This is the Privacy Policy (“Policy”) of Continental Expeditions Inc. d/b/a CloudX (collectively, “we,” “us,” “our,” or “CloudX”). This Policy is here to help you understand how we collect, process, and share your Personal Data (as defined below) on our website, platform, and related services. We also describe our security practices with respect to your Personal Data, as well as your rights & choices with respect to how we process that Personal Data. Please read this Policy carefully.

Scope & acknowledgment

This Policy applies to our “Services”, which consist of:

• our advertising platform for app developers, publishers, and advertisers, including our related SDKs, pixels, or other integrations (the “Platform”) and related services (collectively, “Advertising Services”); and
• our corporate website located at https://www.cloudx.io/ and any other website where we post or link to this Policy (the “Website”).

This Policy does not apply to information processed by third parties, for example, when you interact with advertisers or publishers and their advertisements, websites, and services, except to the extent the enable the operation of our Advertising Services. Please review any relevant third party’s privacy policy for information regarding their privacy practices.

Your use of any portion of our Services indicates your acknowledgement of the notices provided in this Policy.

Categories and sources of personal data

Categories of Personal Data we Process

As part of our Services, we may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements are examples and may change):

Contact Data - Identity Data used to contact an individual, e.g. email address, physical address, or phone number.

Device/Network Data - Personal Data relating to your device, browser, or application e.g. device identifiers, advertising IDs, HTTP header information, vendor or advertiser IDs, tracking preferences, identifiers from cookies, session history and web navigation metadata, app or website utilization or interaction data, and other similar data generated through applications and browsers, including via cookies and similar technologies.

General Location Data - Non-precise location data, e.g. location information derived from IP addresses.

Identity Data - Personal Data about you and your identity, such as your name or IP address, online identifiers, or unique personal IDs.

Inference Data - Personal Data we create or use as part of a profile reflecting your preferences, characteristics, aptitudes, market segments, likes, favorites, or your interests, as well as data relating to inferred contexts in which you interact with a service, such as products or interests that may be inferred from your interaction with our Platform through a publisher’s website or application.

Transaction Data - Information about the products and services we provide to you and about transactions you make either through us or our Advertising Partners (defined below), e.g. advertisement click through, conversion, and the like.

User Content - Personal Data included in content provided by users of our Services in any free-form or unstructured format, such as a text in a “contact us” box, in a file or document, or any other message to us.

Sources of Personal Data

We collect Personal Data from various sources based on the context in which the Personal Data will be processed:

You- We collect Personal Data from you directly on behalf of yourself or, in some cases, your organization, for example, when you create an account, input information into an online form, or contact us directly.

Automatic Collection - We may collect certain Personal Data automatically. For example, we collect Device/Network Data automatically using cookies and similar technologies when you use our Services, access our Services, or when you open our marketing communications.

Service Providers - We receive Personal Data from service providers performing services on our behalf, including payment processors, web hosting service providers, or our delivery and installation partners.

Data we create or infer - We, certain partners, and third parties operating on our behalf create and infer Personal Data such as Inference Data based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you.

Advertising Partners -  We receive Personal Data from advertisers, ad networks, exchanges, demand side platforms, merchants, other advertising partners, as well as optimization and measurement/attribution partners that provide services to us or customer and other social media companies when you interact with our Advertising Services on the Advertising Partner’s own advertisements or services or otherwise in connection with our Services.

Data processing contexts / notice at collection

Advertising Services

This section applies only to our Advertising Services. See below for information relating to the operation of our Website or other data processing contexts.

Platform Account Registration

If you are a user accessing our Platform on behalf of an Advertising Partner, you may create an account. We process Identity Data, Inference Data, Device/Network Data, and Contact Data when you sign up and create that account on our Platform. We process this Personal Data to create and maintain your account, to provide the products and services you request, and for our Business Purposes, and where allowed by law, in connection with Marketing Communications.

Advertising Services

Our Advertising Services involve the enablement and delivery of Targeted Advertising through our Advertising Partners. When our Advertising Partners implement our Advertising Services, we collect and process Identity Data, Device/Network Data, Contact Data, General Location Data, Transaction Data, and Inference Data. That data may be derived from information provided by the Advertising Partner or collected from the operation of our Platform in connection with the services operated by our Advertising Partner. We process this Personal Data as necessary to deliver our Services to our clients and Advertising Partners, to operate the Platform and for our Business Purposes. Our Advertising Services are also used in connection with Targeted Advertising and for other Commercial Purposes.  

Please note: Our Advertising Services may involve the use of artificial intelligence, e.g. to determine the advertisements that might be of greatest relevance or interest to a given user, audience, or publisher. However, we do not intend for or permit our Services to be used to create decisions that will have a legal or similarly significant effect on you.

Please note: Our Advertising Partners are independent third-party controllers and this Privacy Policy does not apply to our Advertising Partners. Please review their privacy policies for more information.

Our Corporate Website and User Portals

This section applies only to the processing of Personal Data on our Website and interactions with the Platform user interface (e.g. portals or dashboards) (“User Portals”). See above for more information regarding our Advertising Services.

Generally

When you visit our Website or use our User Portal, we automatically collect and process Identity Data, Inference Data, General Location Data, and Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Website/Portal, such as delivering webpages or logging activities for security purposes. We may also process this Personal Data for our Business Purposes.

Cookies and Similar Tracking Technologies

We process Identity Data, Device/Network Data, Contact Data, Inference Data, Transaction Data, and General Location Data in connection with our use of cookies and similar technologies on our Website and User Portals. We may collect this data automatically.

We and authorized third parties may use cookies and similar technologies to process such data for the following purposes:

• for “essential” purposes necessary for our Website or User Portal to operate (such as maintaining user sessions, content delivery, and the like);
• for “functional” purposes that enable certain features of our Website or User Portal (for example, to allow users to store preferences, such as preferred language);
• for “analytics” purposes related to the improvement of our Website and User Portal (for example, we can count how many people have looked at a specific page, see how many users use a given feature, distinguish unique visits/visitors to our Website or User Portal, determine referral websites, and analyze other user behaviors that help us improve the design and functionality of the Website and  Portal);

We may also process this Personal Data for our Business Purposes. See the “Rights and Choices” section below for information regarding opt-out rights for cookies and similar technologies.

Contact Us

We process Identity Data, Device/Network Data, and any Personal Data contained within any User Content when you contact us using a contact form or email to ask a question or request support. We process Identity Data, Contact Data, and User Content as necessary to communicate with you about the subject matter of your request and related matters. We may also process this Personal Data for our Business Purposes and if appropriate and where permitted by law, for Commercial Purposes.

Social Media Posts

We process Identity Data, Contact Data, and User Content if you interact with or identify us on social media (e.g. if you post User Content that engages with or tags our official accounts). We process this Personal Data to promote our business, interact with you on social media, and for our Business Purposes and Commercial Purposes (which may include data sales/sharing).

Transactional and Promotional Communications

We process Identity Data, Device/Network Data, and Contact Data in connection with email or SMS communications that we send in relation to our Services. For example, we send transactional emails communications to you if you create an account on our Platform, subscribe to our Advertising Services, or in connection with our delivery of other products or services that you request. Additionally, you may receive promotional email communications if you contact us, choose to receive them, or interact with us in way that allows us to send you those communications (“Marketing Communications”). We may also automatically collect Device/Network Data when you open or interact with those communications so that we can better understand engagement with our communications.

We may process this Personal Data for our Business Purposes and Commercial Purposes (which may include data sales/sharing). You can opt out of promotional communications at any time as specified in the “Rights & Choices” section below.

Feedback

We process Identity Data, Contact Data, and User Content collected in connection with user feedback and reviews that you may submit through our Website or Platform. We process this Personal Data as necessary to respond to your feedback or concerns, for our Business Purposes, and other legitimate interests, such as analyzing user satisfaction or for marketing purposes. Where appropriate, we may also process this Personal Data for our Commercial Purposes (which may include data sales/sharing). We may share Feedback data relating to a third-party service provider or Advertising Partner with those parties, who may use it for their own purposes.

Purposes of processing

Business Purposes

In addition to the processing described above, we generally process Personal Data for several common purposes in connection with our business. Please see below for more information regarding the purposes for which we process your Personal Data.

Operate our Services and Fulfill Obligations

We process any Personal Data as is necessary to provide the Services, and as otherwise necessary to fulfill our obligations to you, e.g. to provide you with the information, features, and services you request.

Internal Processes and Service Improvement

We may use any Personal Data we process through our Services as necessary in connection with our improvement of the design of our Services, to train and develop artificial intelligence algorithms (to the extent permitted by applicable law), to better understand how the Services are used, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to the use of our Services, and for ensuring the security and stability of the Services. Additionally, we may use Personal Data to understand what parts of our Services are most relevant to users, how users interact with various aspects of our Services, how our Services perform or fail to perform, etc.

Security and Incident Detection

We may process Personal information in connection with our legitimate interest in ensuring that our Services are secure, identify and prevent crime, prevent fraud, and verify or authenticate users/individuals, and ensure the safety of our users. Similarly, we process Personal information as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns, and characteristics, maintain and analyze logs and process similar Personal information in connection with our information security operations and related processes.

Aggregate Analytics

We process Personal Data as necessary in connection with our creation of aggregate analytics relating to how our Services are used, the pages and content users view, and to create other reports regarding the use and performance of our Services, and other similar information and metrics. The resulting aggregate data will not contain information from which an individual may be readily identified.

Compliance, Safety & Public Interest

Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Data subject to this Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Commercial Purposes

We and certain third parties process Personal Data to further our commercial or economic interests (“Commercial Purposes,”) depending on the context of collection and your Rights & Choices.

Please Note – We may require your consent, or we may not engage in processing of Personal Data for Commercial Purposes in some jurisdictions. Some of this processing may involve “sales” or “sharing” of Personal Data. See the “Regional Supplements” section below for more information.

Targeted Advertising

The advertising we enable through our Advertising Services involves the processing of Personal Data in order to tailor advertisements based on your interests and activity across various unaffiliated websites and online services (“Targeted Advertising”). Through our Platform, we enable Targeted Advertising by allowing third-party mobile application providers or other third-party offer ad inventory on certain digital properties, and our advertising partners to bid on and place third party advertisements on that ad space.

In each case, the profiles and interests created and processed for Targeted Advertising may be inferred or derived from Personal Data that we or various third parties obtain or infer from your activities across the websites, applications, or services you use. Note that you may interact with us and we may process your Personal Data for Targeted Advertising when you interact with us directly (e.g. on our Website or Platform) or indirectly when a mobile application, platform, or service contains our SDK, or when you interact with other websites or online services that embed our pixel, API, or similar technologies (including Cookies and Similar Technologies). Further, Targeted Adverting includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Data in connection with Targeted Advertising. These parties may be able to identify you across sites, devices, and over time. In some cases, these third parties may build or augment user profiles using your Personal Data, and may track whether you view, interact with, or how often you have seen an ad, or whether you purchased advertised goods or services.

Data sharing

Personal Data we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the categories of recipients or in connection with specific business purposes, described below.

Service Providers

In connection with our general business operations, product improvements, to enable certain features, and in connection with our other lawful business interests, we may share Personal Data with service providers or subprocessors who provide certain services to us, or process data on our behalf. For example, we may use third party hosting providers to host our Website, Platform, or content and use third-party payment processors to process payment transactions. We may also engage with certain advertising measurement service providers that process Personal Data on our behalf, to the extent permitted by applicable law.

Advertisers and Publishers

We share information with our Advertising Partners. Advertising Partners may process Personal Data for Targeted Advertising, to measure how effective ads are, and to undertake analytics to analyze traffic and other ad activity to improve the advertising experience. Note that Advertising Partners are generally independent third-party controllers and their processing of Personal Data is subject to those partners’ own privacy practices and privacy policies, and you should contact them directly to exercise your rights in Personal Data.

To learn more about your rights in Targeted Advertising conducted through our Services, please see the “Your Rights and Choices” section below.

Corporate Events

Your Personal Data may be disclosed to a third party in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Affiliates

In order to streamline certain business operations and develop products and services that better meet the interests and needs of our customers, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.

Legal Disclosures

In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, our correspondence with you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

Your rights & choices

Your Rights

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law. See the following sections for more information regarding your rights/choices in specific regions:

• US States/California
• EU/EEA/UK/Switzerland

Note: We are able to fulfill rights requests regarding Personal Data that we control or process. We may not have access to or control over Personal Data controlled by third parties. Please contact the third party directly to exercise your rights in third party-controlled information.

Verification of Rights Requests

We verify all rights requests to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. For example, we may require that you verify that you have access to the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

Your Choices

You may have the following choices regarding the Personal Data we process, to the extent required under applicable law:

Consent

If we rely on your consent to our processing of Personal Data, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services.

Marketing Communications

You can withdraw your consent to receive Marketing Communications by clicking on the unsubscribe link in an email (for email), by responding with “OPT-OUT”, "STOP", or other supported unsubscribe message (for SMS), or for other communications, by contacting us using the information below. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Cookies & Similar Technologies

If you do not want information collected through the use of cookies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu or our "Manage Cookie Preferences" page. You may need to opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Targeted Advertising

You may opt out or withdraw your consent to Targeted Advertising by visiting our Opt-Out Request Form. In some cases, you may be able to opt-out by submitting requests to third party partners, including for the vendors listed below:

• Digital Advertising Alliance’s opt-out
• Meta Pixel

Do Not Track

Our Website does not respond to your browser’s do not track signal.

Security

We implement and maintain reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and though we may take certain measures to help ensure the security of your Personal Data, we do not control third parties’ security processes. We do not warrant perfect security, and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.

Data retention

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Policy, or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data (without limitation):

• Retention periods established under applicable law;
• Industry best practices;
• Whether the purpose of processing is reasonably likely to justify further processing;
• Risks to individual privacy in continued processing;
• Applicable data protection impact assessments;
• IT systems design considerations/limitations; and
• The costs associated continued processing, retention, and deletion.

We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.

International transfers

We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be processed in the U.S. The U.S. may not provide the same legal protections guaranteed to Personal Data in foreign countries. Contact us for more information regarding transfers of data to the U.S.

Children

Our Services are neither directed at nor intended for use by persons under the age of 18. We do not knowingly collect information from such individuals. If we learn that we have inadvertently done so, we will promptly delete such Personal Data if required by law. Do not access or use our Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

Changes to our policy

We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Services following notice of any changes indicates acceptance of any changes.

Contact us

The controller of your Personal Data under this Policy is Continental Expeditions Inc., d/b/a CloudX. You may contact us as follows:

General Inquiries: privacy@cloudx.io

Data Rights Requests: Use the Privacy Rights Request Form or email privacy@cloudx.io

Manage Website cookies: Use our Cookie Management Tool

Direct Marketing Disclosure Inquiries: email privacy@cloudx.io

Physical Address: 625 E Main St., Suite 102B, Aspen, CO 81611