TruthHUB™ PRIVACY POLICY
Updated September 1, 2023
CloutHub Inc. and Worldwide Tech Connections LLC (collectively, “us”, “we” or “CloutHub®“), takes the privacy of personal information seriously, including personal information that we process on our users’ (“User” or “You”) behalf, and we have prepared this privacy policy (“Privacy Policy”) to describe our practices for collecting, using, maintain, protecting, and disclosing that information. CloutHub®’s TruthHUB™ Platform and Software (as defined in the TruthHUB™ End User Licence Agreement) provides an online based audio-visual communication platform that provides customizable, real-time translation services to Users and User generated content (the “Services”). These Services may include, but are not limited to, hosting of third-party and/or user generated content and communication abilities between users of CloutHub®. This Privacy Policy applies to personal information we process in the course of providing the Services and Platform on behalf of our Users, as well as to the personal information we collect, through our website [INSERT TRUTHHUB WEBSITE URL] and Software (collectively, with the Software and Services the “Platform”). We will only use your personal information in accordance with this Privacy Policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
COLLECTION AND USE OF PERSONAL INFORMATION
Why we collect information on behalf of our Users
In the course of providing Services to our Users, we may obtain personal information about our Users and their invitee participants of the Platform and/or Services as set out below: Personal Information: In order to provide the Platform and/or Services, we collect information that we can reasonably use to directly or indirectly identify you, such as your name, gender email address, internet protocol (IP) address, financial information (where applicable), user name or other similar identifier, and any other identifier we may use to contact you (“Personal Information“). Two-Factor Authentication: In order to comply with our Platform and Service’s application distribution agreements and the Google Play Store’s Terms of Service, and to generally ensure the security of Personal Information, we may also engage in Two-Factor Authentication as necessary. Information Required to Provide the Services: In order to provide the Platform and/or Services, we may also collect information, personal or otherwise, that may be contained in content created and provided by User. We may also obtain Personal Information in response to executing queries on behalf of our Users against Services tenants that may contain Personal Information. Support Services: We may collect certain Personal Information (such as name, email address and query) when we provide User support services by phone or email.How we collect information
Registration: When you download, register with, or use the Platform and/or Services, we will ask you to provide information by filling out the registration form. This includes information, personal or otherwise, initially required to use the Platform and engage with the Services. Inquiries: If you contact us with an inquiry, you may be asked for Personal Information that identifies you, such as your name, and email address along with additional information we need to help us promptly answer your inquiry. We may retain this Personal Information to assist you in the future and to improve our User services and service offerings or as otherwise needed to meet our legal or contractual obligations. Communications/Publications: We may offer you the ability to sign-up to receive CloutHub® and/or TruthHUB™ marketing and promotional communications or download a report, publication or other resources, in which case we collect certain Personal Information (such as first and last name, company name, email address or phone number). We use this information to send you the communications you have requested to receive. You can opt-out at any time of receiving promotional email from us by selecting the “Unsubscribe” option or by contacting our Privacy Officer, Todd Callender at privacy@clouthub.com. Feedback: We may collect and use User feedback about our Platform and/or Services to better understand our Users and enhance our product and service offerings. With your consent, we may publish your feedback on our Platform and Services or other promotional materials. Surveys and User Research: From time-to-time, we may offer Users an opportunity to participate in one or more of our surveys or other User research. The data collected is used in an aggregated, non-personally identifiable form. We use this information to help us understand our Users and to enhance our product and service offerings. Content Creation: We require our Users to ensure that they have obtained all authority to provide Personal Information to us in accordance with applicable privacy laws and any User’s related third-party business associate or privacy policies and agreements and to not provide us with any sensitive information. Users are responsible for providing CloutHub® with accurate and complete information and for contacting us as outlined in the Contact Us section of this Privacy Policy below to correct any inaccurate information provided. Except as set out herein, we do not collect or use Personal Information of our Users for any purpose other than to provide our Platform and Services on behalf of our Users.Automatic information collection and tracking technologies
When you download, access, and use the Platform and/or Services, it may automatically collect information through automatic means and tracking technologies. Usage Details: When you access and use the Platform and/or Services, we may automatically collect certain details of your access to and use of the Platform and/or Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Platform. To do this, the Platform and Services use Google Analytics and Google AdSense. For more information on how these applications collect and process data, visit the Google Privacy Policy. Device Information: We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number. Stored Information and Files: The Platform and/or Services may also access metadata and other information associated with other files stored on your device. This may include, for example, translations, transcripts, audio and video clips, personal contacts, and address book information. The User reserves the right to not allow the Platform and/or Services access to their personal device’s features or storage access. However, we provide no warranty of quality of services with respect to any issues arising from, or affected or created by any such denial of access to a User’s device. Location Information: The Platform and Services neither collect nor monitor real-time information about the geographical location of your device based on IP address or other identifiers. However, to maximize Platform and/or Services performance, we may from time to time use Geo-IP lookups to see if a User is in a specific area to best serve them with respect to providing relevant information, displaying relevant third-party ads or to achieving systems optimization by assisting us in identifying the closest server or other provider so that we can provide content to the User. In the event that we do request a User’s location information, the location information would only be accessed temporarily and not tracked continuously but may be used for security purposes such as User verification or to notify a User that they are signed in at different locations. The technologies we use for this automatic data collection may include: Cookies: Our Platform uses a technology called “cookies”. A cookie is a tiny element of data that our Platform sends to a User’s browser, which may then be stored on the User’s hard drive so that we can recognize the User’s computer or device when they return. Cookies may provide us and our service providers with information that we will use to personalize our Platform and/or Services in accordance with a User’s preferences. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Platform, you may not be able to take advantage of all of the Platform and/or Services features. We may also use a third-party to help us gather and analyze information about the areas that Users visit on the Platform and Services to evaluate and improve the User experience and the convenience of the Platform and Services. Third Party Links: Our Platform and/or Services may contain links to other websites that CloutHub® does not own or operate. We provide links to third-party websites as a convenience to the User. These links are not intended as an endorsement of or referral to the linked websites or any of their services or products. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit. Web Analytic Services: CloutHub® uses Google Analytics and Google AdSense to track user activity metrics for example, to count users who have visited those pages and for other related Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity). For more information on how these applications collect and process data, visit the Google Privacy Policy.How we use your information
Carrying Out Services: We use information that we collect about you or that you provide to us, including any Personal Information, to maintain, improve and carry out the Services. We may use the e-mail address linked to your account to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies. Communications: From time-to-time we may send you marketing and promotional communications and materials. (“Marketing Materials”). Marketing Materials may be sent to Users for our marketing purposes in a variety of ways, such as through the e-mail linked to a User’s account, by text messages, push notifications, in-Platform notifications, featured posts or advertising graphics/videos in accordance with your selected marketing and Platform preferences. You can opt-out of these Marketing Materials at any time. We may also use the e-mail linked to your account to request feedback and to contact you about your use of our Services. Users that subscribe to our Premium CloutHub® Services and opt to provide their mailing address may receive mailed copies of our Marketing Materials. Legal Requests and Harm Prevention: If we receive a subpoena or other legal request valid in the State of Nevada, we may need to inspect the Personal Information we hold in our database to determine how to respond. In the case of a subpoena, the affected User will be notified so they may consult with an appropriate legal professional. Because we collect only the minimal amount of Personal Information necessary to maintain our Platform and Service’s operation and other data only with User permission, we will not collect any additional Personal Information outside of what the User has already given us express permission to access and collect, in response to a subpoena or other valid request from a legal authority.STORAGE OF PERSONAL INFORMATION
How long we keep your information
We will only keep your Personal Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. This period of time varies depending on the type of information. Personal Information relevant to your profile and associated content are held for the duration of your account. Information collected through Google Analytics and Google AdSense are held in accordance with the Google Privacy Policy. All personally identifiable data shall be held for no longer than 2 years past the termination of the User’s account. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, or, if this is not possible then we will securely store your personal information and isolate it from any further processing until deletion is possible.How your information is stored
We understand that data security is a critical issue for our Users, and we are committed to safeguarding the Personal Information in our custody and under our control. We have implemented reasonable administrative, organizational, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control. Access to Personal Information in the delivery of our Platform and Services is based on the concept of least privilege and parties who have access to our Users’ Personal Information are reviewed regularly and may access that data through our systems and/or their physical devices. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their own marketing or other purposes. We have Personal Information retention processes designed to retain Personal Information for no longer than necessary for the purposes of providing Services to our Users or, with respect to the Platform, for the purposes set out in this Privacy Policy or to otherwise meet our legal obligations. After the retention period is over or upon specific request by the User, Personal Information shall be disposed of or destroyed in accordance with CloutHub® policies and in a manner that prevents recovery or unauthorized access after disposal. 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 Platform. 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 Platform. In the event of an unauthorized disclosure, identification of a breach or potential breach that affects or may affect personal information provided by User, we will notify all affected parties in a timely manner (as set out in further below).COOKIE POLICY
How do we use cookies
CloutHub® uses cookies in a range of ways to improve our Services and your experience with the Platform, including:- Keeping you signed in
- Understanding how you use our Platform
- Predicting content that is relevant to you
What types of cookies do we use
Functionality: Cookies are imperative to CloutHub®’s ability to render its Services including recognizing Users on the Platform, remembering your previously selected preferences, sending notifications and providing access to paid, private or restricted content. These could include what language Users prefer and the location a User is in. The Platform and Services employ a mix of first-party and third-party cookies to achieve these purposes. Users can set their browser to not accept cookies and/or remove cookies, however certain features of the Platform and Services may not function as a result. Advertising: CloutHub® uses these cookies to collect information about your use of the Platform and/or Services, the content you viewed, the links you followed and information about your browser, device, and your IP address. CloutHub® may from time to time share some limited aspects of this data with third-parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.How to manage cookies
You can set your browser not to accept cookies and/or remove cookies from your browser. However, some features of the Platform and Services may not function as a result.DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION
As a matter of practice, CloutHub® does not disclose, trade, rent, sell, or otherwise transfer our Users’ Personal Information, except as set out in this policy, agreements, or as required by law. We may transfer or disclose Personal Information as follows: Service Providers & Processors: In connection with our Platform or Services, we may transfer (or otherwise make available) Personal Information to third-parties (including cloud-based service providers) who provide services on our behalf. Personal Information may be maintained and processed by CloutHub® or its third-party service providers in the United States. For example, we may use service providers to host our website, store data and provide back-up services, provide User support software as a service, process User payments, provide data analytics services, conduct surveys or obtain User feedback. Before transferring any Personal Information, we ensure that a contract is in place between CloutHub® and that third-party that includes terms requiring the third-party to only process that information for the limited purposes such processing is intended. CloutHub® also ensures that such contract includes any terms required of processers as defined in the European Union’s General Data Protection Regulation (GDPR). For more information about the way in which our service providers treat Personal Information, contact us as set out in the “Contact Us” section below. Sale of Business: CloutHub® may transfer Personal Information as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of CloutHub® or as part of a corporate reorganization or other change in corporate control. Legal Obligations: CloutHub® and our other service providers and affiliates may disclose your Personal Information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by US federal or state or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable US federal or state law or other international law. Where a disclosure of our Users’ Personal Information is required by applicable law, we promptly notify the affected User prior to complying with such requirements (to the extent we are not prohibited from doing so) and fully co-operate with our User’s instructions with respect to our response.ACCESS AND CONTROL
Information sharing options
We offer several ways in which you can access or limit the Personal Information you provide to us. Account settings: If you would at any time like to review or change the information in your account or terminate your account, you can:- Log into your account settings and update your User account.
- To deactivate your account, send an e-mail to support@CloutHub.com
Information Requests
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes. By law, you have the right to request access to and to correct the Personal Information that we hold about you. If you want to review, verify, correct, or withdraw consent to the use of your Personal Information you may also send us an email at support@CloutHub.com to request access to, correct, or delete any Personal Information that you have provided to us. Please note that 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 obligation or cause the information to be incorrect. CloutHub® will provide access to your Personal Information, correct any factual inaccuracies identified (subject to limited exceptions prescribed by law), or remove Personal Information as requested. We may request certain Personal Information for the purposes of verifying your identity. If access or correction request to your Personal Information is denied for any reason, you will receive notification of the denial and underlying reason in writing via email. If you are concerned about our response or would like to correct the Personal Information provided, you may contact our Privacy Officer Todd Callender at privacy@clouthub.com.Withdrawing your Consent
Where you have provided your consent to the collection, use, and transfer of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support@CloutHub.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We may explain the impact to you at the time to help you make your decision.Minor Access to Platform
Our Platform and Services are not intended for use or access by children under 16 years of age. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Platform and/or Services or provide any information about yourself to us. If we learn we have collected or received Personal Information from a child under 16 without verification of parental or guardian consent, we will delete that information. If you believe we might have obtained any Personal Information from or about a child under 16, please contact us at privacy@clouthub.com. Personal Information Breach In the event that we suffer a breach of Personal Information, and such breach is determined to be likely to result in a high risk to the rights and freedoms of natural persons and/or Users, we will notify affected Users as soon as possible and describe the nature of the breach (“Breach Notification”). However, such Breach Notification will not be required in instances such as:- where we have implemented appropriate technical and organizational protection measures which have been applied to the affected Personal Information that render the Person Information unintelligible or encrypted;
- we have taken subsequent measures to ensure that the high risk to the rights and freedoms of data subjects is no longer likely to materialize; or
- such Breach Notification would involve disproportionate effort, and instead all Users would be provided with a general, public communication as to the events.
COMPLIANCE AND APPLICATION
Changes to this Privacy Policy
This Privacy Policy may be updated periodically to reflect changes to our Personal Information practices. The revised Privacy Policy will be posted on the Platform and is effective immediately. We strongly encourage you to refer to this Privacy Policy frequently for the latest information about our Personal Information practices. Continued use of the Platform and/or Services after any such changes constitutes your consent to such changes. If material changes are made to our Privacy Policy an email will be sent out to all Users notifying them of the update(s).Application of Law
State consumer privacy laws may provide their residents with additional rights regarding our use of their Personal Information. CloutHub® also abides by the rules and regulations as set out by the GDPR. To exercise any of the rights provided, please email our Privacy Officer at privacy@clouthub.comYour data protection rights
CloutHub® wants make sure you are fully aware of all of your data protection rights. Every User is entitled to the following: The Right to Access: You have the right to request copies of your Personal Information from CloutHub®, and other related information such as:- the purposes for which the Personal Information was processed;
- the categories of Personal Information concerned;
- the recipients/categories of recipients to whom the Personal Information has been disclosed;
- the period for which the Personal Information will be stored (where possible);
- the existence of the right to request the rectification or erasure of Personal Information; or
- the right to lodge a complaint with a supervisory authority.
- the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed;
- where you have withdrawn your consent;
- you object to the processing and there are no overriding legitimate grounds for the processing;
- the Personal Information was processed unlawfully; or
- the Personal Information has to be erased for our compliance purposes.
- processing of the Personal Information is necessary for exercising the right of freedom of expression and information;
- for compliance with legal obligations or for task carried out in the public interest;
- for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes insofar as the right to erasure is likely to render impossible or seriously impair the achievement of these objectives; or
- for the establishment, exercise or defense of legal claims.