Privacy Permissions

As of January 1, 2020 Your privacy is important to us. This Privacy Policy (“ Policy ”) applies to services provided by Cloud Castles, Inc.. (“ we ”, “ us ”, or “ Cloud Castles ”) and our website, mobile app, or other platform (collectively, the “ Services ”) explains what information we collect from users of our Services (a “ user ”, “ you ”, or “ your ”), including information that may be used to personally identify you (“ Personal Information ”) and how we use it. We encourage you to read the details below. This Policy applies to any user or visitor to or user of our Services. We will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services. We reserve the right to change this Policy at any time. We will notify you of any changes to this Policy by sending notice to the primary email address specified in your account or by a prominent notice on our website. Significant changes will go into effect thirty (30) days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check our website, including this privacy page, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and sharing of your Personal Information is subject to the updated Policy. What Information Do We Collect? Information Provided by You to Us We collect information that you knowingly give us when you create an account, contact us, or otherwise access or use our Services. This may include: Your name, email address, postal address, gender, telephone number, profession, social security numbers, date of birth, employer, employer address, your responses to surveys that we may ask you to complete for research purposes or to help direct Cloud Castles activities, the contact information of your representative, your social media account information Details of any financial transactions you participate in on the Services, including the amount, currency, and method of payment. Information Collected Automatically Your internet protocol address (i.e., IP address) and, if you access the Services from a mobile application, your unique mobile device ID number and non-email authentication. Browser and device information and information collected through technologies such as cookies, pixel tags, and other technologies. This Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. How Do We Use The Information We Collect? We use the information we collect to: Deliver and improve the Services and your overall user experience. To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity. To link or combine user information with other Personal Information. To compare and verify information for accuracy and update our records. To validate information from users for identity verification, including verification for AML and KYC protocols. Email, text, message, or otherwise contact you with information and updates about us and the Services, and respond to your comments and questions, if you’ve provided us with the means to do so. On a de-identified, aggregated basis, analyze how you use the Services with tools such as Google Analytics and other tools to help us understand traffic patterns and know if there are problems with the Services. Create targeted advertising to promote the Services and engage our users. Do We Share Your Personal Information? We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized, as set forth below. To help us do our work, we may provide limited access to some of your Personal Information to the following third parties: Partners: Sometimes we collaborate with other organizations, including our broker-dealer, to deliver the Services. In these cases, we may share your name, contact information and other details you provided when making an account with our partners. Affiliates: We may share your information with our affiliates and/or subsidiaries. Service Providers: We work with a wide range of third party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, and other non-governmental organizations. We may store your Personal Information and other information, such as suitability information and accreditation, investment experience, user survey responses, in our databases or any information that is necessary to enable us to operate effectively and deliver our services to you. We collect financial account information or card payment information either directly or through our partners or service providers, and we may collect information to verify your income or net-worth. Please note that we do not store your card payment information, but we do store other financial information. We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; and to protect the rights or property of Cloud Castles. In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes. Any third party with whom we share your data will be required to provide the same or equal protection of such data as stated in this privacy policy. Protection of Cloud Castles and Others We will also share Personal Information with companies, organizations or individuals outside of Cloud Castles if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims, or protect against harm our legal rights or safety. How Do We Use Tracking Technologies? A “cookie” is a small file placed on your hard drive by some of our web pages. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies are commonly used at most major transactional websites in much the same way we use them in our Services. Even if you are only browsing the Services, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services) is automatically collected about you. This information will be collected every time you access the Services and it will be used for the purposes outlined in this Privacy Policy. You can prevent or limit the usage of cookies collected from your device. An easy way of doing this is often to change the settings in your browser. If you do that you should know that (a) your use of the Services may be adversely affected (and possibly entirely prevented), (b) your experience of this and other sites that use cookies to enhance or personalize your experience may be adversely affected, and (c) you may not be presented with advertising that reflects the way that you use our and other sites. You find out how to make these changes to your browser at this site: www.allaboutcookies.org/ manage-cookies/. Unless you have adjusted your browser settings so that it will refuse cookies, our system will send cookies as soon as access our Services. By using the Services, you consent to this, unless you change your browser settings. Web beacons may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you visit the Site or access the Services and to help determine how you found the Services. If you would like more information about this and to know your choices about not having this information used by these companies, please visit: the Digital Advertising Alliance’s website, http://www.aboutads.info/, or the Network Advertising Initiative’s website, http://networkadvertising.org/consumer/opt_out.asp. How Do We Secure Your Personal Information? Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Your Choices Regarding Information You have several choices regarding the use of Personal Information on the Services: Changing or Deleting Your Personal Data. All users may review, update, correct or delete the Personal Information furnished by a user in their user account (including any imported contacts) by contacting us at [email protected] or by accessing your user account. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your Personal Information, then your user account may become deactivated. If you wish to cancel your account, you may do so by emailing [email protected], and any personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes. Download or Access Personal Information. You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine readable form by emailing us at [email protected]. Opting Out of Email Communications. We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Cloud Castles features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language) in those communications. You can also contact us at [email protected] to opt out. Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our terms of service or privacy policy. Links to Third Party Websites We may provide links to other websites. We have no control over these websites, and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third party websites. By using the Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites. How We Respond to Do Not Track Signals Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com. Third Party Direct Marketing We do not share personal data with third parties for their directly marketing purposes without your consent. A Note to Users Outside the United States Cloud Castles is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. Contact Us If you have any questions about this Policy, your Personal Information, or the Services, you can contact [email protected]. Cloud Castles Referral Program Terms and Conditions As of January 1, 2020 The Cloud Castles Referral Program (the “Referral Program”) allows Cloud Castles Customers to receive promotional property shares by referring their friends to use Cloud Castles’s Services. To participate, Cloud Castles members must agree to these Referral Program Terms and Conditions (“Referral Terms”), which become part of the Cloud Castles Terms of Service, and which govern your participation in the Referral Program. Capitalized terms that are not defined here will have the same meaning given to them in the Terms. You acknowledge and agree that Cloud Castles’s Referral Program is not intended for and cannot be used by businesses or individuals for affiliate lead generation and that Referral Links (defined below) cannot be posted on discount websites. Both you and the referred Customer must be eligible to use Cloud Castles’s Services to be eligible for the Referral Program. How to Receive referral credits Customers can receive one (1) share towards a future purchase of a property on the Cloud Castles platform for Customer’s use of the Services if: (i) you as a Cloud Castles Customer send someone you know a unique Referral Program code that was provided to you by Cloud Castles (“Referral Link”); (ii) the referred Customer clicks on your Referral Link and creates a valid Cloud Castles Account; and (iii) the referred Customer is actively using the Services by purchasing shares in a property or adding a property to their watch list. If all these conditions are met and subject to compliance with these Referral Terms, both the referring Customer and the referred Customer will get one (1) share (“Referral Credit”) applied toward both of their Cloud Castles Accounts. Redeeming Referral Credits Referral Credits are issued for promotional purposes only; they may not be transferred or exchanged for cash. Referral Credits can only be redeemed on the Cloud Castles application. Customers can view their current Referral Credit balance via their Cloud Castles Account settings. Referral Credits are automatically credited to any purchase on your account at checkout. Subject to applicable law, Referral Credits expire within 12 months of the date on which Customers receive such Referral Credits into their Accounts. After the 12-month period expires, any unclaimed Referral Credits will be forfeited. Referring Customers are eligible to receive multiple Referral Credits if they make multiple referrals that qualify for a Referral Credit as part of this Referral Program subject to compliance with the remaining terms. If for any reason you believe that there is a discrepancy regarding your Referral Credit balance, please contact us at [email protected]. All decisions regarding Referral Credit balances will be final and at Cloud Castles’s sole discretion. You are responsible for any tax consequences that may result from the redemption or use of Referral Credits. Where applicable, Cloud Castles may be required to account for VAT on any Services for which the Referral Credits are redeemed. Prohibited Conduct Multiple Referrals: A referred Customer may only use one Referral Link. If a referred Customer receives Referral Links from multiple Cloud Castles Customers, the referred Customer may only use one Referral Link and obtain one Referral Credit. Existing Customers: Existing Customers cannot send Referral Links to themselves (for example, you are not permitted to use a different email address to send a Referral Link to yourself). Sending yourself a Referral Link and using that Referral Link to receive a Referral Credit on your Account is prohibited and a violation of these Referral Terms. Applicable Laws: You agree to comply with all applicable laws, including, but not limited to the CAN SPAM Act in connection with using the Services and participating in this Referral Program. Any distribution of your Referral Link that could constitute unsolicited commercial email or “spam” under any applicable law is expressly prohibited and will be grounds for immediate termination of any your Account, exclusion from Referral Program, and forfeiture of any Referral Credits in your Account. This includes mass emailing, texting, or messaging people you do not know or using automated systems or bots to distribute your Referral Link. Severability If any provision in these Referral Terms are held to be invalid, void, or unenforceable, such provision (or the part of it that is making it invalid, void or unenforceable) will be struck and not affect the validity of and enforceability of the remaining provisions. Termination and Changes Cloud Castles may suspend or terminate the Referral Program or your ability to participate in the Referral Program at any time for any or no reason. The scope, variety, and type of services and products that users may obtain by redeeming Referral Credits can change at any time. We reserve the right to suspend Accounts or remove Referral Credits if we notice any activity that we believe is abusive, fraudulent, or in violation of the Terms, including these Referral Terms. We reserve the right to review and investigate all referral activities in our sole discretion as deemed fair and appropriate. Subject to applicable laws, if the Referral Program is terminated, any unclaimed Referral Credits will be forfeited at that time. Updates to the Referral Terms We may update these Referral Terms at any time, at our sole discretion. If we do so, we’ll let you know either by posting the updated Referral Terms to the Services or through other communications. It’s important that you review these Referral Terms whenever we update them. If you continue to participate in the Referral Program after we have posted updated Referral Terms, you are agreeing to be bound by the updated Referral Terms. If you don’t agree to be bound by the updated Referral Terms, then you may not participate in the Referral Program anymore. Who we are Our website address is: https://cloudcastles.io. What personal data we collect and why we collect it Comments When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment. Media If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website. Contact forms Cookies If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year. If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day. Embedded content from other websites Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website. Analytics Who we share your data with How long we retain your data If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue. For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information. What rights you have over your data If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes. Where we send your data Visitor comments may be checked through an automated spam detection service. Your contact information Additional information How we protect your data What data breach procedures we have in place What third parties we receive data from What automated decision making and/or profiling we do with user data Industry regulatory disclosure requirements Cloud Castles Inc, Interested in Cloud Castles? Email us at [email protected] or call us at (510)896-9364 Built by people in California, who want people to own real-estate anywhere.