PRIVACY POLICY

1. What Personal Information Do We Collect?

Personal Information is any identifying information that specifically identifies you or, when combined with other information we have, can be used to identify you, such as your name in combination with another identifier, such as date of birth, postal address, email address, telephone number, or government-issued identification number. Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. The specific definition of Personal Information varies from one jurisdiction to another.

Where we have an arrangement in place with an enterprise customer who is encouraging you to use our Services, we operate in the capacity of a processor or a service provider. Our enterprise customer will be deemed the controller or covered business (under applicable laws) which controls such customer data.

We obtain and process your Personal Information only on behalf of and at the instructions of our enterprise customers in accordance with a data processing addendum and/or other agreements, as applicable. The enterprise customer is the entity that solely determines the purposes and means for which the Personal Information is processed. If you have questions about how enterprise customers handle your Personal Information, please refer to their privacy policies and contact them directly.

Personal Information you disclose to us

We collect Personal Information that you voluntarily provide to us when you fill out our “Contact Form,” try a free or paid version of our Platform, register on the Services and create an account, express an interest in obtaining information about us or our products and Services and contact us by telephone or email or send us a message through our Site, when you participate in activities on the Services, or otherwise interact with us on our Services. The Personal Information we collect may include the following:

Contact Information and Other Personal Identifiers: This may include your name, email address(es), postal address(es), social media usernames, and telephone number(s), including your mobile phone number(s), your company name, role and business affiliations.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment data is handled and stored by Stripe and Paypal. You may find their privacy notice link(s) here: https://stripe.com/privacy and https://www.paypal.com/us/legalhub/privacy-full.

Commercial Information. This may include records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and program membership information.

Other Information. We may collect additional information including information you submit via a message box or online forms.

Inferences drawn from other Personal Information. This may include profile information reflecting a person's preferences.

Personal Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. How Do We Process Your Personal Information?

We process your Personal Information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the Personal Information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “What Are Your Privacy Rights?” below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. When and With Whom Do We Disclose Your Personal Information?

We may need to disclose your Personal Information in the following situations:

• Service Provider. We may disclose non-individual information, in the aggregate, regarding your online browsing preferences to allow certain of our service providers with whom we work with to better serve our users. We will not disclose personally identifiable information in these instances, other than as described in this Privacy Notice. These service providers help us initiate direct marketing programs on our behalf, do data tracking, maintain or develop our Services, and help us operate our business.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Legal and Compliance. We may also share your Personal Information in connection with government or law enforcement requests or in response to investigations, subpoenas, court orders, or other legal processes to: operate the Services, process any orders or registrations, protect the rights or property of 639 Cloud, its affiliates, users, and customers, establish or exercise our legal rights or defend against legal claims, or as otherwise required by law.

4. Do We Use Cookies And Other Tracking Technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

Cookies are small data files placed on your device (computer, smartphone, tablet, etc.) when you visit our website. These files help us enhance your experience by remembering your preferences, providing personalized content, and improving website functionality. We use both session cookies which are temporary and persistent cookies that remember your device until it is expired or deleted.

The categories of cookies we use are:

• Essential Cookies. These cookies are necessary to the core functionality of our Services and some of its features, such as access to secure areas.
• Performance and Functionality Cookies. These cookies are used to enhance the performance and functionality of our Services but are nonessential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.
• Advertising Cookies. These cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests.
• Analytics and Customization Cookies. These cookies collect information that can help us understand how our Services is being used. This information can also be used to measure effectiveness in our marketing campaigns or to curate a personalized Services experience for you.
• Social Networking Cookies. These cookies enable you to share our Services' content through third-party social networks and other websites. These cookies may also be used for advertising purposes.

Web Beacons.

The Services and our emails may include web beacons or similar technologies that help us understand usage patterns, measure the effectiveness of communications, and compile aggregate statistics about user engagement.

Pixels.

Pixels are small transparent images embedded in a website, email or ad and may provide information to platforms who may combine your information with other information they have about you. We use pixels to automatically collect information when you visit our Services. These technologies usually track advertising preferences from site to site, and gather data about a users' browsing habits to improve the user experience. You may seek to block tracking pixels by installing a dedicated browser extension or ad-blocking extension for that purpose, adjusting your browser privacy settings or by clicking “Consent Preferences.”

Interest-Based Advertising.

If you have opted in, we also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests. The tailored advertisements may appear on our Services or on other websites. You may be able to reject interest-based advertising and retargeting through the privacy controls offered by third-party advertising platforms. Any such tracking or targeting is governed by the applicable third-party platform's privacy practices, over which we do not have control. Some of the advertisers and service providers that perform advertising-related services for us may participate in the European Interactive Digital Advertising Alliance (“EDAA”), the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). Please see the links below for more information on how to opt out.

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA's opt-out platform: http://www.youronlinechoices.com/
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Use of ZoomInfo for Visitor Identification.

We use services provided by ZoomInfo Technologies LLC (“ZoomInfo”) to help us better understand and engage with visitors to our Site. ZoomInfo may collect and process certain information about your visit, including your IP address, to help us identify the business or organization associated with that IP address. This process may involve correlating your IP address with publicly available or licensed business data to infer potential business contact information.

Managing Your Choices.

You can manage your preferences for cookies and tracking technologies by clicking on “Consent Preferences” at the bottom of our Site. You will not be able to opt-out of any cookies that are “Essential” for the Services. However, you can choose to accept or decline non-essential cookies and tracking technologies as you wish. If you have accepted non-essential cookies and tracking technologies by opting in, you can change your preferences at anytime by opting out of such non-essential cookies and tracking technologies.

Google Analytics.

We use Google Analytics, to analyze how you interact with our Site and Services and to provide targeted marketing and other usage data. Google analytics may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website, and place tags, cookies, beacons and similar tracking mechanisms on your devices. If you don't want Google Analytics to be used in your browser, you can install the “Google Analytics Opt-Out Browser Add-On,” provided by Google.

Google reCAPTCHA.

We use Google reCAPTCHA to protect our Services from spam and abuse. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements.

5. How Do We Handle Your Account Login?

Our Services offer you the ability to register and log in using a third-party platform (like Gmail). Where you choose to do this, we will receive certain profile information about you from the platform which may often include your name, and email address.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your Personal Information by the third party. We recommend that you review their privacy policy to understand how they collect, use, and share your Personal Information, and how you can set your privacy preferences on their sites and apps.

Account Choices

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some Personal Information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

6. Is Any Personal Information Transferred Internationally?

Our Services are targeted to businesses in the United States and our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in the United States, and other countries which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region.

By sending us Personal Information, you agree and consent to the processing of your Personal Information in the United States, which may not offer an equivalent level of protection to that required in other countries (particularly the European Union), and to the processing of that information by us on servers located in the United States, as described in this Privacy Notice.

For transfers to or from the United Kingdom, we make use of the UK addendum. When we disclose Personal Information of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the standard contractual clauses, as well as additional safeguards where appropriate. The safeguards we may take in our discretion include, for instance, entering into specific agreements in connection with any onward transfers of Personal Information. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners.

7. How Long Do We Keep Your Personal Information?

We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this Privacy Notice will require us keeping your Personal Information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Personal Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. Do We Collect Personal Information From Minors?

We do not knowingly collect, target, or market to children under 18 years of age (children under the age of 16 in Europe). By using the Services, you represent that you are at least 18 (at least 16 in Europe) or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that Personal Information from users less than 18 years of age (less than 16 years of age in Europe) has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 (children under the age of 16 in Europe), please contact us at hello@639Cloud.com.

10. What Are Your Privacy Rights?

EEA, UK, and Switzerland Data Subject

Lawful Basis for Processing Personal Information

The legal basis for collecting and using the Personal Information described in this Privacy Notice will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you (for example when you purchase our products), or where the processing is in our legitimate interests and in some cases, we may also have a legal obligation to collect Personal Information from you. For example, we sometimes process your Personal Information to pursue our legitimate interests in running our business, including for delivering our products and/or service, protecting you from fraud, quality assurance, and marketing purposes. However, we also ensure that our legitimate use of your data does not materially infringe your rights, freedoms, or interests when compared to the processing.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

EEA, UK, and Switzerland Data Subject Rights

As a resident of the EEA, UK, and Switzerland, you may have certain rights under the General Data Protection Regulation (“GDPR”). These may include:

Right to be informed. You may have a right to be informed about what Personal Information we collect from you and how it is used, as well as our purposes for processing your Personal Information, how long we retain your data, and who we share it with. This Privacy Notice lays out that information in general; please contact us for details specific to you.

Right of access. You may have the right to know what data has been collected about you and how such data has been processed. If you would like to know exactly what information we have collected about you and how it has been used, please contact us.

Right of rectification. You may have a right to correct any incorrect or incomplete information we have about you. To request a correction, please contact us.

Right to erasure. In certain circumstances, you may have the right to request that we delete your Personal Information.

Right to restrict processing. In certain circumstances, you may have the right to restrict the processing of your Personal Information.

Right to data portability. If our lawful basis for processing your Personal Information is consent or performance of a contract, you may have the right to receive Personal Information we have collected from you in an accessible format. You may also have the right to have the Personal Information we have collected from you transferred to another controller.

Right to object. You may have the right to object to the processing of your Personal Information for direct marketing purposes.

Rights related to automated decision-making including profiling. You may have the right to not be subject to a decision based solely on an automated process (no human involvement) by solely automated processes. We will not make these types of decisions by solely automated processes. If you believe that an automated decision-making process was applied to you, please contact us.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your Personal Information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How Can You Contact Us About This Privacy Notice?” below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at hello@639Cloud.com.

11. Do-Not-Track and the Global Privacy Control Signal

At this stage, no uniform technology standard for recognizing and implementing Do-Not-Track signals has been finalized. As such, we do not currently respond to Do-Not-Track browser signals or any other mechanism that automatically communicates your choice not to be tracked online. We honor the global privacy control signal.

12. Do United States Residents Have Specific Privacy Rights?

Your Rights

Depending on your location, you may have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights may include:

• Right to know whether or not we are processing your Personal Information
• Right to access your Personal Information
• Right to correct inaccuracies in your Personal Information
• Right to request the deletion of your Personal Information
• Right to obtain a copy of the Personal Information you previously shared with us
• Right to opt out of the processing of your Personal Information if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of Personal Information, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

How to Exercise Your Rights

To exercise these rights, you can contact us by visiting http://www.639Cloud.com, by emailing us at hello@639Cloud.com.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

We will not discriminate against you in a manner prohibited by the applicable state laws because you exercise your privacy rights. While you may request to delete your Personal Information, such deletions may affect our ability to offer the Services to you.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “How Can You Contact Us About This Privacy Notice?”

13. Do Other Regions Have Specific Privacy Rights?

Australia and New Zealand

We collect and process your Personal Information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what Personal Information we collect from you, from which sources, for which purposes, and other recipients of your Personal Information.

If you do not wish to provide the Personal Information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• offer you the products or services that you want
• respond to or help with your requests
• manage your account with us
• confirm your identity and protect your account

At any time, you have the right to request access to or correction of your Personal Information. You can make such a request by contacting us by using the contact details provided in the section “How Can You Contact Us About This Privacy Notice?”

If you believe we are unlawfully processing your Personal Information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your Personal Information. You can make such a request by contacting us by using the contact details provided in the section “How Can You Contact Us About This Privacy Notice?”

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of Personal Information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

14. Marketing Emails

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “How Can You Contact Us About This Privacy Notice?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

15. Social Media Links

Our Services may contain links to other websites. These websites may have privacy policies different from our Privacy Policy. The Services may also contain certain social media icons or widgets, such as Instagram, Facebook, LinkedIn, and Twitter (X). Although you can view the material we have linked to, you may have to create an individual account or register to use these third-party social media sites to use interactive features. Any interaction on social media or other third-party websites is governed not by this Privacy Notice but by the terms of use and privacy policy of the particular platform.

16. Do We Make Updates To This Privacy Notice?

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Last Updated” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

17. How Can You Contact Us About This Privacy Notice?

If you have questions or comments about this Privacy Notice, you may email us at hello@639Cloud.com or contact us by post at:

639 DC Main LLC (dba 639 Cloud)

1712 Pioneer Ave, Cheyenne, WY 82001, USA

Suite 500

Cheyenne, WY 82001

United States

If you need to access this Privacy Notice in an alternative format due to a disability, please contact us at hello@639Cloud.com.