CoSo Cloud LLC Privacy Statement

Effective as of Jan. 8, 2018

Welcome, and thank you for your interest in CoSo Cloud LLC (“CoSo”, “we,” or “us”) and our Web site at cosocloud.com (the “Site”), as well as all related websites, downloadable software, mobile applications, connectivity tools, and other products or services, including CoSo Cloud’s Adobe Connect offerings, provided by us and on which a link to this Privacy Policy is displayed (collectively, together with the Site, our “Service”).

This Privacy Policy describes the information that we gather from you on the Service, how we use and disclose such information, and the steps we take to protect such information. By using the Service, you consent to the privacy practices described in this Privacy Policy.

This Privacy Policy is incorporated into and is subject to the CoSo Terms of Service (our “Terms”). Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in the Terms.

We collect Personal Data and Anonymous Data from you when you use the Service and/or when you send us communications. “Personal Data” means data that allows someone to identify or contact you, including your name, address, telephone number, e-mail address, and any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that we create from Personal Data by excluding information that makes such data personally identifiable.

EU – U.S. Privacy Shield and Swiss – U.S. Privacy Shield

CoSo Cloud LLC participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. CoSo Cloud LLC is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.  https://www.privacyshield.gov

CoSo Cloud LLC is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. CoSo Cloud LLC 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 Framework, CoSo Cloud LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission In certain situations, CoSo Cloud LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Information we collect on our Service:

• Billing and Personal Data. We require Participants who register to use the Service to give us “Business Contact Information” (such as their name, company name, address, phone number, and e-mail address). We require each customer to also provide financial qualification and billing information, such as billing name and address, credit card number, and other similar information (“Billing Information”). We will also ask each Appointee to provide us with the number of users within the organization that will be using the Service. If you request additional information, or when you register for the Service, we may also ask for additional Business Contact Information, such as title, department name, or fax number, or additional company information, such as annual revenues, number of employees, or industry.

Cookies and Automatically Collected Data. Our servers (which may be hosted by a third party service provider) collect information related to your use of the Service, such as browser type and version, operating system, platform, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and a date/time stamp for your visit.

We may use Google Analytics and other third party services to gather information about your use of the Service, such as the pages and information you viewed.

We, our suppliers, affiliates, or analytics or service providers use technologies such as cookies, beacons, tags and scripts to analyze trends, administer the site, track users’ movements around the Site and gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We may also automatically collect certain information from Participants and visitors to the Site, such as Internet addresses, as well as call detail records (“CDRs”) that are available to CoSo through the Service and as collected by OEM products CoSo may use. This information is logged to help diagnose technical problems, and to administer our Site in order to constantly improve the quality of the Service. We may also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and Participants and provide such information to third parties.

• Information from Other Sources. We may obtain information, including Personal Data, from third parties and sources other than the Service, such as our Third Party Services and service providers. If we combine or associate information from other sources with Personal Data that we collect through the Service, we will treat the combined information as Personal Data in accordance with this Privacy Policy.

How We Use The Information We Collect.

We use information we collect on the Service in a variety of ways in providing the Service and operating our business, including the following:

• We use information that we collect on the Service to operate, maintain, enhance and provide features of the Service, to provide services and information that you request, and to respond to comments and questions.
• We use information that we collect to contact Participants and Site visitors. For instance, we may contact Participants via email or telephone or otherwise to further discuss interest in our company or our Service, and to send information regarding our company or partners, such as promotions and events. Participants are invited to receive an email newsletter and news about updates to our Service by providing us with an email address. We may also use your email address or other information we collect on the Service to contact you for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to your Content posted on the Service. Generally, you have the ability to opt-out of receiving any promotional communications as described below under “Your Choices Regarding Personal Data”.
• CoSo uses a third-party processor to manage credit card processing. This processor is not permitted to store, retain, or use the information provided, except for the sole purpose of credit card processing. Other third parties, such as content providers, may provide content on the Site but they are not permitted to collect any information nor does CoSo share user information with these parties.
• We use information that we collect on the Service to understand and analyze the usage trends and preferences of our users, to improve the Service, and to develop new products, services, feature, and functionality.
• We may use cookies and automatically collected information we collect on the Service to: (i) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide customized content and information; (iii) monitor and analyze the effectiveness of the Service and our service providers; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any activities on the Service.

When We Disclose Information

Except as described in this Privacy Policy or our Terms, we will not disclose your information that we collect on the Service to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• We pass information regarding Participants’ use of the Service, including the dates and times you used the Service and the features of the Service you used, to the Service account holder.
• When customers of the Service use the Service to host data and information that is deemed confidential CoSo will treat such data and information as Confidential Information and avoid disclosure in accordance with the Terms.
• We may from time to time work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
• We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations and (ii) to assist such parties in understanding how Participants’ use the Service.
• We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We will provide you with notice of such disclosures to the extent permitted under law.
• We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• Information about Participants, including Personal Data, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• We have the right to use, and share with third parties, Anonymous Data for any purpose and in any manner.

Third Party Sites

The Service contains features or links to websites, services, and software provided by third parties, including Adobe. Any information you provide through third-party websites, services and software is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party websites, services or software to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Data that we collect and maintain. We cannot, however, ensure or warrant the security of any information you transmit to us or our service providers or that you store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

If we learn of a data security incident involving the Service that may affect or implicate your Personal Data, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice through the Service if such a security incident occurs.

Privacy Settings

Although we may provide you mechanisms that allow you to adjust your privacy settings to limit access to certain Personal Data, please be aware that no security measures are perfect or impenetrable. We are not responsible for circumvention of any privacy settings or security measures on the Service. Additionally, we cannot control the actions of other users with whom you may choose to share your information. Further, even after information posted on the Service is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Service. We cannot and do not guarantee that information you post on or transmit to the Service will not be viewed by unauthorized persons.

Your Choices Regarding Personal Data

CoSo Cloud offers its visitors and Participants a means to choose how we may use information provided. Of course, you may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your account information and settings at any time by accessing your profile management page on the Service. If you wish to access or amend any other Personal Data we hold about you, you may contact us at support@cosocloud.com. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

If, at any time after registering for information or ordering the Service, you change your mind about receiving commercial messages from us, you can opt-out of being contacted by us, or receiving such information from us, at any time by sending an email to support@cosocloud.com, by following the instructions contained within any commercial email we send you, or by writing to us at the address given at the end of this Privacy Policy. We may also allow you to view and modify settings relating to the nature and frequency of promotional or commercial communications that you receive from us in your account settings on the Service.

Please be aware that if you opt-out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may receive promotional communications from us that you have opted-out from during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

Cross-Border Data Transfers

Although CoSo may offer localized content based on information you provide us, our Service is hosted in and operated from Hong Kong (covering the Asia-Pacific region), the United Kingdom (covering the Europe, Middle East, and Africa regions), and the United States. Data may be transferred between these various locations, as well as intermediary locations incidental to the provision of the Service. Thus, if you choose to use the Service, then please note that you are transferring your Personal Data to various jurisdictions (with laws governing data collection and use that may differ from your own local law) for storage and processing. Also, we may transfer your data from Hong Kong, the UK, or the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including Personal Data, on or to the Service, you consent to such transfer, storage, and processing.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. If we make material changes to the Privacy Policy, we will notify you by posting a prominent notice on our website and/or sending you an e-mail at the email address you provided in the Service. Any changes to this Privacy Policy will be effective immediately for new users of the Service; otherwise these changes will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of a notice on our website(s) and application(s). You are responsible at all times for updating your account to provide to us your most current e-mail address. If the last e-mail address that you have provided to us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. Continued use of the Service following notice of such changes shall indicate your acknowledgment of, and agreement to be bound by, such changes. Except as otherwise provided in this Section, no amendment to this Privacy Policy will be valid.

Contacting Us

Questions regarding this Privacy Policy or the practices of this Site or our Service should be directed to CoSo Cloud by e-mailing such questions to support@cosocloud.com or by regular mail addressed to CoSo Cloud LLC, 827 Broadway, Suite 200, Oakland, CA 94607.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Dispute Resolution

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.com/watchdog/request.