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PRIVACY STATEMENT

Effective: May 7, 2024



Cloud Software Group, Inc. and its subsidiaries (“Cloud Software Group”, “we”,
“us”, and “our”) places importance on privacy and data protection.

This Privacy Statement describes our personal information processing practices,
including the types of personal information we obtain, how we may use that
personal information, with whom we may share it, and how you may exercise your
rights regarding our processing of that information. The Privacy Statement also
describes the measures we take to safeguard the personal information we obtain
and how you can contact us about our privacy practices.

This Privacy Statement applies to the personal information we obtain through
Cloud Software Group properties on which this Privacy Statement is posted,
including websites, products, services, desktop and mobile apps, and other tools
offered by Cloud Software Group that reference this Privacy Statement (“Online
Channels”); offline collection, including Cloud Software Group events, surveys,
questionnaires, customer user research and evaluations (“Offline Channels”); and
third-party sources, including business partners, ad networks and vendors
(collectively, the “Offerings”).

The Online Channels may provide links to other third-party websites and
features. Some of these third-party websites may be co-branded with Cloud
Software Group even though they are not owned, controlled, operated, or
maintained by Cloud Software Group. Unless otherwise disclosed in this Privacy
Statement or other supplementary privacy notice provided to you, Cloud Software
Group does not automatically share your personal information with those
third-party websites and is not responsible for their privacy practices. These
websites are subject to their respective privacy policies. In some cases, we may
provide the Offerings jointly with other businesses. For these co-branded
offerings in which a third party is involved in your transactions, we will
sometimes share or jointly collect customer data–which may include personal
information–related to those transactions with that third party.

References in this Privacy Statement to “Cloud Software Group” are references to
the Cloud Software Group entity responsible for the processing of your personal
information, which generally is the Cloud Software Group entity that collects
your personal information.

This Privacy Statement does not apply to personal information:

 * our employees provide us in connection with their employment, which is
   covered by our Internal Privacy Notice.
 * an individual makes available to us in connection with the recruitment
   process, which is addressed separately by our Candidate Privacy Notice.
 * processed on behalf of our customers when providing Cloud, technical support,
   and consulting services, which is described in the Cloud Software Group Data
   Processing Addendum and related product documentation.  Customer end-users
   should direct any questions about our customers’ privacy practices to our
   customer who collected their information.


ON THIS PAGE

 * What Personal Information We Collect
 * How We Use Personal Information
   * Cookies and Other Similar Technologies
     * Strictly Necessary Cookies
     * Functional Cookies
     * Analytics Cookies
     * Advertising Cookies
   * Interest-Based Advertising
   * App Marketplaces
 * Why & With Whom We Disclose or Share Personal Information
   * International Data Transfers
 * Your Privacy Rights and Choices
   * Communication Preferences
   * Interest-Based Advertising Choices
   * Global Privacy Control (GPC)
   * Other Online Preferences
 * How We Protect Personal Information
 * How Long We Retain Personal Information
 * Children’s Personal Information
 * Supplemental Notice to California Residents
   * Collection, Use, and Sharing
   * We Do Not Sell Your Personal Information
   * Your California Privacy Rights
 * Changes to Our Privacy Statement
 * How to Contact Us


WHAT PERSONAL INFORMATION WE COLLECT

The data we obtain varies based on the Offerings you use. We obtain personal
information through your interaction with the Offerings, such as when you:

 * browse our website;
 * create an account in an Online Channel;
 * sign up for an online program, event, seminar, promotion or sweepstakes;
 * request products (including product evaluations, trials, tech preview and
   beta downloads), services or information;
 * participate in Cloud Software Group events including conferences, webinars,
   surveys, questionnaires, research or evaluations; or correspond with us or
   request information from us.

In addition to personal information you directly provide, we collect personal
information from the following categories of sources:

 * third parties such as your employer, company administrator or business
   partner, through their use of the Offerings;
 * our affiliates;
 * social media networks;
 * personal information contained in forums, blogs, and testimonials you provide
   or that we obtain from publicly available sources (such as social media
   channels);
 * marketing and business information enrichment sources; and
 * advertising networks.

The types of personal information we obtain include:

 * contact information (such as name, email address, telephone number, postal,
   or other physical address) for you or for others (e.g., principals in your
   business or billing contacts);
 * identifiers (such as a real name, alias, postal address, unique personal
   identifier (e.g. device identifier; cookies, beacons, pixel tags, mobile ad
   identifiers and similar technology; customer number, unique pseudonym, or
   user alias; telephone number and other forms of persistent or probabilistic
   identifiers), online identifier, Internet Protocol address, email address,
   account name);
 * information used to create and administer your online account (such as
   username and password);
 * business profile and practices information used to evaluate you as a partner;
 * photographs, video images, voice recordings, or transcripts;
 * billing and financial information (such as name,signature, billing address,
   payment card details and bank account information and purchase history);
 * location data (such as data derived from your IP address, country and zip
   code) and the precise geolocation of your device;
 * Internet and other electronic network activity information, including, but
   not limited to, browsing history, search history, and information regarding
   your interaction with websites, applications or advertisements information
   about your devices, files viewed, and other usage patterns), including across
   the Online Channels and third-party websites, that we obtain through the use
   of cookies, web beacons, pixels, tags, and similar technologies (see our
   description of Cookies and Similar Technologies below);
 * time and date related access to events, offices, or facilities;
 * information collected in forms that may be required on-site to access Cloud
   Software Group facilities;
 * personal information contained in forums, blogs, and testimonials you provide
   or that we obtain from publicly available sources (such as social media
   channels);
 * information related to participation in classroom or online training,
   including programs completed and certifications achieved;
 * information necessary to provide support or other paid consulting services
   (such as contact details, chat services, support details, and event history);
 * commercial information, including records of personal property, products or
   services purchased, obtained, or considered, and other purchasing or
   consuming histories or tendencies;
 * personal information contained in content you submit to us (such as through
   our “Contact” feature or other in-product or in-service messaging);
 * contact information we obtain from third-party information brokers and event
   organizers to enrich our sales & marketing database;
 * in addition to your contact information, if you’re submitting a report to the
   Cloud Software Group Integrity HelpLine, we also collect the contact
   information of the persons you name in your report if you provide such
   information, and a description of the alleged misconduct as well as a
   description of the surrounding circumstances;
 * other personal information we obtain through our Offerings; and
 * inferences drawn from any of the information identified above to create a
   profile about you reflecting your preferences.

Please note that providing personal information to us is voluntary on your part.
If you choose not to provide us certain information, we may not be able to offer
you certain products and services, and you may not be able to access certain
features of the Online Channels.


HOW WE USE PERSONAL INFORMATION

We use the information we collect for the following business or commercial
purposes:

 * to provide and administer our products and services (including websites and
   apps for which you have registered, maintaining or servicing accounts,
   providing customer service, processing or fulfilling orders and transactions,
   verifying customer information, processing payments, providing advertising or
   marketing services, providing analytics services, or providing similar
   services);
 *  to process and fulfill orders in connection with our products and services
   and keep you informed about the status of your order;
 * to help you complete a transaction or order and provide customer support;
 * to bill you for products and services you purchased;
 * to provide training, support, and consulting services;
 * to create and manage your account with Cloud Software Group;
 * to operate, evaluate and improve our business (such as by administering,
   developing, enhancing and improving our products and services; managing our
   communications and customer relationships; and performing accounting,
   auditing, billing, reconciliation and collection activities);
 * to perform data analytics (such as research, trend analysis, financial
   analysis, and customer segmentation);
 * to communicate with you about your account and orders (including sending
   emails relating to your registration, account status, order confirmations,
   renewal or expiration notices, and other important information);
 * to conduct advertising, marketing, and sales activities (including sending
   you promotional materials, generating leads, pursuing marketing prospects,
   performing market research, determining and managing the effectiveness of our
   advertising and marketing campaigns, and managing our brand);
 * to audit audit a current interaction with you and concurrent transactions,
   including, but not limited to, counting ad impressions to unique visitors,
   verifying positioning and quality of ad impressions, and auditing compliance;
 * to conduct short-term, transient use, including, but not limited to, the
   contextual customization of ads shown as part of the same interaction;
 * to communicate with you about, and administer your participation in, events,
   programs, promotions, and surveys;
 * to connect customer employees with their enterprise account administrator;
 * to verify your identity and protect your account against unauthorized use or
   abuse of our services;
 * to protect against, identify, and prevent fraud and other unlawful activity,
   claims, and other liabilities;
 * to detect security incidents, protect against malicious, deceptive,
   fraudulent, or illegal activity, and prosecute those responsible for such
   activity;
 * to protect the health, safety, and security of our employees;
 * to debug to identify and repair errors that impair existing intended
   functionality;
 * to undertake internal research for technological development and
   demonstration;
 * to undertake activities to verify or maintain the quality or safety of a
   service or device that is owned, manufactured, manufactured for, or
   controlled by us, and to improve, upgrade, or enhance the service or device
   that is owned, manufactured, manufactured for, or controlled by us;
 * to comply with and enforce relevant laws, regulations, industry standards,
   contractual obligations, and our policies;
 * to maintain and enhance the security of our Online Channels, products,
   services, network services, information resources, and employees; and
 * to respond to your inquiries.

Depending on the purposes for which personal information is processed, and the
context in which the data is obtained, we may rely on one or more of the
following legal bases:

 * performance of a contract with you or other relevant individual data subject;
 * our legitimate business interests;
 * compliance with a legal obligation, a court order, or to exercise or defend
   legal claims; or
 * your consent, which you can revoke at any time.

We may combine data collected from you with other sources to help us improve the
accuracy of our marketing and communications as well as to help expand or tailor
our interactions with you. This includes combining personal information we
obtain through Online Channels with information we obtain through Offline
Channels, as well as other information (such as referral programs), for the
purposes described above. We may anonymize, pseudonymize, de-identify, and/or
aggregate personal information and use it for the purposes described above and
for other purposes to the extent permitted by applicable law. We also may use
personal information for additional purposes that we specify at the time of
collection. We will obtain your consent for these additional uses to the extent
required by applicable law.

Where required by applicable law, we will obtain your consent for the processing
of your personal information for direct marketing purposes.


COOKIES AND OTHER SIMILAR TECHNOLOGIES

Cloud Software Group uses cookies, web beacons (including pixels and tags), and
similar technologies on our Online Channels which may read or write information
on your device in order to collect certain information about you by automated
means. A “cookie” is a text file that websites send to a visitor’s computer or
other Internet-connected device to uniquely identify the visitor’s browser or to
store information or settings in the browser. A “web beacon,” also known as an
Internet tag, pixel tag or clear GIF, links web pages to web servers and their
cookies and may be used to transmit information collected through cookies back
to a web server.

We use these automated technologies to collect information about your device or
equipment, browsing actions, and usage patterns. The information we obtain in
this manner includes IP addresses and other identifiers associated with your
devices including Apple Advertising Identifier or Android Advertising ID, types
of devices connected to our Offerings, device characteristics (such as operating
system), language preferences, referring/exit pages, navigation paths, access
times, email open rates, browser preferences and characteristics, installed
plugins, local time zones, local storage preferences, clickstream data, and
other information about your online activities.

We use on our Online Channels both first-party cookies (served directly by our
website domain when you visit our Online Channels) and third-party cookies
(served by a third-party website when you visit our Online Channels and certain
third-party websites with whom we have partnered). Some of these cookies are
session cookies (which are automatically deleted when you close your browser)
and others are persistent cookies (which remain on your computer or other
Internet-connected device for a period of time after you end your browsing
session, unless you delete them).

The cookies we use on our Online Channels include: strictly necessary cookies,
functional cookies, analytics cookies, and targeting/advertising cookies, as
described below.

STRICTLY NECESSARY COOKIES

We use strictly necessary cookies on our Online Channels that are necessary for
us to provide you with our products and services. These include cookies used to
securely authenticate you to our website and identify you after you have logged
in and user-centric security cookies used to increase the security of the
products and services we provide to you (such as to detect authentication
abuses). Given the necessary functionality of these cookies, they typically do
not require consent.

FUNCTIONAL COOKIES

These cookies allow us to analyze your use of the Online Channels to evaluate
and improve our performance. They may also be used to provide a better customer
experience on the Online Channels. For example, remembering your log-in details,
saving what is in your shopping cart, or providing us information about how our
site is used.

ANALYTICS COOKIES

We use analytics cookies to collect information on how users navigate and use
our Online Channels, such as how the users traverse our Online Channels, the
pages they view, how long they stay on a page and whether the page is displayed
correctly or whether errors occur. Such cookies help us to improve the
performance of our Online Channels and make the Online Channels more
user-friendly. These cookies are provided by third-party analytics providers,
including Google Analytics. To learn more about Google Analytics and how to opt
out, please visit Google Analytics. To learn more about these analytics services
and how to opt out, please view the Cookie Preferences link in the bottom of the
page for the Cloud Software Group business you are interested in managing
analytics cookies for.

ADVERTISING COOKIES

Advertising cookies are used to control and manage online advertisements. These
cookies may collect information on whether a user has reacted to an
advertisement and visited another website. Such cookies help us offer you
content and provide targeted information that is more relevant to your
interests. They also help us to measure the effectiveness of our advertisements
and communications. In the EU, we deploy analytics and advertising cookies on
our websites only when users have opted-in as required by applicable law.

Your browser may tell you how to be notified when you receive certain types of
cookies or how to restrict or disable certain types of cookies. Please note,
however, that without cookies you may not be able to use all of the features of
our Online Channels. For mobile devices, you can manage how your device and
browser share certain device data by adjusting the privacy and security settings
on your mobile device.

Additional information about our cookie practices and how to manage your cookie
preferences is available in the Cookie Preferences link in the bottom of the
page for the Cloud Software Group business you are interested in managing cookie
preferences for. To the extent required by applicable law, we will obtain your
consent before using cookies or similar tools.

The providers of third-party apps, tools, widgets, and plug-ins on our Online
Channels (such as Twitter, LinkedIn and Facebook) also may use automated means
to collect information regarding your interactions with these features. This
information is collected directly by the providers of the features and is
subject to the privacy policies or notices of these providers. To the extent
permitted by applicable law, Cloud Software Group is not responsible for these
providers’ information practices.


INTEREST-BASED ADVERTISING

When you use our Online Channels, both we and certain third parties (such as our
advertising networks, digital advertising partners and social media platforms)
collect information about your online activities, over time and across
third-party websites (such as on websites that serve our ads). We may use such
information to provide you with advertising about products and services tailored
to your individual interests. We also may obtain information for this purpose
from third-party websites on which our ads are served. You may see certain ads
on other websites because we engage third-party ad buying networks. Through such
buying networks, we can target our messaging to users through demographic,
interest-based and contextual means.

The information our ad networks may collect on our behalf includes data about
your visits to websites that serve Cloud Software Group advertisements, such as
the pages or advertisements you view and the actions you take on the websites.
This data collection takes place both on our websites and on third-party
websites that participate in these ad networks. This process helps us track the
effectiveness of our marketing efforts. To learn how to opt out of this ad
network interest-based advertising, click the Cookie Preferences link in the
footer at the bottom of the page for the Cloud Software Group business you are
interested in managing cookie preferences for. To the extent required by
applicable law, we will obtain your consent before using your information for
interest-based advertising.

Our Cookie Preferences link in the bottom of the page for the Cloud Software
Group business you are interested in provides details about how to exercise your
choices (such as changing your cookie preferences).


APP MARKETPLACES

This Privacy Statement is not applicable to any additional data that may be
collected by an online App Marketplace (e.g., Google Play Store, Apple App
Store). App Marketplaces may collect and use other data about you. Please refer
to the Privacy Policies of the App Marketplaces for more information.

ShareFile for Google Workspace: This app’s use and transfer of information
received from Google APIs to any other app will adhere to Google API Services
User Data Policy, including the Limited Use requirements.


WHY & WITH WHOM WE DISCLOSE OR SHARE PERSONAL INFORMATION

We do not share or otherwise disclose personal information about you except as
described here or at the time of collection. Cloud Software Group may share
personal data in the following reasons:

 * if sharing your data is necessary to provide a product, service, or
   information you have requested;
 * as part of a joint sales promotion or to pass sales leads to our business
   partners;
 * to keep you up to date on the latest product announcements, software updates,
   special offers, or other information we think you would like to hear from our
   business partners;
 * within Cloud Software Group (including among affiliates and subsidiaries) for
   the purposes described in this Privacy Statement; and
 * to connect employees with their company administrator(s).

We share your personal information with the following entities:

 * with our affiliates and subsidiaries;
 * with our customers to report and help manage issues requiring support or as
   part of consulting services;
 * with our customers and partners to inform them about their users’ use of our
   services (such as when a user has obtained credentials or completed a
   course);
 * with persons connected to your business, such as your employer, company
   administrator or business partner;
 * with our vendors and service providers we have engaged to perform services on
   our behalf (such as payment processing, order fulfillment, customer support,
   customer relations management, and data analytics). These service providers
   are contractually required to safeguard the information provided to them and
   are restricted from using or disclosing such information except as necessary
   to perform services on our behalf or to comply with legal requirements;
 * with approved Cloud Software Group Partners, to offer and provide our
   products and services to you;
 * with our joint marketing and sales partners and other business partners who
   help us with our business operations or other aspects of our business and for
   the purposes described in this Privacy Statement; and
 * with third-party marketers (who may combine your personal information with
   their own records, and records available from other sources), for their own
   direct marketing purposes, and the direct marketing purposes of other
   third-party marketers.

We also may disclose personal information about you for the following legal and
public policy reasons:

 1. if we are required or permitted to do so by applicable law, regulation or
    legal process (such as a court order or subpoena),
 2. to law enforcement authorities or other government officials to comply with
    a legitimate legal request,
 3. when we believe disclosure is necessary to prevent physical harm or
    financial loss to Cloud Software Group, its users or the public as required
    or permitted by law,
 4. to establish, exercise or defend our legal rights, and
 5. in connection with an investigation of suspected or actual fraud, illegal
    activity, security or technical issues.

In addition, we reserve the right to transfer to relevant third parties
information we have about you in the event of a potential or actual sale or
transfer of all or a portion of our business or assets (including in the event
of a merger, acquisition, joint venture, reorganization, divestiture,
dissolution, or liquidation) or other business transaction.

We also may share the information in other ways for which we provide specific
notice at the time of collection and obtain your consent to the extent required
by applicable law.


INTERNATIONAL DATA TRANSFERS

We transfer the personal information we collect through the Channels to, and
store such data in, other countries in which Cloud Software Group and its
service providers operate, including the United States, which may have different
data protection laws than the country in which the information was provided. If
we do so, we will transfer the personal information only for the purposes
described in this Privacy Statement. To the extent required by applicable law,
when we transfer your personal information to recipients in other countries, we
will take measures to protect that information including, as appropriate, by
executing data transfer agreements based on the European Commission’s Standard
Contractual Clauses pursuant to article 46 of the General Data Protection
Regulation (GDPR) or by putting in place other appropriate data transfer
mechanism(s).


YOUR PRIVACY RIGHTS AND CHOICES

To the extent provided by the law of your jurisdiction, you may have privacy
rights to access, correct, update, amend, delete, restrict the processing of
your personal information, or object to automated decision-making based on your
personal information.

When Cloud Software Group is acting as a “data controller” under applicable law,
you may exercise such rights by completing a Privacy Request form or by
contacting us using the information under the How To Contact Us section of this
Privacy Statement, or, where applicable, by accessing your Cloud Software Group
account. To help protect your privacy and maintain security, we may take steps
to verify your identity before granting you access to the information. To the
extent permitted by applicable law, a charge may apply before we provide you
with a copy of any of your personal information that we maintain. Depending on
your location, you may have the right to file a complaint with a government
regulator if you are not satisfied with our response.

When Cloud Software group is acting as a “data processor” and you wish to
exercise your privacy rights of access and request corrections, suppression, or
deletion, we will direct you to the data controller under the applicable data
protection laws. Alternatively, to exercise any rights relating to personal
information processed on behalf of our customers in connection with the use of
our products and services, end users may directly contact the relevant customer,
not Cloud Software Group. If you are a customer account administrator or
customer account owner and require assistance with this process, such as if you
want to make a request with respect to your own user data, you may contact us as
described below.


COMMUNICATION PREFERENCES

We also offer choices in connection with the personal information we use to
communicate with you, such as via email or telephone. To update your email and
telephone communication preferences, limit the communications you receive from
us, or submit a related request, please contact us as specified in the How to
Contact Us section of this Privacy Statement. You can also unsubscribe from our
email marketing by following the “Unsubscribe” link in our marketing emails. 
Please note that unsubscribing from  marketing communications does not affect
your receipt of operational communications that are important to your
interaction with us or our services, such as communications about the status of
your subscription, service changes, support communications, security updates,
event registration updates or account management communications.


INTEREST-BASED ADVERTISING CHOICES

We support the Self-Regulatory Principles for Online Behavioral Advertising
("Principles") of the Digital Advertising Alliance in the U.S., the Digital
Advertising Alliance of Canada, and the European Interactive Digital Advertising
Alliance in the EU. If you live in the United States, Canada, or the European
Union, you can visit Ad Choices, Ad Choices Canada or Your Online Choices to
find a convenient place to indicate your preferences, including the option to
make one "universal" opt-out of interest-based advertising with participating
entities.

These websites also provide detailed information about interest-based
advertising and tips for managing your privacy online and in applications.
Opting out of interest-based advertising does not mean you will no longer see
advertisements from us or on the Online Channels; rather, opting out means that
the online ads that you do see will not be based on your interests. When you opt
out of receiving interest-based advertisements through the links above, cookies
and other technologies on the Online Channels may still collect information
about your use of the Online Channels, including for analytics, fraud
prevention, and any other purpose permitted under the Self- Regulatory
Principles.


GLOBAL PRIVACY CONTROL (GPC)

Cloud Software Group recognizes Global Privacy Control (“GPC”) signals where
legally required. GPC is a browser setting that a user can set in order to send
a signal to websites visited regarding the user’s cookie preferences. If your
browser or browser extension has GPC enabled, we will recognize that signal and
opt you out of non-essential cookies. For more information about GPC and how to
implement GPC opt-out preference signals, please visit globalprivacycontrol.org.


OTHER ONLINE PREFERENCES

When you use our Online Channels, both we and certain third parties (such as our
advertising networks, digital advertising partners, and social media platforms)
may collect personal information about your online activities, over time and
across third-party websites. Certain web browsers allow you to instruct your
browser to send Do Not Track (“DNT”) signals to websites you visit, informing
those sites that you do not want your online activities to be tracked. Our
Online Channels are not designed to respond to “do not track” signals received
from web browsers. However, you can manage your cookie preferences in connection
with the personal information we collect about you by clicking on the Cookie
Preferences link in the bottom of the page for the Cloud Software Group business
you are interested in managing cookie preferences for.

Where provided by law, you may withdraw any consent you previously provided to
us or object at any time on legitimate grounds to the processing of your
personal information, and we will apply your preferences going forward. This
will not affect the lawfulness of our use of your information based on your
consent before its withdrawal. You may also have a right to lodge a complaint
with the supervisory authority or other data protection regulator in your
jurisdiction.

Some of the rights described above may be subject to limitations under
applicable law.


HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical, and physical safeguards designed to
protect the confidentiality, integrity, and availability of Personal
Information.


HOW LONG WE RETAIN PERSONAL INFORMATION

To the extent permitted by applicable law, we typically retain personal
information we obtain about you for as long as it is needed (1) for the purposes
for which we obtained it, in accordance with the terms of this Privacy
Statement, which generally means that we will keep your personal information for
the duration of our relationship or as long as you keep your account open with
us; (2) only for as long as we have a legitimate business need; and/or (3) for
complying with legal requirements, taking into account applicable statute of
limitation periods and complying with applicable laws, resolve disputes, and
enforce our agreements. As described in the “Your Privacy Rights and Choices”
section above, to the extent provided by the law of your jurisdiction, you may
request that we delete your information or restrict the processing of such
information by contacting us as indicated below.


CHILDREN’S PERSONAL INFORMATION

The Online Channels are designed for a general audience and are not directed to
children under the age of 13. We do not knowingly collect or solicit personal
information from children under the age of 13 through the Online Channels. If we
become aware that we have collected personal information from a child under the
age of 13, we will promptly delete the information from our records. If you
believe that a child under the age of 13 may have provided us with personal
information, please contact us as specified in the How To Contact Us section of
this Privacy Statement.


SUPPLEMENTAL NOTICE TO CALIFORNIA RESIDENTS

This section applies solely to California consumers and is intended to address
the relevant notice requirements of the California Consumer Privacy Act of 2018,
Cal. Civ. Code § 1798.100 et seq. (the “CCPA”). Certain terms used herein have
the meaning given to them in the CCPA.


COLLECTION, USE, AND SHARING

During the prior 12-month period, we may have collected, used, and shared your
personal information as described in this Privacy Statement. Each category of
personal information we may use or share with third parties is outlined in this
Privacy Statement.


WE DO NOT SELL YOUR PERSONAL INFORMATION

California residents have the right to know whether your personal information is
being sold. Your personal information is “sold” when it is provided to a third
party for monetary or other valuable consideration for a purpose that is not a
“business purpose” as set forth in the CCPA. We do not sell your personal
information.


YOUR CALIFORNIA PRIVACY RIGHTS

California residents have the privacy right to:

 * Know what specific pieces of personal information we have collected and
   retained about you over the previous 12 months;
 * Correct inaccurate personal information we may have retained;
 * Receive a copy of your personal information;
 * Delete your personal information;
 * Limit our use of your sensitive personal information; and
 * Opt out of our sharing of your personal information.

To opt out of our sharing of your personal information through cookies and other
similar technologies, click the Cookie Preferences link in the footer at the
bottom of the page for the Cloud Software Group business you are interested in
managing cookie preferences for.

To submit a request related to your other California privacy rights, you may
complete a Privacy Request form or contact us as specified in the How To Contact
Us section below. To help protect your privacy and maintain security, we take
steps to verify your identity before granting you access to your personal
information or complying with your request.

To the extent permitted by applicable law, we may charge a reasonable fee to
comply with your request. We will not deny, charge different prices for, or
provide a different level or quality of goods or services if you choose to
exercise these rights.


CHANGES TO OUR PRIVACY STATEMENT

This Privacy Statement may be updated periodically to reflect changes in our
privacy practices. We will indicate at the top of this Privacy Statement when it
was most recently updated. However, if we make any material change, we will
notify you by means of a notice on this website or by other means prior to the
change becoming effective. By continuing to use our Offerings after such
revisions are in effect, you accept and agree to our revised Privacy Statement.
We encourage you to periodically review this Privacy Statement for the latest
information on our privacy practices.


HOW TO CONTACT US

If you have questions, requests or concerns relating to one of our customer’s
handling of your personal information, please contact the relevant customer. If
you have any questions or comments about our privacy practices, this Privacy
Statement, or your privacy rights and preferences, you may contact us at:

Cloud Software Group
Attn: Chief Privacy Officer (CPO)
4980 Great America Parkway
Santa Clara, CA 95054
United States
privacy@cloud.com

In addition to our above internal contact information, we have appointed a Data
Protection Officer (DPO) for the EU, UK, Germany, and Singapore. If you wish to
contact them, their details are as follows:

Bird & Bird Privacy Solutions
Bird & Bird DPO Services SRL
Avenue Louise 235 Box 1
1050 Brussels
Belgium
DPO.Cloud@twobirds.com

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