Protecting the individual's privacy on the Internet is crucial to the future of Internet-based business and the move toward a true Internet economy. We have created this Privacy Statement to demonstrate our firm commitment to the individual`s right to data protection and privacy. This Privacy Statement outlines how we handle information that can be used to directly or indirectly identify an individual ("Personal Data").
A. General Information
B. Processing based on a statutory permission
C. Processing based on consent
D. Cookies and similar tools
E. Country-Specific Provisions
A. General Information
Who is the Data Controller? The data controller of www.cirrocloudsolutions.com is Cirro Cloud Solutions AG, Morgartenstrasse 9 CH-6003 Lucerne – Switzerland (“Cirro”). Where a registration form is presented on this website, the data controller may vary depending on the actual offering or the purpose of the data collection, but it is in any case displayed on the individual registration form’s privacy statement. The Cirro Group’s data protection officer can be reached at firstname.lastname@example.org
What Personal Data does Cirro collect?
When you visit Cirro’s websites, Cirro stores certain information about your browser, the operating system, and your IP address.
If you use a registration form, Cirro will collect the information you provide to Cirro, which consists of your first and last name, email addresses, telephone numbers, location (country, state/province, Canton, city), company name, job title and role, department and function, current relationship to QPES, and your company’s industry. If you provide a credit card number or bank details to order goods or services from Cirro, then Cirro will collect this information to process your payment for the requested goods or services.
Why does Cirro need your Personal Data? Cirro requires your Personal Data to provide you with access to this site; to deliver any ordered goods or services; and to comply with statutory obligations, including checks required by applicable export laws. Further information on why Cirro needs your Personal Data can be found in Section B, below, if Cirro’s use of your Personal Data is based on a statutory permission. Further information on why Cirro needs your Personal Data can be found in Section C, below, if Cirro’s use of your Personal Data is based on your consent. If Cirro’s use of your Personal Data is based on consent, note that the information in this Privacy Statement on respective consent statements for certain types of Personal Data uses can also be found in the Consent Resource Center. As a general matter and although providing Personal Data is voluntary, Cirro may not be able to perform or satisfy your request without it; for example, Cirro might require your Personal Data to process an order you place, or to provide you with access to a web offering that you requested. In these cases, it is not possible for Cirro to satisfy your request without certain Personal Data.
Kindly note that you can order goods or services without providing a consent into Cirro’s further marketing operations.
From What Types of Third Parties does Cirro obtain Personal Data?
In most cases, Cirro collects Personal Data from you. Cirro might also obtain Personal Data from third parties, if the applicable national law allows Cirro to do so. Cirro will treat this Personal Data according to this Privacy Statement, plus any additional restrictions imposed by the third party that provided Cirro with it or the applicable national law. These third-party sources include:
Cirro and/or Cirro Group’s business dealings with your employer
Third parties you directed to share your Personal Data with Cirro
How long will Cirro store my Personal Data?
Cirro will only store your Personal Data for as long as it is required:
to make goods and services requested available to you, including use of Cirro.com;
for Cirro to comply with its statutory obligations resulting inter alia from applicable export laws;
until you object against such use by Cirro, if Cirro’s use of your Personal Data is based on Cirro’s legitimate business interest as further stated in this Privacy Statement;
until you revoke your consent granted in this Privacy Statement, if Cirro is processing your Personal Data based on your consent;
by applicable mandatory law to retain your Personal Data longer or where your Personal Data is required for Cirro to assert or defend against legal claims, Cirro will retain your Personal Data until the end of the relevant retention period or until the claims in question have been settled.
Who are the recipients of your Personal Data and where will it be processed? Your Personal Data will be passed on to the following categories of third parties to process your Personal Data:
companies within the Cirro Group
Third-party service providers; e.g., for the provision of the website or newsletter dispatch, for consulting services and other additional related services.
As part of a global group of companies operating internationally, Cirro has affiliates (the “Cirro Group”) and third-party service providers outside of the European Economic Area (the “EEA”) and will transfer your Personal Data to countries outside of the EEA. If these transfers are to a country for which the EU Commission has not issued an adequacy decision, Cirro uses the EU standard contractual clauses to contractually require that your Personal Data receives a level of data protection consistent with the EEA. You can obtain a copy (redacted to remove commercial or irrelevant information) of such standard contractual clauses by sending a request to email@example.com. You can also obtain more information from the European Commission on the international dimension of data protection here.
What are your data protection rights?
You can request from Cirro: access at any time to information about which Personal Data Cirro processes about you and the correction or deletion of such Personal Data. Please note, however, that Cirro can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Cirro to retain it. Kindly note further that if you request that Cirro deletes your Personal Data, you will not be able to continue to use any Cirro service that requires Cirro’s use of your Personal Data.
If Cirro uses your Personal Data based on your consent or to perform a contract with you, you can further request a copy of the Personal Data that you provided to Cirro. To do so, please contact the email address below and specify the information or processing activities to which your request relates, the format in which you would like to receive this information, and whether the Personal Data should be sent to you or another recipient. Cirro will carefully consider your request and discuss with you how it can best fulfill it.
Furthermore, you can request from Cirro that Cirro restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data Cirro has about you is incorrect, subject to the time Cirro requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for Cirro processing your Personal Data and you demand that Cirro restricts your Personal Data from further processing, (iii) Cirro no longer requires your Personal Data but you state that you require Cirro to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by Cirro based on Cirro’s legitimate interest (as further set out below under Section C.), subject to the time required for Cirro to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.
Please note, however, that Cirro can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Cirro to retain it. Kindly note further that if you request that Cirro deletes your Personal Data, you will not be able to continue to use any Cirro service that requires Cirro’s use of your Personal Data.
How will Cirro verify requests to exercise data protection rights?
Cirro will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection right you want to exercise. When feasible, Cirro will match Personal Data provided by you in submitting a request to exercise your rights with information already maintained by Cirro. This could include matching two or more data points you provide when you submit a request with two or more data points that are already maintained by Cirro.
Cirro will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.
Right to lodge a complaint. If you take the view that Cirro is not processing your Personal Data in accordance with the requirements in this Privacy Statement or under applicable EEA data protection laws, you can at any time lodge a complaint with the data protection authority of the EEA country where you live or with the data protection authority of the country or state where Cirro has its registered seat.
Can I use Cirro’s goods and services if I am a minor or child?
Children. Cirro websites and online services are not directed to users below the age of 16 years, or equivalent minimum age in the relevant jurisdiction. If you are younger than 16, you cannot register with and use this websites or online services.
Why does Cirro need to use my Personal Data and on what legal basis is Cirro using it?
Processing to fulfill contractual obligations. Cirro requires your Personal Data to deliver goods or services you order under a contract Cirro has with you, to establish a contract for goods or services between you and Cirro, or to send you invoices for ordered goods or services. Cirroprocesses Personal Data to fulfill contractual obligations pursuant to Article 6(1), lit. b GDPR or under the equivalent article under other national laws, when applicable.
Processing when necessary to fulfill Cirro’s contractual obligation includes responding to your related inquiries, processing your feedback or providing you with support. This can also include conversation data that you may initiate or enable such as through the chat functionalities on Cirro.com or other local Cirro web presences, through contact forms, emails, or by telephone. In this Privacy Statement, “goods and services” includes access to Cirro’s web services, offerings, contests, sweepstakes, other content, non-marketing related newsletters, whitepapers, tutorials, trainings and events.
Furthermore, Cirro communicates on a regular basis by email with users who subscribe to its services and will also communicate by phone to resolve your or other customer complaints or to investigate suspicious transactions.
Cirro will use your email address to confirm your opening of an account, to send you notice of payments, to send you information about changes to its products and services, and to send notices and other disclosures as required by law. Generally, users cannot opt out of these communications because these communications are required for the relevant business relationship and not marketing-related in nature.
For marketing-related communications such as emails and phone calls, Cirro will (i) only provide you with such information after you have opted in, if legally required, and (ii) provide you the opportunity to opt out if you do not want to receive further marketing-related communications. You can also opt out of marketing-related communications at any time by updating that preference.
Processing to ensure compliance. Cirro and its products, technologies, and services are subject to the export laws of various countries including, without limitation, those of the European Union and its member states, and of the United States of America. You acknowledge that, pursuant to the applicable export laws, trade sanctions, and embargoes issued by these countries, Cirro is required to take measures to prevent entities, organizations, and parties listed on government-issued sanctioned-party lists from accessing certain products, technologies, and services through Cirro’s websites or other delivery channels controlled by Cirro. This could include (i) automated checks of any user registration data as set out herein and other information a user provides about his or her identity against applicable sanctioned-party lists; (ii) regular repetition of such checks whenever a sanctioned-party list is updated or when a user updates his or her information; (iii) blocking of access to Cirro’s services and systems in case of a potential match; and (iv) contacting a user to confirm his or her identity in case of a potential match. Any such use of your Personal Data is based on the permission to process Personal Data in order to comply with statutory obligations (Article 6(1) lit. c GDPR) and Cirro‘s legitimate interest (Article 6(1) lit. f GDPR) or under the equivalent articles under other national laws, when applicable.
Furthermore, you acknowledge that information required to track your data protection and privacy choices for processing your Personal Data, or for receipt of marketing materials (that is to say, depending on the country in which the relevant Cirro Group company operates and whether you have expressly consented to or opted out of receiving marketing materials) may be exchanged among members of the Cirro Group when necessary to ensure compliance.
Processing based on Cirro’s legitimate interest. Cirro can use your Personal Data based on its legitimate interest (Article 6(1), lit. f GDPR) or the equivalent article under other national laws, when applicable, as follows:
Fraud and Legal Claims. If required, Cirro will use your Personal Data for the purposes of preventing or prosecuting criminal activities such as fraud and to assert or defend against legal claims.
Questionnaires and surveys. Cirro could invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any data that can be used to identify you. If you nonetheless enter such data in a questionnaire or survey, Cirro will use this Personal Data to improve its products and services.
Contract Performance. If you purchase or intend to purchase goods or services from Cirro on behalf of a corporate customer or otherwise be the nominated contact person for the business relationship between a corporate customer (a “Customer Contact”) and Cirro, Cirro will use your Personal Data for this purpose. This includes, for the avoidance of doubt, such steps which are required for establishing the relevant business relationship. In case that an existing Customer Contact informs Cirro that you are his replacement, Cirro will, from the point in time of such notification, consider you to be the relevant Customer Contact for the respective customer until you object as further set out below.
Creation of anonymized data sets. Cirro will anonymize Personal Data provided under this Privacy Statement to create anonymized data sets, which will then be used to improve its and its affiliates’ products and services.
Personalized Content. If you opt-in to receive marketing communications such as and including newsletters, brochures or white papers from Cirro, Cirro will collect and store details of how you interact with such content to help create, develop, operate, deliver and improve our communications with you. This information is aggregated and used to help Cirro provide more useful information and to understand what is of most interest to you.
Recordings for quality improvement purposes. In case of telephone calls or chat sessions, Cirro will record such calls (after informing you accordingly during that call and before the recording starts) or chat sessions to improve the quality of Cirro’s services.
To keep you up-to-date or request feedback. Within an existing business relationship between you and Cirro, Cirro might inform you, where permitted in accordance with local laws, about its products or services (including webinars, seminars and events) which are similar or relate to such products and services you have already purchased or used from Cirro. Furthermore, if you attend a webinar, seminar or event of Cirro, download or view whitepapers, newsletters, videos, software free trials, or purchase products or services from Cirro, Cirro might contact you for feedback regarding the improvement of the relevant material, product or service.
Right to object. You can object to Cirro’s use of your Personal Data as set forth in this section at any time by updating that preference. In this case, Cirro will carefully review your objection and cease further use of the relevant information unless Cirro has a compelling legitimate ground for continued use of the information and such ground overrides your objection, or if Cirro requires the information for the establishment, exercise or defense of legal claims.
Processing under applicable national laws. If the applicable national law allows Cirro to do so, Cirro will use information about you, some of which is Personal Data, for the following business purposes:
to plan and host events
to host online forums or webinars
for marketing purposes such as to keep you updated on Cirro’s latest products and services and upcoming events
to contact you to discuss further your interest in Cirro services and offerings
to help Cirro create, develop, operate, deliver and improve Cirro services, products, content and advertising and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Cirro
to provide more personalized information to you
for loss prevention
for account and network security purposes
for internal purposes such as auditing, analysis, and research to improve Cirro’s products or services
to verify your identity and determine appropriate services
detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
debugging to identify and repair errors that impair existing intended functionality
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by QPES.
C. Processing based on consent
In the following cases, Cirro will process your Personal Data if you granted prior consent to the specific proposed processing of your Personal Data (Article 6(1) lit. a GDPR) or the equivalent article under other national laws, when applicable. Each below section about a processing operation of Personal Data is linked to one consent statement in the Consent Resource Center. If you re-open this Privacy Statement after you initially grant one or more consents, you will see the full Privacy Statement and not just information on the consents you granted.
News about Cirro’s Products and Services. Subject to a respective provision and your consent, Cirro may use your name, email and postal address, telephone number, job title and basic information about your employer (name, address, and industry) as well as an interaction profile based on prior interactions with Cirro (prior purchases, participation in webinars, seminars, or events or the use of (web) services - further details on this topic can be found in the Cookie Statement displayed on the relevant Cirro website) in order to keep you up to date on the latest product announcements, software updates, software upgrades, special offers, and other information about Cirro’s software and services (including marketing-related newsletters) as well as events of Cirroand in order to display relevant content on Cirro’s websites. In connection with these marketing-related activities, Cirro may provide a hashed user ID to third party operated social networks or other web offerings (such as Twitter, LinkedIn, Facebook, Instagram or Google) where this information is then matched against the social networks’ data or the web offerings’ own data bases in order to display to you more relevant information.
Forwarding your Personal Data to other Cirro companies. Cirro may transfer your Personal Data to other entities in the Cirro Group. The current list of CirroGroup entities can be found here. In such cases, these entities will then use the Personal Data for the same purposes and under the same conditions as outlined in this Section C. above.
Forwarding your Personal Data to other Third Parties. At your request, as indicated by your consent, Cirro will transfer your registration data to the companies listed on the registration page. The companies will use your registration data for the purposes of their participation in the event and are obliged to delete the data thereafter. If a company intends to use your data for any other purposes, they will contact you to explain how and for which other purposes they will use your registration data.
Revocation of a consent granted hereunder. You may at any time withdraw a consent granted hereunder by unsubscribing. In case of withdrawal, Cirro will not process Personal Data subject to this consent any longer unless legally required to do so. In case QPES is required to retain your Personal Data for legal reasons your Personal Data will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal data by Cirro up to the point in time of your withdrawal. Furthermore, if your use of an Cirro offering requires your prior consent, QPES will not be (any longer) able to provide the relevant service (or services, if you revoke the consent for Cirro to use your profile under the Cirro Cloud Platform Identity Authentication Service for multiple Cirro offerings), offer or event to you after your revocation.
D. Cookies and similar tools
Information gathered by cookies or similar technologies, and any use of such information, is further described in Cirro’s Cookie Statement. You can exercise your cookie preferences as outlined in Cirro’s Cookie Statement by visiting the “Cookie Preferences” link in the bottom footer of the Cirro.com homepage