Privacy Policy

Hi!  Welcome to our Privacy Policy (“Privacy Policy”).

Chances are high that you’re looking for some specific information and to help you get to what you’re looking for quickly we want to provide you with these content links:

• What does this Privacy Policy cover?
• What information do we collect about you?
• How do we use the information that we collect about you?
• Do we share the information that we collect about you?
• Where and how do we store your information and how is it protected?
• Do we collect information from minors?
• Things change, will this Privacy Policy change?
• Who should I contact if I have questions or concerns?

What does this Privacy Policy cover?

This Privacy Policy describes the privacy practices for Rubikloud’s websites (“the Sites”) and our marketing and advertising practices.

Our Recruitment Information Policy (“Recruitment Information Policy”) describes the privacy practices for our job applicant process. You can learn more about career opportunities here.

Our product contracts and terms and conditions documentation describe additional privacy practices for our products and services.

Protecting the privacy and confidentiality of personal information within our possession and control is an important aspect of the way that we conduct our business. We strive to protect and respect the personal information of our customers, business partners, employees, consultants, job applicants, and event registrants in accordance with all applicable laws and have appointed a Privacy Officer to maintain stewardship over our Privacy Policy and practices.

Our Privacy Officer is:

Tom Lieu
Chief Financial Officer

What information do we collect about you?

We require certain information to provide our services to you. We collect certain personal information when you access our website, download our content, register for our events, request information, or when you use our products or services. We may also combine information you provide with data we collect automatically (as further described below) and with data we receive from third parties.

The personal information that we collect depends on the context of your interactions with us, the choices you make and the products and features you use. The personal information we collect can include the following:

Information collected directly from you: In registering with us, downloading content, requesting information, participating in activities on our Sites (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us you may provide us with:

• Identity and contact information, including your first name, last name, industry, organization name, job role, e-mail address, phone number, address and demographic information.
• Product related information, such as product registration information, product interest information or transaction information.

Information collected via automated means:

We may collect Automated Information through the use of cookies (refer to our Cookie Policy), and other technologies. In addition to cookies, such other technologies may include:

• “Pixel tags” (also known as a “clear GIFs” or “web beacons”) which are tiny images (in most cases, typically just one-pixel) that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.
• “Embedded scripts” (bits of programming code included within some of our web pages) that measure how you use those web pages, such as which links you click. We use this information to improve our websites, tailor our websites to your likely interests, and conduct market research. You may be able to turn off scripting functionality, such as JavaScript, within your browser. Note that if you disable scripting functionality, some of our websites may not function properly.
• “HTML5” (the language some websites, such as mobile websites, are coded in) may be used to store information on your computer or device about your website usage activities, authenticating you, keeping track of information you have provided to us, and remembering your preferences.

The above tracking technologies may be deployed by us or our service providers on our behalf. You can find more information on our third-party service providers in the Data Sharing section of this Policy.

Automated Information includes information such as:

• IP address
• Geolocation
• Operating system used (for example: iOS)  Internal resolution of the browser window
• Device type
• Country code
• Identifiers associated with technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address)
• Dates and times of access

An Internet protocol (“IP”) address is the unique number assigned to your server or Internet Service Provider. We may track such IP addresses for the purposes described in this Privacy Policy.

In addition, we or our third-party service providers may assign you a unique identifier through automated means in order to match information collected from you through different means or at different times, (including both personal information and Automated Information) and to use such information as described in this Privacy Policy.

Information collected directly by Third Parties:

Our website contains third party sites linked from our websites to other websites, including those of our partners and sponsors, whose information practices may be different from ours. Sometimes these third-party websites might conduct contests or sweepstakes and other activities that are promoted on our websites and visitors are directed away from our websites in order to participate in such activities.

You may also connect to third party services to share your information on and through their social
media platforms, websites, applications, and services through “plug-ins,” widgets, buttons, and other
third-party features on and connected with our websites.

We may also offer ways to share through independent third-party sites, plug-ins and online services. We are not responsible for the activities of these third parties. We encourage you to review their privacy policies to understand how they use your information. Because your posts and information shared through websites are public and can be seen by others, we caution all users to consider what they post and share online and not to disclose any personal information as part of their posts, even if requested to do so by other posters. We will not be responsible in the event that you disclose personal information in your posts, through our public services or during any other communication with other site users.

This Privacy Policy does not apply to the direct data collection or processing activities of any third parties when they are collecting or using data for their own purpose or on behalf of others. Please consult the respective privacy policies and statements of such third parties for more information. A link to these third-party privacy policies has been provided in the Data Sharing section of this Privacy Policy.

How do we use the information that we collect about you?

We use personal information collected through our Sites for a variety of purposes described in this Privacy Policy and as disclosed to you in connection with our Sites, including:

• To fulfill our commitments and obligations to you under a contract, or when you ask us to do something before entering into a contract, such as to:
• Provide and deliver products or services you’ve requested
• Respond to your comments and questions and provide customer service
• Send you service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages

• For our legitimate business interests and those of our partners, vendors and/or affiliates, including:
• To operate and improve our internal operations, systems, products, and services;
• To understand you and your preferences to enhance your experience and provide you with better and more personalized service;
• To evaluate and aggregate visitor usage so that we may optimize our content, events, and marketing to better meet your needs;
• To deliver targeted communications to you and your referrals about promotions, upcoming events, and news about products and services offered by us and our selected partners;
• To protect against, investigate, and deter fraudulent, unauthorized, or illegal activity;
• For system administration, to report aggregate information, site tracking and to prevent our servers from being abused;
• To enforce our terms and conditions or protect our business, partners, or users;

• With your consent to:
• Communicate with you and your referrals about promotions, upcoming events, and news about products and services offered by us and our selected partners

To administer prize draws and competitions when you elect to participate in competitions

• To meet other non-contractual legal obligations, including:
• Complying with legal or regulatory requirements, judicial process and/or industry standards

To perform the above functions, we may match information collected from you through different means or at different times and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual.

Do we share the information that we collect about you?

We do not rent, sell, or share personal information about you with other people or non-affiliated companies, except under the following circumstances:

• Third-Party Service Providers. We share your data with various categories of third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work as described below. We maintain contracts with these companies restricting their access, use and disclosure of personal data in compliance with this Privacy Policy. We may be liable if they fail to meet those obligations and we are responsible for the event giving rise to the damage.
• Marketing providers. We, or the third-party service providers we use to assist us with marketing our own products to you, may use the information we collect from you to provide advertisements and offers for our other products. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. The Privacy Policies of these providers can be found here:
  

  Triblio [Account Based Marketing]: https://triblio.com/privacy-policy/
  ZoomInfo [Site Visitor Identification]: https://www.zoominfo.com/business/aboutzoominfo/privacy-policy
  Linked In [Social Media Campaigns]: https://www.linkedin.com/legal/privacypolicy

  Additionally, if we obtain your information in connection with a contest, event, offering or other promotional activity that is jointly offered by us and any third parties we may share your information with our co-sponsor. We may also share your information with a third party service provider who administers the event and/or contest. The third parties we work with for event management may vary depending on the event and/or contest, and we may use introduce new ones at any time. We encourage you to review their Privacy Policies as presented to you directly by these third parties at the time of event entry. The Privacy Policies of our key event partners can be found here:

  Microsoft [Event Partner]: https://privacy.microsoft.com/en-us/privacystatement
  REPL [Event Partner]: https://www.replgroup.com/terms-conditions-privacypolicy/

• Website Analytics: Our website uses Google Analytics (GA) to help analyze how visitors use this site. For more information on how GA collects and uses personal information refer to:
  

  Google Analytics: https://support.google.com/analytics/answer/6004245

• Vendors, Consultants and Other technology providers necessary to provide our services (including cloud storage and web hosting providers). We may make certain Automated Information and/or aggregate or non-personally identifiable information available for various purposes including monitoring network traffic to detect malicious actors and to protect against malware, fraud or other unlawful uses or activity.
• Business Transfers. We reserve the right to transfer or disclose personal information in our
  system in connection with or during negotiation of any merger, financing, acquisition, bankruptcy,
  dissolution, transaction or other proceeding involving sale, transfer, divestiture or assignment of
  all or a portion of our business or assets to a different entity.
• Affiliates. We may share some or all of your information with our current or future “affiliates”
  (which includes any parent company, subsidiaries, joint ventures, or other companies under
  common control), in which case we will require our affiliates to honor this Privacy Policy.
• Compliance with Laws. We may disclose personal information to comply with laws or in
  response to legal process, for example, in response to a court order or a subpoena. We also
  may disclose personal information in response to a law enforcement agency’s request, or where
  we believe it is necessary to investigate, verify, prevent, enforce compliance with, or take action
  regarding:
  • illegal or suspected illegal activities;
  • suspected fraud;
  • situations involving potential threats to the physical safety of any person;
  • protection of the rights and property of Rubikloud, our agents, customers or others;
  • violations or suspected violations of our agreements, policies, Terms of Use or End User License Agreements; or as otherwise required or permitted by law or consistent with legal requirements
• With your Consent. We may disclose your personal information for any other purpose with your consent.

Finally, we may also share aggregated, anonymized or statistical information about you, including demographics data, with others for a variety of purposes, including for their own uses, for example, for improving their products and services for Rubikloud and others.

Where and how do we store your information and how is it protected?

Protection of personal data

We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information throughout our websites.

However, despite our best efforts, no security controls are 100% effective and no company, including us, can fully eliminate or warrant the security risks associated with personal information. To help protect yourself, please use a strong password, do not use the same passwords to access your Rubikloud accounts that you use with other accounts or services, and protect your usernames and passwords to help prevent others from accessing your accounts and services.

Storage and transfers of personal data

Rubikloud is a global company with affiliates, varied business processes, management structures and technical systems that cross borders. Information collected by us or on our behalf may be stored on your computers, on your mobile devices and/or on our servers or the servers of companies we hire to provide services to us. Your personal information may be transferred across national borders because we have servers located worldwide and the companies we hire to help us run our business are located in different countries around the world.

We and our service providers may transfer, access or process your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. These countries include but are not limited to Canada, United States, England, France, Australia, Singapore, Japan, Taiwan, and China, and any other country where we, or our service providers, maintain facilities or support centers.

Some countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.

In compliance with GDPR requirements, we use the following mechanisms to protect the privacy of your data when transferring personal information from the European Economic Area:

• Pursuant to an adequacy decision for countries that the European Commission has deemed to adequately safeguard personal information,
• Pursuant to the recipient’s compliance with standard contractual clauses (also known as Model Clauses), EU-US Privacy Shield, or Binding Corporate Rules,
• Pursuant to the consent of the individual to whom the personal information pertains, or
• As otherwise permitted by applicable EEA requirements.

Retention of personal data

Personal information we collect may be retained for as long as needed to fulfill legitimate business purposes, including the purposes outlined in this Privacy Policy, or for a period of time specifically required or allowed by applicable regulations or laws.

What are my privacy choices and rights?

Depending on where you live, you may be entitled to certain rights regarding your personal data as detailed below.

Residents of the European Economic Area (EEA)

As a resident of the EEA, you may have some or all of the following rights in relation to how we use your personal information:

• Access: you may request access to your personal information and receive copies of it;
• Correction: you may have inaccurate/incomplete personal information corrected and updated;
• Object to, or Limit or Restrict, Use of Data: you can ask us to stop using all or some of your personal information or to limit our use of it;
• Deletion: in certain circumstances, you can request to have your information deleted. We will honor such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
• Portability: in certain circumstances, you have the right to obtain a transferable version of your personal information to transfer to another provider;
• Consent Management: where we rely on consent to process your personal data, you may withdraw consent at any time. You do not have to provide a reason for your withdrawal where processing is based on consent.

If you are a resident of the EEA and you wish to access, change or delete personal information we hold about you, you may send us an e-mail using the privacy e-mail provided in this Policy or writing to us at the mailing address provided here.

If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide you with our Services or some of the features and functionality of our Services. Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For example, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.

For your protection, we may require proof of identity and verification before we can answer the above requests

Residents of California

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may provide you with
rights that are in addition to those set forth elsewhere in this Privacy Policy regarding our use of your
personal information. The CCPA Notice applies to “Consumers” as defined by the law.

This section describes your CCPA rights as a California Consumer and explains how to exercise
those rights:

• Access to Information and Data Portability Rights
  • You have the right to send us a request, no more than twice in a twelve-month period, for any of the following for the period that is twelve months prior to the request date:
  • The categories of personal information we have collected about you.
  • The categories of sources from which we collected your personal information.
  • The business or commercial purposes for our collecting or selling your personal information.
  • The categories of third parties to whom we have shared your personal information.
  • The specific pieces of personal information we have collected about you.
  • A list of the categories of personal information disclosed for a business purpose in the prior 12 months, or that no disclosure occurred.
  • A list of the categories of personal information sold about you and the categories of third parties to which we sold personal information to in the prior 12 months, or that no sale occurred.
  • You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your personal information that we have collected in the period that is 12 months prior to the request date and are maintaining.
• Data Deletion Rights
  • Except to the extent we have a basis for retention under CCPA, you may request that we delete your personal information that we have collected directly from you and are maintaining. Note also that we are not required to delete your personal information that we did not collect directly from you.

To make a request for access, portability or deletion according to your rights under CCPA, you may send us an e-mail using the privacy e-mail provided in this Policy or writing to us at the mailing address provided here. California Consumers may exercise these rights via an authorized agent who meets the agency requirements of the CCPA. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.

Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”), which must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate,
  and respond to it.

Some personal information we maintain about Consumers is not sufficiently associated with enough personal information about the Consumer for us to be able to verify that it is a particular Consumer’s personal information (e.g., data tied only to a pseudonymous identifier). As required by the CCPA, we do not include that personal information in response to Verifiable Consumer Requests. If we cannot comply with a request, we will explain the reasons in our response.

We will make commercially reasonable efforts to identify Consumer personal information that we collect, process, store, disclose, and otherwise use and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

All other individuals

If you are not a resident of the EEA or California, you may still be able make requests to access, correct and/or delete certain personal information that you provide to us. For your protection, we may require proof and verification of identity before we can answer the above requests.

If you wish to make such a request, you may send us an e-mail using the privacy e-mail provided in this Policy or writing to us at the mailing address provided here. If we change or delete your personal information or if you decline to actively share certain personal information with us, we may not be able to provide to you our services or some of the features and functionality of our services. Once we have verified your identity, we will honor requests as required by law and subject to our business and legal needs to retain your data.

Marketing Opt-Outs

Our marketing emails tell you how to “opt-out” of receiving further marketing emails. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you, and, as allowed by applicable law, requests for your participation in surveys. You may also contact us privacy@rubikloud.com at any time to unsubscribe and let us know that you no longer wish to receive further marketing emails.

You may also be able to opt-out of tracking and other marketing related activities performed directly by our third-party service providers. For more information, visit the following:

ZoomInfo: https://www.zoominfo.com/about-zoominfo/privacy-center
Google Analytics: https://tools.google.com/dlpage/gaoptout
Digital Advertising Alliance: http://www.aboutads.info/choices/

In addition, when you use our websites, you can usually choose to set your browser to remove cookies and to reject cookies from our servers. If you choose to remove cookies or reject cookies, this could affect certain features or services of our websites. Cookie management tools provided by your browser may not remove Flash cookies. If you delete your cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choices.

While we and others give you certain choices, as further outlined in this Privacy Policy, there are many ways that web browser signals and similar mechanisms can indicate your choice to disable tracking, and we may not be aware of nor honor every mechanism.

Do we collect information from minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of our Sites. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please send us an e-mail using the privacy e-mail provided in this Policy or writing to us at the mailing address provided here.

Things change, will this Privacy Policy change?

Occasionally we may collect and use personal information in ways not previously disclosed in our Privacy Policy. If our information practices change we will post any adjustments to our policy on this website and change the “Last Updated” date above. For new visitors, the change will become effective upon posting. For existing users, unless additional notice or consent is required by applicable laws, this will serve as your notification of these changes. If you are concerned about how your information is used, bookmark this page and check back periodically.

Things change, will this Privacy Policy change?

Occasionally we may collect and use personal information in ways not previously disclosed in our Privacy Policy. If our information practices change we will post any adjustments to our policy on this website and change the “Last Updated” date above. For new visitors, the change will become effective upon posting.  For existing users, unless additional notice or consent is required by applicable laws, this will serve as your notification of these changes. If you are concerned about how your information is used, bookmark this page and check back periodically.

Who should I contact if I have questions or concerns?

You may direct any inquiries or complaints concerning our Privacy Policy to privacy@rubikloud.com. We will respond within ten (10) business days.

If you live in the EEA, you may also file a complaint with your local data protection regulator.

Written communication should be sent to Rubikloud Technologies, Inc., Attn: Privacy Office, 207 Queens Quay West, Suite 801, Toronto, Ontario, Canada, M5J 1A7.

Thank you for reading our Privacy Policy.