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:
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.
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:
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:
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.