Privacy Policy

Introduction and Scope

CloudTwin ("CloudTwin", "RedHold LLC", "RedHold", "we", "us" or "our") respects the privacy of our Website visitors ("you" or "your"). This privacy policy (as posted on our website here at https://cloudtwin.ai/privacy and as amended from time to time and effective as of the date posted) ("Privacy Policy") describes the types of information we collect from you or that you may provide when you visit or use our cloudtwin.ai website ("Website"), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information.

This Privacy Policy applies to the data collected by us, or those working on our behalf, through the information you enter or from the data imported from sources authorized or approved by us. It does not apply to data collected through third-party websites, or to products, or services not approved by us.

If you are a customer, the collection, use, disclosure, etc., of Personal Information in connection with the services we provide customers ("Services") is governed by the terms of our Subscription Agreement with your company, and this Privacy Policy does not apply to data collected under such agreement.

Acknowledgement and Consent

By visiting our Website in any manner you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, process, share, retain, and transfer your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website.

Your use of our Website is at all times subject to our Terms of Use (available at https://cloudtwin.ai/terms and as amended from time to time and effective as of the date posted (the "Terms")), which is incorporated by reference herein. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

Changes to Our Privacy Policy

We are constantly working to improve our Website, and we may need to change this Privacy Policy from time to time as well. Our current Privacy Policy will always be on our Website at https://cloudtwin.ai/privacy and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates.

If you use the Website after any changes to the Privacy Policy have been posted, you agree to the new Privacy Policy. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

What Information Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of your personally identifiable information. "Personal Information" generally refers to any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person.

If you are a citizen or resident of the European Economic Area ("EEA"), United Kingdom, or Switzerland, the definition of Personal Information is defined under the General Data Protection Regulation ("GDPR") and you have certain rights; therefore, please see the section below entitled "GDPR".

Personal Information does not include information publicly available from government records or information excluded by applicable law. Personal Information also does not include your Personal Information that has been de-identified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable.

Individuals under the Age of 18

We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under the age of 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database.

Personal Information We Collect

We collect several categories of Personal Information from and about you as summarized in the following table:

Information You Provide Us:

• Information that you provide by filling in web forms on our Website
• Records and copies of your correspondence (including email addresses)
• Your responses to surveys that we or our Service Providers might ask you to complete
• Your search queries on the Website
• When communicating with customer service/support
• Through participation in loyalty/rewards programs
• Third party websites and mobile applications
• Joint marketing partners
• Online advertising companies
• Social media companies
• Other Service Providers
• Responding to employment opportunities
• Applying to become a certified or approved partner or reseller

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following:

• Details of your visits to our Website, including website traffic data, logs, and other communication data
• Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type
• Behavioural tracking using De-Identified Personal Information

The technologies we use for automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, IP address, and other technologies.

Cookie Notice and Policy

Browser Cookies: Browser cookies are small files placed on the hard drive of your computer or mobile device. Different types of cookies which have different purposes are used on our Website.

Essential Cookies: Essential cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies: Performance cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing.

Functionality Cookies: Functionality cookies enable our Website to remember the choices you have made when browsing. For example, we can store your general geographic area in a cookie so that the Website corresponding to your geographic area is shown.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:

• To present to you our Website and contents and provide information and notices related thereto
• To provide Services and information related thereto that you request from us
• To provide customer Service and support
• To send you emails and newsletters with Service, company, and other information and offers
• To contact you about and to process discounts, offers, loyalty rewards, promotions, contests, sweepstakes, awards, and/or rebate requests
• To allow you to participate in interactive features on our Website
• To ask for ratings and reviews and request your participation in surveys, polls, focus groups, trials, or other initiatives
• To enhance and improve our Services
• For internal purposes, such as Website and system administration or internal audits and reviews
• To comply with applicable law(s)

Sharing of Your Personal Information

We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more of the following purposes:

Disclosures to Service Providers: We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third-party service providers which perform services on our behalf ("Service Providers").

Event-Related Disclosure: From time to time, we may conduct events, run contests, make special offers, or other activities ("Events"), possibly together with an exhibitor, sponsor or other Service Provider.

Required Disclosures: Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process (e.g., subpoena), including, but not limited to, in order to respond to any government, regulatory, or licensing request.

Security

We have implemented technical, administrative, and organizational security measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, destruction, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do use security measures designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk.

Data Retention

In general, the time period for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as we have a legitimate business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request.

Notices; Opting Out

If you prefer not to receive marketing-related communications from us, please let us know by clicking on the unsubscribe link within a marketing message or newsletter you receive, or by updating your email preferences under your profile, or by contacting us.

By providing us with your phone number and/or email address you consent to our using the email address and/or phone number to send you Service-related notices by email or by calling you, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail.

Contact Information

If you have any questions about this Privacy Policy or our privacy practices, please contact us: by email at legal@cloudtwin.ai; or, by mail at RedHold LLC, Attn: Legal, 8401 Mayland Dr, STE S, Richmond, VA 23294, USA.

Where We Process and Store Personal Information

We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us.

If you are a resident or citizen of the UK, European Economic Area ("EEA"), or Switzerland, please see the section below on GDPR compliance.

GDPR: The Following Provisions Apply only to Citizens and Residents of the United Kingdom, EEA, and Switzerland

The following provisions apply only if you are a citizen or resident of the UK, EEA, or Switzerland (collectively referred to in this section for convenience as the "EU Region"). For such citizens or residents, all processing of your Personal Information is performed in accordance with privacy rights and regulations, in particular, (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation ("GDPR", and which includes the UK's similar law), and our processing will take place in accordance with the GDPR.

Your Data Rights Under GDPR:

• The right to access - Upon request, we will confirm any processing of your Personal Information and provide you with a copy of that Personal Information
• The right to rectification - You have the right to have us correct any inaccurate Personal Information
• The right to erasure - You may ask us to delete or remove your Personal Information
• The right to restrict processing - You have the right to ask us to suppress the processing of your Personal Information
• The right to object to processing - You have the right to object to your Personal Information used in certain manners
• The right to data portability - You have the right to obtain your Personal Information from us
• Rights regarding automated decision making - You have the right not to be subject to a decision based solely on automated processing
• The right to complain to a supervisory authority - You have the right to file a complaint with a supervisory authority
• The right to withdraw consent - If we are processing your Personal Information based on your consent, you may withdraw that consent at any time