Effective: April 1, 2018
1.1. LogicCloud IT, Inc. (we, us or our) recognizes the importance of protecting your privacy.
1.3. We abide by the California Online Privacy Protection Act and the CAN-SPAM Act as well as other applicable laws and regulations in the United States. Our policy for the management of Personal Information is set out in this document.
(a) to business or corporate information (unless it is also about any identifiable person); or
- Collection of Information
2.1. The Personal Information we collect from you will depend on our relationship with you, the circumstances of collection and the types of services provided.
2.2. We may collect your Personal Information directly from you when we communicate by email or by telephone or when you access and use our Sites and Marketing Materials. For example, we may collect your personal information when you:
(a) participate in and respond to any polls or surveys;
(b) subscribe to receive communications from us or notifications about offers;
(c) enter into any competitions;
(d) respond to our lead qualification calls;
(e) provide feedback on any of the products or services;
(f) interact with our Marketing Materials or Sites;
(g) complete a web or physical form; or
(h) otherwise interact with us or disclose your personal information to us.
2.3. On some occasions, we may collect your personal information from third parties such as from a third party provider where you are a customer of that third party provider or have otherwise opted in with that provider.
2.4. We may not provide the option of not identifying yourself, or using a pseudonym, when dealing with us. It may be impracticable for us to deal with individuals who have not identified themselves or who have used a pseudonym.
- Use of “cookies” or other web tracking systems
3.1. We collect general information from your device when you interact with our Sites and Marketing Materials. This might include your geo-location, IP address, device identifier, the browser and operating system you are using, and details of website that IP address has come from, the pages accessed on our website and the next website visited.
3.3. We may use and combine information collected using cookies and tools with information we already have about you to maintain, secure and improve our website, enhance your experience when using our website, display and deliver relevant information and advertising (including direct marketing and targeted ads on third party websites and social media sites) and understand the effectiveness of our marketing and advertising.
3.4. If you want, you can disable your web browser from accepting cookies. You can configure your web browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. However, you may not be able to access all or parts of our website, or you may experience reduced functionality when accessing certain services (for example, automatic log in may not function properly). Each web browser is different, so check the “Help” menu of your web browser to learn how to change your cookie preferences. If you disable your web browser from accepting cookies, you can still access our Sites and Marketing Materials, but not all services may be available. Third party service providers may have their own privacy policies in relation to their cookies and tools.
3.5. Pages of our Sites and Marketing Materials may contain Web Beacons, small electronic files or parts of code, such as tracking pixels, that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics. We, or third parties acting on our behalf, may use web beacons or related technology on our Sites, in our communications, or on other sites including our Marketing Materials. A web beacon is an electronic image that can be used to recognize a cookie on your equipment when you view a web page or online communication. The information we collect may include Personal Information, and web beacons allow us to recognize users by accessing cookies. Web beacons help us measure the effectiveness of our Marketing Materials and Sites and our interactions with you in various ways, for example, by counting the number of individuals who visit our Sites and Marketing Materials from a particular communication or make a purchase from our Sites and Marketing Materials after viewing a particular message as well as by telling us when a web page is viewed and providing a description of the page where the web beacon is placed. Web beacons also help us measure the effectiveness of our communication campaigns, for example, by counting the number of individuals who open or act upon a message, determining when a message is accessed and determining how many times a message is transmitted onwards. We may also combine the information that we collect through web beacons with other Personal Information we have collected from you. We, or third parties acting on our behalf, or third parties on whose behalf we are acting, use all of this information to better tailor interactions with you and may use this information for other purposes, such as to customize content on our website, serve advertising to you and for internal research purposes.
3.7. We use Google Display Advertising, and other third party providers, for re-marketing purposes. In addition to using cookies and related technologies as described above, we also may permit certain third party companies to help us tailor and serve advertising that we think may be of interest to users and to collect and use other data about user activities on our Sites and/or Services. These companies may deliver ads that might also place cookies, and related technologies as described above, and otherwise track user behavior. This means we will continue to show ads to you across the internet, specifically, but not limited to, on the Google Content Network (GCN). As always, we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager.
- Use of Personal Information
4.1. We collect, use, hold and disclose your Personal Information for purposes reasonably necessary for or related to one or more of our functions or activities. Such purposes include:
(a) to provide and administer our products and services, including to send digital marketing material on behalf of our clients or third party suppliers, including marketing emails, posts on social media platforms or display advertising and following up on leads from our digital marketing activities on our clients’ behalf;
(b) to provide customer support and respond to questions, queries, requests for information and applications;
(c) to operate our competitions and promotions including determining entry eligibility, awarding prizes and publishing or otherwise making available a list of prize winners;
(d) to conduct marketing and advertising activities, including displaying content on our Sites and Marketing Materials and serving display advertising on third party websites;
(e) to provide information about our products and services, including through distributing newsletters and other communication on information about us and our related services and your use of our services;
(f) to develop and improve our products and services, including our Sites and Marketing Materials and to provide a more personalized service;
(g) to analyze the effectiveness and optimize the performance of any specific marketing campaign we undertake, including on behalf of our clients;
(h) to create aggregated, de-identified profiling data, by combining your Personal Information with information from other users of our Sites or Marketing Materials including statistical and analytical data; and
(j) to manage and carry out our business and operational functions, including business decisions and technical operations.
4.2. In addition to the matters set out at the paragraph above, we may collect, hold and use your Personal Information:
(a) when you give us express or implied consent to do so;
(b) for purposes related to the reason for which you gave us the Personal Information, but only if you would reasonably expect us to use it for those purposes; and
(c) as otherwise permitted by or under any law.
4.3. We will take all reasonable steps to destroy or permanently de-identify Personal Information if we no longer need it for any purpose for which we have collected, used or disclosed your Personal Information or by you contacting our Privacy Officer, details below.
- Direct Marketing
5.1. We will not send any direct marketing to you unless you have opted-in to receive direct marketing communications from us, our clients or our third party suppliers. If we do send you direct marketing information we will also give you the opportunity to opt-out of receiving any further direct marketing of that kind from us.
5.2. Every time that we send emails or other materials for marketing or promotional purposes, our communications will contain instructions on how you may opt out of receiving direct marketing of that kind from us.
5.3. You can also opt out of receiving direct marketing from us by contacting our Privacy Officer, details below.
5.4. Please note, however, that certain of our distribution lists are managed by third parties with whom you have a relationship (such as your IT supplier, your insurance provider or your employer). In cases where you have a relationship with more than one of our third party providers, you may need to separately opt out of receiving direct marketing from us on behalf of or through each of those organizations. We do not keep record of which third parties have provided us with what information.
- Disclosure of Personal Information
6.1. In order to carry out the above purposes, we may disclose your Personal Information:
(a) to our clients and our third party suppliers to analyze the effectiveness and optimize the performance of a marketing campaign, provide information to you, draw a prize, validate a sale, register a sales opportunity or assist with or fulfill a transaction or provide a quotation to you in respect of the products or services of such third parties;
(b) to service providers who help us deliver, administer and support our functions and activities, including to help maintain our Sites, Marketing Materials and corresponding databases, conducting data analysis, serving advertising, providing IT services, data processing, storage and backup and telemarketing services;
(c) to our related companies (as identified on our Sites or Marketing Materials), but only for purposes reasonably necessary for or directly related to one or more of our functions or activities;
(d) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Sites and Marketing Materials is among the assets transferred;
(f) in circumstances permitted by or under any law.
- International Transfers
- Where you are submitting personal information, such information may be transferred to countries outside of where you are submitting from.
- By way of example, some of the third parties we disclose your personal information to may be based or have servers located overseas outside of the United States in various countries, including Australia, Germany, and the Philippines. Before we disclose your information to our overseas recipients, we will take all reasonable steps to ensure that your information is only used for authorized purposes, in a manner that is consistent with our Privacy Notice. You consent to us disclosing your personal information to overseas recipients on this basis.
7.1. We take the security of your Personal Information seriously and we take reasonable steps to ensure that all Personal Information we collect or use.
7.2. We have implemented procedures to safeguard the security and confidentiality of your personal information, however, because of the nature of the Internet and modern computer systems, we cannot guarantee that it is totally protected from hackers or misuse.
7.3. Once your Personal Information is no longer required by us, including under any contractual or legal requirement, we will take all reasonable steps to ensure that it is either destroyed or de-identified.
- Access, correction and removal of your personal information
9.1. It is important to us that the information we hold about you is up-to-date, accurate and complete, and we will try to confirm your details through our communications with you and promptly add updated or new Personal Information to existing records when we are advised.
9.2. Please contact our Privacy Officer, via the contact details below, if you:
(a) wish to update the Personal Information which we hold about you;
(b) wish to seek access to or request that we modify Personal Information which we hold about you;
(c) wish to request the removal of Personal Information about you from our records; or
(d) believe Personal Information about you is inaccurate, outdated, incorrect or is misleading because it is incomplete and you wish to change it; or
(e) have any questions regarding any aspect of our privacy practices or our collection or use of Personal Information.
9.3. Our Privacy Officer can be contacted on 480-210-5248, by mail at 64 E Broadway Rd STE 200 Tempe, AZ 85282, or by email at [email protected].
9.4. After verifying your identity, we will generally provide you with access to your Personal Information if practical and will take reasonable steps to amend any Personal Information about you which is inaccurate or outdated or remove such information upon request. In some circumstances we may not permit you access to your Personal Information or may refuse to correct or remove your Personal Information, in which case we will generally provide you with reasons for this decision unless we have a legally permitted reason not do to so. If you are requesting the removal of your information as part of the European General Data Protection Regulation 2016 (GDPR) and the UK Data Protection Act 2018 and any other applicable data privacy laws concerning personal information of individuals you must state that as part of your request and provide proof of residency for the applicable laws after which we will conform to our obligations under such laws.
10.1. We take your complaints seriously and we will attempt to resolve any issues quickly and fairly.
10.2. If you have a complaint about how we have handled your Personal Information, or about any other privacy-related matter, please contact our Privacy Officer referred to above.
10.3. Within 30 business days of receiving a complaint we will seek to contact you to confirm that we have commenced an investigation, and we will endeavor to complete our investigation within a further 180 days from the date of confirmation. We will let you know the outcome of our investigation once it is complete, including any actions that we will take to address your complaint.
- Amendments to this policy
- Governing Law & Indemnification
12.1. By accessing or using our sites, any site we manage or maintain, or otherwise submit Personal Information to us, you agree to hold LogicCloud IT, Inc, its partners, its agents, affiliates, licensors or any other associated party harmless against any loss, damage, cost, claim, or any other harm that may be associated with any use of your Personal Information, including the collection, publishing and sharing.
This policy will be governed in the State of Arizona, U.S.A., without giving effect to the principles of its conflict of law provisions and you agree and consent to the jurisdiction of and venue in the courts in Maricopa County, Arizona, U.S.A. in any and all disputes or other matters arising out of this policy or any information covered by it.