Last Updated: October 2020
Your privacy is important to us and maintaining your trust is one of our highest priorities.
1 What Information We Collect About You
Our Use of the Subscription Services
When You Visit our Websites
You are free to explore the Websites without providing any Personal Data about yourself. When you visit the Websites or register for the Subscription Services, we request that you provide Personal Data about yourself, and we collect Navigational Information.
We collect personal data from you when you submit web forms or interact with our Website, for example subscribing to a Cloutlayer blog, signing up for a webinar, or requesting customer support. We also collect personal data when you sign up for a Cloutlayer user account or/and Cloutlayer tenant account.
"Personal Data" refers to any information that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Data can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or information that we acquire from service providers.
Personal Data includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual.
Navigational information refers to information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the "Use of Navigation Information" section below.
Payment information includes information we collect and process from you when you subscribe to the Subscription Services, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect other Sensitive Information from you.
This refers to credit or debit card numbers, financial account numbers or wire instructions, government issued identification numbers (such as Social Security numbers, passport numbers), biometric information, personal health information (or other information protected under any applicable health data protection laws), personal data of children protected under any child data protection laws, and any other information or combinations of information that falls within the definition of “special categories of data” under GDPR or any other applicable law relating to privacy and data protection.
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Cloutlayer to provide general statistics regarding use of the Websites. For these purposes, we do link this automatically-collected data to other Personal Data such as name, email address, address, and phone number.
Information we collect from third parties
From time to time, we may receive Personal Data about you from third party sources (partners, social media, etc.).
Information About Children
The Websites are not intended for or targeted at children under 18, and we do not knowingly or intentionally collect personal data about children under 18. If you believe that we have collected personal data about a child under 18, please contact us, so that we may delete the information.
2 How We Use Information We Collect
We Never Sell Personal Data
We will never sell your Personal Data to any third party.
Use of Personal Data
- improve your browsing experience by personalizing the Websites
- develop and improve our products and services
- send information or Cloutlayer content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences
- provide other companies with statistical information about our users (but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis)
- contact you about billing, account management, and other administrative matters
- investigate and help prevent security issues and abuse
- meet legal requirements.
We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your Personal Data to the third party.
Legal basis for processing Personal Data (EEA visitors only)
If you are a visitor located in the European Economic Area ("EEA"), Cloutlayer LLC is the Data Controller of your Personal Data.
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data). Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites and to provide you with a better experience when you interact with Cloutlayer. We may also use Navigational Information alone or in combination with Personal Data to provide you with personalized information about Cloutlayer. Navigational Information, such as IP address, is used to approximate your location. For example, we may use your approximate location to provide content that has been translated or send emails at certain times using your local time zone.
Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Data. We obtain each customer's consent via email prior to posting the customer's name and testimonial.
Use of Payment Information
Social Media Features
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others.
3 How we Share Information we Collect
We may share and disclose Personal Data to the following types of third parties and for the following purposes:
We may disclose information to our customers in the form of aggregated, anonymous data about the way the Services have been used to enable us to provide and improve our Subscription Services, to provide strategic advice to our customers, and to further and enhance our role as a thought leader in the industry.
To vendors, consultants and other service providers
We may disclose information to third-party vendors, consultants and other service providers in connection with our marketing efforts, or in connection with our general business purposes.
To comply with laws
We may disclose information to a third party where we are legally required to do so in order to comply with any applicable law, regulation, legal process or governmental request.
To protect our legal rights
We may also disclose information where we believe it necessary in order to protect or exercise, establish or defend our legal rights.
We may share or transfer information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
To provide our Subscription Service
We use sub-processors in our provision of the Subscription Service to our customers, such as third-party hosting providers and third-party database support services. Some of these third-party sub-processors may have logical access to data about you, but in all cases, any sub-processor to whom we disclose any information will be subject to a written agreement containing confidentiality protections designed to protect any Personal Data that is shared with them.
To manage events
In individual instances, we may share Personal Data with professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance and accounting services, but only to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.
Publicly shared data
Any Personal Data or other information you choose to submit in communities, forums, blogs or chat rooms on our Website may be read, collected and used by others who visit these forums, depending on your account settings.
4 International Transfers, Security and Data Retention
We do not tranfer data internationally. All data live in the European Economic Area (“EEA”).
We use technical, organizational and administrative security measures designed to protect the security, confidentiality and integrity of information.
We will retain Personal Data we collect from you for so long as we have an ongoing legitimate business need to do so. When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible.
The data our customers collect by using the Subscription Service is retained according to the relevant agreements with our customers.
5 Cookies and Similar Technologies
Navigational Information Collected by Our Customers
Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their websites. Cloutlayer does not control our customers' use of these tools, nor do we control the information they collect or how they use it.
Flash Cookies and Other Third Party Tracking Technologies
Third Party Tracking Technologies
6 How to Access & Control Your Personal Data
Reviewing, Correcting and Removing Your Personal Data
You have the following privacy rights:
- You can request access, correction, updates or deletion of your personal data.
- You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data.
- If we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal data.
Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.
To exercise any of these rights, please contact us. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
If you would like to access or control your data with one of our customers or users of the Subscription Services, please contact the customer or user directly. Cloutlayer acts as a Data Processor for our customers and will work with our customers to fulfill these requests when applicable.
Our Acceptable Use Policy, Email Acceptable Use Policy, SMS Acceptable Use Policy, and Anti-Spam Policy, applies to us and to our customers and, among other things, prohibits use of the Subscription Services to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Services of an "opt-out" mechanism and other required information. We require all of our customers to agree to adhere to the acceptable use policies at all times, and any violations of the acceptable use policies by a customer can result in immediate suspension or termination of the Subscription Services.
Unsubscribe from our mailing list
You may at any time ask us to remove you from any mailing list by going to our Subscriptions Portal, or by clicking "Unsubscribe" in any email communications we send you.
Please note that opting-out of the receipt of marketing communications from us 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.
Unsubscribe from our Customers' mailing list
Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our customers' marketing communications by clicking on the "Unsubscribe" link located on the bottom of their emails, or by contacting them directly.
7 Data Protection Officer
dpo [at] cloutlayer [dot] com
100 Laskaridou, 2nd Floor
Kallithea, Attiki, 17676, Greece