1. INTRODUCTION

At CloudLabs, we respect your privacy. Therefore, the personal information we collect while doing our activities is processed under the laws of the United States of America, in accordance with the General Data Protection Regulation of the European Union (GDPR), ensuring high levels of protection. In addition, given that CloudLabs products are intended for the use of both teachers and students, including those in the K-12 age group, we abide by the rules protecting children’s data, particularly the Children’s Online Privacy Protection Act (or COPPA) and the Family Educational Rights and Privacy Act (or FERPA).

Therefore, we have developed this Privacy Policy to inform you about the data we collect, how we use them, and your rights regarding your personal data.

If you are under 18, we suggest you review this Policy with your parents’ assistance.

2. WHO ARE WE?

We are CloudLabs LLC, a company duly incorporated under the laws of Florida in the United States of America, and we are responsible for the processing of your data.

3. PERSONAL DATA PROCESSING PRINCIPLES

Your privacy is important to us. Therefore, we want you to know what principles we apply in processing your personal data.

• Lawfulness, transparency, and fairness: we treat your data in a legal, fair, and transparent way.
• Purpose limitation: Your data is collected for specific, explicit, and legitimate purposes. We undertake not to process your data in a way that is incompatible with these purposes.
• Data minimization: we only process the data that is required for each of the purposes for which it is intended.
• Accuracy: We ensure that your data is always up-to-date and that erroneous information is erased or modified.
• Storage limitation: We only keep your data for as long as is required to achieve the purposes for which it is processed.
• Security outcomes: We analyze the risks related to the data we process in order to establish measures to ensure the availability and confidentiality of the data.

4. DATA REQUESTED

4.1 THE DATA WE PROCESS

We only collect and process the personal data we need according to the applicable law and the type of relationship that binds us. Some of the information that we request from you and that you voluntarily supply to us may include the following:

However, depending on the relationship that binds us, we may request additional information.

4.2  LEGAL BASIS FOR PROCESSING DATA

We will not process your data without a legal justification for doing so. Therefore, depending on the type of relationship that binds us, we will process your data based on the following information:

Whatever the legal basis for processing your data, we will inform you at the time the data is requested.

5. WHAT DO WE USE YOUR DATA FOR?

We don’t sell, rent or trade your personal data

We process your data according with the purposes that best suit the relationship that bind us,  as follows:

5.1 IF YOU ARE A CURRENT USER

If you are a user of CloudLabs products, we will use your data, among other things, to:

• Make our products available to you.
• Process your requests, questions, concerns and complaints.
• Perform statistical analysis.
• Obtain your feedback on our products, websites, mobile applications and other services.
• Control the license that allows you to use our products.

The purposes for which we will use your data will be communicated to you at the time we request the information.

5.2 IF YOU ARE A CLIENT

If you are a customer of CloudLabs products, but you are not the end-user, such as publishers, educational institutions, and those who purchase our products through our online store, we will use your data to:

• Process your orders.
• Process your payments.
• Personalize your shopping experience.
• Communicate with you to provide you with information about our products.
• Provide you with advertising and promotions.
• Process your requests, questions, complaints, and claims.
• To fulfill our contractual obligations.

The purposes for which we will use your information will be communicated to you at the time we request the information.

5.3 IF YOU ARE A SUPPLIER OR CONTRACTOR.

If you are a supplier or contractor, we will use your information to:

• Comply with our legal obligations.
• Comply with out contractual obligations

5.4 IF YOU ARE AN EMPLOYEE OR A CANDIDATE

If you are our employee or candidate, we will use your data to:

• Comply with our legal obligations.
• Comply with our contractual obligations such as sending notices.
• To carry out the selection and recruitment process.

6. HOW LONG DO WE KEEP YOUR DATA?

We keep your data for the minimum time necessary for the purposes for which they were collected. At the time we request your data, we will inform you how long we will retain your information as this depends on the purposes for which the data is requested and the need for retention in accordance with applicable laws.

7. WHO DO WE SHARE YOUR DATA WITH?

We only share your personal data in order to provide, maintain, and enhance our products and services, as well as to comply with legal obligations.

Therefore, we share your personal data with third parties when:

• We are required to do so by law or by a public authority.
• We must establish, exercise, or defend our rights.
• Third-party services are required to complete processes required for the operation of our products, website, and applications. For example, we share your personal data with service providers that host data from our Platform in the cloud. In this instance, we ensure that your data is processed on our behalf and according to our instructions, preventing your data from being used for any other purpose.
• There is room for a business transfer such as an eventual sale, merger or acquisition.

In addition, it is important for you to know that Cloudlabs is part of a multinational group of companies, made up of several companies, so we share your personal information with the companies in our group to provide, maintain, and improve our products and services. However, we guarantee that the companies in our group that have access to your data will respect the provisions of this Privacy Policy.

8. KNOW YOUR DATA PRIVACY RIGHTS

Below, we present the rights you have over your data. To exercise them, you must make a request directly or through your legal representative, by means of our contact channels. Please note that in order to process your request, we may ask you for information to confirm your identity and we will provide you with a response within the term indicated by applicable law.

8.1 RIGHT TO BE INFORMED

You have the right to receive information about your personal data. This includes the following:

• The identity of who is processing your data.
• The reason why we process your data and why we do it.
• The legal basis for processing your data.
• The length of time we will keep your data.
• The information available about how we obtained your data.
• The rights you have over your data.
• Who receives your data (if applicable).
• If available, the contact details of the data protection officer.
• The steps taken in the transfer of your data to a third country or international organization.
• The logic applied to the processing when it is carried out with the help of automated electronic means, as well as the significance and repercussions that such processing has for you.

8.2 RIGHT TO ACCESS

You have the right to access the personal data we hold about you. This right also allows you to confirm whether or not we are processing your data and to access a copy of it.

8.3 RIGHT TO RECTIFICATION

You have the right to ask us to correct your data if it is inaccurate, incomplete, or outdated.

8.4 RIGHT TO OBJECT

You have the right to object to the processing of your data when:

• They are processed on the basis of public interest or legitimate interest.

In this case, we will stop processing your data unless our legitimate interests prevent us from doing so, or the processing is required for the formulation, exercise, or defense of claims.

• They are processed for direct marketing purposes, including profiling.

8.5 RIGHT TO ERASURE

This right, also known as the “right to be forgotten”, obliges us to delete your personal data upon your request and in the following events:

• If your personal data is no longer necessary for the purposes for which it was collected.
• If the processing of your personal data is based on the authorization you gave us and you decide to withdraw it, as long as there is no other reason that legitimates us to continue processing your data.
• If you have exercised your right of opposition in accordance with the provisions of this policy,
• If your personal data has been unlawfully processed.
• If your personal data must be deleted in order to comply with a legal obligation.

This right is not unlimited. We may continue to process your data when it is necessary to:

• Exercising the right to freedom of expression and information.
• Compliance with a legal obligation.
• Reasons of public interest.
• The formulation, exercise, or defense of claims.

8.6 RIGHT TO RESTRICT PROCESSING

You have the right to limit the processing of your data by requesting the suspension  of the processing or the conservation of your data, as follows:

Suspension

• When you contest the accuracy of your personal data, for a period of time that allows the data controller to verify it.
• When you have objected to our processing of your data on the basis of a legitimate interest, while we verify whether these interests prevail over yours.

Retention / Conservación

• When the processing is unlawful and you have objected to its deletion.
• When we no longer need your personal data for the purposes of processing, but you need them for the formulation, exercise or defense of claims.

8.7 RIGHT TO DATA PORTABILITY

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format. You may also ask for your data to be transferred directly to another data controller, where technically possible.

You can exercise this right when:

• The processing of your data is based on your consent or a contract.
• The processing is carried out by automated means.

8.8 RIGHT NOT TO BE SUBJECTED TO AUTOMATED DECISION-MAKING

You have the right not to be subject to a decision based solely on automated processing of your data, including profiling, that has legal effects concerning you or has a comparably significant impact.

This right does not apply when:

• it is required to conclude or perform a contract with us.
• Your consent to the automated processing of your data was previously stated.

9. CONFIDENTIALITY, INTEGRITY AND AVAILABILITY

We are committed to the security and confidentiality of your personal data. To this end, we implement technical and organizational measures to protect your personal information from accidental or unlawful destruction, loss, alteration, and disclosure, as well as from unauthorized access. Some of these measures include:

• Ensuring that our employees and contractors comply with this Policy.
• Ensure that our service providers adopt adequate security measures compatible with this policy.
• Limit access to our facilities to those authorized to do so.
• Train employees who have access to the personal data we process to be in compliance with this policy.
• Implement access controls to our computer systems.
• Use appropriate procedures and technical measures to safeguard information on our computer systems, networks, websites and applications.
• Ensure that, when one of our group companies processes personal data on our behalf, it does so only on our instructions and that such company adheres to this Policy.

10. WHAT HAPPENS IF OUR COMPANY CHANGES HANDS?

We may expand or reduce our business in connection with a sale, merger, and/or transfer of control of all or part of our business.

Any personal data you have provided, where relevant to the business being transferred, will be transferred with that part of the business and the new owner or controller will be able to use your data. In these cases, we will make our best efforts, from a commercial point of view, to ensure that your data is only used for the purposes for which it was originally collected while maintaining the security, integrity, and privacy of the information on terms comparable to those set out in this policy.

11. CHILDREN PRIVACY POLICY

If you are under 16 years of age, note that your data is treated in a special manner under the Children’s Online Privacy Protection Act (COPPA), so the following special rules apply to the extent they are more favorable to you and to the protection of your data:

If you are under 16 years of age, note that your data is treated differently under the Children’s Online Privacy Protection Act (COPPA). Therefore, the following special rules apply to the degree they are more beneficial to you and your data’s protection:

11.1  THE DATA WE PROCESS, HOW WE COLLECT THEM, WHAT WE COLLECT THEM FOR, AND HOW LONG WE KEEP THEM.

Most of our products are aimed at elementary, middle, and high school students, which normally includes children under the age of 16. Therefore, if you are a user under the age of 16, you should know what information we request from you and what we do with it, bearing in mind that we only collect the information that is strictly necessary for you to access and use our products, and that we always request prior consent from your parents or legal representatives.

We keep your data for the duration of the license that allows you to access them and for three more years, in order to meet any formulation, exercise or defense of claims.

11.2 PUBLIC AVAILABILITY OF DATA AND COLLECTION OF PARTY DATA

Children under the age of 16 may not make their information publicly available on our website or our products.

In addition, we do not allow third parties to use our website, applications or products to collect information from children under the age of 16 who use them.

11.3  RIGHTS OF PARENTS OR LEGAL REPRESENTATIVES

If you are a parent or legal guardian of a minor (as deemed by applicable law), you have the following special rights:

• Review the child’s personal information.
• Request erasure of your child’s data and refuse to allow collection or use of your child’s data. Please note that, in order to comply with these requests, you may need to authorize us to terminate the license that allows the child to use our products.
• Agree to the collection and use of your child’s data to the exclusion of disclosure to third parties, except where this is necessary to fulfill our contractual obligations.

Any request related to these rights must be addressed through our contact channels and will be answered within the term indicated by the applicable law.

12.  COOKIE POLICY

You can access our Cookies Policy here: https://cloudlabs.us/es/politica-de-cookies/

13. UPDATES TO THIS PRIVACY POLICY

We may modify or update our Privacy Policy, for example, to comply with new legal requirements. We will notify you when this occurs.

14. HOW TO CONTACT US?

If you wish to exercise any of your rights regarding your data or have any questions or complaints about this policy or the way in which we treat your personal data, please contact us through the following means:

info@cloudlabs.us -dmacias@cloudlabs.us

3651 FAU Boulevard, Suite 400, Boca Raton, FL, 33431

Thanks for reading our private policy.