VCLOUD WEBSITE PRIVACY POLICY 

I. Last Updated: FEB 2023 

This Privacy Policy applies to all VCloud website user(s) and/or visitor(s) as well as all of its features and web pages. Please read this Privacy Policy carefully.

II. Summary of Key Points 

VCloud Interactive, LLC, does not collect personal information or personal identifiable information from the VCloud website except for necessary cookies to make the website work. 

VCloud uses the necessary and minimum personal data you share or that we collect to provide our website services, to enhance our websites and mobile applications, to market VCloud’s products to you, for security purposes, and to comply with applicable laws, regulations, and other legal requirements.

VCloud does not sell the personal data we collect. We do share that data with select third parties, but only in connection with ensuring the VCloud website works, our customers, or when we have a legal basis for such sharing. 

VCloud uses cookies and other tracking technologies to track your use and interoperability of our website. This Privacy Statement also describes opportunities for controlling our use of such technologies. 

VCloud respects privacy rights, and we built our privacy compliance program with The European General Data Protection (the “GDPR”), The Data Protection Act 2018 (DPA 2018 and/UK GDPR), the California Consumer Privacy Act (the “CCPA”), as amended by The California Consumer Privacy Rights Act (CPRA) and other privacy laws and regulations firmly in mind. 

VCloud takes personal information/data security seriously, and its security controls are designed to safeguard personal data.

III. User Information 

This Privacy Statement reflects VCloud Interactive, LLC, hereinafter referred to as VCloud (collectively with its subsidiaries and affiliated companies, “VCloud” “we,” “our,” and “us”) commitment to privacy and data protection. This Privacy Statement describes how we collect and process data about visitors to our website(s) (the “Site”), users of our web and mobile applications (“Applications”). By using VCloud website services, you are consenting to the practices described in this Privacy Notice. 

At VCloud, we are committed to protecting a visitor's/user’s privacy and providing the visitor/user with the most powerful and secure online experience. You can browse through most of the VCloud website without giving VCloud any information about yourself.

IV. Acceptance

The VCloud Website Privacy Policy covers and regulates the use of VCloud’s website only. By accessing and using the VCloud website, you accept and agree to this Privacy Notice. 

By using the VCloud website, you consent to the collection of necessary information, not necessarily personal information or personal identifiable information, when you use the VCloud website. VCloud may use your information for the following purposes: 

• To proceed with your registration and to make the Site easier for you to use by not requiring you to enter your information more than once; 
• To deliver services or products that you request, purchase, or download;
• To help you quickly find products, services, or information; 
• To notify you of product upgrades, special offers, updated information, and new services via email, phone, chat or other means; 
• To respond to inquiries or to communicate with you, such as through welcome messages, newsletters, or direct marketing; 
• To facilitate participation in our online communities; 
• To perform market research or to conduct surveys unless you have requested that we not contact you for this purpose; 
• To personalize the user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested; 
• To send periodic emails, calls, or chats regarding your order or other products and services; 
• To enhance our marketing and to improve our Site, services, and products; 
• To consider you for employment, if you have provided information for such purpose; or 
• To comply with legal requirements and to prevent activities that may violate our policies.

By using the Site, you consent to our use of your information for these purposes, among other purposes as may deem appropriate by VCloud Interactive, LLC.

V. Sharing of Your Information

VCloud will not disclose your personal information outside of VCloud except in limited circumstances, such as: 

• We may share your personal information with other VCloud companies and our business partners when necessary in order to support the uses mentioned above. 
• We may hire other companies to provide limited services on our behalf, including packaging, mailing and delivering purchases or postal mail, answering customer questions about products or services, and processing event registration. We will provide those companies with only the information they need to deliver the service, and they are prohibited from using that information for any other purpose. 
• We may disclose your personal information if required to do so by law or in the good faith belief that such action is necessary (i) to conform to the edicts of the law or comply with legal process served on us, (ii) to protect and defend the rights or property of VCloud, or (iii) to act in exigent circumstances to protect the personal safety of our users or the public. 
• In the event that VCloud, or any portion thereof, is sold, transferred, merged, financed, or dissolved, in whole or in part, your personal information that we may possess may be sold, transferred, or otherwise disclosed as part of the transaction or proceeding, unless you instruct us not to do so. 
• We may use a third-party service to host our online communities or to provide website analytics. We may also hire third parties to collect data or may purchase data from third parties, including renting email address lists for use in email campaigns. We will provide the same security and management options as set forth herein for data collected from our Site, phone system, chat, social media, support portal, or other system. However, you may encounter links to third-party sites (e.g., business partners) and, although a connection may be made to such sites, we are not responsible for their privacy policies and this Privacy Notice does not cover their practices.

VI. Control of Your Information

When you provide personal information to VCloud, unless under exceptional instances, VCloud will not share that information with third parties without your permission, other than in circumstances referred to above. We may send out important notices informing you of changes to our policies, technical service issues related to a product or service, or other information that is essential to the use of our Site, services, and products. 

Embedded content from other websites 

Articles on the Website may include embedded content (e.g. videos, charts, etc.). Embedded content from other websites behaves in the exact same way as if the visitor had visited the other website. 

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

VII. Rights for California Consumers

Information We Collect as a Business Under the California Consumer Privacy Act (“CCPA”) 

We do not collect personal information, meaning information that identifies, relates to, references, describes, or is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or device. 

For the purposes of this CA Notice, personal information does not include: 

• Publicly available information from government records. 
• Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a consumer.

We do not collect personal information from and about consumers for a variety of business purposes.

Purposes for Collecting Personal Information from CA resident individuals

We may collect, use or disclose personal information about you for one or more of the following business and/or commercial purposes: 

• To provide the requested services to you; 
• To provide you with useful content; 
• To ensure the proper functioning of our services; 
• To offer and improve our services; 
• To provide you with requested information or technical support; 
• To facilitate your movement through our websites or your use of our services;
• To do a better job of advertisg and marketing our services (subject to your consent where required by applicable law);
• To diagnose problems with our servers or our services in connection with our security and compliance programs; 
• To administer our websites; 
• To communicate with you; 
• To target current or prospective customers with our products or services through online advertisements served on third-party sites by third-party vendors, such as Google (subject to your consent where required by applicable law); and To advertise and market third party products and services (subject to your consent where required by applicable law);
• To assist us in offering you a personalized experience or otherwise tailor our services to you.

Your California Privacy Rights As a California resident

You may be able to exercise the following rights with respect to your personal information that we have collected, subject to certain exceptions:

The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon our verification of your identity: 

• The specific pieces of personal information we have collected about you;
• The categories of personal information we have collected about you; 
• The categories of sources of your personal information; 
• The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; 
• The categories of personal information we have sold about you (if any), and the categories of third parties to whom the information was sold; and
• The business or commercial purposes for collecting or, if applicable, selling the personal information.

These are your other CA rights: 

1. The Right to Access Data 
2. The Right to be Forgotten 
3. The Right to Opt Out of the Sale of your Personal Information 
4. The Right to Non-Discrimination 
5. The Right to Correct Inaccurate Personal Information 
6. The Right to Data Portability 
7. The Right to Restriction of Personal Information Collection 
8. The Right to Limit Use of Sensitive Personal Information

How to Exercise Your California Consumer Rights 

Although our website does not collect any of your personal information, you may exercise your California Consumer Rights by submitting a request to us by: 

• Calling the toll free phone number or clicking the “contact us” link located on the homepage for the products or services you receive from us; or 
• sending an email to compliance@vcloud.com.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. If you are using an authorized agent, please note that you will be required to verify your identity and provide written confirmation that you have authorized the agent to make a request on your behalf.

For requests to access or delete, we may require you to verify your identity directly with us, and directly confirm with us that you provided the authorized agent permission to submit the request. 

VCloud as a Service Provider 

VCloud does not act as a service provider to any of our website visitors/users unless otherwise provided by contractual stipulations. If you are an end user of one of our clients whose personal information we process and you are seeking to exercise your rights under the CCPA, you should contact our client directly. 

If you are a California resident, you may have certain rights. California law may permit you to request that we: 

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; 
• the categories of sources of such information; 
• the business or commercial purpose for collecting or selling your personal information; and 
• the categories of third parties with whom we shared personal information.
• Provide access to and/or a copy of certain information we hold about you.

Delete certain information we have about you 

VCloud will take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and physical address. 

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request. 

You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our website services to you. If you ask us to delete it, you may still be able to use our website services but some functionalities may not be available to you. 

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at compliance@vcloud.com or fill out this form.

VIII. Security of Your Information 

We are committed to protecting the security of your personal information and we honor your choices for its intended use. We have implemented the appropriate safeguards to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. We make good faith efforts to provide the security measures necessary to keep the integrity and confidentiality of your information safe. However, no system can be completely secure and we do not guarantee that our security measures are impenetrable. You also have a significant role in protecting your information. As an example, you should not share your password with anyone. If you believe that your password has been compromised, you should immediately change your password.

IX. Cookies and Other Mechanisms

A cookie is placed on your machine (if you accept cookies) or is read if you have visited our Site previously. All of this is done in accordance with applicable laws. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer, Google Chrome) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. 

Web beacons, also known as clear gif technology, or action tags, assist in delivering the cookie. This technology tells us how many visitors clicked on key elements (such as links or graphics) While using the Site, we do not use this technology to access your personally identifiable information on the Site; it is a tool we use to compile aggregated statistics about Site usage. We may share aggregated Site statistics with our business partners but do not allow other companies to place clear gifs on the Site. 

To ensure we are creating and publishing relevant content, we may use information collected from cookies and other mechanisms. We may use this information in aggregated form and use site-visitation statistics to improve our sites. If you choose to not have your browser accept cookies from our Site, you will be able to view the text on the screens, however, you will not experience a personalized visit or to subscribe to the service offerings on our Site. 

This website uses the Google AdWords remarketing service to advertise on third-party websites (including Google) to previous visitors on our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site – for example, using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the VCloud website. Of course, any data collected, if there are any, will be used in accordance with our own Privacy Notice and Google’s Privacy Notice. 

Information collected via cookies may be transferred outside of the USA (Google Analytics, for example). Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. For information on Google’s Restricted Data Processing go to https://privacy.google.com/businesses/rdp/. 

Type of Cookies Description Manage Settings 

• Required Cookies: Required cookies are necessary for basic website functionality. If you have provided your identity, we may place a cookie in your browser that identifies you when accessing our site. Because required cookies are essential to operate the websites, there is no option to opt out of these cookies.

• Functional Cookies: Functional cookies enhance functions, performance, and services on the website. Some examples include: cookies used to analyze site traffic, cookies used for market research. Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often. We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements. (See Google Adwords above, for example.) You can choose to opt out of functional cookies when accessing the site. You may also control cookies via browser settings.

• Advertising Cookies: Advertising cookies track activity of the user across various websites in order to collect user interests and direct marketing. We sometimes use advertising cookies (from VCloud and from third parties) to show ads on your device and to track the effectiveness of ads.You can choose to opt out of functional cookies when accessing the site. You may also control cookies via browser settings.

X. Transfer of Your Information Across Borders

Your information may be stored and processed in the United States or any other country in which VCloud or its vendors maintain facilities. By using our Site and if the need arises, you consent to any transfer, storage, or processing of information outside of your country. Several countries, including those in the European Economic Area, have established data protection laws and regulations that place restrictions on the transfer of personal information across country borders. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. We are committed to complying with all of those laws and regulations. However, when you use our Site and provide such personal information, you should do so in compliance with the applicable data protection laws and regulations in your country. 

XI. Children’s Information

The Site is not intended for use by individuals under the age of 13. We do not knowingly collect personal data from nor send requests for personal data to individuals under the age of 13. 

XII. Modifications to the Privacy Policy

VCloud may update and make changes to this Privacy Notice periodically and without prior notice to our website’s users/visitors to reflect changes in our information practices or relevant laws. VCloud will post a notice on https://vcloud.com/ that points to this Privacy Policy to notify you of any substantive changes to the way we collect and use information. VCloud will indicate at the top of this Privacy Notice when it was last updated.