Last Updated: December 6, 2019.
- Cyclonis Backup: a backup and recovery storage solution that allows you to upload, store and manage your data on a cloud-based platform. Not yet available. Release expected Winter 2019.
- Cyclonis Password Manager: a password management solution that allows you to save and manage your online account passwords and other sensitive information.
- Cyclonis Screen Capture: a software solution that allows you to save, share and manage, among other things, screenshots, images, digital materials and video captures on your device. Not yet available. Release expected Winter 2019.
- Cyclonis World Time: a customisable clock app for your device that allows you to track and display selected time zone locations and check time around the world.
If you are resident in the European Economic Area, Cyclonis Limited is a data controller responsible for your personal information.
1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
To enable your use and access of our Products, we collect the following kinds of personal information in different ways:
A. Directly from you
We collect certain information from you when you provide it directly to us:
- Basic details and account information - In order to use and access our Products, you typically must first create and register a personal profile and password by completing a registration form. Depending on the Product you are using, the registration form and/or purchase forms can require you to provide us with certain information, such as your name, email address, possibly your phone number, possibly your company name and/or your user name and, depending upon the product(s) and purchase processing, possibly credit card/debit card/PayPal account information, billing address and banking or other information.
- Customer support - In order to provide you with effective customer support, we will need to obtain and retain information from you such as contact details (for example, email address and possibly your phone number and/or billing information) in order to contact you about your query.
- Surveys and Feedback - Periodically, we may request information from users via surveys or requests for feedback. The requested information typically includes contact information (such as name, address and email address) and geographic information (such as postcode or zip code). Survey information will be used for purposes of monitoring and improving the operation, development, quality, suitability, use and user satisfaction of our Products. We may use a third party to help us conduct these surveys. These third parties are not authorized to use this information for any other purpose.
- Geographic Location Data - By default, the Cyclonis World Time app does not automatically collect your geographic location (geolocation) data. By default, your Cyclonis World Time local time zone will be set based on your operating system’s settings. You can also set your location/time zone manually. If you choose to let Cyclonis World Time set your time zone automatically using your location, your current IP address will be used to set your local time zone in the Cyclonis World Time application based on that IP address (the time zone selected may vary depending upon the IP address detected). You may disable this functionality at any time; however, as a result, you may not be able to use some of the Product's features or functionality.
- Other Information - From time to time you may share other information with us through your use of the Product, for example, a Cyclonis Product may ask you to choose a name to identify the device you are using with the Product.
B. From third parties
- Payment details - If you take out a paid subscription to any of our Products, our trusted third party payment providers or business partners will also collect and/or use your, or someone in your company’s, payment details when you subscribe or renew your subscription for the Product. This information may include name, company name, telephone number, email address, billing address, and credit card, debit card, PayPal, banking or other payment information.
C. Automatically collected information
When you access or use our Products, you automatically provide us and/or one of our affiliated companies or trusted partners, such as our payment service providers, vendors, or business partners with certain types of personal information. We automatically collect the following personal information from users:
- Server Log Files - We track information that your browser or your use of our Products provide us. Our servers use log files to analyse trends, track the different locations a user may use our Products in the aggregate, and gather broad demographic information for aggregate use. This information may include IP addresses, geolocation information, hardware ID, browser type, operating system, internet service provider (ISP), date/time stamp, referring/exit pages, and/or clickstream data. To improve our products over time and to consider strategies for delivering the up-to-date products for users we use tracking services. These may include Google, Microsoft, Facebook and Alexa. We also from time to time use tracking analytical measures across the use of our Products and those of our affiliate companies or trusted business partners in order to provide you with information about Products and services available. We may also use Data to provide you with support and technical assistance. The foregoing information may be linked to your account depending on our different tracking methods for purposes of improving the Products/Services and supporting your use.
- User content - We may collect user content and/or related data which may be transmitted, processed or stored using our Products. We may also collect information on the files on your device, for example, the file name, file extension, file size and folder name, as well as retrieval and access activity for your data/files.
- Device data - We collect technical information about the type of device you use to access our Products, such as device type, IP address or hardware ID in order to activate accounts or provide support services.
- Flash LSOs - We may use Local Shared Objects (LSOs), such as Flash LSOs, to store content information and preferences. Third parties with whom we partner to provide certain features on our website, in our Products or to display advertising based upon your web browsing activity may use Flash LSOs to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs, please visit the following third party website: https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html
2. HOW DO WE USE THIS INFORMATION?
We use your personal information for the purposes described below, except where required by law. In doing so, we rely on a number of separate and overlapping legal bases to lawfully process your personal information.
We process your personal information where necessary to carry out our contractual obligations to you. In particular, we process your personal information to:
- Fulfill our contracts with customers: Your personal information is processed in order to provide you with the use of and access to our Products in accordance with our relevant Terms of Service / End User Licence Agreement for each Product. These include the arrangement of any payments for the Products, carrying out user instructions and the provision of customer support. Please see below links to the applicable Terms of Service / End User Licence Agreement:
- Fulfill our contracts with vendors: Your personal information is processed in order to perform contracts, for example, to process payments in accordance with any terms of service / service agreements that exist between us, our affiliate companies, vendors, trusted business partners and any third party payments processor(s), or to provide customer general support, technical support, server services, storage services, archiving services, or data back-up / restoration services. In order to provide our Products to you, it will be necessary that we process your personal information. In the absence of some of this personal information, we will be unable to provide our Products to you. We may also process your information where necessary to further our legitimate interests and those of others, where those legitimate interests are not overridden by your rights or interests. In particular, we process your personal information for the following legitimate interests:
- Providing, improving, maintaining and developing our Products: We use your personal information to provide, improve, maintain and develop our Products. We do so as it is necessary to pursue our legitimate interests of providing a valuable, quality and/or secure offering to all our customers on a continuing basis.
- Providing seamless services across our group of companies: Where the Products require the engagement of our affiliates, subsidiaries or related companies, we share your information with them to provide, administer and improve the Services and Products.
- Customer support: We, our trusted business partners or our third party customer support agents, may communicate with users to assist with inquiries and to provide users with better customer service and/or technical support by means of the contact information provided to us by the user and maintained by us for these purposes.
- Service announcements: On occasion, it may be appropriate to send you a service or Product related announcement. For instance, if one of our Products is temporarily suspended for maintenance or we want to notify you about changes to our Products, availability of our Products, features of our Products or changes to our terms or other policies, we may contact users or send users an email or other communication. These communications are not primarily promotional in nature.
- Safety and security: We use your personal information as it is necessary to pursue our and our users’ legitimate interests in ensuring our Products are secure, such as by implementing and enhancing security measures and protections, protecting against and investigating security breaches, fraud, and spam. It is also in our legitimate interests to use your personal information to prevent unlawful activities, to ensure your safety and security, the safety and security of our personnel, to protect our property and to deter crime.
- Legal proceedings: We process your information if necessary to defend or pursue our interests in legal proceedings. In certain circumstances, we may also use your personal information to comply with our legal obligations, such as to comply with applicable laws, and to assist law enforcement when we have a good-faith belief that such cooperation is reasonably necessary or meets the applicable legal standards.
- Marketing: With your consent we may use your information for us, our affiliated companies and/or trusted business/commercial partners to contact you and/or send you promotional/marketing communications and/or contact you directly by email, post or other electronic means for any purpose, including to provide information about various apps, services, products, special offers, discounts, coupons, news, and events which may interest you. You have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you can follow our Unsubscribe instructions such as found on our "Unsubscribe" page or the "Unsubscribe" link in the marketing communications to advise us.
3. SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES
The information we collect from you may be transferred to third parties in connection with operating the Products, providing the related services and operating our business. It may also be processed by these third parties and/or by our and their respective employees and service providers. We take steps to ensure that these third parties only process data in accordance with our instructions, and take appropriate security measures to protect your data.
By submitting your information, you agree to this sharing, storing and/or processing of your personal information by us.
We may disclose your information to the following third parties:
- our related companies, affiliates, vendors or our trusted business or commercial partners and other businesses, contractors and consultants we work with;
- our professional advisers in order for them to provide us with advice;
- third party service providers, where necessary for them to provide us with services or to provide Products and Services that you have requested, for example, payment service providers, customer support service providers, advertising networks, data analytics providers, marketing advisors/distributors, and customer support agencies;
- our technology providers, including those which host store or process your data on our behalf and/or your behalf and/or provide certain IT support and IT professional services to us; and/or
- business partners and/or possible acquirers or investors (and our and/or their advisors) in the context of facilitating or implementing a business reconfiguration or re-organisation or a transfer/sale of all or part of our assets or business, including, but not limited to a divestiture, acquisition and/or business reconfiguration.
Where required or authorised by law, we reserve the right to release personal information without your consent and/or without consulting you, when we believe that this is appropriate to comply with our legal obligations, to protect the security of our Products, systems and related technologies, to prevent and minimise the effects of fraud, and otherwise to protect our legitimate interests and/or the legitimate interests of our staff, users or members of the public.
You always have a choice as to whether or how you interact with an advertisement (for example, by clicking to learn more about an offer). During use or access, our Products or services may show you ads for our other Products or services and discounts or offers as well as those offered by our affiliated companies or trusted business partners. We may also place ads for our Products or those offered by our affiliated companies or trusted business partners on various third party websites and platforms, and, as a result, you may see ads for our Products when visiting, for example, Google, YouTube, Facebook, and/or a variety of other websites and platforms. We may ask the proprietors of these websites/platforms to present our ads to particular demographic groups, for example, women over 25 years of age, or all visitors to a website who are in Ireland or another geographical location. The third party websites/platforms may use information they already have about the user, or may place cookies or similar tracking technologies in the user's browser, in order to decide what ads the user will see, including potentially our ads. If you wish to opt out of interest-based advertising and you are located in the European Union please visit the following URL: https://www.youronlinechoices.eu. If you are located anywhere else please visit the following URL: https://preferences-mgr.truste.com. You will still see ads but the ads you see will likely be less relevant to you and your interests. If a user has any questions or concerns about the ads they see on any of these third party websites/platforms or if they have questions generally about the privacy practices of those sites, we encourage them to consult the privacy policies of those sites or enquire with the proprietors of those sites.
5. SECURITY AND PROTECTION OF YOUR INFORMATION
We will store information you provide to us on what we believe to be secure servers and will maintain appropriate technical and organisational measures to protect against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your information. We will provide a level of security that is proportionate to the risks that are presented by the processing activity, having regard to the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing.
While we maintain appropriate technical and organisational measures to protect the security of your information, you should be aware of the many information security risks that exist and take appropriate care to help safeguard your information. The nature of the Internet is such that we cannot guarantee the security of the information you transmit to us electronically, and any such transmission is at your own risk.
We also rely on you to maintain the security of your account(s) with us. You are responsible for safeguarding your account(s) by keeping secure all of your account information and passwords.
Due to the security features of the Cyclonis Password Manager Product, we do not have access to your Cyclonis Password Manager master password, information about your third party accounts that you store in your encrypted vault, or any passwords that you store in your encrypted vault. For the Cyclonis Password Manager Product we recommend you use a strong master password, treat it in a confidential and secure manner, and do not use this password with any other service or account. Importantly, we also recommend that you do not lose your master password for Cyclonis Password Manager because, for security reasons, we do not have access to it and cannot help you with your account should you lose it.
As part of the security features of the Cyclonis Backup Product, although certain meta data is accessible (for example, file name, file size, etc.), Cyclonis Backup is purposely designed so that Cyclonis Limited is not able to access the content of your backed up data.
7. GLOBAL DATA TRANSFERS
We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the European Union that are subject to different standards of data protection. We will take appropriate steps to ensure that the transfer of personal information is in accordance with applicable law and is managed carefully to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. As a result:
- where we transfer your personal information outside Cyclonis or to third parties who assist us to provide our Products, we obtain contractual commitments from them to protect your personal information, in particular through standard contractual clauses adopted by the European Commission or through other means we understand to be reasonable; or
- where we receive requests for information from law enforcement or regulators, we consider these requests carefully before any personal information is disclosed.
You have a right to contact us at email@example.com for more information about the safeguards that we have put in place to ensure the adequate protection of your personal information when it is transferred as described in this Section 7.
8. YOUR RIGHTS
If you are a resident of the EEA you have a number of rights with regard to your personal information that we process. To exercise these rights you may contact us at firstname.lastname@example.org. You may:
- Access the information we hold about you. You can access some of your information by logging into your user account or by contacting us using the details provided in the "Contact Us" section below (section 10).
- Have your information corrected or deleted. You can also rectify, restrict, limit or delete some or all of your information by contacting us at the email address provided in the "Contact Us" section below.
- Have the information you provided to us sent to another organisation. You may do this where we hold this information with your consent or for the performance of a contract with you, where it's technically feasible.
- Object to us processing your information. If we process your information based on our legitimate interests as explained above, you can object to this processing in certain circumstances. In such cases, we will stop processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. If we use your data for direct marketing, you can always object using the unsubscribe link in such communications or changing your account settings.
- Complain. If you wish to raise a concern about our use of your personal information, you have the right to do so with the Irish Data Protection Commission or your local supervisory authority in the EEA country in which you reside. You can contact the Irish Data Protection Commission through their website at https://forms.dataprotection.ie/contact or by telephone +353 578 684 800. You can find out more about your data protection rights on the website of the Irish Data Protection Commission (https://www.dataprotection.ie/).
10. CONTACT US