Last updated 2019-02-04
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.
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.
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.
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/
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.
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
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.