Website to be collected.
Facebook Social Widgets
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Google+ Social Widgets
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.
Twitter Social Widgets
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
LinkedIn Social Widgets
The LinkedIn share button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn.
Summary Of Your Rights Under GDPR
Under the GDPR, you have:
the right to request access to, deletion of or correction of, your personal data held by Us;
the right to complain to a supervisory authority;
be informed of what data processing is taking place;
the right to restrict processing;
the right to data portability;
object to processing of your personal data;
rights with respect to automated decision-making and profiling (see section 14 below).
Automated Decision-Making And Profiling
1. In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
2. The right described in section 14.1 does not apply in the following circumstances:
The decision is necessary for the entry into, or performance of, a contract between the You and Us;
The decision is authorised by law; or
You have given you explicit consent.
3. Where We use your personal data for profiling purposes, the following shall apply:
Clear information explaining the profiling will be provided, including its significance and the likely consequences;
Appropriate mathematical or statistical procedures will be used;
Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.