Last Updated: December 30, 2019.
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:
B. From third parties
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:
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:
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:
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:
10. DO NOT TRACK ("DNT")
We may not recognize Do Not Track ("DNT") signals from your browser or device. There is not yet a universally accepted standard on how to interpret and respond to DNT signals, which often conflict with other settings. If a standard approach is established, we will re-examine how we can appropriately respond to DNT signals.
11. NOTICE TO CALIFORNIA CONSUMERS/RESIDENTS
Under the CCPA, California consumers have the following rights towards their personal information:
As we understand the applicability of the current requirements and legal thresholds set forth in the CCPA, the CCPA does not apply to Cyclonis Limited because the legal requirements of the CCPA are not triggered under our business operations and circumstances. If at some point in the future the CCPA requirements should be triggered for Cyclonis Limited, the following rights, depending upon the circumstances, may exist for California consumers of our products.
Right to equal services and prices prohibits businesses from discriminating against consumers who exercise their CCPA rights. Today, our services in this regard are free.
Should the foregoing CCPA rights become applicable, you, depending on the circumstances, may also have the right to appoint an authorized agent to make requests under the CCPA on your behalf. The right to make an appointment of an authorized agent by you, should it become available, will be conditioned and dependent upon the submission of a letter of authorization appointing an agent and sufficient documentary proof validating such appointment was properly made by you, in forms sufficient to ensure proper application of the law.
If you should have any questions regarding the CCPA and the foregoing, please contact us at email@example.com or call us at +1 (800) 721-6206 and please type in "Request for California Privacy Information" in the subject line and in the body of your message.
Under California's "Shine the Light" law, California residents who provide certain personal data in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us once per calendar year information about the information that we shared with other businesses for their own direct marketing uses. If this legal provision should become applicable to you (depending upon the business operations and circumstances of Cyclonis Limited), this information would include the categories of information and the names and addresses of those businesses with whom we shared information for the immediately prior calendar year. To obtain this information, please contact us at firstname.lastname@example.org or call us at +1 (800) 721-6206 with "Request for California Privacy Information" in the subject line and in the body of your message. If applicable, we will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements, and only information on covered sharing will be included in our response. We may ask for additional information to verify your identity.
Consumer Rights Notice. Under California Civil Code Section 1789.3, we hereby provide California residents with the following specific consumer rights information:
12. CONTACT US