Applicable date: May 24, 2019
MeaningCloud LLC — 1030 Salem Rd, Union, NJ 07083, USA
By using or registering with MeaningCloud Services or by providing personal information, you agree to abide by these terms. We may from time to time modify these terms and will post a copy of the amended Agreement at http://www.meaningcloud.com/data-protection-policy/.
Information We Collect and Use
Information You Provide
Our communications with you
Users of the MeaningCloud service: as part of our service, MeaningCloud will contact you to inform you of any circumstance that you need to know and necessary for the provision of such service: of operation, maintenance or billing incidents, launch of new products or new versions of existing ones, replacement or discontinuation of products, etc. To unsubscribe from the contents necessary for the provision of the service, it is necessary to unsubscribe from the service itself.
Users registered to receive marketing communications: if you have registered to receive our marketing communications, you can receive information on the following topics:
- Product news: launch of new products or new versions of existing ones, substitution or discontinuation of products, training events, use tutorials, etc.
- Invitations to events and other content of interest for your position or industry: conferences, webinars, white papers, customer cases, etc.
- Periodical Newsletter: an updated summary about MeaningCloud and its industry (product news, new clients, events, presence in media, etc.)
You can control your subscription to all these types of content through our Communications Preference Center.When you use the Service, we may send one or more “cookies” – a small data file – to your computer to uniquely identify your browser and let MeaningCloud help you log in faster and enhance your navigation through the site. A cookie may convey anonymous information about how you browse the Service to us. A persistent cookie remains on your hard drive after you close your browser so that it can be used by your browser on subsequent visits to the Service. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled. MeaningCloud website can use the following types of cookies:
|Necessary||Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.|
|Antispam||Antispam cookies are used to prevent automated attacks (by bots) to the website.|
|Statistics||Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.|
|Marketing||Marketing cookies are used to track visitors across websites. The intention is to build a profile of your behavior and interests so that more personalized experiences and content can be offered to you.|
Disabling cookies in your browserYou can easily disable cookies from being installed on your machine, by configuring your browser settings. These are instructions for the most common browsers:
Clear Gifs Information
Third Party Tools
Service Providers, Business Partners, and Others
Third Party Services
Compliance with Laws and Law Enforcement Requests; Protection of MeaningCloud’s Rights
Non-Personally Identifiable Information
How We Protect Your Information
Your Choices About Your Information
MeaningCloud Blog & Community
International Data Transfer
Links to Other Web Sites
MeaningCloud Privacy Shield Policy
MeaningCloud LLC ("MeaningCloud") has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that MeaningCloud obtains from Individual Customers located in the European Union and Switzerland and to personal data received in the U.S. from other Data Subjects in the EU and Switzerland, including EEA Employees of MeaningCloud.
MeaningCloud complies with the EU-U.S. Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. The term “Individual Customers” needs to be interpreted in a broad sense: these are actual (paying or not) users of MeaningCloud’s products, but also prospective customers that register with MeaningCloud and opt-in to attend its events or download its contents. MeaningCloud stores and processes their data to keep these people informed about its products and services.
The Federal Trade Commission (FTC) has jurisdiction over MeaningCloud's compliance with the Privacy Shield.
All MeaningCloud employees in the U.S. who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section XIV of this Privacy Shield Policy.
For the full terms and conditions governing your use of the MeaningCloud service, please see our Terms and Conditions (http://www.meaningcloud.com/terms-and-conditions).
Please also review our full Data Protection Policy (http://www.meaningcloud.com/data-protection-policy).
This Policy applies to the processing of Individual Customer Personal Data that MeaningCloud receives in the United States concerning Individual Customers located in the European Union and Switzerland. MeaningCloud provides products and services to businesses and consumers.
The term “Individual Customers” designates actual (paying or not) users of MeaningCloud’s products, but also prospective customers that register with MeaningCloud and opt-in to attend its events or download its contents.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)
II. RESPONSIBILITIES AND MANAGEMENT
MeaningCloud has designated the Legal Department to oversee its information security program, including its compliance with the EU and Swiss Privacy Shield program. The Legal Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to firstname.lastname@example.org.
MeaningCloud will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. MeaningCloud personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that MeaningCloud has undertaken to protect Personal Data.
III. RENEWAL / VERIFICATION
MeaningCloud will renew its EU-U.S. Privacy Shield and Swiss-US Privacy Shield certifications annually, unless it subsequently determines that it no longer needs such certification or if it employs a different adequacy mechanism.
Prior to the re-certification, MeaningCloud will conduct an in-house verification to ensure that its attestations and assertions about its treatment of Individual Customer Personal Data are accurate and that the company has appropriately implemented these practices. Specifically, as part of the verification process, MeaningCloud will undertake the following:
- Ensure that this Policy continues to comply with the Privacy Shield principles.
- Confirm that Individual Customers are made aware of the process for addressing complaints and any independent dispute resolution process (MeaningCloud may do so through its publicly posted website, Individual Customer contract, or both).
- Review its processes and procedures for training employees about MeaningCloud's participation in the Privacy Shield programs and the appropriate handling of Individual's Personal Data.
MeaningCloud will prepare an internal verification statement on an annual basis.
IV. COLLECTION AND USE OF PERSONAL DATA
MeaningCloud provides various solutions to its Individual Customers who purchase its products. MeaningCloud collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, MeaningCloud Individual Customers may choose to seek live support or post to a message board.
The Personal Data that we collect may vary based on the Individual Customer's interaction with our website and request for our services. As a general matter, MeaningCloud collects the following types of Personal Data from its Individual Customers: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Individual Customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.
When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.
MeaningCloud uses Personal Data that it collects directly from its Individual Customers for the following business purposes, without limitation:
- maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing analysis requests, reporting, invoices, renewals, and other operations related to providing services to a Individual Customer);
- satisfying governmental reporting, tax, and other requirements (e.g., import/export);
- storing and processing data, including Personal Data, in computer databases and servers located in the United States;
- verifying identity (e.g., for online access to accounts);
- as requested by the Individual Customer;
- for other business-related purposes permitted or required under applicable local law and regulation;
- and as otherwise required by law.
MeaningCloud does not disclose personal information to third parties other than our agents. Should this change in the future, we will provide individuals with the option to opt-out, or opt-in for sensitive data, for any personal information so disclosed.
MeaningCloud provides an individual opt-out choice, or opt-in for sensitive data, before we use your personal information for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to email@example.com.
V. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Except as otherwise provided herein, MeaningCloud discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
MeaningCloud may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, MeaningCloud may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by MeaningCloud and they must either:
- comply with the Privacy Shield principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Data;
- or agree to provide adequate protections for the Personal Data that are no less protective than those set out in this Policy;
MeaningCloud also may disclose Personal Data for other purposes or to other Third Parties when a Data Subject has consented to or requested such disclosure. Please be aware that MeaningCloud may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. MeaningCloud is liable for appropriate onward transfers of personal data to third parties.
MeaningCloud’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, MeaningCloud remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless MeaningCloud proves that it is not responsible for the event giving rise to the damage.
VI. SENSITIVE DATA
MeaningCloud does not collect Sensitive Data from its Individual Customers.
VII. DATA INTEGRITY AND SECURITY
MeaningCloud uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. MeaningCloud has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to MeaningCloud's electronic information systems requires user authentication via password or similar means. MeaningCloud also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
Further, MeaningCloud uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.
IX. ACCESSING PERSONAL DATA
MeaningCloud personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.
X. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
A. Right to Access. Individual Customers and other Data Subjects have the right to know what Personal Data about them is included in the databases in the United States and to ensure that such Personal Data is accurate and relevant for the purposes for which MeaningCloud collected it. Individual Customers may review their own Personal Data stored in the databases and correct, erase, or block any data that is incorrect, as permitted by applicable law and MeaningCloud policies. Upon reasonable request and as required by the Privacy Shield principles, MeaningCloud allows Individual Customers and other Data Subjects access to their Personal Data, in order to correct, amend, or delete such data where inaccurate or collected in a manner inconsistent with the Principles. Individual Customers may edit their Personal Data by logging into their account profile or by contacting MeaningCloud by phone or email. In making modifications to their Personal Data, Data Subjects must provide only truthful, complete, and accurate information. To request erasure of Personal Data, Individual Customers should submit a written request to local MeaningCloud office.
B. Requests for Personal Data. MeaningCloud will track each of the following and will provide notice to the appropriate parties under law and contract when either of the following circumstances arise: (a) legally binding request for disclosure of the Personal Data by a law enforcement authority unless prohibited by law or regulation; or (b) requests received from the Data Subject. If MeaningCloud receives a request for access to his/her Personal Data from a Data Subject, then, unless otherwise required under law or by contract with such Data Subject, MeaningCloud will refer such Data to the Data Subject.
C. Satisfying Requests for Access, Modifications, and Corrections. MeaningCloud will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
XI. CHANGES TO THIS POLICY
This Policy may be amended from time to time, consistent with the Privacy Shield Principles and applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.
XII. QUESTIONS OR COMPLAINTS
In compliance with the Privacy Shield Principles, MeaningCloud commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact MeaningCloud by email at firstname.lastname@example.org.
XIII. ENFORCEMENT AND DISPUTE RESOLUTION
MeaningCloud has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD . If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and MeaningCloud does not address it satisfactorily, MeaningCloud commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Contact details for the EU data protection authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
XIV. DEFINED TERMS
"Individual Customer" means an individual customer or client of MeaningCloud from EU or Switzerland. The term also shall include any individual agent, representative, of an individual customer of MeaningCloud and any employee of Individual Customers where MeaningCloud has obtained his or her Personal Data from such Individual Customer as part of its business relationship with MeaningCloud.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
"EEA Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of MeaningCloud or any of its affiliates or subsidiaries, who is also a resident of a country within the European Economic Area.
"Personal Data" as defined under the European Union Directive 95/46/EC means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, e-mail address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither MeaningCloud nor a MeaningCloud employee, agent, contractor, or representative.