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PRIVACY POLICY


Effective: September 29, 2023



Cloud Software Group, Inc. and its subsidiaries (“Cloud Software Group”),
respect your concerns about privacy. References in this Privacy Policy to “Cloud
Software Group”, “we”, “us”, and “our” 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 Policy describes 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
Policy 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
Policy applies to the personal information we obtain through Cloud Software
Group properties, including websites, products, services, desktop and mobile
apps, and other tools offered by Cloud Software Group that reference this
Privacy Policy (“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. Cloud Software Group does not share your
personal information with those 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
related to those transactions with that third party.

This Privacy Policy does not apply to the personal information:

 * an individual makes available to Cloud Software Group in connection with the
   recruiting process addressed by our Candidate Privacy Notice.
 * collected as part of a business conduct investigation which described in the
   Cloud Software Group Business Conduct Reporting Privacy Policy
 * 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.  Customer end-users should direct any questions about
   our customer’s privacy practices to our customer who collected their
   information. 

On this page

 * Personal Information We Obtain
 * How We Use Personal Information
 * Cookies and Other Technologies
 * Interest-Based Advertising
 * App Marketplaces
 * How We Share Your Personal Information
 * International Data Transfers
 * Your Rights and Choices
 * How We Protect Personal Information
 * Retention of Personal Information
 * Notice to California Residents
 * Children’s Personal Information
 * Changes to Our Privacy Policy
 * How to Contact Us


PERSONAL INFORMATION WE OBTAIN

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.

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);
 * register or apply to a Cloud Software Group Partner or Referral program;
 * request access or visit our offices or facilities;
 * information used to create 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, billing address, payment
   card details and bank account information and purchase history);
 * IP address and location data (such as data derived from your IP address,
   country and zip code);
 * the precise geolocation of your mobile device;
 * clickstream data and other information about your online activities (such as
   information about your devices, files viewed, and other browsing actions or
   usage patterns), including across the Online Channels and third-party
   websites, that we obtain through the use of cookies, web beacons 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);
 * personal information contained in content you submit to us (such as through
   our “Contact” feature or other in-product or in-service messaging); and
   
 * other personal information we obtain through our Offerings.
   

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 obtain to:

 * provide and administer our products and services (including websites and apps
   for which you have registered);
 * process and fulfill orders in connection with our products and services and
   keep you informed about the status of your order;
 * help you complete a transaction or order and provide customer support;
 * bill you for products and services you purchased;
 * provide training, support and consulting services;
 * create and manage your account with Cloud Software Group;
 * 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);
 * perform data analytics (such as research, trend analysis, financial analysis
   and customer segmentation);
 * 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);
 * 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);
 * communicate with you about, and administer your participation in, events,
   programs, promotions and surveys;
 * connect employees with their enterprise account administrator;
 * verify your identity and protect your account against unauthorized use or
   abuse of our services;
 * protect against, identify and prevent fraud and other unlawful activity,
   claims and other liabilities;
 * protect the health, safety and security of our employees;
 * comply with and enforce relevant industry standards, contractual obligations
   and our policies;
 * maintain and enhance the security of our Online Channels, products, services,
   network services, information resources and employees; and
   respond to your inquiries.

Depending on the purposes for which personal information is used, 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 a relevant party;
 * our legitimate business interests;
 * compliance with a legal obligation, a court order, or to exercise or defend
   legal claims; or
 * your consent to the processing, 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 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 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 equipment,
browsing actions, and usage patterns. The information we obtain in this manner
includes IP address 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,
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 (1) essential and functional
cookies; (2) analytics cookies; and (3) targeting/advertising cookies, as
described below.


ESSENTIAL AND FUNCTIONAL COOKIES

We use cookies on our Online Channels that are necessary for us to provide you
with our products and services. This includes essential cookies (such as those
used to authenticate you to our website and identify you after you have logged
in), functional cookies (such as those that remember what you added to your
shopping cart or the language preference you selected), 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 may not be disabled on our Online
Services.


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 and Marketo. 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 advertisements. These Cookies
may collect information on whether a user has reacted to an advertisement and
visited another website. Such cookies help us to 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 Policy 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.
 


HOW WE SHARE YOUR PERSONAL INFORMATION

We do not sell 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 ways:

 * 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 Policy;
 * to connect employees with their company administrator(s);
 * 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 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; and
 * 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 Policy.

We also may disclose personal information about you

(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 U.S., 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 Policy. 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 selecting data recipients that are certified to the EU-U.S. Data Privacy
Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S.
Data Privacy Framework (Swiss-U.S. DPF) described below.

EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S.
DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF)

With respect to transfers of personal information from the EU, United Kingdom
and Switzerland to the U.S., Cloud Software Group complies with the EU-U.S. Data
Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S.
Department of Commerce . Cloud Software Group have certified to the U.S.
Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework
Principles (EU-U.S. DPF Principles) with regard to the processing of personal
data received from the European Union in reliance on the EU-U.S. DPF and from
the United Kingdom (and Gibraltar) under the UK Extension to the EU-U.S. DPF. 
Cloud Software Group has certified to the U.S. Department of Commerce that it
adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF
Principles) with regard to the processing of personal data received from
Switzerland under  the Swiss-U.S. DPF.  If there is any conflict between the
terms in this privacy policy and the EU-U.S. DPF Principles and/or the
Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the
Data Privacy Framework (DPF) program, and to view our certification, please
visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over Citrix Systems, Inc and Cloud
Software Group’s compliance with the EU-U.S. DPF, the UK Extension to the
EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Cloud Software Group
may be required to disclose personal data in response to lawful requests by
public authorities, including to meet national security or law enforcement
requirements.

In compliance with the EU-U.S. DPF,  the UK Extension to the EU-U.S. DPF, and
the Swiss-U.S. DPF, Cloud Software Group commits to cooperate and comply with
the advice of the panel established by the EU data protection authorities
(DPAs), the UK Information Commissioner’s Office (ICO) and the Gibraltar
Regulatory Authority (GRA), and the Swiss Federal Data Protection and
Information Commissioner (FDPIC) with regard to unresolved complaints concerning
our handling of human resources data received in reliance on the EU-U.S. DPF,
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF in the context of
the employment relationship.

For complaints regarding DPF compliance not resolved by any of the other DPF
mechanisms, you have the possibility, under certain conditions, to invoke
binding arbitration. Further information can be found on the official DPF
website. If you have questions or complaints regarding our Privacy Policy or
practices, please contact privacy@cloud.com.

EU and Swiss individuals with inquiries or complaints regarding the Cloud
Software Group Data Privacy Framework policy should first
contact privacy@cloud.com. If you have an unresolved complaint related to Cloud
Software Group that has not been addressed to your satisfaction, please contact
or visit https://feedback-form.truste.com/watchdog/request (a U.S.-based
alternative dispute resolution provider) for more information or to file a
complaint.

The services are provided at no cost to you.


YOUR RIGHTS AND CHOICES

We offer you certain choices in connection with the personal information we
obtain about you, such as how we use the information and how we communicate with
you. To update your preferences, limit the communications you receive from us or
submit a request, please contact us as specified in the How to Contact Us
section of this Privacy Policy. You can also unsubscribe from our mailing lists
by following the “Unsubscribe” link in our emails.

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
should contact the relevant administrator for the Offering associated with the
information, 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.

To the extent provided by the law of your jurisdiction, you may request access
to the personal information we maintain about you or request that we correct,
update, amend or delete your information, or that we restrict the processing of
such information by contacting us as indicated below or 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.

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 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.


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 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, consistent with
legal requirements where the personal information was obtained, designed to
protect against unlawful or unauthorized destruction, loss, alteration, use or
disclosure of, or access to, the personal information provided to us through the
Channels.


RETENTION OF 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 Policy,
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;
or (2) to take into account applicable statute of limitation periods and comply
with applicable laws, resolve disputes and enforce our agreements. As described
in the “Your 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.


NOTICE TO CALIFORNIA RESIDENTS

A California Consumer Privacy Statement supplements this Cloud Software Group
Privacy Policy. The Statement applies solely to California consumers and is
available for review here. The following is a summary of selected portions of
the Statement, although you should refer to the Statement itself for any
questions you may have about applicable rights and obligations.

You may have the right to request, twice in a 12-month period, the following
information about the personal information we have collected about you during
the past 12 months:

 * the categories and specific pieces of personal information we have collected
   about you;
 * the categories of sources from which we collected the personal information;
 * the business or commercial purpose for which we collected or sold the
   personal information;
 * the categories of third parties with whom we shared the personal information;
   and
 * the categories of personal information about you that we sold or disclosed
   for a business purpose, and the categories of third parties to whom we sold
   or disclosed that information for a business purpose.

You also may have the right to request that we provide you with (1) a list of
certain categories of personal information we have disclosed to third parties
for their direct marketing purposes during the immediately preceding calendar
year and (2) the identity of those third parties. In addition, you have the
right to request that we delete the personal information we have collected from
you.

You have the right to opt out of the sale of your information. To opt out, click
Cookie Preferences link in the bottom of the page for the Cloud Software Group
business you are interested in managing preferences for or email
privacy@cloud.com.

To submit a request related to other rights, you or an authorized agent may
contact us as specified in the How To Contact Us section of the Cloud Software
Group Privacy Policy below. To help protect your privacy and maintain security,
we take steps to verify your or your agent’s identity before granting access to
your personal information or complying with a request. In order to verify a
request, we may require authentication information from you that is reasonable
in light of the nature of the personal information requested. This may include
personal information previously collected in order to associate you with the
information provided. Under the CCPA, you may designate an authorized agent to
make a request on your behalf. The agent will need to complete a verification
process, including the submission of proof that it has been designated to act on
your behalf, and we also may require you to verify your own identity directly
with us.

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.


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 Policy.


CHANGES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically and without prior notice to you
to reflect changes in our information practices. We will indicate at the top of
this Privacy Policy when it was most recently updated. However, if we make any
material changes we will notify you by means of a notice on this website prior
to the change becoming effective. We encourage you to periodically review this
Privacy Policy for the latest information on our privacy practices.


HOW TO CONTACT US

If you have questions, requests or concerns relating to our customer’s handling
of your information, please contact the relevant customer. If you have any
questions or comments about this Privacy Policy or if you would like us to
update information we have about you or your preferences, please contact us by
email at privacy@cloud.com or write to us at:

Cloud Software Group
Attn: Chief Privacy Officer
4980 Great America Parkway,
Santa Clara, CA 95054
United States

Cloud Software Group EU representative is:
Cloud Software Operations (Ireland) Ltd.
Attn: Chief Privacy Officer
Eastpoint Business Park
Alfie Byrne Rd, East Wall
Dublin, Ireland



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