Effective Date: February 11, 2021
Types of Information We Collect
We collect the following information about you:
- “Personal Information”. This is information that directly or indirectly identifies you, such as your name, email address, or other identifying information about you, or that would, when combined with other information you provide or that is broadly available, be likely to identify you.
- “Other Information”. Other Information is information that is not Personal Information, that is, by itself, it does not individually identify you, such as browser type, operating system, technical data, and usage. We may link together different types of Other Information or link Other Information to Personal Information.
Individuals may interact with Cloud for Utilities in ways that require Cloud for Utilities to gather Personal Information. The amount and type of information that Cloud for Utilities gathers depends on the nature of the interaction. Generally, we collect the following data elements from you when we process your Personal Information for the purposes we described in this policy. We process:
- Your first and last name
- Email address
- Physical Address
- Country of residence or business
- Internet or other electronic network activity.
For operational purposes or to verify identity, or if we offer new services, and depending on the reason for your contacting us, we may also collect additional information such as:
- Partial credit card information as part of a tokenized payment transaction
- Testimonials and other information you voluntarily provide.
If you do not wish for Cloud for Utilities to collect any information about you, you can simply not utilize any of the Resources or otherwise supply Personal Information. Your choice not to provide information may, however, prevent you from using certain Resources or engaging in certain activities on an Electronic Platform.
Like most website and application operators, Cloud for Utilities collects Other Information of the sort that web browsers, applications and servers typically make available to operators, like the browser type, language preference, referring site, and the date and time of each visitor request. Cloud for Utilities may use this information for a number of purposes including, for example, to better understand how Cloud for Utilities’ visitors use its website. The purposes for collecting and using this data may change from time to time at Cloud for Utilities’ discretion, and Cloud for Utilities may release non-Personal Information in the aggregate. By utilizing any of the Resources, you agree to such use.
How We Collect Information
We collect Personal Information and Other Information in the following ways:
- Information You Give Us. For example, an Electronic Platform may require you provide an email address, phone number, or company information, or if you utilize any other Resources, we may ask for Personal Information.
- Information We Get from Your Use of Services. We may collect information about the Resources that you use and how you use them. This information includes:
- Computer, tablet, or mobile telephone information. We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, device sensors and mobile network information including phone number) and device sensors and related information. Cloud for Utilities may associate your device identifiers or phone number with your account. We will comply with the usage/license restrictions and requirements applicable to the device from which the information comes.
- Log information. When you use an Electronic Platform or view content provided by us, we may automatically collect and store certain information in server logs. This may include, for example:
- details of how you used our Resources.
- Internet protocol address
- device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL
- cookies that may uniquely identify your browser or your account.
- Location information. When you use a location-enabled Electronic Platform, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We also may use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.
- Local storage. We may collect and store information (including Personal Information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
- Cookies and anonymous identifiers. We use various technologies to collect and store information when you visit an Electronic Platform as described below, and this may include sending one or more cookies or anonymous identifiers to your device.
How We Use Information We Collect
We take your privacy seriously. We use the information that we collect about you to provide, maintain, protect and improve the services and products that Cloud for Utilities provides to you. We do not sell your information to any third parties and only use it for legitimate business purposes.
We use your Personal Information for the following purposes, or may use it for these purposes in the future:
- To respond to questions that you may have.
- To provide you with information and register you for our conferences
- To provide membership benefits to you
- To inform you of updates regarding Cloud for Utilities conferences or services that may be of interest to you
- To place you in contact with our business partners and other trusted members
- To provide administrative notices or communications applicable to your use of the Resources
- To manage your participation in events and other promotions where you have signed up for such events and promotions
- To operate, evaluate and improve our business and the products and services we offer
- To analyze and enhance our marketing communications and strategies
- To analyze trends and statistics regarding visitors’ use of our Electronic Platforms including social media assets
- To protect against and prevent fraud, unauthorized transactions, claims and other liabilities
- To improve our customer service
- To respond to and support customers regarding their use of the Resources
- To comply with all applicable legal requirements
Cookies and Other Tracking Technologies
In addition, some of our Electronic Resources may utilize “cookies” and other tracking technologies like pixel tags and web beacons (often called “smart cookies”) to improve the functionality of the Website. Cookies are text files that are sent by servers to web browsers and stored on your computer. They tell us which parts of the Electronic Resources you’ve visited so Cloud for Utilities can alert you to software compatibility issues and save your preferences for future visits to the Electronic Resources. Web beacons and pixel tags are images embedded in a webpage or e-mail for the purpose of measuring and analyzing usage and activity. The Electronic Resources, or third-party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality. Some cookies and other technologies may serve to recall Personal Information previously provided by a user.
How We Share Information We Collect
As part of the use of your information for the above purposes, we may disclose your Personal Information or Other Information to our vendors and other contractors who perform various functions on our behalf. We share your Personal Information with third parties on the basis of the consent you provide to us or in order to fulfill our contractual obligations as part of the services we provide to you when you decide to engage with us. We require these third parties to safeguard your Personal Information against improper disclosure and in accordance with the law. These third parties may include:
- Payment processors engaged by us to securely store or handle payments information, such as credit card details.
- Providers of email management and distribution tools – for example, if you sign up to receive newsletters or other marketing messages, we will manage the delivery of these to you using a third-party email distribution tool.
- Providers of security and fraud prevention services.
- Providers of data aggregation and analytics software services that enable us to effectively monitor and optimize the delivery of our services.
- Data hosting companies that provide the infrastructure to host our applications, facilitate network connectivity from outside agencies and maintain our data.
We also may share Personal Information with our members so that they may contact you about potential business opportunities.
We also may provide information about you to other third parties with your consent or for one of the purposes above, e.g., following a subpoena or other legal process or to a regulatory agency in order to protect against fraud or investigate a criminal or civil matter or when Cloud for Utilities believes in good faith that disclosure is reasonably necessary to protect Cloud for Utilities’ rights and interests, third parties, or the public at large.
How We Protect Your Information
Cloud for Utilities discloses Personal Information to those of its employees, contractors, agents and affiliated organizations that need to know that information in order to process it on Cloud for Utilities’ behalf or to provide services. Some of those employees, contractors, agents and affiliated organizations may be located outside of your state, province or country. By using the Resources or providing us information, you consent to the transfer of such information to them.
If you are a registered user of one or more Resources or have supplied your email address, you agree that in addition to any Resources you may have solicited or requested, Cloud for Utilities may further send you emails to provide you with information, to inform you of new products, to solicit your feedback, or to keep you up to date on Cloud for Utilities and its products. 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. You may choose not to receive marketing email communications from us by clicking on the “unsubscribe” link in our marketing emails. You also may ask us not to send you other marketing communications by contacting us as specified in the “Contact Us” section below, and we will honor your request.
We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, we may not immediately delete residual copies of Personal Information that is on our active servers and may not remove information from our backup systems. If you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated below.
Cloud for Utilities undertakes commercially reasonable efforts to guard against unauthorized access, use, alteration or destruction of Personal Information, which efforts you agree are sufficient, adequate and complete. In some cases, we cannot control, and are not responsible for, information that is shared about you. For example:
- Information You Share. Some of our Electronic Platforms or other Resources may let you share information with others. Remember that when you share information publicly, it may be indexable by search engines or otherwise further disclosed.
- Accessing and Updating Personal Information. If you provide us with information or create an account in order to access or receive Resources, we may or may not be able to provide you with access to your Personal Information. If information that we control about you is incorrect, we strive to give you ways to update it quickly or to delete it (unless we have to keep that information for legitimate business or legal purposes). When updating your Personal Information, we may ask you to verify your identity before we can act on your request.
Third Party Links
The Electronic Platforms may contain links to webpages or tools operated by parties other than Cloud for Utilities. We do not control such websites or tools and are not responsible for their contents or the privacy policies or other practices of such websites or service providers. Our inclusion of links to an outside website or tool does not imply any endorsement of the material on such websites or tools or any association with their operators. Further, it is up to you to take precautions to ensure that whatever links you select or software you download (whether from an Electronic Platform or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which you will be subject to upon accessing the third party’s website. We strongly recommend you review the third party’s terms and policies.
The Electronic Platforms are not intended for use by individuals under the age of 18. We do not intentionally gather Personal Information about individuals who are under the age of 18. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 18, please contact us at firstname.lastname@example.org. If we learn that we have inadvertently collected the Personal Information of a child under 18, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell websites and online services that you do not want to have your online activities tracked. Such browser features and industry standards are not uniform, so our websites and online services do not respond to those signals.
Notice to California Residents
This section is applicable to residents of California. The following do not apply to individuals who do not live in California on a permanent basis.
Rights Provided by California Civil Code Section 1798.83
A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. California Customers may request further information about our compliance with this law by mailing us at Post Office Box 15317 Washington, DC 20003 or emailing Cloud for Utilities at email@example.com. Please note that we are only required to respond to one request per California Customer each year under Code Section 1798.83.
Rights Under The California Consumer Privacy Act
We are not a “business” as defined by the California Consumer Privacy Act, and therefore we are not subject to its requirements. Nonetheless, we respect the privacy and wishes of individuals regarding their privacy. As such, you may make a request regarding our use, handling and protection of your personally identifiable information by emailing us at the email address below.
Visitors from Canada, Switzerland and the European Economic Area
Information Regarding Commercial Electronic Messages (“CEM”) in Canada
Canada’s Anti-Spam Law requires that the Cloud for Utilities obtain the express consent of Canadian citizens before sending an electronic message such as an email that contains a promotion about our products. If you are a Canadian citizen, we will ask you for your explicit consent when you provide us with your email address or other personal information through which we intend to encourage your participation in a commercial activity, such as a promotion for our products.
If you explicitly consent to receiving CEM, each communication sent to you will contain an option to unsubscribe to the communications or to revoke your consent to receive CEM. Alternatively, you can contact us at the address or email provided below in the “Contact Us” section to be removed from our mailing lists.
General Data Protection Regulations (“GDPR”)
Identification of Data Controller:
The Data Controller is Cloud for Utilities Inc. To contact Cloud for Utilities please see the section titled “Contact Us” below.
Identification of Primary Member State Supervisory/Data Protection Authority
You have the right to lodge a complaint regarding the processing of your Personal Data with us by contacting our Data Protection Officer listed above. You also may lodge a complaint with the Data Protection Authorities in the Member State where you habitually reside, work, or where an infringement occurred. You can find a list of Data Protection Authorities here.
Legal Basis for Processing:
GDPR allows processing of personal data based on one of six legal bases. The legal bases for processing personal data are:
- Consent – your freely given, specific, informed and unambiguous indication of your wishes by which you agree to the processing of personal data.
- Contract – Cloud for Utilities needs to process your personal data for performance of a contract or processes the information at your request prior to entering into a contract.
- Legal Obligation – processing is necessary to comply with a legal obligation.
- Vital Interests – your (or someone else’s) health, safety or other vital interests require processing personal data.
- Public Interest – Cloud for Utilities needs to process personal data to carry out a task that’s in the public interest.
- Legitimate Interest – processing personal data is in Cloud for Utilities legitimate interests.
|Request information from website||Consent|
|To monitor and improve the experience of the Website||Consent|
|To conduct promotional and marketing efforts||Consent|
|To provide products or services||Contract|
|To process payments||Contract|
|To comply with legal obligations and to cooperate with public and government authorities, courts or regulators||Legal Obligation|
|To comply with judicial proceedings, court orders or legal processes||Legal Obligation|
Cloud for Utilities will not disclose Personal Data to a third party except as stated below:
- Cloud for Utilities may disclose Personal Data to subcontractors and third-party agents. Before disclosing Personal Data to a subcontractor or third-party agent, Cloud for Utilities will obtain assurances by contractual agreement from the recipient that it will: (i) transfer such data only for limited and specified purposes; (ii) ascertain that the subcontractor or third-party agent is obligated to provide at least the same level of privacy protection as is required by the GDPR; (iii) take reasonable and appropriate steps to ensure that subcontractors and third-party agents effectively process the personal information transferred in a manner consistent with the organization’s obligations under the GDPR; (iv) require subcontractors and third-party agents to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the GDPR; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with subcontractors and third-party agents to the Supervisory Authorities upon request.
We may also be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements, or in the event of a merger or acquisition.
Retention of Personal Data:
Right of Access to your Personal Data
Data Subjects have the right to access the Personal Data an organization holds about them. If such Personal Data is inaccurate or processed in violation of the GDPR, a Data Subject may also request that Personal Data be corrected, amended, or deleted. When Cloud for Utilities receives Personal Data, it does so on behalf of the individual submitting such Personal Data. To request access to, or correction, amendment or deletion of, Personal Data, Data Subjects should contact Cloud for Utilities. Cloud for Utilities will cooperate with all reasonable requests to assist Data Subjects to exercise their rights under the GDPR.
Data Subjects have the right to opt out of (a) disclosures of their Personal Data to third parties not identified at the time of collection or subsequently authorized, and (b) uses of Personal Data for purposes materially different from those disclosed at the time of collection or subsequently authorized. Data Subjects who wish to limit the use or disclosure of their Personal Data should submit that request to Cloud for Utilities. Cloud for Utilities will cooperate with the Data Subjects’ instructions regarding Data Subjects’ choices.
Transfers to the United States from the European Union:
When we transfer personal information from the EU to entities within our organization located outside of the EU, we rely on standard contractual clauses adopted by the European Commission to help establish adequate safeguards. If we transfer personal information from the EU to another party located outside the EU, we will rely on a legal framework that provides appropriate safeguards, which could include the standard contractual clauses, binding corporate rules, or another framework deemed adequate by the European Commission.
- Cloud for Utilities
Post Office Box 15317
Washington, DC 20003