This Privacy Policy (the “Policy”) addresses personal information collected and processed by CloudPay Inc. (“CloudPay”) and its US subsidiary CloudPay Solutions Inc at www.cloudpay.net (the “Website”) and via our Global Payroll Managed Services solution (the “Payroll Solution”).

 

PERSONAL INFORMATION CLOUDPAY PROCESS

 

WEBSITE VISITORS

CloudPay collects personal information about a visitor to our website when you voluntarily supply us with this information and through Cookies.

For voluntarily collected information, on certain pages you may choose to provide CloudPay with your name, e-mail address, telephone number or other information, to request details about CloudPay, including information about CloudPay’s Payroll Solution. This information enables CloudPay to follow up with you after your visit. If you have voluntarily provided this information, you have consented to the collection and use of your personal information as described in the Policy.

For information collected via Cookies, CloudPay is using technology that many other websites employ, small data files stored on your computer’s hard drive, to collect information (“Cookies”). If your browser is set to accept Cookies, then your browser adds the text in a small file. CloudPay does not use Cookies to read any other information on your computer’s hard drive. CloudPay uses Cookie technology to authenticate your access to various areas of our websites, and tailor its content to your preferences. Cookies help us analyze web traffic in general. You can set your browser to refuse cookies, or to warn you before a cookie is placed.

You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookies. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will issue Cookies when you log on to our Website. Please note that any third-party sites which are linked via our web site may also use Cookies, over which CloudPay has no control.

CloudPay also uses web beacons, or transparent GIF files, provided by our service provider to report activity on our site. The beacons help us manage our online advertising and measure its effectiveness. These files enable our service provider to recognize a Cookie on your web browser, which in turn enables us to learn which communications are most effective. Either CloudPay or our services providers place the Cookie. The information that CloudPay collects by means of these technologies is anonymous and is not personally identifiable unless you have chosen to identify yourself through a form on the website.

PAYROLL SOLUTION USERS

In the normal course of using the Payroll Solution, our customers and their users may enter personal information into the Payroll Solution. Personal information is generally limited to an individual’s business contact information, and payroll information with respect to customer employees. By submitting personal information into the Payroll Solution, you consent to CloudPay’s processing, storage and use of this information in accordance with this Policy. 

 

USE AND DISCLOSURE OF PERSONAL INFORMATION

 

CloudPay treats personal information as confidential and CloudPay may only access personal information provided by you to provide the Payroll Solution to you, and enhance your use of the Payroll Solution and the Website.

CloudPay does not sell any personal information to any third parties. CloudPay may not share any personal information with third parties unless: (i) authorized by you in writing, (ii) with business partners authorized by CloudPay to perform payroll related services for you on CloudPay’s behalf and for the purposes described in this Policy, and only when confidentiality agreements are in place, or (iii) compelled to do so by a governmental authority, regulatory body, or under subpoena or similar governmental request, including to meet national security or law enforcement requirements, or to establish or defend a legal claim, subject to the applicable confidentiality agreement in place with you. CloudPay may use and share information that is in a de-identified form that does not allow an individual or customer to be identified, primarily to enhance your use of the Payroll Solution and for benchmarking purposes.

 

ACCESS

 

WEBSITE VISITORS

If at any time after registering to receive information, you change your mind about receiving information from CloudPay, please click on the unsubscribe link in the communication. CloudPay acknowledges the individual’s right to access their personal data. If you wish to contact CloudPay directly to access to the personal information that CloudPay holds about you, you may email your request to CloudPay at: legal@cloudpay.net. CloudPay will provide you with the information you have sought by email, or if possible, in another form that you have requested. CloudPay may need to verify your identity or to take other steps to respond to your request. If CloudPay decides to deny you access to some or all of your personal information, CloudPay will notify you in writing of our decision and explain why and how you can complain if you are not satisfied with our decision.

PAYROLL SOLUTION USERS

In accordance with our acknowledgement regarding your right to access your personal data, if you are an employee of a customer and you seek access, or seek to correct, amend, or delete inaccurate data, you may direct your request to your employer, as our customers generally have administrative rights to make these changes. If our customer, or any employee thereof requests CloudPay to remove any personal information to comply with data protection regulations, CloudPay will respond to the request within thirty (30) business days. If you wish to contact CloudPay directly to access to the personal information that CloudPay holds about you, you may email your request to CloudPay at: legal@cloudpay.net. CloudPay will provide you with the information you have sought by email, or if possible, in another form that you have requested. CloudPay may need to verify your identity or to take other steps to respond to your request. If CloudPay decides to deny you access to some or all of your personal information, CloudPay will notify you in writing of our decision and explain why and how you can complain if you are not satisfied with our decision.

Our site may, from time to time, contain links to and from the websites of our partner networks, suppliers, business associates, clients, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that CloudPay does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

 

USES MADE OF THE INFORMATION

 

CloudPay uses information CloudPay possess to: (i) ensure that content from our site is presented in the most effective manner for you and for your computer, (ii) provide you with information, products or services that you request from us or which CloudPay feels may interest you, where you have consented to be contacted for such purposes, (iii) carry out our obligations arising from an agreement entered into between you and us, (iv) allow you to participate in interactive features of our service, when you choose to do so, and (v) to notify you about changes to our Payroll Solution.

 

CLOUDPAY EU-US PRIVACY SHIELD FRAMEWORK AND SWISS-US PRIVACY SHIELD FRAMEWORK PRIVACY STATEMENT

 

CloudPay complies with the applicable provisions of the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from the European Union and Switzerland to the United States, respectively. CloudPay has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view CloudPay’s certification, please visit: https://www.privacyshield.gov/

 

COMPLAINT HANDLING; DISPUTE RESOLUTION

 

In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, CloudPay commits to resolve complaints about your privacy and our collection or use of your personal information. Individuals with inquiries or complaints regarding this Privacy Policy should contact CloudPay at: legal@cloudpay.net.

CloudPay has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Additionally, in accordance with the EU-U.S. Privacy Shield, an individual may, under certain conditions, invoke last resort binding arbitration before a Privacy Shield Panel.

 

INVESTIGATIONS; ENFORCEMENT; LIABILITY

 

As a result of CloudPay’s adherence to the EU-U.S. and Swiss-U.S. Privacy Shield Principles, CloudPay is subject to the investigatory and enforcement powers of the Federal Trade Commission. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US and Swiss-U.S. Privacy Shield Principles, CloudPay is potentially liable.

 

CHANGES TO THIS PRIVACY POLICY

 

This Privacy Policy is effective and current as of May 22, 2017. CloudPay reserves the right to change, update, modify, add or remove any part of this Policy from time to time and in our sole discretion to reflect changes to technology, our legal obligations and information handling practices. CloudPay will alert you to any changes by indicating on this Policy the date it was last updated. When you visit the site, you are accepting the current version of this Policy as posted on the site at that time. CloudPay recommends that users revisit this Policy on occasion to learn of any changes.

 

SECURITY

 

CloudPay maintains a comprehensive, written information security program that contains industry standard, administrative, technical and physical safeguards designed to prevent unauthorized access to personal information. CloudPay limits access to personal information to those persons and authorized service providers who have a specific business purpose for maintaining and processing such information. CloudPay’s employees who have been granted physical access to personal information are made aware of their responsibilities to protect the confidentiality, integrity and availability of that information and are providing regular training and instruction on how to do so.

 

CONTACT

 

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Kingsgate House, Newbury Road, Andover, Hampshire, SP10 4DU, United Kingdom Attn: General Counsel or legal@cloudpay.net.