Privacy Policy

CLOUD ACE CO., LTD (“we,” “our,” or “us”) recognizes the importance of data protection for our customers (“you,” or “your”) and establishes this Privacy Policy (this “Policy”) to ensure the proper handling of your Personal Information (as defined below) in accordance with the applicable laws and regulations in respect with protection of your Personal Information (“Applicable Laws”).

1. PERSONAL INFORMATION WE COLLECT

We will collect and process the following Personal Information (data which relates to a living individual who can be identified from that data or from that data and other information that is in the possession of, or is likely to come into the possession of us, hereinafter the same in this Policy).

  • Name, postal address, company name, department name, job title, email address; and phone number.

  • Information about business negotiations and transactions

2. USE OF PERSONAL INFORMATION

We may use and process your Personal Information for one or more of the following purposes indicated below:

  • To provide our products and services
  • To provide announcements and conduct sales activities about our products and services
  • To contact you about our latest information and seminars, events and exhibitions
  • To request surveys and other questionnaires
  • To provide information about our business activities

3. LEGAL GROUND FOR DATA PROCESSING

3.1 We will primarily process your Personal Information based on your consent to this Policy. If you wish to withdraw your consent pursuant to the Applicable Laws, you may do so at any time by informing us of the withdrawal of consent to us through our contact channel that is specified in “9. CONTACT US”. However, the withdrawal of consent will not affect the collection, use, or disclosure of Personal Information you have already given consent to us.

3.2 Other than where justified by your consent, we will usually process Personal Information where necessary pursuant to the Applicable Laws (i) for the performance of contracts executed with you; (ii) for ensuring compliance with our legal obligations; and (iii) for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests.

3.3 We will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.

4. SHARING OR DISCLOSURE OF PERSONAL INFORMATION

4.1 We may share or disclose your Personal Information as set forth in “1. PERSONAL INFORMATION WE COLLECT” to a third party for the purposes listed in “2. USE OF PERSONAL INFORMATION”, including but not limited to, our group companies and service providers listed below and may jointly use your Personal Information with our group companies under our management responsibility. These third parties will be subject to appropriate data protection obligations and they will only use your Personal Information as described in this Policy.

Salesforce Japan Co.,Ltd.
Nissey Marunouchi Garden Tower
1-1-3, Marunouchi, Chiyoda-ku,Tokyo 100-0005, Japan

Google LLC
1600 Amphitheatre Parkway
Mountain View, CA 94043. USA

Slack Technologies Limited
Salesforce Tower
60 R801, North Dock, Dublin. Ireland

Zendesk, Inc.
989 Market St
San Francisco, CA 94103. USA

Sansan, Inc.
Aoyama Oval Building 13F, 
5-52-2 Jingumae, Shibuya-ku, Tokyo 150-0001, Japan

4.2 We may share or disclose your Personal Information to the extent required by law, for example if we are under a duty to disclose your Personal Information in order to comply with any legal obligation, or to establish, exercise or defend our legal rights.

5. SOURCES OF PERSONAL INFORMATION

We collect your Personal Information as set forth in “1. Personal Information We Collect” directly from you. In other instances, we collect your Personal Information as set forth in “1. Personal Information We Collect” from our group companies to which each employee belongs.

6. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

In sharing or disclosing your Personal Information to a third party, we may transfer your Personal Information to countries outside your country of residence. These countries may not have personal data protection laws as comprehensive as those that exist in your country of residence, and the same level of protection as that set forth in the personal data protection laws in your country may not necessarily be guaranteed. In such case, we shall implement necessary safety management measures pursuant to the requirements of to any and all the Applicable Laws.

7. RETENTION OF PERSONAL INFORMATION

Your Personal Information will be stored securely in our data server or in the third-party’s data server. We will strictly control access to this information and will review such access control from time to time. We will not keep your Personal Information for longer than required for the purpose of which it has been processed, in accordance with the Applicable Laws or, in any case, to allow us to protect our or a third party’s legitimate rights and interests. To determine the appropriate retention period for the Personal Information, we shall consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, the purposes for which we process the Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. YOUR RIGHTS AND CHOICES UNDER APPLICABLE LAWS

8.1 Pursuant to the Applicable Laws, you may have several rights on our processing of your Personal Information, which may include, to request access to, correct, or delete your Personal Information, to restrict processing of your Personal Information, to ask for data portability, and to withdraw your consent to this Policy. You are also entitled to object to the processing of your Personal Information in certain instances pursuant to the Applicable Laws.

8.2 When we receive a request based on your rights above, we will conduct all necessary investigations without delay and consider whether your request meets the criteria and condition to exercise such rights under the Applicable Laws. To exercise your rights specified in this section, you can reach out to us through our contact channel that is specified in “9. CONTACT US”.

9. CONTACT US

If you have any questions or comments about this Policy, the ways in which we collect and use your Personal Information described above, or wish to exercise your rights provided in “8. YOUR RIGHTS AND CHOICES UNDER APPLICABLE LAWS”, please do not hesitate to contact us at:

Address: H3 Building, 1st floor, 384 Hoang Dieu, Ward 6, District 4, Ho Chi Minh City, Vietnam

Email Address: legal-cavn@cloud-ace.com

Effective: July 1st, 2024


Supplementary Provisions for Processing of Personal Information of California Residents

In addition to the provisions set forth above, the following provisions apply to the processing of Personal Information of residents residing in the state of California in the United States (that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household, hereinafter the same in this Supplementary Provisions)) in accordance with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).

1. Categories of Personal Information We Collect and the Parties Receiving the Information

We will collect and has collected in the last twelve (12) months, the following categories of personal information from you. Further, we have disclosed the Personal Information collected in the last twelve (12) months to the receiving party indicated in “3. SHARING OR DISCLOSURE OF PERSONAL INFORMATION” above.

Category
Identifiers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Commercial Information

For details on personal information we collect, refer to “1. PERSONAL INFORMATION WE COLLECT” above, for the business purpose and commercial purpose of personal information we collect, refer to “2. USE OF PERSONAL INFORMATION” above, for the sources of Personal Information we collect, refer to “5. SOURCES OF PERSONAL INFORMATION” above, and for the retention period of the personal information we collect, refer to “7. RETENTION OF PERSONAL INFORMATION” above.

2. Your Rights and Choices under CCPA

The CCPA provides residents of California with specific rights regarding personal information. If the you are is a California resident, the following describes your rights under the CCPA and explains how to exercise those rights.

 

(1) Right to access personal information

You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your personal information. Once we receive and confirm your verifiable request, we will disclose the following information to you:

  • The categories of Personal Information we collected about you;
  • The categories of sources for the Personal Information we collected about you;
  • Our business or commercial purposes for collecting, selling, or sharing such Personal Information;
  • The categories of third parties with whom we share such Personal Information;
  • The categories of Personal Information that we sold, and for each category identified, the categories of third parties to whom we sold such Personal Information;
  • The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed such Personal Information; and
  •  The specific pieces of Personal Information we collected about you.

 

 (2) Right to request deletion

You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and notify our contractors to delete the same) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our contractors in order to:

  • Complete the transaction for which personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
  • Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
  • Debug products to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights provided for by law;
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; and
  •  Enable solely internal uses that are reasonably aligned with consumer expectations based on the relationship between you and us; or
  • Comply with legal obligations.

 

 (3) Right to request correction

You have the right to request that we corrects any of your inaccurate personal information that we have collected from you and retained. Once we receive and confirm your verifiable request, we will correct (and notify our contractors to correct the same), your inaccurate personal information. We may deny your request for correction if we determine that the contested personal information is more likely than not to be accurate based on the totality of the circumstances.

 

(4) Right to opt-out of sale or sharing

We have not sold or shared personal information collected from You in the last twelve (12) months and it will not sell or share them in the future.

 

(5) Right to limit the use of sensitive personal information

We have not used and disclosed and will not use or disclose sensitive personal information collected from you for any purpose other than the following:

  • To perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services;
  • To help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
  • For short-term, transient use (except those involving profiling or changes to the future consumer experience);
  • To perform services on our behalf; and
  •  To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us.

 

 (6) Non-discrimination

We will not discriminate against California residents for exercising any of their rights under the CCPA. Moreover, unless permitted by the CCPA, we will not:

  • Deny the goods or services to you;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services;
  •  Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or
  • Retaliate against an employee, applicant for employment, or independent contractor.

 

 (7) Exercising rights for disclosure request, deletion request and correction request

To exercise your rights for disclosure request, deletion request and correction request described above, please submit a verifiable request to us by contacting us in the manner set forth in section “9. CONTACT US” above.

Only you, a natural person or a person registered with the California Secretary of State that you authorize to act on your behalf, or a person who has a power of attorney or is acting as a conservator for you, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child.

The verifiable request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information or an authorized representative; and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.