Last Updated: 2025-22-08 

1. Purpose and Scope 

CloudBlue LLC (for this policy, we will call ourselves “CloudBlue”, “we”, “us”, “our”, and “ours”) provides customers with the ability to purchase or access a variety of product and service offerings made available by CloudBlue and various third-party providers (we call them “Offerings”) both directly from CloudBlue and through resellers and distributors. EACH OFFERING MAY BE SUBJECT TO OFFERING-SPECIFIC PRIVACY POLICIES WHICH MAY COMPLEMENT OR SUPERSEDE THE TERMS OF THIS PRIVACY POLICY. PLEASE MAKE SURE YOU CAREFULLY READ THE PRIVACY POLICY OF ANY OFFERING BEFORE ACCESSING OR USING THAT OFFERING. 

This Privacy Policy describes how we collect, use, store, and share your Personal Data, both offline and online through our web pages, data, blogs, and any applications available within them (collectively, the “Sites”), and your rights and choices in connection with your Personal Data. This Privacy Policy does not apply to any Personal Data we access or receive when acting as a data processor on behalf of our customers. 

Any translations of this policy are provided as a courtesy. Some things as written in English may not translate easily into other languages. Should there be any differences or discrepancies between the English Privacy Policy and any translations, the English Privacy Policy takes precedence. 

2. General Principles for the Processing of Personal Data 

Personal Data will be collected, stored, processed, and transmitted in accordance with CloudBlue’s established policies and applicable regional, federal, and international laws, rules, and regulations. 

The principles of CloudBlue with respect to the processing of Personal Data are as follows: 

1. Personal Data will be processed fairly and lawfully; 
2. Personal Data will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes; 
3. Personal Data collected by CloudBlue will be adequate, relevant, and not excessive in relation to the purposes for which it is collected; 
4. Personal Data collected by CloudBlue will be kept up to date to the best of our ability; 
5. Personal Data will be protected against unauthorized access and processing using appropriate technical and organizational security measures and controls; and, 
6. Personal Data collected by CloudBlue will be retained as identifiable data for no longer than necessary to serve the purposes for which the Personal Data was collected. 

If CloudBlue engages in the processing of Personal Data for purposes other than those specified in this Privacy Policy, CloudBlue will provide a notice of these changes, the purposes for which the Personal Data will be used, and the recipients of Personal Data. 

Where the term is applicable, CloudBlue is a “data controller” for the information we collect from you. In certain cases, we are also a “data processor” for data collected by our customers; for more information on customer-collected data, please see “Information collected by our customers” below. 

3. Collection of Personal Data 

We collect information from you in order to deliver services that you purchase and to monitor and improve the customer experience on our Sites. We may collect Personal Data about you from a variety of sources, as detailed below. 

CloudBlue services are intended for business use, and we do not knowingly market to or collect Personal Data from people under the age of 18. 

3.1. Information We Collect 

Personal Data collected by, or on behalf of, CloudBlue could include anything from the following list. The actual Personal Data collected depends on the nature of your interactions with us:  

1. “Identity Data” such as first name, last name, username or similar identifier, title, company name, and government issued identification number. 
2. “Contact Data” such as billing address, email address, and telephone numbers. 
3. “Financial Data” such as bank account number, payment card details, and credit history. 
4. “Transaction Data” such as details about payments from you and other details of products and services you have purchased from us. 
5. “Technical Data” such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Sites. 
6. “Profile Data” such as your username and password used to access your account, your account number, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
7. “Usage Data” such as information about how you use our Sites, products, and services, as well as information about what you type into web chats and form fields on our Sites.
8. “Preference Data” such as your preferences in receiving marketing from us and our third parties, and your communication preferences.
9. “Professional Data” such as your company affiliation, job title, office location, and professional contact information if you interact with us on behalf of a business customer or vendor.
10. Other information that we collect with your consent from time to time.  

3.2. Sources of Information 

CloudBlue collects Personal Data as follows and from the following categories of sources. 

1. Information You Provide Voluntarily. We collect Personal Data that you voluntarily provide. For example, when you register online to create an account, access Offerings, sign up for marketing, send us emails, and so on. If we ask you to provide Personal Data, we will also explain why we need you to provide it. Please keep in mind that if you directly disclose Personal Data through CloudBlue’s social media pages, this information may be collected and used by others.  
2. Information that We Collect Automatically. When you visit our Sites or interact with our online ads, content, cookies, or emails that we send to you, we collect certain information automatically from your device. Specifically, the information we collect automatically may include the things described as Technical Data and Usage Data in Section 3.1 (above) as well as your broad geographic location (e.g. country or city-level location). Collecting this information enables us to better understand the visitors who come to our Sites, where those visitors come from, and what content on our Sites, advertisements, and emails is of interest to them. We use this information for our internal analytics and to improve the quality and relevance of our Sites, digital content, and emails for our visitors. 
3.  From Resellers and Distributors. We may obtain Personal Data about you from the resellers and distributors that purchase Offerings available from us and provide such Offerings to you. 
4.  From Our Vendors. We may obtain Personal Data about you from the third-party vendors that make Offerings available through us. 
5.  From Our Service Providers. We may obtain Personal Data about you from the service providers that help us operate our business. For example, payment processing providers may collect your payment information. Our advertising technology vendors, analytics providers, and other service providers may also provide us with Personal Data about you. 
6.  From Data Providers. CloudBlue may also obtain or license Personal Data from third parties that maintain information about you and that have the right to provide that Personal Data to us. We may also contract with companies that are in the business of providing information to businesses such as ours to verify certain information about you or obtain information. 
7.  From Publicly Available Sources. We may also obtain Personal Data from publicly-available sources such as open government databases or other data in the public domain. 
8.  From Affiliates and Subsidiaries. We may obtain Personal Data from our Affiliates and Subsidiaries. 

 4. Cookies and Other Website Usage Information 

CloudBlue uses “cookies” and other automated tracking technology like “web beacons” to help personalize your online experience. 

4.1. Cookies 

A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.  

The cookies used on the Sites can be broken down into the following categories:  

1. Strictly necessary cookies. These are required for the Sites to operate properly. 
2. Analytical/performance cookies. These monitor and analyze Sites’ performance, which allows us to improve your experience in using the Sites. 
3. Functional/tracking cookies. These allow us to recognize repeat visitors to our Sites, know where the visitors came from, links clicked, and search engines used. 
4. Targeting cookies. These make advertising displayed on our Sites more relevant to your interests. We may also share this information with third parties for this purpose. 

 Cookies can be either session cookies or persistent cookies.  

1. Session cookies. These cookies are deleted when you close your browser. They do not contain any Personal Data, and help by minimizing the need to transfer Personal Data across the internet. 
2. Persistent Cookies. These cookies stay for a fixed period of time (from a few hours to a year or longer) and are not deleted when the browser is closed. 

 You can choose to accept or decline cookies. Many of our Sites include cookie banners that allow you to proactively choose the types of cookies you prefer. Additionally, you can usually modify your browser setting to decline cookies. 

Please be aware that if you modify your browser to decline cookies, this will include the “strictly necessary” cookies described above which may prevent some features and services on our Sites from working properly.  

4.2. Web Beacons 

A “web beacon” (also known as a clear pixel or pixel tag) includes an electronic image embedded in the website interface that allows us to recognize when you visit that area of the Sites. These may also be used in connection with some Sites’ pages and HTML-formatted email messages to, among other things, track the actions of website users and e-mail recipients, measure the success of our marketing campaigns, and compile statistics about Sites usage and email response rates.  

5. Use of Personal Data 

CloudBlue uses Personal Data we collect to operate our business and provide you with Offerings, which includes using this data to improve our Offerings and personalize your experiences. We also may use the data to communicate with you, for example, informing you about your account and product information.  

Depending on the nature of your interactions with us, CloudBlue may use your Personal Data for a variety of purposes (the “Purposes”), including to:  

1. Manage our everyday business needs. This includes things like registering new customers, processing orders and payments, collecting account receivables owed by CloudBlue customers, provisioning and maintaining Offerings, developing new Offerings, and maintaining and improving the Sites. 
2. Communicate with you. This includes responding to customer service inquiries and to provide customer support. We may also deliver information, updates, notices of functionality changes, upcoming payments, and planned service maintenance for Offerings you have purchased. 
3. Send you marketing, depending on your preferences. If you allow, this includes newsletters, announcements, and special offers (you can unsubscribe at any time by clicking “Unsubscribe” in marketing emails or by contacting us as described below). We may also deliver tailored advertising if your cookie settings allow. 
4. Research our performance. This includes compiling aggregated statistics and otherwise analyzing the effectiveness of the Sites, marketing, advertising, and sales efforts. We may use automated systems that analyze data using machine learning. 
5. Provide security. This includes protecting our rights and the rights of our customers, and detecting, investigating, and preventing fraud or other illegal activities. We share Personal Data with credit reference, fraud prevention, and “denied party” agencies as described in the next section. We may ask you to verify your identity before discussing your account or Personal Data. 
6. Comply with legal requirements. We may be legally obligated to disclose or process Personal Data in order to comply with legal, regulatory, and law enforcement requests. We may also use Personal Data when involved in a court case, arbitration, or similar legal proceedings.  

We may combine and enhance the Personal Data we collect about you with other information we receive from third parties.  

We may also use the Personal Data we collect about you through the Sites to generate anonymized, aggregated data. When we do so, we ensure that the anonymized, aggregated data is no longer personally identifiable and may not later be used to identify you. This will include, by way of example, storing the anonymized, aggregated data separately from any Personal Data.  

5.1. Change of Purpose 

We will only use your Personal Data for the purposes for which we collected it, unless we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your Personal Data for a new, unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  

6. Information Sharing 

Depending on the nature of your interactions with us, we may disclose your Personal Data, including Sensitive Personal Data, as follows:  

6.1. With Vendors 

CloudBlue may share Personal Data about you with the third-party vendors that make Offerings available through us. Depending on your preferences, we may also share your Personal Data with a third-party vendor if that vendor co-sponsors a marketing activity with us. This will be done to verify your participation in the marketing activity.  

6.2. With Resellers and Distributors 

CloudBlue may share your Personal Data with the resellers and distributors that purchase Offerings available through the Sites. For example, we may share your Personal Data if you purchase or access an Offering through a reseller or distributor, and that reseller or distributor leveraged our reseller tools and services.  

6.3. With Service Providers 

CloudBlue may provide your Personal Data to vendors that provide services to assist us with running our business, operating the Sites, and achieving the Purposes. For example, these service providers may include providers of customer service, payment processing, email and messaging support, hosting, management, maintenance, information analysis, offering fulfillment or delivery, or other services we may receive on an outsourced basis. A list of third-party service providers is available upon request.  

6.4. With Law Enforcement and Safety 

CloudBlue may share your Personal Data with any law enforcement, regulatory, government agency, court, other governmental officials, or other third-party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, and/or (iii) to protect your vital interests or those of any other person.  

6.5. With Advertisers and Advertising Companies 

With your consent, CloudBlue may share your Personal Data with advertisers, advertising networks, advertising servers, and analytics companies or other third parties in connection with our and their marketing, promotional, and other offers, as well as product information.  

6.6. Sale or Acquisition of Assets 

Should CloudBlue become part of a merger, acquisition, corporate reorganization, or any other change of control, your Personal Data will be included in CloudBlue’s sale of business assets. This means that it could be shared with CloudBlue’s new owners, or with a new business that CloudBlue acquires. If this happens, CloudBlue will make reasonable efforts to notify you and inform you of any choices you may have about the information you shared with us.  

6.7. Credit Reference Checks, Fraud Prevention, and Denied Parties 

The Personal Data that we collected from you when setting up an account may be shared with credit reference, fraud prevention, and “denied party” agencies who use it to prevent fraud and money laundering and to verify your identity. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide services to you. 

 If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to fraud prevention agencies, law enforcement agencies and other organizations. 

7. Your Privacy Rights 

You are entitled to certain privacy rights based on where you are located. To exercise your rights, contact us at cb-privacy@cloudblue.com as described in our “How to Contact Us” section below. We will verify your identity before acting on any requests. This is to ensure that the request is coming from you and not from someone pretending to be you.  

You may designate an authorized agent to make a request on your behalf. When submitting the request, please ensure the authorized agent notifies us of being an authorized agent and can provide evidence of this status.  

We will respond to requests we receive from individuals wishing to exercise their privacy rights in accordance with applicable privacy laws. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. However, we will not discriminate against you (deny you any products or services, charge you different prices, provide a different level of service, etc.) for exercising your privacy rights.  

7.1. United States Privacy Rights 

The United States does not have consistent privacy rights. Only some US States have privacy laws, and those privacy laws do not offer the same privacy rights from State to State. Depending on where you live in the United States, you may be entitled to all or only some of these rights. 

1. Information. You may have the right to know if we process your Personal Data as well as some details about categories of data collected, categories of data sources, categories of personal data we have disclosed, and if we sell Personal Data, categories of data we have sold. 
2. Portability. You may have the right to obtain a copy of the Personal Data we have processed. We will provide it in a commonly used format for you to download. Please note that it is your responsibility to obtain the tools necessary to properly access the data. 
3. Rectification. You may have the right to request that we correct, update, or modify the Personal Data we maintain about you. 
4. Erasure. You may have the right to request that we erase the copies of your Personal Data that we maintain, subject to certain exceptions and limitations. 
5. Opt Out of Automated Decision Making. You may have the right to request to opt-out of any profiling or automated decision-making we may perform, subject to any limitations under applicable privacy laws. 
6. Do Not Sell/Share My Personal Data. You may have the right to opt-out of the sale or sharing of your Personal Data for targeted advertising. To opt out, contact us at cb-privacy@cloudblue.com as described in our “How to Contact Us” section below.  

7.1.1. Additional California Privacy Disclosures 

For purposes of California privacy law, California residents should note the following:  

1. We collect and use the following categories of Personal Data for the business and commercial purposes described in this Privacy Policy (See Section 3.1 above for more details): 
   1. Identifiers and personal information categories listed in Cal. Civ. Code § 1798.80(e) (such as your name, contact information, government identification numbers, and IP address);  
   2. Commercial information (such as details of the Offerings and services you purchase, your marketing preferences, and your survey responses);  
   3. Internet or other electronic network activity information (such as your interactions with our Sites);  
   4. Geolocation data (but not precise geolocation);  
   5. Professional information (such as your company affiliation and job title);  
   6. Sensitive personal information (namely, your payment card details, CloudBlue account login details, and government identification numbers); and,  
   7. Inferences from the data collected. 
2. We use the above-described categories of personal information for our compliance, business and commercial purposes described in Section 5 above. 
3. We collect these categories of Personal Data from the following categories of sources, as more fully described in Section 3.2 above: directly from you; automatically from your devices; from resellers and distributors that resell our Offerings, from vendors that make Offerings available through us, from our service providers who help us run our business, from third-party customers that contract with us for services, from data providers and data licensors, from publicly available sources, and from our Affiliates and Subsidiaries. 
4. We disclose each of the foregoing categories of Personal Data to our Affiliates and Subsidiaries, to our service providers who help us run our business, to advertisers who advertise on our Sites, to advertising networks, to resellers and distributors of the Offerings, to data analytics providers, to other website visitors (at your direction), with entities for legal compliance purposes, and with potential acquirers of parts of our business. See Section 6 above for more details. 
5. We may “sell” or “share” some of the following categories of personal information: identifiers; personal information categories listed in Cal. Civ. Code § 1798.80(e); commercial information; Internet or other electronic network activity; and geolocation data. We sell and share this personal information with advertisers, advertising networks, social networks, other business partners and Affiliates and Subsidiaries. We do not knowingly sell or share the personal information of individuals under 18 years of age. 
6. We do not use or disclose sensitive personal information for purposes other than those specified under applicable California privacy regulations. 
7. See Section 10 for information about how long we retain Personal Data.  

California’s “Shine the Light” law also provides that California residents have a right to request that businesses tell them how their personal information has been shared with third parties for their direct marketing purposes. There is an exception to this requirement for businesses that have adopted and disclosed, in their privacy policy, a policy of not disclosing a person’s personal information to third parties for direct marketing purposes if that person has exercised an option to opt-out of the disclosure of their Personal Data to third parties for such purposes. We have adopted a policy of allowing you to opt-out of the disclosure of your personal information to third parties for direct marketing purposes and thus fall within this exception. To opt-out of the sharing of your personal information to third parties for direct marketing purposes or otherwise exercise your rights under this section, please contact us as per the “How to Contact Us” section below.  

7.2. European Economic Area (EEA) / United Kingdom (UK) and Switzerland Privacy Rights 

7.2.1. Our Legal Basis For Processing Your Information 

CloudBlue will process your Personal Data under any of the following legal bases: 

1. Contract: Your Personal Data is necessary for providing the services you requested. This includes payment and setting up the services, and also the assistance and support we provide to make sure your services are working properly. 
2. Consent: CloudBlue may collect your consent to process your Personal Data in additional ways, such as to put cookies on your browser or send you announcements and special offers. You may withdraw your consent at any time. 
3. Legal Obligation: CloudBlue may be required to process any Personal Data we collect in order to comply with legal, regulatory, and law-enforcement requests.

7.2.2. Your Rights 

If you reside in the EEA, Switzerland, or the UK, you can make the following requests to us regarding Personal Data of yours that we are processing.  

1. Access: You have the right to obtain access to your Personal Data. Where such access is not possible, we will provide you with a copy of your Personal Data. 
2. Rectification: You can request that we correct, update, or modify the Personal Data we maintain about you. 
3. Erasure: You can request that we erase the copies of your Personal Data that we maintain, subject to certain exceptions and limitations. 
4. Object to Processing: You can object to our processing of your Personal Data in certain ways. 
5. Restrict Processing: You can ask us to restrict processing of your Personal Data or block the further use of your Personal Data. When processing is restricted, we can still store your Personal Data. 
6. Portability: You can obtain a copy of the Personal Data we have processed. We will provide it in a commonly used format for you to download. Please note that it is your responsibility to obtain the tools necessary to properly access the data. 
7. Refuse or Withdraw Consent: If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Please note that withdrawing your consent does not automatically result in data deletion. We can also continue to process data we collected with your consent if we have another reason for doing so (such as legal obligation).  

7.3. Your Privacy Rights – Other Jurisdiction Privacy Rights 

Depending on where you reside or access the Sites or our services from, you may have certain privacy rights available to you, similar to the ones described above. Even though we have not included your jurisdiction in this Privacy Policy, we will still respect the privacy rights of where you live.  

8. Other Important Privacy Information 

CloudBlue uses technical and organization controls and measures designed to secure and protect your Personal Data from unauthorized loss, misuse, and disclosure, such as strong user access controls, segmented network architecture, and comprehensive employee policies and training.  

Unfortunately, no data transmitted over or accessible through the Internet can be guaranteed to be 100% secure. As a result, while CloudBlue attempts to protect all Personal Data, CloudBlue cannot ensure or warrant that Personal Data will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network.  

CloudBlue will notify you in the event we become aware of a security breach involving your Personal Data (as defined by the applicable international, national, regional, and local laws) stored by us or for us, in accordance with applicable laws.  

9. International Data Transfers 

Our primary servers are in the United States and our Subsidiaries and third-party service providers and partners operate around the world. This means that when we collect your Personal Data we may process it in any of these countries. These countries may have data protection laws that are different to the laws of your country. However, we have taken appropriate safeguards to require that your Personal Data will remain protected in accordance with this Privacy Policy.  

For Personal Data collected in the countries of the European Economic Area, Switzerland and/or the UK and transferred or accessed by CloudBlue in the United States, CloudBlue respects the Data Privacy Framework Principles and has executed the European Commission’s Standard Contractual Clauses (and their UK and Swiss equivalents) in addition to appropriate technical and organization controls. CloudBlue is responsible for processing the Personal Data that we receive under the Standard Contractual Clauses, including when that data is subject to onward transfers to third parties with whom we have contracted. Under these circumstances, we remain liable if these third parties fail to meet their obligations to process the Personal Data consistent with the  Standard Contractual Clauses and we are responsible for the event giving rise to any damage. We have implemented similar appropriate safeguards with our third-party service providers and partners as well as for additional transfers of Personal Data between our Subsidiaries outside the EEA, Switzerland and/or the UK and the United States.  

10. Retention Period 

We retain Personal Data for as long as we have an ongoing legitimate business need to do so (for example, to provide you with an Offering you have ordered or to comply with applicable legal, tax, or accounting requirements). The criteria we use to determine whether we have an ongoing legitimate business need to retain Personal Data include among others: (i) regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting, and securities, (ii) whether a legal claim might be brought against us, for which the Personal Data would be relevant, (iii) the necessity of the Personal Data to provide Offerings to our customers, and (iv) the types and sensitivity of Personal Data being processed. 

11. Third-Party Websites 

Through links on our Sites, you may be able to access other websites where you can purchase products and services or register to receive materials or new product updates. If you complete an order or provide Personal Data to a website or service that is not provided by CloudBlue, we have no control over the third party’s use of any Personal Data. This Privacy Policy does not apply to those third-party websites. Please be careful when visiting those sites, and be sure to read their privacy policies.  

12. Changes to this Privacy Policy 

CloudBlue reserves the right to modify this Privacy Policy at any time. If required by local privacy laws, we will notify you of changes to this Privacy Policy. Otherwise, please check back regularly to make sure you are aware of any changes and to stay informed of how we are protecting your information. Changes to the Privacy Policy and related data collection will become effective on the date the revised Privacy Policy is published (visible at the top of the policy). We will seek your consent on any changes in the use of your Personal Data where new consent is required by applicable data protection laws.  

13. How to Contact Us 

We welcome your comments regarding this Privacy Policy. If you believe we have not adhered to this Privacy Policy or you require any changes or access to your personal information, please contact our Privacy team by emailing us at cb-privacy@cloudblue.com    

Alternatively, you can contact us in writing at:  

CloudBlue LLC 

2430 Military Road #1013 

Niagara Falls, NY 14304  

We will use commercially reasonable efforts to promptly investigate and resolve the problem.