Privacy Policy

Last Updated: October 2020

Your privacy is important to us and maintaining your trust is one of our highest priorities.

We at Cloutlayer (Cloutlayer LLC and the Cloutlayer affiliates if any) are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Cloutlayer as a controller (Data Controller), including the information collected on our Websites (*.cloutlayer.com) or through other channels as described below. This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices regarding use, as well as your rights of access and correction of your Personal Data. If you do not agree with the data practices described in this Privacy Policy, you should not use the Websites or/and the Subscription Service.

This Privacy Policy does not apply to the data Cloutlayer processes on behalf of our customers (Customer Data) in our capacity as a Data Processor. Cloutlayer’s privacy commitments to its Customers in its capacity as a Data Processor, where we process Personal Data on behalf of our Customers, are outlined in Cloutlayer’s agreements with such Customers.

We periodically update this Privacy Policy. If we change our Privacy Policy, we will update the "Last Updated" date at the top of this webpage. We encourage you to review this Privacy Policy frequently to stay informed of the latest modifications.

1 What Information We Collect About You

Our Use of the Subscription Services

We use our own Subscription Services for various business purposes. Information that we collect and manage using the Subscription Services for our own marketing belongs to us and is used, disclosed and protected according to this Privacy Policy.

When You Visit our Websites

You are free to explore the Websites without providing any Personal Data about yourself. When you visit the Websites or register for the Subscription Services, we request that you provide Personal Data about yourself, and we collect Navigational Information.

Personal Data

We collect personal data from you when you submit web forms or interact with our Website, for example subscribing to a Cloutlayer blog, signing up for a webinar, or requesting customer support. We also collect personal data when you sign up for a Cloutlayer user account or/and Cloutlayer tenant account.

"Personal Data" refers to any information that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Data can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.

Personal Data includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.

Navigational information refers to information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Use of Navigation Information" section below.

Payment information includes information we collect and process from you when you subscribe to the Subscription Services, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect other Sensitive Information from you.

Sensitive Information

This refers to credit or debit card numbers, financial account numbers or wire instructions, government issued identification numbers (such as Social Security numbers, passport numbers), biometric information, personal health information (or other information protected under any applicable health data protection laws), personal data of children protected under any child data protection laws, and any other information or combinations of information that falls within the definition of “special categories of data” under GDPR or any other applicable law relating to privacy and data protection.

Log Files

When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Cloutlayer to provide general statistics regarding use of the Websites. For these purposes, we do link this automatically-collected data to other Personal Data such as name, email address, address, and phone number.

Information we collect from third parties

From time to time, we may receive Personal Data about you from third party sources (partners, social media, etc.).

Information About Children

The Websites are not intended for or targeted at children under 18, and we do not knowingly or intentionally collect personal data about children under 18. If you believe that we have collected personal data about a child under 18, please contact us, so that we may delete the information.

2 How We Use Information We Collect

Compliance with Our Privacy Policy

We use the information we collect only in compliance with this Privacy Policy. Customers who subscribe to our Subscription Services are obligated through our agreements with them to comply with this Privacy Policy.

We Never Sell Personal Data

We will never sell your Personal Data to any third party.

Use of Personal Data

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Data to:

  • improve your browsing experience by personalizing the Websites
  • develop and improve our products and services
  • send information or Cloutlayer content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business
  • promote use of our services to you and share promotional and information content with you in accordance with your communication preferences
  • provide other companies with statistical information about our users (but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis)
  • contact you about billing, account management, and other administrative matters
  • send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements
  • investigate and help prevent security issues and abuse
  • meet legal requirements.

We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Data to the third party.

Legal basis for processing Personal Data (EEA visitors only)

If you are a visitor located in the European Economic Area ("EEA"), Cloutlayer LLC is the Data Controller of your Personal Data.

Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

Use of Navigational Information

We use Navigational Information to operate and improve the Websites and to provide you with a better experience when you interact with Cloutlayer. We may also use Navigational Information alone or in combination with Personal Data to provide you with personalized information about Cloutlayer. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.

Customer Testimonials and Comments

We post customer testimonials and comments on our Websites, which may contain Personal Data. We obtain each customer's consent via email prior to posting the customer's name and testimonial.

Use of Payment Information

If you give us Payment information, we use it solely as authorized by you in accordance with this Privacy Policy in order for you to use the Subscription Services, including to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

Social Media Features

Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share Button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, 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 Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites

Our Websites provide links to other websites of third parties. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Public Forums

We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others.

3 How we Share Information we Collect

We may share and disclose Personal Data to the following types of third parties and for the following purposes:

To Customers

We may disclose information to our customers in the form of aggregated, anonymous data about the way the Services have been used to enable us to provide and improve our Subscription Services, to provide strategic advice to our customers, and to further and enhance our role as a thought leader in the industry.

To vendors, consultants and other service providers

We may disclose information to third-party vendors, consultants and other service providers in connection with our marketing efforts, or in connection with our general business purposes.

To comply with laws

We may disclose information to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process or governmental request.

To protect our legal rights

We may also disclose information where we believe it necessary in order to protect or exercise, establish or defend our legal rights.

Business transfers

We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

To provide our Subscription Service

We use sub-processors in our provision of the Subscription Service to our customers, such as third-party hosting providers and third-party database support services. Some of these third-party sub-processors may have logical access to data about you, but in all cases, any sub-processor to whom we disclose any information will be subject to a written agreement containing confidentiality protections designed to protect any Personal Data that is shared with them.

To manage events

If you use our Website to register for an event or webinar organized by one of our partners who may be a co-sponsor of the event, we may share your Personal Data with the co-sponsor to the extent this is required to process your registration and ensure your participation in the event; in such instances, our co-sponsor will process the relevant Personal Data as a separate controller and the sponsor’s use and control over your Personal Data will be governed by the sponsor’s privacy policy.

To advisors

In individual instances, we may share Personal Data with professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance and accounting services, but only to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.

Publicly shared data

Any Personal Data or other information you choose to submit in communities, forums, blogs or chat rooms on our Website may be read, collected and used by others who visit these forums, depending on your account settings.

4 International Transfers, Security and Data Retention

International Transfers

We do not tranfer data internationally. All data live in the European Economic Area (“EEA”).

Security

We use technical, organizational and administrative security measures designed to protect the security, confidentiality and integrity of information.

Data Retention

We will retain Personal Data we collect from you for so long as we have an ongoing legitimate business need to do so. When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible.

The data our customers collect by using the Subscription Service is retained according to the relevant agreements with our customers.

5 Cookies and Similar Technologies

Cookies

Cloutlayer and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our Websites and how to manage your cookie preferences please see our Cookie Policy.

Navigational Information Collected by Our Customers

Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their websites. Cloutlayer does not control our customers' use of these tools, nor do we control the information they collect or how they use it.

Flash Cookies and Other Third Party Tracking Technologies

The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as "Flash cookies." Cloutlayer does not use Flash cookies. However, our customers of our software platform may create pages on the Cloutlayer platform that employ Adobe Flash cookies. For more information on "Flash cookies" and how you can manage them please visit our Cookie Policy.

Advertising

We partner with a third party ad network to either display advertising on our Website or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Third Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.

6 How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Data

You have the following privacy rights:

  • You can request access, correction, updates or deletion of your personal data.
  • You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
  • If we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal data.
    Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.

To exercise any of these rights, please contact us. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

If you would like to access or control your data with one of our customers or users of the Subscription Services, please contact the customer or user directly. Cloutlayer acts as a Data Processor for our customers and will work with our customers to fulfill these requests when applicable.

Anti-Spam Policy

Our Acceptable Use Policy, Email Acceptable Use Policy, SMS Acceptable Use Policy, and Anti-Spam Policy, applies to us and to our customers and, among other things, prohibits use of the Subscription Services to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Services of an "opt-out" mechanism and other required information. We require all of our customers to agree to adhere to the acceptable use policies at all times, and any violations of the acceptable use policies by a customer can result in immediate suspension or termination of the Subscription Services.

Unsubscribe from our mailing list

You may at any time ask us to remove you from any mailing list by going to our Subscriptions Portal, or by clicking "Unsubscribe" in any email communications we send you.

Please note that opting-out of the receipt of marketing communications from us does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.

Unsubscribe from our Customers' mailing list

Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers' marketing communications by clicking on the "Unsubscribe" link located on the bottom of their emails, or by contacting them directly.

7 Data Protection Officer

dpo [at] cloutlayer [dot] com

Cloutlayer, LLC
100 Laskaridou, 2nd Floor
Kallithea, Attiki, 17676, Greece