DivvyCloud Privacy Statement

Effective date: January 27, 2020

We at DivvyCloud (Divvy Cloud Corporation and our affiliates) are committed to protecting your privacy.  This Privacy Policy applies to all of our websites (Websites), including www.divvycloud.com,   www.cloudsummitdc.com, and any other website owned and controlled by DivvyCloud. This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. By using the Websites, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not access the Websites.

This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website or online service operated by us (including any affiliates or subsidiaries) or any third party.  This Privacy Policy is part of and incorporated into our Terms of Use. As described below, this Privacy Policy may be updated or revised from time-to-time in our sole discretion.         

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@divvycloud.com or by mail to DivvyCloud 2111 Wilson Blvd suite 300, Arlington, VA 22201, USA, Attn: Privacy.

What information DivvyCloud collects and why

Information we collect automatically from website visitors. If you’re just browsing the Websites, we collect the same basic information that most websites collect. We use common internet technologies, such as cookies and web server logs. This is information we collect from everybody.  The information we collect automatically about all visitors to the Websites includes the visitor’s IP address, browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. 

Information we collect from visitors who request information.  If you request information or services, we may require the submission of certain personal information at the time of request. We may require you to provide first and last name, corporate title, company name, a valid email address, phone number, or other information. You may also have the option to give us more information if you want to. The personal information we require or request may include “Visitor Personal Information.”  For example, you will need to provide some basic personal information to request a trial license.  

“Visitor Personal Information” is any information about one of our visitors which could, alone or together with other information, personally identify him or her. Information such as name, email address, and phone number are examples of “Visitor Personal Information.”

Visitor Personal Information does not include aggregated, non-personally identifying information. We reserve the right to use aggregated, non-personally identifying information to operate, improve, and optimize our Websites and services.

What information DivvyCloud does not collect

We do not intentionally collect sensitive personal information, such as social security numbers, credit card or other financial information, health information, or religious information. If you believe that you have inadvertently submitted sensitive personal information about you to us, please contact us at privacy@divvycloud.com, so that we may delete the information.

The Websites are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at privacy@divvycloud.com, so that we may delete the information.

How we use and share the information we collect

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Visitor Personal Information to:

  • improve your browsing experience by personalizing the Websites;
  • perform user identification if necessary;
  • enable sales, marketing, and business transactions;
  • send product information to you which we think may be of interest to you by post, email, or other means;
  • send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you; and
  • provide other companies with statistical information about our users — but this information will not be used to identify any individual user.

We may share Visitor Personal Information with trusted partners to contact you based on your request to receive such communications, so we can perform services you have requested, to help us perform statistical analysis, or to provide customer support.  Visitors can opt out of receiving marketing or promotional messages from us at any time and at no cost.   To do so, see the section below, “Opt Out and Unsubscribing.”

We may share Visitor Personal Information with a limited number of third-party service providers who process it on our behalf to provide or improve our service.  These service providers perform services on our behalf such as marketing, advertising, payment processing, customer support ticketing, network data transmission, and other similar services.  These service providers are contractually required to implement appropriate security measures.

We may share Visitor Personal Information if we are involved in a merger, sale, or acquisition.

We may occasionally embed content from third party sites, such as YouTube, and that content may include ads. While we try to minimize the amount of ads our embedded content contains, we cannot always control what third parties may show.

We do not sell, rent, or trade Visitor Personal Information with third parties for their commercial purposes.

We reserve the right to share certain aggregated, non-personally identifying information with others about how our users, collectively and anonymously, access and use the Websites, or how our users respond to our other offerings, such as our conferences or events.  However, we do not sell this information to advertisers or marketers.

Our use of cookies and tracking

Cookies

DivvyCloud uses cookies to make interactions with our service easy and meaningful. We may use cookies (and similar technologies, like HTML5 localStorage) to keep you logged in, remember your preferences, provide personalized experiences, and provide information that enables sales, marketing, and business transactions.

A cookie is a small piece of text that our web server stores on your computer or mobile device, which your browser sends to us when you return to our site. Cookies do not necessarily identify you if you are merely visiting DivvyCloud; however, a cookie may store a unique identifier for each identified visitor. The cookies DivvyCloud sets are essential for the operation of the website or are used for performance or functionality.  By using our Websites, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept cookies, you may not be able to use DivvyCloud’s Websites.

Certain pages on our site may set other third party cookies. For example, we may embed content, such as videos, from another site that sets a cookie. While we try to minimize these third party cookies, we can’t always control what cookies this third party content sets.

We use the following types of cookies on the Websites:

  • “Required” or “Essential” cookies are necessary for the operation of the Websites.
  • “Functional” cookies enable the Websites to remember information a user has provided and personalize functionality.
  • “Analytics” cookies collect and analyze how the Websites are used, typically on an aggregate and anonymous basis.
  • “Advertising” cookies are used by us or third parties to place or recognize a unique cookie on your browser when you visit our Websites for the purpose of serving you targeted advertising, including on other websites.  To learn more about targeted advertising and advertising networks and about your ability to opt out of collection by certain third parties, please visit the opt-out pages of the Network Advertising Initiative (here), or the Digital Advertising Alliance (here).  Please note that opting out of cookies does not mean that you will not be served ads; you will continue to receive generic ads.

You have the ability to accept or decline most cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Depending on the type of browser being used, it may be able to alert users of the presence of cookies.  However, if you choose to decline cookies, you may not be able to fully experience the interactive features of the Site.  If you wish to find out more about cookies, or how to refuse cookies for your browser, please visit the Interactive Advertising Bureau’s web site at http://www.allaboutcookies.org/manage-cookies/.   

Clear Gifs (Web Beacons/Web Bugs)

We may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage the Websites by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users.  In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages or in emails. We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients.  This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. We tie the information gathered by clear gifs in emails to our customers’ Visitors Personal Information. If you would like to opt-out of these emails, please see “Opting Out and Unsubscribing”.

Google Analytics

We use Google Analytics, and other similar vendors, as third party tracking services. For example, we use Google Analytics to collect information about how our Websites perform and how our users, in general, navigate through and use the Websites.  Google provides further information about its own privacy practices and offers a browser add-on to opt out of Google Analytics tracking.

Social Media Features

Our Websites may include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features.  Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites

Our Websites may provide links to websites owned or controlled by others. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.  It is recommended that you review these other websites’ privacy and other relevant policies before providing any personal information. 

Retention of Visitor Personal Information

We will only retain Visitor Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

International Transfer of Information

We are located in the United States.  Information that we collect will be stored and processed in the United States in accordance with this Privacy Statement. To facilitate our global operations, we may transfer and access Visitor Personal Information from around the world, including to the United States. This Privacy Policy shall apply even if we transfer Visitor Personal Information to other countries.  By accessing the Websites or providing us with any Visitor Personal Information, you consent to this transfer, processing, and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside.  You also understand that the US Government may be able to obtain access to the Visitor Personal Information for national security purposes.  

Compelled Disclosure

We reserve the right to use or disclose your Visitor Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

Opting Out and Unsubscribing

Upon request DivvyCloud will provide you with information about whether we hold any of your Visitor Personal Information. If you have provided us with your Visitor Personal Information, you have the following rights with respect to that information:

  • To review the Visitor Personal Information that you have supplied to us
  • To request that we correct any errors, outdated information, or omissions in user information that you have supplied to us
  • To request that your Visitor Personal Information not be used to contact you
  • To request that your Visitor Personal Information be removed from any solicitation list that we use
  • To request that your Visitor Personal Information be deleted from our records
  • To opt out of being solicited by DivvyCloud or third parties

To exercise any of these rights, please contact us at privacy@divvycloud.com or by mail to2111 Wilson Blvd suite 300, Arlington, VA 22201, USA, Attn: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

You may unsubscribe from our marketing communications by clicking on the “Unsubscribe” link located on the bottom of our emails, or by sending us email us at privacy@divvycloud.com, or by sending us postal mail to 2111 Wilson Blvd suite 300, Arlington, VA 22201, USA, Attn: Privacy.  There is no cost to exercise these rights or unsubscribe.  

Legal Basis

Our legal basis for collecting and using your personal information is (i) to do so with your consent; (ii) where we need the personal information for performance of a contract or requested service, or (iii) where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collect your personal information with your consent, you may withdraw your consent at any time. You understand and agree that we may collect, use, disclose, and otherwise process the personal information you provide even if you are located outside the United States.  

Residents of the EEA and Switzerland

For residents of the European Economic Area (EEA) and Switzerland, we advise that your personal information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective.  The United States has not sought or received a finding of “adequacy” from the European Union under Article 45 of the General Data Protection Regulation (“GDPR”).  Our legal basis for collecting and using your personal information is to do so with your consent; where we need the personal information for performance of a contract or requested service, or where the collection and use is in our or another’s legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collected your personal information with your consent, you may withdraw your consent at any time and at no cost.

Residents of the EEA and Switzerland have the right to:

  • Access your personal information;
  • Delete, or request deletion of, your personal information;
  • Object to or restrict processing of your personal information; 
  • Request portability of your personal information;
  • Complain to your local data protection authority at any time;
  • Object to automated decision making; and
  • Update your personal Data.

Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If we ask you to provide personal information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your personal information is required and if not, the consequences of not sharing your personal data with us.  

Similarly, if we collect and use your personal information in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.  

We endeavor to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.  

To withdraw consent or exercise these rights, please:

  • Contact us via email at privacy@divvycloud.com; or 
  • Adjust your preferences through the Account preferences (if available).

California Residents 

Pursuant to California’s “Shine The Light law (California Statute § 1798.983), California residents are entitled to request, once a year and free of charge, certain information regarding what types of their personal information may be shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business is to either provide California customers certain information upon request or permit California customers to opt out of this type of sharing.  Note, however, that we do not sell, rent, lease or otherwise make available Visitor Personal Information to third parties for their marketing purposes, unless giving you a choice before disclosing to third parties.  

You may request this information by contacting us at privacy@divvycloud.com and indicate in the email subject line, “California Shine The Light Request.”  Please include your mailing address, state of residence and email address with your request. 

For California residents under the age of 18 and registered users of the Websites, California law (Business and Professionals Code § 22581) provides that you can request the removal of content or information you posted on Website.  Any such request should be sent to us at privacy@divvycloud.com along with a description of the posted content or other information to be removed.  Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.  

For purposes of the California Consumer Privacy Act (CCPA), Divvycloud does not “sell,” as defined in the CCPA, the Visitor Personal Information of California consumers.  While Divvycloud is not a covered business under the CCPA, we nonetheless will honor requests from California consumers to know what categories Visitor Personal Information we may have collected about them and to what categories of third parties the personal information was disclosed for the preceding 12 months, or to delete their personal information from our systems and records.  To submit either a “Request to Know” or “Request to Delete”, please email as us:  privacy@divvycloud.com.  Please indicate in the subject line of your email either “Request to Know” or “Request to Delete.”  To verify your request and to help us search our systems and records, we will need certain personal information from you: name, email address and/or telephone number.

Do Not Track

We currently do not honor browser-based Do-Not-Track signals.

Data Security

We have implemented commercially reasonable and appropriate technical and organizational security measures to help protect your Visitor Personal Information from accidental or unlawful destruction, loss, alteration, misuse, or unauthorized access or disclosure; unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Visitor Personal Information, we cannot guarantee its security. You use the Services and provide us with information at your own initiative and risk. 

Changes to this Privacy Policy

The Effective Date of the current version of the Privacy Policy is provided above.  DivvyCloud reserves the right to modify this Privacy Policy from time-to-time in our sole discretion and without notice.  You are advised to review this Privacy Policy periodically for any changes, which will be noted by an updated Effective Date.  Your continued access of the Websites after any modification indicates your agreement to the new or revised terms and conditions in this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy@divvycloud.com or postal mail at:

Divvycloud

2111 Wilson Blvd Suite 300

Arlington, VA 22201

 USA