Last Updated: August 19, 2019

OVERVIEW

We are Cyclonis Limited, a company incorporated under the laws of Ireland with company registration number 574974, whose registered office is 3 Castle Street, Dublin 2, Ireland ("we", "us", or "our"). This Privacy Policy applies to the products, services, software, apps, and related technology that we offer, including the use and access of our website(s), processing any necessary payments, and the provision of customer support (together the "Products").

Our Products:

We collect information in order to operate efficiently and provide you with the full use of and access to our Products. We are committed to maintaining robust privacy protections when you purchase, use and access our Products. This Privacy Policy is designed to help you understand how we collect, use and safeguard your information.

If you are resident in the European Economic Area, Cyclonis Limited is the 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:

B. From third parties

We may collect certain information about you from you and/or from third parties, as set out below. This information will be processed in accordance with this Privacy Policy.

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:

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:

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:

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 to contact you and/or send you promotional / marketing communications and/or contact you directly (by email, phone, electronically or otherwise) about our Products, services, discount terms and promotions/offers and those of our affiliates, companies, vendors or trusted business partners 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 use the "unsubscribe" link in the marketing communications to advise us.

3. SHARING YOUR PERSONAL INFORMATION WITH THIRD PARTIES

We will only share the information we collect from you with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal information to 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:

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.

When using our Products, you may be redirected via a link to third party websites. Your use of these websites and any associated services will be subject to these third parties’ terms of use, privacy policies, legal requirements, cookie policies and/or other policies. Please review the specific privacy policy and terms of conditions of these websites, as we are not responsible for them.

4. ADVERTISING

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.

6. RETENTION

We retain your personal information for no longer than is necessary with regard to the purposes for which it was collected or lawfully further processed, as set out in this Privacy Policy, or for so long as may be necessary in light of our legal or statutory obligations (for example, as may be required to comply with audit requirements) or in order to exercise our legal rights or defend legal claims. We commit to undertaking periodic reviews of the personal information we hold to ensure personal information is not held for any longer than is necessary. In some instances we may delete some of the personal information we hold about you once you stop using a Product.

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:

You have a right to contact us at gdpr@cyclonis.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 gdpr@cyclonis.com. You may:

9. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated from time to time for any reason, for example, due to changes in applicable law or regulations, or for business or operational reasons. We will notify you of any change, and the date on which it will take effect, in accordance with law.

Your continued access or use of the Product after such change takes effect will constitute your acknowledgement of the change and your agreement to be bound by the revised Privacy Policy. If you do not agree to the change or update to this Privacy Policy it is your responsibility to cancel your account (including any paid subscription) and stop using the Product before the effective date of the change.

The latest version of this Privacy Policy is always accessible on our website at https://www.cyclonis.com. To view when this Privacy Policy was last updated you can look for the "Last Updated" date stated at the top of the Privacy Policy.

10. CONTACT US

If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us by sending an email to gdpr@cyclonis.com or by writing to us at Legal Department, Cyclonis Limited, 3 Castle Street, Dublin 2, Ireland.