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Privacy Policy

Privacy Policy
Last updated 2019-02-04

The following Privacy Policy describes the information that ClusterCS gathers, uses, and shares in connection with your use of ClusterCS website (www.clustercs.com), services, and software (collectively, the "Services").

The use of the following terms "ClusterCS", "we", "us", or "our", reffers to Soft Dreams SRL., the company that owns and operates ClusterCS and its Affiliates, which headquarter is in Bucharest, Romania.

For the purposes of this Policy:

  • "Websites" refers to www.clustercs.com as well as any other websites ClusterCS owns and that link to this Policy. For clarity, "Websites" does not include any sites owned or operated by our Customers.

  • "Customers" are those who register on their own or on behalf of an entity or organization to use our Services.

  • "End Users" means individuals who visit our Customers' websites.

 

OUR PRIVACY PRINCIPLES

We keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose your personal information to anyone except as necessary to provide our services or as otherwise described in this Policy without first providing you with notice and the opportunity to consent.

 

INFORMATION WE COLLECT

Name, Email Address, and Other Contact Information. We collect personal information you provide us when you sign up for our Services, submit forms on our websites, and send us support or sales inquiry emails.

Cookies and Other Tracking Technologies. We may use cookies and other information gathering technologies for a variety of purposes, such as providing us with information about how you interact with our Services and assisting us in marketing and advertising. You may opt-out of such personalized advertising if located in the United States or in the European Union. For analytics, we use services such as Google Analytics and Clicky that set their own cookies. You can read about how Google Analytics uses your data here and Clicky here . We also use Elev.io and Intercom for offering customer support. You can read how Elev.io uses your data here and Intercom here.

Our payment processors such as Mobilpay or PayPal set their own cookies, as well. Their privacy Policy and information about their use of data is available on their websites.

User Content. Our websites may offer publicly accessible forums or discussion sections. If you choose to participate in any of these areas, any information you post in the area might be read, collected, and used by others who access it. If you wish to remove your personal information from any these areas, please see Your Data Rights below.

Log Database. When you visit our Websites, we gather certain information and store it in our log database. This information may include but is not limited to IP addresses, browser version information, and URLs of referring pages.

Server Usage and Contents. For servers you use with our Service or install our software on, we may collect and monitor information about the server, including hardware information, server username and password, configuration information, network traffic, and file contents. We use this data for the purposes described in this Policy such as to operate, improve, and personalize the Services, provide customer support, protect the security and safety of our Customers, and develop aggregate analysis.

Customer Account Information. When you register for a ClusterCS account, we collect your email address. Once registered, you may provide additional information to help us identify you.

Payment Information. When you sign up for one of our paid Services, you must provide billing information. For example, if you pay with a credit card, we will collect your card information which we store with a third-party payment processor such as Paypal.

 

LEGAL BASIS FOR PROCESSING

Our legal basis for collecting and using your personal information depends on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) we need your personal information to perform a contract with you (e.g. to deliver the Services you have requested), or (c) the processing is in our legitimate interests. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, improving our platform, protecting the safety and security of our Services and our Customers, undertaking marketing, or for the purposes of detecting or preventing illegal activities. Please note that in most cases, if you do not provide the requested information, ClusterCS will not be able to provide the requested service to you.

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

 

SECURITY OF PERSONAL DATA

ClusterCS is committed to protecting the security of customer collected Personal Data. To do so we employ a variety of industry-standard security technologies and measures to help protect your data from unauthorized access, use, or disclosure which include but are not limited to encrypting any transmission of said information using secure socket layer (SSL), passing of credit card information directly to our Merchant Processor, encryption of any collected credit card information, encryption of passwords and other authentication mechanisms such as API keys, and restricting access to encrypted information to support personnel at ClusterCS. We require that customers enter in a password to access their account information and request that customers use a password composed of different characters and of a large length to strengthen security and that they do not disclose this information to others via electronic formats or otherwise. Please note that ClusterCS cannot fully eliminate security risks associated with the collection of said data and mistakes and security breaches may happen, please contact us if you have any questions regarding the security of our website, application, or otherwise.
 

HOW WE USE THE INFORMATION WE COLLECT

ClusterCS only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized. We may use the information we collect (including personal information, to the extent applicable) to:

  • provide, operate, maintain, improve, personalize, and promote the Website and Services;

  • enable access and use the Website and Services;

  • process and complete invoice payments;

  • send transactional messages, including to provide customer support, and send you technical notices and security alerts;

  • send commercial communications, in accordance with your communication preferences, such as providing you with information about products and services;

  • monitor and analyze usage for marketing or advertising purposes;

  • comply with legal obligations as well as for the purpose of investigation and prevention of fraudulent transactions, unauthorized access to the Services, and other illegal activities;

  • other purposes for which we obtain the Customer’s consent.

Information from Third Party Services. We may combine information we collect as described above with personal information we obtain from third parties. For example, for sales inquiries, we may combine information provided by you with information from third parties in order to better market our services to you.

 

INFORMATION SHARING

We work with other companies who help us run our business ("Service Providers"). These companies provide services to help us deliver customer support, process credit card payments, provide marketing support, and otherwise operate and improve our Services.

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:

  • with ClusterCS Affiliates (other services owned and operated by SC Soft Dreams SRL.);

  • when we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or to defend against legal claims from third parties.

  • where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations;

  • as you may otherwise consent to from time to time.

We do not sell, rent, or share personal information with third parties for their direct marketing purposes.

 

DATA AGGREGATION

ClusterCS may aggregate data we acquire about our Customers and their End Users, including the Log Database and Server Usage and Contents described above. For example, we may assemble data to determine whether attacks are being performed against servers and applications of our Customers or their End Users, to identify common applications and application versions, to identify server and application performance profiles, or to compile information and statistics for informational or marketing purposes.

 

INTERNATIONAL INFORMATION TRANSFERS

We store your information in Romania, country member of the European Union. If you are accessing or using our Websites or Services or otherwise providing information to us, you are agreeing to the transfer of your personal information to Romania. ClusterCS is subject to the investigatory and enforcement powers governed by the laws in action in the European Union.

 

YOUR DATA RIGHTS

Regardless of country, you can always contact us if you wish to exercise your data protection rights in accordance with applicable data protection laws.

If you are a resident of the EEA, you have the following data protection rights under the General Data Protection Regulation (GDPR):

  • Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time.

  • Where we rely on our legitimate interests to process your personal data, you have the right to object.

  • You have the right to access, correct, update, export, or delete your personal information.

  • You can access, correct, update, or export your account information by editing your profile at https://www.clustercs.com/

  • To delete your account information or make any other personal information requests, you can email us at office@clustercs.com. ClusterCS customers can opt out of providing and asking that any Personal Data that was collected be removed if they believe it is being used in a manner not consistent with the what was presented in the privacy policy. In the event and at the sole discretion of ClusterCS if it is determined that service no longer be provided a pro-rated refund of service will be refunded to the customer and the data will be removed as requested.

 

YOUR CHOICES

You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.

You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.

Many browsers have an option for disabling cookies, which may prevent your browser from accepting new cookies or enable selective use of cookies. Please note that, if you choose not to accept cookies, some features and the personalization of our Services may no longer work for you. You will continue to receive advertising material but it will not be tailored to your interests.

 

COMMUNICATION PREFERENCES

You may manage your receipt of commercial communications by clicking on the "unsubscribe" link located on the bottom of such emails. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes such as to notify you of material changes to this Privacy Policy or respond to support requests.

 

DATA SECURITY, DATA INTEGRITY, AND ACCESS

We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate technical and administrative measures to safeguard and secure your information, and we make use of technologies such as encryption to increase privacy and security.

 

NOTIFICATION OF CHANGES

This Privacy Policy is subject to occasional revision, and if any substantial changes are made to the way your Personal Data is used, we will notify you by email to the email address that you have provided as being the most current posting the notice of such changes on our website. Any changes to the Privacy Policy will be effective upon the earlier of either thirty (30) calendar days from the dispatch of the email notice to you or thirty (30) calendar days following our posting of the update terms on our website, or the date on which you accept the terms by clicking "I Accept" or similar means. These changes will be effective immediately for any new users and customers of our website and related products and services. Please note that you are responsible at all times for updating your Personal Data and with providing us with your most recent and current email address. In the event that the email address is no longer valid the date at which the proposed changes were dispatched will still constitute effective notice of any changes to the Privacy Policy. If you do not wish to permit changes in our use of your Personal Data you must notify us prior to the effective date of the changes and that you wish to deactivate your account. Continued use of our website, products, and or related services, following notice of any such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

 

BUSINESS TRANSACTIONS

We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale, change in control, or reorganization of all our part of our business.

 

CONTACT INFORMATION

If you have any questions about this Privacy Policy, you can contact us by email at office@clustercs.com