Privacy & Cookie Policy
Last updated: 18th August 2020 - The General Data Protection Regulation (GDPR) which comes into effect from 25th May 2018 aims to protect the rights of data subjects. We have updated our Privacy Policy that refers to how CumulusPro handles your personal data in compliance with the GDPR regulations.
CumulusPro values and respects your privacy in your personal information and any content we may have access through your use of our Services. This Privacy Policy explains what information CumulusPro (“CumulusPro” or “we” or “us”) collect about you and why, and what we may do with that information and how we process your Content.
Scope
This Privacy Policy is incorporated into the CumulusPro Terms of Use and applies to the information obtained by us through your use of this website, CumulusPro solutions and Cloud Services.
Changes
As CumulusPro and the Internet evolves, we may need to update this Policy to keep pace with changes in our Services, our business and laws applicable to us and you. We will always maintain our commitment to respect your privacy. We will post any revisions to this Policy or any other legal-related statements, with their effective dates, on our website.
We recommend that you periodically check back here to stay informed of any changes. Your consent to such changes may be required if applicable by law. However, the continuation of your CumulusPro Service account after such change means that you agree with, and consent to be bound by the new Privacy Policy. If you disagree with any changes in this Policy and do not wish your information to be subject to the revised Policy, you may need to discontinue your service with us in writing.
Who we are
CumulusPro is in the business of offering Business Transformation Solutions (“CumulusPro Services”) from a cloud-based Business Process Management (BPM) Platform. “CumulusPro Services” are offered as a Software-as-as-Service. Our technology comprises of technology components, automation services, web clients, mobile apps, vertical business solutions, web services and web portals that are made available to our customers from the cloud.
Personal Data
CumulusPro uses the information collected from you on this website solely for the purpose to provide quotations, present software demonstrations, make telephone contact and/or to email PR and marketing information which we believe may be of interest to you and your business. In your action of establishing initial contact on our website, you consent to CumulusPro maintaining a dialogue with you until you either opt-out (which you can do at any stage).
In the delivering of CumulusPro Services to our customers or partners, CumulusPro performs exclusively as a data processor. All all times, CumulusPro will work closely with our clients and partners (the data controllers or sub-processors) to ensure that we are GDPR compliant.
Some personal data may be collected about you from the contact forms you complete, from records of our correspondence and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. CumulusPro may from time to time use such information to identify its visitors.
Cookies
What are cookies
A cookie is a small text file stored on your computer or mobile device and retrieved from there on your subsequent visits. We use cookies to enhance and provide you with the best user experience possible.
We do not use cookies to store personal information or to provide information to third parties.
How we use cookies
The following section details the third-party cookies you might encounter through this site.
- Analytics – We use Google Analytics to analyse the use of our website. Visit the official Google cookie policy page for more information.
- Cookie consent – We use cookies to store your preferences in relation to the use of cookies on this website.
- Contact form submission – We use Zoho forms to provide a secured form collaboration tool. Visit Zoho cookie policy page for more information.
- Social media - We use social media buttons and/or plugins on this site. Visit our social media service providers cookie policy for more information.
Disabling cookies
You can manage the use of cookies by adjusting the settings on your browser.
Disabling cookies on your browser may affect the functionality of our website and other websites that you may visit.
Most browsers allow you to refuse to accept cookies and to delete cookies. You can obtain up-to-date information about the blocking and deleting cookies via these links:
- Turning cookies on or off on Chrome.
- Managing cookies and cache on Firefox.
- Managing privacy on Opera.
- Deleting and manage cookies on Internet Explorer and MS Edge (Windows 7 – 10).
- Managing cookies and data on Mac (Safari).
Legitimate interests
To promote, market, and delivery of Cloud Services offered by CumulusPro.
Legal basis for processing personal data
CumulusPro collects or processes personal data for the sole purpose of meeting the contractual obligations of delivering CumulusPro Cloud Services to our customers and partners.
Disclosure
Through the delivery of CumulusPro Cloud Services, CumulusPro may transfer your Personal Information to our sub-processors exclusively to process work in accordance to orders provided by our Customers or Partners (“data controllers”). In the event of such a transfer, CumulusPro will require our sub-processors to agree to process this information based on our instructions and requirements that are consistent with this Privacy Policy and GDPR.
At any time, CumulusPro does not broker or transfer any information gained from your engagement with CumulusPro without your consent. However, CumulusPro may disclose your Personal Information to meet legal obligations, regulations or valid governmental requests.
Retention Policy
CumulusPro will process personal data during the duration of a valid Service Agreement which requires the processing (Cloud Services) of personal information. And in the duration of delivering the service, CumulusPro will continue to store only personal data that is required in accordance to the Service Requirements to meet any legal obligations.
Data storage and security
CumulusPro is committed to protecting the security of your information and content and takes all reasonable precautions to protect it. Unless specified, Personal Data that we collect from you will be stored at a secure cloud data centre hosted by Microsoft and located within the European Economic Area.
We use industry-standard encryption to protect your data in transit. This is commonly referred to as transport layer security (“TLS”) or secure socket layer (“SSL”) technology. However, these internet data transmissions are not guaranteed to be 100% secure, and as a result, we cannot ensure the security of information during its transmission between you and us; accordingly, you acknowledge that you do so at your own risk.
In the event that your Content is uploaded to our servers for processing and temporary storage, they are protected on Microsoft Azure Data centres using a combination of administrative, physical and logical security safeguards covered by Microsoft's multiple security audit certifications; one of which is ISO/IEC 27001 (See: http://azure.microsoft.com/en-us/support/trust-center/compliance/).
The security of the information stored locally on your computing device while using our Service is dependent upon you utilising all available security features on your device. We recommend that you take the appropriate steps to secure all computing devices that you use with our applications and Service.
Your rights as a data subject
If you are an EU resident, at any point whilst CumulusPro or our sub-processors are in possession, or processing your personal data, all data subjects (you) have the following rights:
Right of access – you have the right to request for the details of personal information that we have of you.
Right of rectification – you have a right to amend data that is inaccurate or incomplete.
Right to be forgotten – you have the right to request that your data are removed from our records in accordance with Article 17 GDPR.
Right to restriction of processing – you have a right to restrict the processing if applicable Article 18 GDPR.
Right of portability – you have the right to have the data we hold about you transferred to another organisation (Article 20 GDPR).
Right to object – you have the right to object to certain types of processing such as direct marketing (Article 21 GDPR).
Right to object to automated processing, including profiling – you have the right not to be subject to the legal effects of automated processing or profiling (Article 22 GDPR).
The following information may be requested from us through our main contact form (https://cumuluspro.com/contact/):
- The contact details of the organisation (Data Controller) that has designed on how and why your data is collected and processed.
- Contact details of the data protection officer(s) (if available).
- The purpose of the processing your information.
- Details of your personal data that has been collected and processed.
- The intended recipient(s) that your data is/will be disclosed to.
- Retention period of the data in CumulusPro data servers.
- Procedures on lodging complaint with the appropriate supervisory authority (ICO).
- Source of personal data if it wasn’t collected directly from you.
- Any other details and information of automated decision making, such as profiling, or any meaningful information about the logic involved, as well as the expected consequences of such processing.
Rights to access personal data
To protect your personal data, CumulusPro will only accept the following forms of identifications when you request for information: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. Minimally, we will require one piece of photographic ID and a supporting document. If CumulusPro feels that we cannot positively identify you from your submitted identification proof, we will seek further information before personal data can be released.
You can make your requests on https://cumuluspro.com/contact/ with a valid email address that we can get back to you.
Children's Privacy
As CumulusPro focus in offering business transformation solutions for business needs. CumulusPro Services are not directed to children (minors under 18) and we do not promote or market our services to minors. If you believe that we have mistakenly or unintentionally collected Personal Information of a minor through our Services without appropriate consent, please notify us through our Contact form so that we may immediately delete the information from records and make any other necessary corrections.
I. Information Collection and Use
What Information CumulusPro Collects and Why
If you register for or maintain a CumulusPro Service account:
| We collect | Why we collect it |
|---|---|
| Your username, email address and contact preferences |
|
| The geographic area where you use your computing devices and the language you select | To localise your interaction with the Service and improve our understanding of how users interact with the Service and the Market. |
| Your device identifier and Unique Application numbers |
|
| Actions you perform using your account, including your use of certain features and your storage of particular formats of Content (e.g., PDFs or JPGs), as well as the type of device and software you are using |
|
| Log Information. This may include: Details of how you use our app; Internet Protocol (IP) address; Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL |
|
Additional information we collect in connection with CumulusPro Business accounts:
| We collect | Why we collect it |
|---|---|
| Business name, name and email address of account creator | To create and support your account. |
| Billing information (i.e., address, email address and telephone number) | To communicate with the Billing Contact on the account and provide account support. |
| Email addresses of Business account Administrators and end-users | To support the account and communicate with account Administrators and end-users. |
Email Communication
From time to time, we may want to contact you with information about product announcements, software updates and special offers. We also may want to contact you with information about products and services from our business partners. We consider your acceptance of this Privacy Policy as your acceptance of our offer to send you these emails.
Opt-out
If you do not want us to send any marketing updates or product information as part of the pool of anonymized data you may choose to opt-out by leaving us a message on our general contact form with your email address.
II. Information Access and Disclosure
Sharing of Personal Information and Content
CumulusPro does not sell or rent user information. Your information may ONLY be provided to 3rd party service providers (or sub-processors) when:
Explicit consent is given by you to share your information.
Your information is required by service providers;
tto process data on our behalf in order to operate the Service and/or complete your payment transactions; and these providers are subject to strict data protection law requirements.
to fulfil your product or service requests, including sales, delivery and support for certain products or services.
Investigation of potential violations of our Terms of Use, to enforce those Terms of Use, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud or potential threats against persons, property or the systems on which we operate the Service.
Access, preservation or disclosure of information is required permitted by law to protect the rights, property or personal safety of CumulusPro, our partners and users of the Service, or is required to comply with applicable laws, including compliance with warrants, court orders or other legal process.
Some third-party applications and services that work with our Service may ask for permission to access your Content or other information about your account. Those applications may provide you with notice and request your consent in order to obtain such access. Please consider your selection of such applications and services, and your permissions, carefully. We encourage you to review our certified third party applications list and each party’s privacy policy before proceeding.
Some third parties may embed plugins on the Service, such as Facebook “Like” buttons, and may allow their operators to learn that you have visited our website. They may combine this information with other, identifiable information they have collected about your visits to other websites or online services. Our website as well as some of our web application pages use social media features provided by companies and services such as Facebook, Twitter, Google+, YouTube and LinkedIn to enable you to share information with these social channels. These Social connections are identified on our website by the display of the companies’ logos. These social connection are enabled by cookies owned and controlled by these third parties, and the third parties are responsible for their use.
When you visit a page on the CumulusPro website or application pages that contains Social Features, your browser establishes a direct connection to the applicable social network’s servers. The Social Features inform the social networks what pages you have accessed on CumulusPro website, and, if you are logged into the social network, your visit may be logged to your account on that service. For example, if you click the Facebook “Like” button, that information is transmitted from your browser directly to Facebook and stored by them. Even if you are not logged into the social network, and do not click on a Social Feature on the Evernote site, there is still a possibility that a Social Feature can transmit your IP address and cookie information to the operator of the social network. However, we do not and will not transmit any information regarding your Contents to such social networks.
For information on the purpose and scope of data processing by a social network, as well as your options for protecting your privacy, please review the appropriate social network's privacy policy. For your convenience, below are links to the most commonly used Social Features you’ll see on the Evernote site.
Facebook: https://www.facebook.com/about/privacy
Twitter: http://twitter.com/privacy
CumulusPro’s Access to Your Documents, Images and Metadata
Without your consent, CumulusPro employees do not monitor or view your personal information or any Content stored in the Service, but in an event that we suspect our Terms of Use have been violated and confirmation is required, or when we need to do so in order to respond to your requests for support, or when we have an obligation to review it as described in our Terms of Use.
Your Content may be viewed where necessary to protect the rights, property or personal safety of CumulusPro and its users, or in order to comply with our legal obligations, such as responding to warrants, court orders or other legal processes. We vigilantly protect the privacy of your account contents and, whenever we determine it possible, we provide you with notice if we believe we are compelled to comply with a third party’s request for information about your account.
Protection of Personal Information and Content
Any information that you post in our public social media sites like LinkedIn, Twitter, Google+, Facebook, comments can be read, collected and used by anyone and could enable others to send you unsolicited messages, or if you choose to allow your content to be downloaded, screenshot, email, shared, uploaded or distributed using your email, or chat applications, CumulusPro is not responsible for any publication or use of any Personal Information you choose to post, shared or distribute in these locations.
Violation of Terms of Use
If your Service account has been suspended or closed due to a violation of Terms of Use, you may contact CumulusPro to request a reinstatement or deletion of your data, and CumulusPro will evaluate such requests on a case-by-case basis, pursuant to our legal obligations.
Contact Us
CumulusPro welcomes your feedback regarding this Privacy Policy. If you have questions, comments or concerns about this Policy, please contact us by email at gdpr@cumuluspro.com or complete the online form here.