Privacy Policy

1. Introduction

CloudSteer, Inc. ("Company" or "we") respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website cloudsteer.io (our "Website"), use our applications, APIs, platforms, or services (collectively, the "Services"), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website or Services.
• Through software applications provided by CloudSteer that you download or access.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or Services. By accessing or using our Website or Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Website or Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Children Under the Age of 13

Our Website and Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website or Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@cloudsteer.io.

3. Information We Collect About You

We collect several types of information from and about users of our Website and Services, including information:

• By which you may be personally identified, such as name, postal address, email address, telephone number, company name, job title, or any other identifier by which you may be contacted online or offline ("personal information").
• That is about you but individually does not identify you, such as non-identifying information.
• About your internet connection, the equipment you use to access our Website or Services, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through our Website or use our software tools. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From data imported into our tools and platforms.
• Through navigation and usage tracking within our Services.
• From third parties.

Information You Provide to Us

The information we collect on or through our Website and Services may include:

• Information that you provide by filling in forms on our Website or within our Services. This includes information provided at the time of registering to use our Website or Services, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website or Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website or Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website or Services.
• Your search queries on the Website or within the Services.
• Account metadata, user profiles, and other information associated with your use of the Services.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or Services or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website or Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website and Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website and use of our Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website or within the Services.
• Information about your computer, device, and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website and Services according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website or Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website or Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

4. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website or within the Services are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website or Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) targeted advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the Choices About How We Use and Disclose Your Information section below.

5. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and Services and their contents to you.
• To provide you with information, products, or services that you request from us.
• To provide you with notices about your account.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or Services or any products or services we offer or provide through them.
• To allow you to participate in interactive features on our Website or within our Services.
• To provide you with updates regarding our products and services.
• To solicit feedback from you regarding our products and services.
• To contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please send an email to privacy@cloudsteer.io to opt out.
• To display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

Automated Processing and AI

Our Services may use automated systems, machine learning, and artificial intelligence technologies to process data, improve functionality, and deliver enhanced user experiences. We implement appropriate safeguards to ensure that automated processing is conducted fairly and transparently, and in compliance with applicable laws and regulations. Where automated processing may significantly affect you, you have the right to request human review of such decisions.

6. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, cloud infrastructure providers, analytics providers, payment processors, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CloudSteer, Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CloudSteer, Inc. about our Website and Services users is among the assets transferred.
• To third parties to market their products or services to you if you have not opted out of these disclosures. You can opt out of receiving third-party marketing communications by sending an email to privacy@cloudsteer.io.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CloudSteer, Inc., our customers, or others.

7. Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

CloudSteer can remove your personal information upon your request. To request removal, please send an email to privacy@cloudsteer.io.

8. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website or Services may then be inaccessible or not function properly.
• Do Not Track Signals. We do not currently respond to Do Not Track ("DNT") signals. We will make reasonable efforts to respond to DNT signals if a uniform technology standard for recognizing and implementing DNT signals is established.
• Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending us an email stating your request to privacy@cloudsteer.io.
• Promotional Offers from the Company. If you do not wish to have your email address or other contact information used by the Company to promote our own or third parties' products or services, you can opt out by sending us an email stating your request to privacy@cloudsteer.io.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by sending us an email stating your request to privacy@cloudsteer.io. For this opt-out to function, you must have your browser set to accept all cookies. You may also visit the Network Advertising Initiative ("NAI") website at www.networkadvertising.org to opt out of targeted advertising from NAI member companies.

9. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website or Services and visiting your account profile page.

You may also send us an email at privacy@cloudsteer.io to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website or Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access and use of information provided on the Website or Services, including User Contributions, is governed by our Terms of Use.

10. California Privacy Rights

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 privacy@cloudsteer.io.

11. GDPR Compliance

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. CloudSteer, Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information. You have the following data protection rights:

• The right to be informed about the collection and use of your personal data.
• The right of access to your personal data.
• The right to rectification if your personal data is inaccurate or incomplete.
• The right to erasure (the "right to be forgotten") of your personal data.
• The right to restrict processing of your personal data.
• The right to object to processing of your personal data.
• The right to data portability to receive your personal data in a structured, commonly used, and machine-readable format.
• Rights in relation to automated decision making and profiling.

We aim to respond to all legitimate requests within one month. Occasionally, it may take longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. To exercise any of these rights, please contact us at privacy@cloudsteer.io.

Legal Basis for Processing

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal data. In most cases, the legal basis will be one of the following:

• Consent: You have given us consent to process your personal data for one or more specific purposes.
• Performance of a contract: Processing is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into a contract.
• Legal obligation: Processing is necessary for compliance with a legal obligation to which we are subject.
• Vital interests: Processing is necessary to protect the vital interests of you or another natural person.
• Public interest: Processing is necessary for the performance of a task carried out in the public interest.

International Data Transfers

Your personal data may be processed in the United States or other jurisdictions where our service providers maintain facilities. These countries may have data protection laws that are different from the laws of your country. We take appropriate safeguards to ensure that your personal data remains protected in accordance with this privacy policy and applicable law when transferred internationally.

12. Data Security

We have implemented administrative, technical, and organizational security measures designed to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or within the Services.

13. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

14. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@cloudsteer.io.