Latest update: May 20, 2021
This Cloud4Wi Privacy Statement (“Privacy Statement”) explains our privacy practices for the activities described herein. Please read this Privacy Statement carefully to learn how we collect, use, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.
A reference to “Cloud4Wi,” “we,” “us” or the “Company” is a reference to Cloud4Wi, inc. and its relevant affiliate involved in the collection, use, sharing, or other processing of Personal Data. You can find our address and our affiliates’ addresses here.
1. Responsible Cloud4Wi entity
Cloud4Wi is the controller of your Personal Data as described in this Privacy Statement, unless specified otherwise.
This Privacy Statement does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our customers, including where we offer to our customers various cloud products and services through which our customers (or their affiliates): (i) create their own web portals and applications running on our platforms; (ii) sell or offer their own products and services; (iii) send electronic communications to others; or (iv) otherwise collect, use, share or process Personal Data via our cloud products and services.
For detailed privacy information related to a Cloud4Wi customer or a customer affiliate who uses the Cloud4Wi cloud products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement. For more information, please also see Section 10.3 below.
2. Processing activities covered
This Privacy Statement applies to the processing of Personal Data collected by us when you:
Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.
3. What Personal Data do we collect?
3.1 Personal Data we collect directly from you
The Personal Data we may collect directly from you includes identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information. We collect such information in the following situations:
If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent or identified other lawful grounds, and acknowledge that it may be used in accordance with this Privacy Statement. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in the “Contacting us” section below.
3.2 Personal Data we collect from other sources
We may also collect information about you from other sources including third parties from whom we purchase Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we collect such Personal Data from the following sources:
4. What device and usage data do we process?
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.
4.1 Device and usage data
As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites.
In addition, we gather certain information automatically as part of your use of our cloud products and services. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system and system configuration information and date and time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities, and for the security of Cloud4Wi generally (in addition to the security of our products and services). Some of the device and usage data collected by the services, whether alone or in conjunction with other data, could be personally identified to you. Please note that this device and usage data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.
4.2 Cookies, web beacons and other tracking technologies on our website and in email communications
When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer-browsing preferences, and improve and customize your browsing experience.
We also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our websites and marketing emails. For instructions on how to unsubscribe from our marketing emails, please see Section 10.4 below.
The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:
|Type of Cookies||Description||Managing Settings|
|Strictly necessary cookies||These trackers are used for activities that are strictly necessary to operate or deliver the service you requested from us and, therefore, do not require you to consent.||Because strictly necessary cookies are essential to operate the websites, there is no option to opt out of these cookies.|
|Basic interactions & functionalities cookies||These trackers enable basic interactions and functionalities that allow you to access selected features of our service and facilitate your communication with us.||You can choose to opt out of basic interactions & functionalities cookies. To change your cookie settings and preferences, click the Cookies link in the footer of the page.|
|These trackers help us to provide a personalized user experience by improving the quality of your preference management options, and by enabling the interaction with external networks and platforms.||You can choose to opt out of experience enhancement cookies. To change your cookie settings and preferences, click the Cookies link in the footer of the page.|
|Measurement cookies||These trackers help us to measure traffic and analyze your behavior with the goal of improving our service.||You can choose to opt out of measurement cookies. To change your cookie settings and preferences, click the Cookies link in the footer of the page.|
|Targeting & Advertising cookies||These trackers help us to deliver personalized marketing content to you based on your behavior and to operate, serve and track ads.||You can choose to opt out of Targeting & Advertising cookies. To change your cookie settings and preferences, click the Cookies link in the footer of the page.|
4.3 Notices on behavioral advertising and opt-out for website visitor
As described above, we or one of our authorized partners may place or read cookies on your device when you visit our websites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). To learn more about targeted advertising and advertising networks please visit the opt-out pages of the Network Advertising Initiative, here, and the Digital Advertising Alliance, here.
To manage the use of targeting and advertising cookies on this website, click the Cookies link in the footer of the page or consult your individual browser settings for cookies. To learn how to manage privacy and storage settings for Flash cookies, click here. Various browsers may also offer their own management tools for removing HTML5 local storage.
4.4 Opt-Out from the setting of cookies on your individual browser
In addition to using the user preference Cookies link, in many cases you may opt-out from the collection of non-essential device and usage data on your web browser (see the “What device and usage data we process” section, above) by managing your cookies at the browser or device level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. Cloud4Wi takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
4.5 Social Media Features
Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our websites, the platform may receive information showing that you have visited our websites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.
We also allow you to log in to certain of our websites using sign-in services like Facebook Connect or Google Firebase. These services authenticate your identity and provide you the option to share certain Personal Data from these services with us such as your name and email address to pre-populate our sign-up form.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.
4.6 Telephony log information
If you use certain features of our services on a mobile device, we may also collect telephony log information (like phone numbers, time and date of calls, duration of calls, SMS routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language), and location information (through IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers).
5. Purposes for which we process Personal Data and the legal bases on which we rely
We collect and process your Personal Data for the following purposes. Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect and process your Personal Data.
If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
6. Who do we share Personal Data with?
We may share your Personal Data as follows:
We may also share anonymous or de-identified usage data with Cloud4Wi’s service providers for the purpose of helping Cloud4Wi in such analysis and improvements. Additionally, Cloud4Wi may share such anonymous or de-identified usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.
Anyone using our communities, forums, blogs, or chat rooms on our websites may read any Personal Data or other information you choose to submit and post.
For more information on the recipients of your Personal Data, please contact us by using the information in the “Contacting us” section, below.
7. International transfer of Personal Data
Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates and third-parties disclosed in Section 6, above, that are based in other countries. The addresses of our offices where Cloud4Wi, Inc. and its affiliates are located can be found here.
Therefore, your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the EEA. We ensure that the recipient of your Personal Data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulator. Where required by applicable law, we will only share, transfer or store your Personal Data outside of your jurisdiction with your prior consent.
Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16 unless (a) we have obtained consent from a parent or guardian, (b) such collection is subject to a separate agreement with us or (c) the visit by a child under the age of 16 is unsolicited or incidental. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section below and we will take steps to delete their Personal Data from our systems.
9. How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data and the legal bases on which we rely” section, above) or as long as required to fulfill our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.
For more information on data retention periods, please contact us by using the information in the “Contacting us” section, below.
10. Your rights relating to your Personal Data
10.1 Your rights
You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
10.2 How to exercise your rights
To exercise your rights, please contact us by using the information in the “Contacting us” section, below. Your personal data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a Cloud4Wi customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.
Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.
To update your billing information, discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contacting us” section, below.
10.3 Your rights relating to customer data
As described above, we may also process Personal Data submitted by or for a customer to our cloud products and services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data (see the “Responsible Cloud4Wi entity” section above). We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Statement. If your data has been submitted to us by or on behalf of a Cloud4Wi customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the Cloud4Wi customer who submitted your data to us. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.
10.4 Your preferences for email and SMS marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from Cloud4Wi by clicking on the “unsubscribe” link located on the bottom of Cloud4Wi marketing emails, by replying or texting ‘STOP’ if you receive Cloud4Wi SMS communications. Please note that, notwithstanding the above, you will continue to receive marketing and non-transactional communications from Cloud4Wi Services (for example by subscribing to demo experiences managed by the Cloud4Wi Services) unless you manage your receipt of such communications by clicking on the “unsubscribe” link located on the bottom of Cloud4Wi Platform marketing emails, replying or texting ‘STOP’ to Cloud4Wi Platform SMS communications.
You may also turn off push notifications on Cloud4Wi Demo apps on your device, or unsubscribe by contacting us using the information in the “Contacting us” section, below.
Please note that opting out of marketing communications 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.
10.5 Your preferences for telemarketing communications
If you want your phone number to be added to our internal Do-Not-Call telemarketing register, please contact us by using the information in the “Contacting us” section, below. Please include your first name, last name, company and the phone number you wish to add to our Do-Not-Call register.
Alternatively, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.
11. How we secure your Personal Data
We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contacting us” section, below.
12. Changes to this Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.
13. Contact us
Cloud4Wi Inc. is a company established at:
68 Jay Street, New York, NY 11201, United States of America.
Cloud4Wi Inc. has appointed Cloud4Wi Srl, with registered address at:
Via Filippo Corridoni 117/D, 56125 Pisa, Italy,
as its representative in the European Union for the purposes of the General Data Protection Regulation.
If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us using the contact details below. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timeframes provided by applicable data protection laws.
We may be reached at: firstname.lastname@example.org.
You may also contact our Data Protection Officer by emailing the following: email@example.com.
14. Additional Disclosures for California Residents
The California Consumer Privacy Act requires businesses to disclose whether they sell Personal Data. As a business covered by the CCPA, we do not sell Personal Data. We may share Personal Data with third parties or allow them to collect Personal Data from our sites or Services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data, or if you use Cloud4Wi sites or Services to interact with third parties or direct us to disclose your Personal Data to third parties.
California law requires that we detail the categories of Personal Data that we disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in Sections 5 and 6 of this Privacy Statement. We disclose the following categories of Personal Data for our business purposes:
California law grants state residents certain rights, including the rights to access specific types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, and not to be denied goods or services for exercising these rights.
If you are a California resident under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our website(s). Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.
For information on how to exercise your rights, please refer to Section 10.2 of this Privacy Statement. If you are an authorized agent wishing to exercise rights on behalf of a California resident, please contact us using the information in the “Contacting Us” section above and provide us with a copy of the consumer’s written authorization designating you as their agent.
We may need to verify your identity and place of residence before completing your rights request.