Effective Date: 11/01/2017
EU-U.S. PRIVACY SHIELD AND SWISS-U.S. PRIVACY SHIELD
lcloud, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List. [https://www.privacyshield.gov]
lcloud, Inc. is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. lcloud, Inc. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, lcloud, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.live/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
WHAT INFORMATION DOES lcloud COLLECT AND HOW IS IT USED?
The information we collect is primarily used to provide the Services, to process and complete any transactions, to respond to inquiries, to personalize and improve the Services, to monitor and analyze usage and trends of the Services, and to allow our business partners to understand how you interact with our Services, as described in this Policy. In connection with certain aspects of the Services, we may request, collect and/or display some information about you. We collect the following types of information from our users.
Registered User Information:
When you create an Account, we will collect personal information from you, such as your name and email address. If you create an Account using your login from another account, such as Facebook or Twitter, we will access and collect the personal information about you that the account provides (which is based on your privacy settings), so that you can create your Account with us. We use your contact information to send you information about our Services. You may unsubscribe from receiving certain types of these messages through your Account settings, although lcloud reserves the right to contact you when we believe it is necessary, such as for administrative and account management purposes.
Note regarding children: We do not knowingly collect personal information from children. If we learn that we have collected personal information of a child under 13, we will take steps to delete such information from our files as soon as possible.
One feature of the Services is the ability to create shortened uniform resource locators (URLs) of websites ("lcloud Links"). When you create a lcloud Link, lcloud collects and stores both the original URL and the shortened URL and, if you are logged in to your Account, we will associate that information with your Account. lcloud also collects and stores your IP address, the time and date on which you shortened the original URL, and when you share the lcloud Link and information on the channels through which the lcloud Link was shared.
Metrics and Analytics:
lcloud collects information about accesses (such as clicks) of every lcloud Link created through the Services. This information includes, but is not limited to: (i) the IP address and physical location of the devices accessing the lcloud Link; (ii) the referring websites or services; (iii) the time and date of each access; and (iv) information about sharing of the lcloud Link on Third Party Services such as Twitter and Facebook. This information is used by lcloud and its partners to improve their websites and services by, for example, providing value-added features, and to analyze clicks on lcloud Links, for example to understand how, when and where lcloud Links are clicked.
Information Collected From Third Party Services:
Some features of the Services allow you to share your content and lcloud Links through your accounts with other companies such as Facebook and Twitter. If you choose to connect lcloud to such Third Party Services, we may collect information related to your use of those Third Party Services, such as authentication tokens that allow us to connect to your Third Party Service accounts. We will ask you for permission before you authorize our collection of this information. We will only use that information for the specific reason for which it was provided to us. We may also collect information about how you are using the Services to interact with those connected Third Party Services. Note that Third Party Services may have the ability to restrict the information that is provided to us based on your privacy settings of that account.
Information Collected Automatically:
- lcloud automatically receives and records information from your web browser when you interact with the Services (including creating or clicking on lcloud Links), such as your IP address, browser type, your general location and cookie information. This information may be used to help us understand how users transit a website, to fight spam/malware, to facilitate collection of data concerning your interaction with the Services (e.g., what lcloud Links you have clicked on) and for other similar purposes.
- lcloud also automatically receives and records information that your mobile device transmits when you access the Services, like a device identifier, device settings, and operating system. This information is used to facilitate your access and use of the Services, to access and use other Third Party Services, and for other similar purposes.
- Generally, the Services automatically collect Site usage information, such as the number and frequency of visitors to the Site. lcloud may use this data in aggregate form, that is, as a statistical measure. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Site so that we can analyze and improve them.
- We will collect information about your general location (such as your city and state, which is derived from your IP address) when you visit the Site or use the Services, such as by clicking a lcloud Link and we may use various technologies to determine your location (if you enable this feature), when you access and use the Services through a mobile device.
- We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.
- lcloud cookies also allow lcloud to track when you have clicked on a lcloud Link. Each click of a lcloud Link is tracked using a unique identifier assigned to you in one or more cookies stored by your web browser and associated with lcloud. We may associate the unique identifier in our cookies with the other information we automatically collect when you use the Services, as described above, including your IP address, lcloud Links you click, lcloud Links you create, and information with your Account if you have one.
- Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. If you disable cookies, you will not be able to use some features of the Services. lcloud cookies are set to automatically expire after 6 months from when they are set.
- You may also ask lcloud not to place cookies on your web browser. When cookies are disabled in this manner, clicks on lcloud Links are not tied back to or associated with your web browser. However, we will still automatically collect the IP addresses of computers or mobile devices that click on or create lcloud Links.Cookies on lcloud Links:
Cookies on lcloud.live:
- You can also manage other companies’ cookies used for online advertising here: Consumer Choice Page
WHAT INFORMATION IS SHARED?
The Services are designed to help you share information with others. As a result, much of the information generated through the Services is shared publicly or with third parties.
We may share the information we collect as described in this policy with third-party business partners, for instance, for the purpose of enhancing our products and services, so that they can market their products or services to you, or so that they may analyze trends about the creation of, and clicks on, lcloud Links. If you do not want us to share your personal information with these companies, contact us at firstname.lastname@example.org.
lcloud Links and Usage Information:
Much of your activity on and through the Services is public by default. This includes, but is not limited to:
- The original URLs you have shortened, their corresponding lcloud Links, the time and date those URLs were shortened, and metrics and analytics information for your lcloud Links, as described above;
- Information about what lcloud Links you have clicked on and associated metrics and analytics information, as described above; and
- Any Bundles you have created, along with content added to those Bundles, if you have elected to make those Bundles public.
For registered users, some of this information is publicly accessible through a unique URL, which you can make non-public through your Account settings when you are logged in. Removing access to the unique URL does not, however, make this information non-public, and it may still be accessible through other means, such as lcloud's API services.
Please also remember that if you choose to provide information about yourself using certain features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available to others.
IP Address Information:
While we collect and store IP address information, that information is not shared publicly. As described above, we may share IP address information we collect when you create or click a lcloud Link with our business partners, service providers and other organizations with whom we conduct business for the purposes described in this policy.
Information You Elect to Share:
When creating a lcloud Link, you can share that lcloud Link through Third Party Services. Any information that you elect to distribute through Third Party Services is provided to them and may then become accessible to users of those services. You can also access other Third Party Services through the Services, for example by clicking on links in the Statistics page for a lcloud Link. We recommend that you review the terms of services and privacy policies of such Third Party Services that you access through the Services, since lcloud does not control and is not responsible for the privacy practices of these Third Party Services.
To opt out from having information about your clicks on lcloud Links shared with our business partners, please opt-out using the link provided on this page.
User Profile Information:
User profile information including your username, Twitter handle and Facebook account name (to the extent you have linked your Account with those services), and other information you enter may be displayed to other users to facilitate user interaction within the Services. Users' email addresses will not be directly revealed to other users by lcloud.
Information Shared with Service Providers of lcloud:
We may employ and contract with third parties to perform certain tasks on our behalf and under our direction (our "Service Providers"). We may need to share information about you with our Service Providers in order to provide our product with research and analytics on user behavior and to provide advertising products and services to users, and email marketing and support services. Unless we tell you differently, our Service Providers do not have any right to use the information we share with them beyond what is necessary to assist us. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Information Disclosed Pursuant to Business Transfers:
We may transfer and/or provide information about our users in connection with an acquisition, sale of company assets, or other situation where user information would be transferred as one of our business assets. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
In such a case, the acquirer of lcloud may continue to use your information as set forth in this policy.
Information Disclosed for the Protection of lcloud and Others:
lcloud may access, read, preserve, and disclose any information it collects when it has a good faith belief that doing so is reasonably necessary to (i) comply with a law, regulation, or compulsory legal request, including process from a governmental law enforcement or national security agency (ii) enforce these Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect the rights, property or safety of lcloud, its users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
Information We Share With Your Consent:
We will share information about you when you instruct us to do so, such as when you share lcloud Links or content with others through the Services or if we notify you that the information you provide will be shared in a particular manner and you provide such information (like sharing/posting it with a Third Party Service).
HOW IS MY INFORMATION PROTECTED?
Your Account information is protected by a password for your privacy and security. You can prevent unauthorized access to your account by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account.
lcloud endeavors to protect the information it collects about its users using industry-standard security processes and controls, however, despite these efforts, no security measure is perfect or impenetrable and lcloud does not guarantee or warrant that such measures will prevent unauthorized access to the information about you that is stored by lcloud. In the event we experience a breach of security, we will promptly notify you if your personal information has been compromised, in accordance with applicable law. If you have any questions about the security of your personal information, you can contact us at email@example.com.
WHAT CHOICES DO I HAVE AND WHAT INFORMATION OF MINE CAN I ACCESS?
You don't need an account to create lcloud Links and you can use many of the features of the Services without registering, thereby limiting the type of information that is collected about you individually.
Upon request, lcloud will provide you with information about whether we hold any of your personal information. In order to identify you, we may need to request additional information from you in order to respond to your request. You may access, correct, or request deletion of your personal information by logging into your account or contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
lcloud acknowledges that you have the right to access your personal information. lcloud has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the lcloud's Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
If you are a registered user, you can access information associated with your Account by logging into the Site. This information includes a history of the URLs you have shortened, and access to the metrics pages for those URLs. You can deactivate your Account at any time through your Account settings page. If you deactivate your Account, you will no longer be able to access or use the Services.
Please note that in the interest of ensuring that existing lcloud Links continue to function for all of our users, the lcloud Links that you have created and shared cannot be deleted or disabled (even if your Account is deactivated), and any shortening and sharing activity that has already occurred on your Account also cannot be deleted (but your user history can be set to private from within your Account settings). If you have concerns about any unauthorized usage of your Account, please contact us at email@example.com and we will disable future shortening activity on your Account.
If you are not a registered user, you can access the metrics pages for your lcloud Links by adding the "+" symbol to the end of the URL.
WHAT IF I HAVE QUESTIONS OR CONCERNS?
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to: firstname.lastname@example.org. We will make every effort to resolve your concerns.