Last updated: April 16, 2018
Privacy Policy
1. Introduction
Cloud Coach International, Ltd (“Cloud Coach”) is committed to protecting the privacy of individuals who visit our website, who use our project management and professional services automation services (the “Services”), who register to attend our events (in person or online), sign up for additional content, request demonstrations of the Services, or sign up to our newsletter. It is important to Cloud Coach that you understand what information we collect and also that you understand what we may do with that information, as well as individuals’ choices regarding use, access and correction of personal information.
By accessing or using the Services, www.cloudcoach.com, support.cloudcoach.com, or milestonessupport.cloudcoach.com (collectively “the Site”) you consent to the terms of this Privacy Policy and you signify your assent to all of the terms of this Privacy Policy as to Cloud Coach, including all owned brands and trade names and also including its affiliates and assigns. If you do not agree with any terms of this Privacy Policy, please do not use this Site or Services or submit any personal information.
Please carefully read this Privacy Policy to be sure you understand how your information may be used. This Privacy Policy also covers the collection of data from applications on mobile devices.
By providing us with your data, you warrant to use that you are over 13 years of age.
Cloud Coach is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details:
Our full details are:
Cloud Coach International, Ltd.
Email Address: privacy@cloudcoach.com
Postal address: ℅ 2580 East Harmony Road
Suite 201
Fort Collins, CO 80528
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at privacy@cloudcoach.com
2. What Data Do We Collect About You
Personal data means any information capable of identifying an individual. It does not include anonymized data.We may process certain types of personal data about you as follows:
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access the Site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences (other than as a part of our internal hiring processes through standard background checks).
Where we are required to collect personal data by law, or under the terms of the contract between us and you, if you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver the Services to you). If you don’t provide us with the requested data, we may have to cancel your order of the Services. If we do, we will notify you at that time.
3. How We Collect Your Personal Data
We collect personal data about you through a variety of different methods including:
- Direct Interactions: You may provide data when filling in forms on the Site (or otherwise) by communicating with us by post, phone, email, or otherwise, including when you:
- subscribe to our Service;
- create an account on the Site;
- request resources or marketing be sent to you;
- request a demonstration of the Service;
- watch a demo or install the Service from the Salesforce AppExchange;
- give us feedback.
- Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive technical data about you if you visit other websites that use our cookies. Please see the cookie section of this policy for further details.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers such as Google based outside the EU;
- Identity and Contact Data from publicly available sources such as LinkedIn.
- Interactions with Cloud Coach specific listings on the Salesforce AppExchange.
4. How We Use Your Data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at marketing@cloudcoach.com.
Purposes for processing your personal data
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at privacy@cloudcoach.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Notifying you about changes to our online MSA |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services |
| To enable you to partake in a prize drawing, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business |
| To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation |
| To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests to develop our products/services and grow our business |
Marketing communications
- requested information from us or purchased goods or services from us; or
- interacted with Cloud Coach listings on the Salesforce AppExchange;
- provided us with your details for us to send you marketing communications; and
- in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at marketing@cloudcoach.com at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at privacy@cloudcoach.com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Salesforce.com, inc. and its subsidiaries (“Salesforce”) who hosts the Services as well as some of the systems we use to store and process personal data.
6. International Transfers
Different countries offer different levels of protection for personal data. European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at privacy@cloudcoach.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your information may be stored in whole or in part on equipment or in facilities leased or licensed from others (i.e., Salesforce.com Platform). Cloud Coach relies on the statements of those vendors regarding the safety and security of their storage equipment and services as part of its evaluation. All information collected and stored on the Salesforce Platform is subject to the Salesforce Data Protection addendum located here.
By using the Site and Services, you agree that CLOUD COACH is not responsible if the storage equipment and services provided by others aren’t working like they are supposed to, and that you will have to seek any remedies from those providers, not CLOUD COACH.
While CLOUD COACH has robust security measures to help protect the information under our control, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. Please contact us immediately at privacy@cloudcoach.com if you have reason to believe that your interaction with us is no longer secure.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
If you are an individual residing in the EU, Switzerland or the UK, you may be able to request that we delete your personal data. Additional information is below.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your Legal Rights
If you are an individual residing in the EU, Switzerland or the UK, you have the following rights for personal information processed outside of our Services:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please use our data access form.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please note that personal data processed in our Services is considered Customer Data, and that we process it for our Customers. Our contracts with our customers restrict us from accessing Customer Data, including personal data, in our Services. If you believe Cloud Coach may be processing personal information relating to you in our Services, please contact the Cloud Coach Customer that you believe is the controller of this data.
10. Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
11. Use of Cookies
Our Services run on Salesforce. Salesforce may collect website navigational information from you when you use our Services. The website navigational information they collect, and how they use it, are described here.
12. Changing Our Policy
This Privacy Policy is subject to change. We will prominently post a notice on the Site when there are material changes in the way we treat personal data. You should periodically check back and review this Privacy Policy so that you always will know what information we collect, how we use it, and with whom we share it.