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LEGAL – PRIVACY POLICY




WELCOME TO CLUMIO’S PRIVACY POLICY


YOUR PRIVACY IS CRITICALLY IMPORTANT TO US.

It is Clumio’s policy to respect your privacy regarding any information we may
collect while using our website at clumio.com (“Website”) and our
software-as-a-service offerings (“Service”) (the Website and Service,
collectively, the “Services”) operated by Clumio, Inc. and its affiliates
(hereinafter, “Clumio,” “us,” or “we”). We respect your privacy and are
committed to protecting personally identifiable information you may provide us
through the Services. We have adopted this privacy policy (“Privacy Policy”) to
explain what information may be collected through our Services, how we may use
this information, and under what circumstances we may disclose such information
to third parties. This Privacy Policy applies only to information we collect
through the Services.

This Privacy Policy, together with the clumio.com Terms of Use and our SaaS
Terms of Service, set forth the general rules and policies governing your use of
our Services. Depending on your activities when using our Services, you may be
required to agree to additional terms and conditions.


WEBSITE VISITORS

Like most website operators, Clumio collects non-personally-identifying
information of the sort that web browsers and servers typically make available,
such as the browser type, language preference, referring site, and the date and
time of each visitor request. Clumio’s purpose in collecting non-personally
identifying information is to better understand how Clumio’s visitors use its
Website. From time to time, Clumio may release non-personally-identifying
information in the aggregate, e.g., by publishing a report on trends in the
usage of its Website.

Clumio also collects personally-identifying information, for example Internet
Protocol (IP) addresses for logged in users and for users leaving comments on
http://clumio.com blog posts. Clumio only discloses logged in user and commenter
IP addresses under the same circumstances that it uses and discloses
personally-identifying information as described below.


WHAT PERSONAL DATA DOES CLUMIO COLLECT?

Certain users of Clumio’s Services choose to interact with the Services in ways
that require Clumio to gather personally identifying information. The amount and
type of personal information that Clumio gathers depends on the nature of the
interaction. For example, we ask visitors who sign up for a blog at
http://clumio.com to provide a username and email address.


PERSONAL DATA SHARING

Clumio may share your personal information with third parties for the purposes
of operating our business, delivering, improving, and customizing our Services,
sending marketing and other communications related to our business, and for
other legitimate purposes permitted by applicable law or otherwise with your
consent.

Clumio may share personal information in the following ways:

 * Within Clumio for purposes of data processing or storage;
 * With business partners, service vendors, authorized third-party agents, or
   contractors to provide a requested solution, service or transaction (examples
   include, but are not limited to: processing of orders and credit card
   transactions, hosting websites, hosting seminar registration, assisting with
   sales-related efforts or post-sales support, and providing customer support);
 * In connection with, or during negotiations of, any merger, sale of company
   assets, consolidation or restructuring, financing, or acquisition of all or a
   portion of our business by or to another company;
 * In response to a request for information by a competent authority if we
   believe disclosure is in accordance with or is otherwise required by, any
   applicable law, regulation or legal process;
 * With law enforcement officials, government authorities, or other third
   parties as necessary to comply with legal process or meet national security
   requirements, to protect the rights, property, or safety of Clumio, its
   business partners, you, or others, or as otherwise required by applicable
   law;
 * In aggregated and/or anonymized form which cannot reasonably be used to
   identify you; and
 * If we otherwise notify you and you consent to such sharing.


PERSONAL DATA SECURITY

The security of your Personal Information is important to us, but please
remember that no method of transmission over the Internet or method of
electronic storage is 100% secure. We strive to use commercially acceptable
means to protect your personal information; however, we cannot guarantee its
absolute security.


DATA RETENTION

We will only retain your personal information for as long as necessary to
fulfill the purposes for which it was collected. We will retain and use your
personal information as necessary to provide the Services, comply with our
business requirements, legal, accounting or reporting obligations, resolve
disputes, protect our assets, and enforce our agreements.

To determine the appropriate retention period for personal data, we consider the
amount, nature and sensitivity of the personal data, the potential risk of harm
from unauthorized use or disclosure of the personal data, the purposes for which
we process the personal data, whether we can achieve those purposes through
other means, and any applicable legal requirements.


LINKS TO EXTERNAL SITES

Our Services may contain links to external sites that are not operated by us. If
you click on a third-party link, you will be directed to that third party’s
site. We strongly advise you to review the privacy policy and terms and
conditions of every site you visit.

We have no control over, and assume no responsibility for the content, privacy
policies or practices of any third-party sites, products, or services.


PROTECTION OF PERSONAL INFORMATION

Clumio discloses personally-identifying information only to those of its
employees, contractors, and vendors, and those of its affiliated organizations,
that (i) need to know that information in order to process it on Clumio’s behalf
or to provide the Services, and (ii) that have agreed not to disclose it to
others. Some of those employees, contractors, vendors, and affiliated
organizations may be located outside of your home country; by using Clumio’s
Services, you consent to the transfer of such information to them. Clumio will
not rent or sell personally-identifying information to anyone. Other than to its
employees, contractors, vendors, and affiliated organizations, as described
above, Clumio discloses personally-identifying information only in response to a
subpoena, court order, or other governmental request, or when Clumio believes in
good faith that disclosure is reasonably necessary to protect the property or
rights of Clumio, third parties, or the public at large.

If you are a registered user of the Services and have supplied your email
address, Clumio may occasionally send you an email to tell you about new
features, solicit your feedback, or just keep you up to date with what’s going
on with Clumio and our services. If you send us a request (for example via a
support email or via one of our feedback mechanisms), we reserve the right to
publish it in order to help us clarify or respond to your request or to help us
support other users. Clumio takes all measures reasonably necessary to protect
against the unauthorized access, use, alteration or destruction of
personally-identifying information.


AGGREGATED STATISTICS

Clumio may collect statistics about the behavior of users of its Services.
Clumio may display this information publicly or provide it to others. However,
Clumio does not disclose your personally-identifying information.


COOKIES

To enrich and perfect your online experience, Clumio uses “Cookies”, similar
technologies and services provided by others to display personalized content,
appropriate advertising and store your preferences on your computer.

A cookie is a string of information that a website stores on a visitor’s
computer, and that the visitor’s browser provides to the website each time the
visitor returns. Clumio uses cookies to help Clumio identify and track visitors,
their usage of clumio.com, and their Website access preferences. Clumio visitors
who do not wish to have cookies placed on their computers should set their
browsers to refuse cookies before using Clumio’s Websites, with the drawback
that certain features of Clumio’s Websites may not function properly without the
aid of cookies.

By continuing to navigate our Website without changing your cookie settings, you
hereby acknowledge and agree to Clumio’s use of cookies.


CHILDREN’S PRIVACY

Clumio does not knowingly collect personal information from children or
distinguish visitor’s to the Clumio website or platform. If you believe that we
may have collected personal information from someone under the applicable age of
consent please let us know by emailing privacy-requests@clumio.com, and we will
take appropriate measures to investigate and address the issue promptly.


GDPR COMPLIANCE AT CLUMIO

If you are using the Services from the EU or where applicable EU data protection
laws so provide, you may exercise the following rights regarding your personal
data:

 * The right to be informed – You have the right to be informed where personal
   data is collected from the data subject;
 * The right to access – You have the right to request copies of your personal
   data (we may charge you a small fee for this service);
 * The right to rectification – You have the right to request that we correct
   any personal data you believe is inaccurate. You also have the right to
   request that information you believe is incomplete be completed;
 * The right to erasure – You have the right to request erasure of your personal
   data, under certain conditions;
 * The right to restrict processing – You have the right to request the
   processing of your personal data be restricted, under certain conditions;
 * The right to object – You have the right to object to the processing of your
   personal data, under certain conditions;
 * The right to data portability – You have the right to request that collected
   data be transferred to another organization, or directly to you, under
   certain conditions;
 * The rights in relation to automated decision making and profiling – You have
   the right to not be subject to a decision based solely on automated
   processing, including profiling, which produces legal effects concerning him
   or her.

If you make a request under GDPR, we have one month to respond to you. If you
would like to exercise any of these rights, please contact us at through the
email or physical address listed below.


LEGAL PROCESSING BASIS

There are several alternative ways in which the lawfulness of a specific case of
processing of personal data may be established under GDPR. It is Clumio’s policy
to identify the appropriate basis for processing and to document it, in
accordance with the Regulation, as follows:

 * Consent
 * Performance of a Contract
 * Legal Obligation
 * Vital Interests of the Data Subject
 * Task Carried Out in the Public Interest


CCPA COMPLIANCE AT CLUMIO

Your Consumer rights under the CCPA

Under the CCPA, you may have the following consumer rights:

 * The right to know about the personal information a business collects about
   you and how it is used and shared – You may request that businesses disclose
   to you what personal information they have collected, used, shared, or sold
   about you, and why they collected, used, shared, or sold that information;
 * The right to delete personal information collected from you (with some
   exceptions) – You may request that businesses delete personal information
   they collected from you and to tell their service providers to do the same;
 * The right to opt-out of the sale of your personal information – You may
   request that businesses stop selling your personal information (“opt-out”).
   With some exceptions, businesses cannot sell your personal information after
   they receive your opt-out request unless you later provide authorization
   allowing them to do so again; and
 * The right to non-discrimination for exercising your CCPA rights – Businesses
   cannot deny goods or services, charge you a different price, or provide a
   different level or quality of goods or services just because you exercised
   your rights under the CCPA.

Additional Rights under California Law

Residents of the State of California, under California Civil Code § 1798.83,
have the right to request, from companies conducting business in California, a
list of all third parties to which the company has disclosed their personal
information during the preceding year for direct marketing purposes.
Alternatively, the law provides that if the company has a privacy policy that
gives either an opt-out or opt-in choice for use of their personal information
by third parties (such as advertisers) for marketing purposes, the company may
instead provide you with information on how to exercise their disclosure choice
options.

Clumio qualifies for the alternative option. We have a comprehensive privacy
statement, and provides you (including residents of the State of California)
with details on how you may either opt-out or opt-in to the use of your personal
information by third parties for direct marketing purposes. Therefore, we are
not required to maintain or disclose a list of the third parties that received
your personal information for marketing purposes during the preceding year.

CCPA 1798.140 Data Categories Processed by Clumio:

(A) Identifiers Real name, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address or other similar
identifiers. (B) Personal information listed in § 1798.80 of the California
Customer Records statute Signature, transactional business information e.g.
orders, invoices (D) Commercial Information Records of products or services
purchased (F) Internet or other electronic network activity information
Interaction with our Services, applications, or advertisements. (G) Geolocation
Data Location based on IP addresses collected from website (I) Professional or
employment-related information Job Title, Business email, Company NameSubmitting
a Request to Exercise Your Rights

If you are a California resident and request information about how to exercise
your third party disclosure choices, please contact us by:

 * Email at privacy-requests@clumio.com.
 * Phone (844) 425-8646
 * Mail at 4555 Great America Parkway, Suite 101
   Santa Clara, CA 95054


DO NOT TRACK

Clumio tracks its customers over time and across third party websites to better
understand and improve the usability, performance, and effectiveness of the
website and to help tailor content or offers.

In addition, some third-party sites keep track of your browsing activities when
they serve you content, which enables them to tailor what they present to you.
Third parties that have content embedded in Clumio’s Website such as a social
networking feature, may set cookies on a user’s browser and/or obtain
information about the fact that a web browser visited a specific Clumio Website
from a certain IP address. Third parties cannot collect any other personally
identifiable information from the Clumio Website unless you provide it to them
directly. Clumio also uses remarketing services, including Google AdWords,
discussed below, and other such services.

At this time Clumio does not respond to Do Not Track (DNT) signals.


GOOGLE ADWORDS AND OTHER SERVICES FOR REMARKETING

Clumio uses remarketing services to advertise on third party websites (including
Google) to previous visitors to our site. It could mean that we advertise to
previous visitors who haven’t completed a task on our site, for example using
the contact form to make an inquiry. This could be in the form of an
advertisement on the Google search results page, a site in the Google Display
Network, or another third-party site. Third-party vendors, including Google, use
cookies to serve ads based on someone’s past visits. Any data collected by
Clumio will be used in accordance with this Privacy Policy. Any data collected
by a third-party will be used in accordance with such third-party provider’s
policy, such as Google’s privacy policy.

You can set preferences for how Google advertises to you using the Google Ad
Preferences page. You can opt-out of interest-based advertising entirely by
cookie settings or permanently using a browser plugin.


CONTACT INFORMATION

If you have any questions about this Privacy Policy. please contact us via email
to privacy-requests@clumio.com.

Clumio Headquarters is located at:

4555 Great America Parkway, Suite 101
Santa Clara, CA 95054


PRIVACY POLICY CHANGES

This Privacy Policy was last revised effective June 3, 2021. Clumio may change
its Privacy Policy from time to time, and in Clumio’s sole discretion. Clumio
encourages visitors to frequently check this page for any changes to its Privacy
Policy. Your continued use of the Services after any change in this Privacy
Policy will constitute your acceptance of such change.

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© Copyright 2022 Clumio, Inc. All Rights Reserved. Read Privacy Policy and Terms
of Use.
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