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PRIVACY POLICY


Effective on: December 13, 2022


Introduction and Scope

Info Cloud Technology (“we”, “us”, “our”) takes the protection of personally
identifiable information (“Personal Data”) very seriously. Info Cloud Technology
assists in the provision of lead generation services, including content
syndication, data analytics and email marketing (collectively, the “Lead
Generation Services”). This Privacy Notice (the “Notice”) addresses Personal
Data collected via our website and in connection with our Lead Generation
Services. This Notice does not apply to Personal Data we collect by other means,
such as Personal Data of our employees.


Categories of Personal Data

We may process the following types of Personal Data:

 * biographical information, such as first and last name and date of birth; and
   contact information, such as email address, phone number, postal address, and
   country of residence postal;
 * employment information, such as industry, job title, company name, department
   name, or company size; and
 * business contact information, such as company email address and postal
   address; and public LinkedIn profile.
 * analytics information;
 * device, internet and mobile information such as the hardware model, operating
   system version, unique device identifiers, browser type, language, wireless
   network, and mobile network information (including the mobile phone number);
 * geo-location information when you use our website and Lead Generation
   Services; and/or
 * records and copies of your correspondence (including e-mail addresses), if
   you contact us. This may include call recordings where we monitor and record
   such calls for staff training or quality assurance purposes.


How We Receive Personal Data

 * We may receive your Personal Data when:
 * you provide it directly to us through our websites;
 * our clients (including their employees, contractors, and other
   representatives) provide it to us;
 * we receive it from other companies within our corporate group;
 * our service providers provide it to us;
 * we purchase lists of individuals who might be interested in becoming
   customers of our clients;
 * you provide it on publicly accessible sources, such as on LinkedIn or your
   company website; or
 * such information is captured as cookies, as outlined in the “Cookie” section
   below.
 * 
   Purposes of Processing

We may process your Personal Data for the purposes of:

 * responding to your requests or questions; and
 * sending you promotional communications, such as providing you with
   information about services, features, surveys, newsletters, offers, and
   events; and providing other news or information about us, and the Lead
   Generation Services; and
 * to verify your identity and prevent fraud or other unauthorized or illegal
   activity.

Basis of Processing

We may process your Personal Data on the basis of:

 * your consent;
 * our legitimate interests in providing Lead Generation Services to our
   clients;
 * the need to comply with the law; or
 * any other ground, as required or permitted by law.




Where we process your Personal Data based on your consent, you may withdraw it
at any time. However, this will not affect the lawfulness of our processing
before you withdrew your consent. It will also not affect processing performed
on other lawful grounds.


Data Retention

When the purposes of processing are satisfied, we will delete the related
Personal Data within six months, unless applicable laws require otherwise.




Sharing Personal Data with Third Parties

We may share Personal Data with our affiliates and clients, as well as with our
service providers who process Personal Data on our behalf and who agree to use
the Personal Data only to assist us in providing our services to our clients, or
as required by law. Our service providers may provide:

 * application hosting services;
 * cloud storage services;
 * business productivity services;
 * communication services and software;
 * email verification software;
 * customer relationship management (CRM) software; and
 * contact verification and data enrichment services.




Some of these third parties may be located outside of the United States.
However, before transferring your Personal Data to these third parties, we will
either ask for your explicit consent or require the third party to maintain at
least the same level of privacy and security for your Personal Data that we do.
We remain liable for the protection of your Personal Data that we transfer or
have transferred to third parties through our designated data transfer
mechanism, except to the extent that we are not responsible for the event that
leads to any unauthorized or improper processing.




Some of these third parties may be located outside of the European Union or the
European Economic Area. In some cases, the European Commission may not have
determined that the countries’ data protection laws provide a level of
protection equivalent to European Union law. We will only transfer your Personal
Data to third parties in these countries when there are appropriate safeguards
in place. These may include the Standard Contractual Clauses (“SCCs”) as
approved by the European Commission. The SCCs are formally integrated into our
agreements with third parties that we share EEA Personal Data with, and third
parties on whose behalf we receive EEA Personal Data.


Other Disclosure of Your Personal Data

We may disclose your Personal Data to the extent required by law, or if we have
a good-faith belief that we need to disclose it in order to comply with official
investigations or legal proceedings (whether initiated by governmental/law
enforcement officials, or private parties). We may also disclose your Personal
Data if we sell or transfer all or some of our company’s business interests,
assets, or both, or in connection with a corporate restructuring. Finally, we
may disclose your Personal Data to our subsidiaries or affiliates, but only if
necessary for business purposes, as described in the section above.




We reserve the right to use, transfer, sell, and share aggregated, anonymous
data for any legal business purpose. Such data does not include any Personal
Data. The purposes may include analyzing usage trends or seeking compatible
advertisers, sponsors, and customers.




If we have to disclose your Personal Data to governmental/law enforcement
officials, we may not be able to ensure that those officials will maintain the
privacy and security of your Personal Data.




Cookies

A “cookie” is a small file stored on your device that contains information about
your device. We may use cookies to provide basic relevant ads, website
functionality, authentication (session management), usage analytics (web
analytics), and to remember your settings, and generally improve our websites
and services.




We use session and persistent cookies. Session cookies are deleted when you
close your browser. Persistent cookies may remain even after you close your
browser, but always have an expiration date. Please refer to the policies of
these third parties to learn more about the way in which they collect and
process information about you.




If you would prefer not to accept cookies, you can change the setup of your
browser to reject all or some cookies. For more information, please visit
https://www.aboutcookies.org/.




You may also set your browser to send a Do Not Track (DNT) signal. For more
information, please visit https://allaboutdnt.com/.


Data Integrity & Security

We have implemented and will maintain technical, administrative, and physical
measures that are reasonably designed to help protect Personal Data from
unauthorized processing. This includes unauthorized access, disclosure,
alteration, or destruction.


Your Rights

If we process your Personal Data, you may have the right to request access to
(or to update, correct, or delete) such Personal Data. You may also have the
right to ask that we limit our processing of such Personal Data, as well as the
right to object to our processing of such Personal Data. You may also have the
right to data portability, meaning that you can request that your data be
transferred to you in a structured, commonly-used and machine-readable format.




We sometimes use computers to study your Personal Data. We might use this
Personal Data so we can attempt to predict your buying behavior and interests.
For decisions that may seriously impact you, you have the right not to be
subject to automatic decision-making, including profiling. But in those cases,
we will always explain to you when we might do this, why it is happening and the
effect.




If you object to our processing of your Personal Data, we will stop processing
the relevant Personal Data unless: (i) we have compelling legitimate grounds for
the processing that override your interests, rights, or freedoms; or (ii) we
need to continue processing your Personal Data to establish, exercise, or defend
a legal claim.




Info Cloud Technology has limited rights to access Personal Data our service
providers submit to us. Therefore, if you contact us with such a request, we
will forward your request to that service provider and provide any needed
assistance as they respond to your request.




If we have received your Personal Data in reliance on the Privacy Shield, you
may also have the right to opt out of having your Personal Data shared with
third parties and to revoke your consent to our sharing your Personal Data with
third parties. You may also have the right to opt out if your Personal Data is
used for any purpose that is materially different from the purpose(s) for which
it was originally collected or which you originally authorized. To submit these
requests or raise any other questions, please contact us by using the
information in the “Contact Us” section below.


Privacy of Children

The Services are not directed at, or intended for use by, children under the age
of 13.


EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

For Personal Data processed in the scope of this Notice, the data controller
complies with the principles of the EU-U.S. Privacy Shield Framework and
Swiss-U.S. Privacy Shield Framework (the “Privacy Shield”), as adopted and set
forth by the U.S. Department of Commerce regarding the processing of Personal
Data transferred from the European Union, or Switzerland to the United States,
or otherwise received in reliance on the Privacy Shield.




We commit to maintain adherence to the Privacy Shield Principles with regard to
Personal Data that was received in reliance on Privacy Shield and have certified
our adherence to the Department of Commerce. We do not currently use the Privacy
Shield as our data transfer mechanism from the EEA. We use the SCCs as its
primary data transfer mechanism for EEA Personal Data.




To learn more about the Privacy Shield Principles, and to view our certification
information, please visit https://www.privacyshield.gov and
https://www.privacyshield.gov/list, respectively.


U.S. Regulatory Oversight

Info Cloud Technology is subject to the investigatory and enforcement powers of
the United States Federal Trade Commission.


European Union Supervisory Authority Oversight

If you are a data subject whose Personal Data we process, you may also have the
right to lodge a complaint with a data protection regulator in one or more of
the European Union member states.


Changes to this Notice

If we make any material change to this Notice, we will post the revised Notice
to this web page. We will also update the “Effective” date.


Contact Us

If you have any questions about this Notice or our processing of your Personal
Data, please write to us by email at news@infocloudtechnology.com or by postal
mail at:




Info Cloud Technology

Attn: Paul Hong, COO

316 California Ave. #34 Reno NV 89509

United States




Please allow up to four weeks for us to reply.