2. KEY DEFINITIONS
- “European Data Protection Law” means the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable national legislation implementing the GDPR and, if applicable, the UK data Protection Act 2018 and the UK GDPR.
3. INFORMATION WE COLLECT
We may collect data, including personal data, about you as you use our Websites and Cloud Services or request our Cloud Services, and otherwise interact with us. Some of our Website’s functionality can be accessed without providing any personal data. We process three broad categories of personal data:
- Information provided directly by you;
- Information received from third parties
- Information collected automatically.
3.1 Information Provided Directly by You
- Account registration. If you register with the Cloud Services through our Website, then as part of such registration we will ask you to provide certain personal data, including your name, your company name, address, phone number, your email address and password.
- Communication with V2 Cloud. We collect personal data that you voluntarily give us when you contact us with inquiries (including by filling out relevant forms on our websites), engage with our chat bot on the Website, respond to one of our surveys, contact our customer support regarding a problem you are experiencing with the Cloud Services or otherwise contact us regarding the website or the Cloud Services.
- Transactions. We collect details of transactions you carry out using the Cloud Services including information you provide to enable us to fulfill your orders, which may include financial information such as your credit card number. As a Customer of the Cloud Services, we will receive your payment transaction details (for example, your name, the amount paid and the date of payment).
- Payment Information. We collect payment and billing information when you register for Cloud Services. For example, upon registration we ask you to designate a billing representative, including name and contact information. You may also provide payment information, such as payment card details, which we collect via secure payment processing Cloud Services. If you sign-up for a free trial account, you are not required to enter your credit card information unless and until you decide to continue with a Subscription Plan to Cloud Services.
- Additional Payment Information. You may choose to provide additional information such as your VAT, additional billing address or name of the entity that you represent.
3.2 Information Received from Third Parties
We may combine personal data we receive from you with personal data we obtain from other sources, such as:
- Our authorized resellers or distributors, for example, if you purchase access to the Cloud Services through one of these partners. The personal data we may receive may include mailing addresses, job titles, email addresses, and phone numbers.
3.3 Information Collected Automatically
- Device and Usage Data. When users come to the Website, we may track, collect, and aggregate information indicating, among other things, which pages of the Website were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to the Website. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Website. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of their point of connectivity.
- Cookies and Similar Technologies. The current version of the Website uses a variety of “cookies”. Cookies are small text files which a website may put on your computer or mobile device when you first visit a site or page. The cookie will help the website, or another website, to recognize your device the next time you visit. We use the term “cookies” to refer to all files that collect information in this way. There are many functions cookies serve. For example, they can help us remember your preferences, analyze how well the Website is performing, or even allow us to recommend content we believe will be most relevant to you. Most cookies will not collect information that identifies you, but will instead collect more general information such as how users arrive at and use the Website.
Cookies do not cause any damage to the terminal, but make it easier, for example, to find preferences, pre-fill certain fields and adapt the content of the Cloud Services on the site visited. Such data allows the improvement of ergonomics and Cloud Services according to your interests. If you are unable to use our Website, you may need to activate your browser’s cookies option.
Please note that, depending on the settings you choose, enabling the cookie option may allow other servers to install cookies on your system. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it.
In addition, V2 Cloud uses Google Analytics, a web analytics tool. Information concerning your navigation on the Website is collected, in particular :
- The pages you visit;
- The date, time, duration and frequency of your visits;
- The links you click on;
- The type of operating system on your computer, and the language of your computer;
- The name of your Internet service provider;
- Your geographical location;
- Your IP address (anonymised);
- Your browser type and version;
- The address of the referring site, if you are accessing the site from another site.
This information is used to produce statistics and reports on the browsing of the Website and thus to enable us to provide a tailored service to users
A user can configure their browser to prevent cookies from being saved and to prevent this browsing information from being saved by installing a Google Analytics disabling browser add-on on your computer.
4. HOW WE USE YOUR INFORMATION
We use the personal data we collect, described above, as follows:
- To provide the Cloud Services and related support, process transactions, manage your user account and respond to your requests. This is necessary to fulfil the contract we are about to enter into or have entered into with you.
- To the extent permitted by applicable law, and for certain legitimate interests, including:
- To manage our relationship with you, which includes sending administrative information to you, for example, information regarding the website and changes to our terms, conditions, and policies, information on our own products and Cloud Services that may be of interest to you and responding to your requests or communicating with you;
- To analyze your preferences, interests and behavior (such as your usage of and interactions with our websites and Cloud Services) to identify insights, trends and correlations. This enables us to improve your experience with our Cloud Services by providing you with more relevant content and service offerings and helps us improve our Cloud Services (including our Service’s functionality, product features, and user-friendliness) and develop new products and Cloud Services.
- For other internal business purposes, such as data analysis, benchmarking, audits, conducting research, analysis, studies or surveys and identifying usage trends. To prevent fraud or criminal activities, misuse of our products or Cloud Services and ensure the security of our IT systems, architecture and networks;
- To (a) comply with legal obligations and legal process; (b) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) enforce our Terms of Service; (d) protect our operations; (e) protect our rights, privacy, safety of property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.
- If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfill your request, to keep basic data to identify you and prevent further unwanted processing.
- For marketing and advertising, including sending you updates and information about our new products and Cloud Services, upcoming events or other promotions or news, including by email or push notification, as permitted by law. Where required by law we will only send you marketing information if you consent to us doing so at the time you provide us your personal data. You may opt-out of receiving such emails by following the instructions in each promotional email we send you or by updating your user settings. If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to [email protected]. Please be aware that if you opt-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, you will continue to receive administrative messages from us regarding the Service. We do not share your information with non-affiliated third parties for their own marketing purposes.
5. HOW WE SHARE YOUR INFORMATION
We do share your information as follows:
- Sales Channel Partners and Distributors: We may provide information about you to carefully screened entities that work on our behalf, such as our marketing Cloud Services suppliers, newsletter distributors or other service partners, to market V2 Cloud products and Cloud Services. Only trusted companies who require the use of said information for business purposes are given access to it.
- Service Providers. We may share your information with other third-party service providers to assist us in providing our Cloud Services to you, responding to your requests, and/or to provide you with the partner Cloud Services you have purchased.
We also may share your information in the following circumstances:
- Business Transfers. If we are acquired by or merged with another company, if substantially all our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company. We also may transfer our rights under any customer agreement we have with you.
- In Response to Legal Process. We may disclose the information we collect from you to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- Aggregate and Anonymous Information. We may share aggregate or anonymous information about users with third parties for research or similar purposes.
6. LINKS TO THIRD PARTY WEBSITES
7. DATA RETENTION
We retain your personal data for as long as reasonably necessary to provide the Cloud Services and fulfil the Subscription Plan you have purchased, complying with our legal obligations or for other legitimate business purposes, such as maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. After the applicable retention period has elapsed, your personal data will be anonymized and deleted, subject to your selected back-up plan. For our Website, we retain your information as long as we have a legitimate business interest to process it or as long as you have not withdrawn your consent. This includes data you or others provided to us and data generated or inferred from your use of our Website.
V2 Cloud takes security of all data, especially your personal data, seriously. We do our best to protect your information from any unauthorized access or loss with implemented security features and procedures. You should, however, be aware that the transmission of information via the Internet is never completely secure. You should also take necessary steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
9. UPDATING AND ACCESSING YOUR PERSONAL DATA
You may access, review, modify and delete your Customer Account by going to your account and editing your information. However, if you want to update, delete, limit the use or disclosure of, or access the personal data we hold about you in our systems, you will need to email your request to us at [email protected].
Our Cloud Services are not directed at children who are under the age of 16. We do not knowingly collect personal data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal data to us through the Cloud Services, please contact us at [email protected] and we will endeavor to delete that information from our databases.
11. COUNTRY AND STATE SPECIFIC DATA INFORMATION
- Quebec Law 25 (The Privacy Legislation Modernization Act)
V2 Cloud has appointed a Data Protection Officer who is contactable at [email protected].
- California Consumer Privacy Act
We do not sell your personal data. You have rights which impact how your personal data is being processed, including:
- The right to know what information is collected, used, shared or sold;
- The right to delete (erasure right) information processed by us;
- The right to opt-out of the sale of your information. If you are under the age of 16, we will only sell your information if you opt-in, with your parent or guardian consenting if you are under 13;
- The specific personal data right to request a copy of the specific personal data collected about you during the past 12 months; and
- The right to non-discrimination in how we provide the Cloud Services to you when you exercise any of your rights under the CCPA.
Submitting a personal data or erasure request
- Exercising Your Rights: California residents can exercise the above privacy rights by contacting us at [email protected].
- Verification: to protect your Personal data from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal data. If you do not have a Customer Account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional personal data for verification. If we cannot verify your identity, we will not provide or delete your personal data.
- Authorized Agents: you may submit a request to know or a request to delete your personal data through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.
- European Users (This section applies to individuals in the EEA or the UK.)
You as a data subject have rights to impact how your personal data is processed. You can:
- Request access to your personal data that we process
- Withdraw your consent if our use of your personal data is based on consent
- Request that your personal data to be deleted or for you to be forgotten (right to erasure)
- Request that we correct or change your personal data. As a customer you may also do this by logging in to your Customer Account.
- Limit, restrict or object to our use of your personal data
- Access your personal data and/or receive it in a machine-readable form
- Subject to applicable law, lodge a complaint with your local data protection authority.
- Quebec Law 25 (The Privacy Legislation Modernization Act)
Please note that if you request to remove your personal data, we may retain some of the personal data for specific reasons, such as to resolve disputes, troubleshoot problems, and as required by law. Furthermore, some personal data is never completely removed from our databases due to technical constraints and the fact that we regularly back up our systems.
- International Transfers of Personal data
V2 Cloud is based in Canada and other members of our group are based in countries outside of Canada, EEA or the UK. Please note that if you access our Website or register for our Cloud Services your personal data may be transferred across international borders or from the country in which you are located, to countries that do not have laws providing an adequate level of data protection.
We transfer your personal data as described above, and to ensure adequate protection for personal data, we will take steps to ensure that your personal data receives adequate security protection where it is processed and your rights continue to be protected pursuant to the applicable data protection law, including using Standard Contractual Clauses approved by the European Commission.
V2 Cloud uses certain platform sub-processors, as well as infrastructure suppliers and other third-party business partners, to provide Cloud Services to its customers. The following is a list of the name(s), location(s) and activities of the infrastructure suppliers for V2 Cloud eSignature.
|Entity Name||Purpose; applicable Cloud Services||Country location(s)|
|Intercom R&D Unlimited Company||User engagement and outreach||USA (SCC)|
|Google, Inc.||Infrastructure – Regional Data Processing||USA (SCC)|
|Cloudflare||Content Delivery Network||Local **Data Centers located all around the world. Traffic will be automatically routed to the nearest data center.|
|OVH||Hosting & Infrastructure||Local **Data Centers located all around the world. Traffic will be automatically routed to the nearest data center.|
|PhoenixNAP||Hosting & Infrastructure||Singapore|
|THG/Ingenuity Cloud Services||Hosting & Infrastructure||USA|
|Servers Australia||Hosting & Infrastructure||Australia|
|Sentry||Provides parts of the Service and related technical support||Canada|
|Datadog||Monitoring of servers, databases, tools, and services||USA|
|SendGrid||Email service provider||USA|
|Atlassian||Bug tracking and agile project management||USA|
|Stripe||applicable Cloud Services: V2 CLoud uses Stripe for credit card payment processing. Customers submit information directly to Stripe through Stripe’s API. V2 Cloud does not collect credit card information.||USA|