Privacy Policy

This Privacy Policy (the "Privacy Policy") is designed to provide data subjects (individuals) with information on the processing of their personal data (any information relating to them) in the context of DoubleCloud services.

This Privacy Policy is based on the provisions of data protection laws, which may be applicable in the country of your residence, including the General Data Protection Regulation (GDPR) and other laws.

Terms and definitions in this Privacy Policy shall have meaning that is given to them in applicable data protection laws, in particular:

"Personal data" means any information relating to an identified or identifiable natural person ("data subject").

"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

1. Controller

Data controller with regard to personal data processed under this Policy is Direct Cursus Technology LLC with place of business: UAE, Dubai, Trade Center Second, The Offices 2, Unit No. TO2-FLR03-03.05-17, and date of incorporation 20.09.2022.

Depending on the specific purpose and other circumstances of data processing, DoubleCloud may act as a controller or a processor. When acting as a controller, DoubleCloud independently determines the purposes and means of the processing of personal data. At the same time, being a processor, DoubleCloud processes personal data on behalf of the user and under its instructions.

When DoubleCloud is a data controller, the data subjects can contact DoubleCloud on any questions relating to the processing of their personal data by either of the following methods:

Email: privacy@double.cloud

Postal address: UAE, Dubai, Trade Center Second, The Offices 2, Unit No. TO2-FLR03-03.05-17

As a controller, DoubleCloud processes personal data to manage provision of the services to its users (customer registration/authentication, provision of access to the service, support and troubleshooting, billing, etc.), to comply with applicable laws, to market the DoubleCloud services and other products, to improve the DoubleCloud services, to provide security of the DoubleCloud services, to protect its legal rights.

When doing so, DoubleCloud relies on (1) the necessity of the processing for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (2) the necessity of the processing of personal data to comply with its legal obligations; (3) the necessity of the processing of personal data for the purposes of the legitimate interests pursued by DoubleCloud. In some cases, DoubleCloud relies on (4) a consent of a data subject to process his or her personal data. Please note that direct marketing communications with you shall be made only upon your prior opt-in consent, and you will have an opportunity to opt-out at any time using the "unsubscribe" button in messages you receive from us.

The legitimate interests of DoubleCloud consist of (1) compliance with applicable laws and regulations; (2) marketing of the DoubleCloud services and other products (except for the cases, where consent is required); (3) improvement of the DoubleCloud services; (4) provision of security of the DoubleCloud services; (5) protection of its legal rights. Data subjects can get more information on the legitimate interests pursued by DoubleCloud and relevant balancing tests by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

At the same time, DoubleCloud processes personal data shared by users (e.g. uploaded into the cloud) for the purpose of providing its services. In this case, DoubleCloud generally acts as a processor on behalf and under the instructions of the user.

3. Categories of personal data concerned

As a controller, DoubleCloud processes personal data related to its potential and current customers (individuals or representatives of legal entities), individuals who actually use the DoubleCloud services (users), users of the website. Categories of processed personal data include:

1. Personal data collected directly from the data subject:

  • full name;

  • email address;

  • phone number;

  • job title;

  • company name;

  • authentication data;

  • information about choices regarding marketing communications;

  • payment data.

2. Automatically collected personal data related to the usage of the service:

  • information about usage of the service;

  • billing data;

  • IP address;

  • type and device ID;

  • browser type and version;

  • geographical location based on the IP address;

  • service access times;

  • statistics on page views and time spent on pages;

  • log files generated during usage of the service;

  • information about usage of the website obtained through Google Analytics or similar technologies.

3. Personal data received from third parties:

  • personal data specified above if obtained from authorized third parties on an appropriate legal basis;

  • standard claims from Google or SSO provider (email, name, surname, middle name, picture, gender, address, birthdate);

  • data from EDM (name and surnames of signatories, contact details of signatories, power of attorney data).

4. Recipients of personal data

DoubleCloud discloses certain personal data to the following recipients to the extent required or permitted by applicable law and/or based on their legitimate and reasonable requests:

  • affiliate entities which are a part of DoubleCloud group of companies;

  • third-party providers of cloud services (e.g. AWS);

  • partners providing analytic and workspace services (e.g. Google and PostHog);

  • Appcues, Inc. (https://www.appcues.com/) for enhancing your user experience when using the service;

  • payment service providers (e.g. Stripe);

  • partners providing sales and marketing services;

  • providers of CRM, ERP, billing and other systems required for administrating DoubleCloud business processes;

  • partners otherwise assisting in provision of DoubleCloud services and achievement of other purposes mentioned in the section 2 of this Privacy Policy;

  • various state and municipal authorities if strictly required to respond to their legitimate formal inquiries;

  • other third parties when it is required for compliance with applicable laws.

5. Transfers to third countries

DoubleCloud may transfer personal data of the data subjects to third countries, including those that do not provide the same level of data protection as in the country of your residence. When doing so, DoubleCloud ensures implementation of security measures aimed at protection of your personal data in an appropriate manner.
The data subjects can get more information on the mechanisms of transfers to third countries by DoubleCloud by sending a request with the use of contact details specified in section 1 of this Privacy Policy.

6. Storage periods

DoubleCloud stores personal data as long as it is required to achieve the purposes of the processing specified in section 2 of this Privacy Policy, unless there are specific periods defined in applicable laws.

7. Basic rights of data subjects

The data subjects, in respect of their personal data, have rights to:

  1. access;

    (The data subject can ask DoubleCloud to confirm whether or not DoubleCloud processes their personal data. If so, the data subject can access these personal data and can ask DoubleCloud to explain certain details of the processing.)

  2. rectification;

    (The data subject can ask DoubleCloud to correct inaccurate personal data concerning him or her. If it complies with the purposes of the processing, the data subject can ask DoubleCloud to complete incomplete personal data.)

  3. erasure ('right to be forgotten');

    (The data subject can ask DoubleCloud to erase personal data concerning him or her under applicable law. For example, this applies if (1) the personal data are no longer necessary in relation to the purposes for which they were processed; (2) the data subject withdraws consent to the processing and there is no other legal ground for the processing; (3) the personal data have been unlawfully processed.)

  4. restriction on processing;

    (The data subject can ask DoubleCloud to mark the stored personal data with the aim to limit their processing in the future under applicable law. This applies if (1) the data subject contests the accuracy of the personal data; (2) the data subject asks to restrict the use of the personal data when their processing is unlawful; (3) the data subject needs personal data to protect their rights when DoubleCloud no longer needs the personal data; (4) the data subject has objected the processing based on the legitimate interests pursued by DoubleCloud or by a third party.)

  5. objection to processing;

    (The data subject can object, on grounds relating to their particular situation, at any time to processing of personal data concerning him or her which is based on the legitimate interests pursued by DoubleCloud or by a third party. DoubleCloud shall no longer process the personal data unless DoubleCloud demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.)

  6. portability;

    (When the processing is based on consent of the data subject or on a contract with the data subject, and is carried out by automated means, the data subject can receive the personal data concerning him or her, which he or she has provided to DoubleCloud, in a structured, commonly used and machine-readable format and can freely transmit those data to another controller. Where technically feasible, the data subject can also ask DoubleCloud to transmit the personal data directly to another controller.)

To exercise their rights, data subjects can contact DoubleCloud with the use of contact details specified in section 1 of this Privacy Policy.

Where processing is based on consent (or explicit consent), the data subject has the right to withdraw consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal. To withdraw consent, the data subject can contact DoubleCloud with the use of contact details specified in section 1 of this Privacy Policy or use other available methods.

9. Right to lodge a complaint with a supervisory authority

When Article 77 of the GDPR (or the relevant provision of other applicable laws) applies, a data subject has the right to lodge a complaint with a supervisory authority in the area of data protection in the country of his/her residence.

10. Necessity to provide personal data

The data subjects shall provide DoubleCloud with certain personal data processed under this Privacy Policy so that DoubleCloud can comply with applicable laws as well as provide the DoubleCloud services to the data subjects. If the data subjects do not provide DoubleCloud with the relevant personal data, they cannot use the DoubleCloud services.

11. Sources of personal data

DoubleCloud collects personal data from the data subjects themselves. However, in certain cases and for specific purposes it may also acquire some data from external providers of sales and marketing services.

12. Changes to this Privacy Policy

DoubleCloud may change this Privacy Policy from time to time at its sole discretion. If so, DoubleCloud may notify the data subjects about these changes by an appropriate method. If there is no explicit notification, the data subjects may always review the up-to-date version of this Privacy Policy located at https://double.cloud/legal/privacy

____________________________________

Web address: https://double.cloud/legal/privacy

Date of publication: 1 January 2024

Effective date: 1 January 2024 (30 January 2024 for the DoubleCloud users who signed up before 1 January 2024)

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