Privacy.

SNOW Cloud United States Privacy Policy

Effective Date of Policy:  November 1, 2024

Introduction.

This Privacy Policy (“Privacy Policy”) exists to inform users of the both the SNOW Cloud platform and the SNOW Cloud mobile application about the ways that SNOW Cloud LLC (the “Company” or “SNOW Cloud”) collects, uses, and shares personal information, in compliance with applicable law. This Privacy Policy applies to the use of our services and products, as well as the other activities, services, business activities, events, applications, communications, and other interactions between the Company, Customers, and Guests. Please read the following information carefully and take it into consideration when deciding whether to share personal data with us. By visiting our website, engaging with us, submitting information, or otherwise interacting with SNOW Cloud, you acknowledge that you accept the practices and policies outlined in this then-current Privacy Policy. If you do not agree with this Privacy Policy, it is incumbent upon you to neither use our products, services, or other business activities, nor provide us your personal information.

Definitions. 

The word “Customer” or “Customers”, as used throughout this Policy, shall refer to the entity that contracts with SNOW Cloud to use SNOW Cloud and provide, among other services, cloudbased ticketing services and sales through the SNOW Cloud platform. 

The word “Guest” or “Guests”, as used throughout this Policy, shall refer to the individual(s) or entities purchasing admission products or any other product or service from Customer through the SNOW Cloud platform. 

The word “you” or “yours”, as used throughout this Policy, shall refer to the individual(s) or entities providing information or otherwise engaging with the SNOW Cloud platform, and includes both “Guests” and “Customers”.

What is Personal Data?

Generally, we may collect two types of information: Personal Information as defined by this

Privacy Policy and Other Information that does not generally identify you. We consider Personal Information as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social identity. If we are required by law to treat that data that does not generally identify you as “Personal Information,” then we will collect, use, and disclose it in the same manner in which we collect, use, and disclose Personal Information as detailed in this Privacy Policy.

Purposes for Collection of Personal Information. 

This Privacy Policy identifies the purposes for which SNOW Cloud collects Personal Information.

If SNOW Cloud elects to add additional uses, they will be identified in an updated version of this Privacy Policy or else will be disclosed at or before the time the information is collected or, when appropriate, at or before the time the Personal Information is used for a new purpose. We only process this information after careful consideration related to the risks of your privacy. As detailed in this Privacy Policy, we offer you control over your personal information, when possible. 

We generally collect Personal Information to fulfill a contractual obligation so that we can establish and maintain a responsible relationship between us, Guests, and customers for reasons related to the business and other legitimate interests. These legitimate interests include:

      To understand the needs and preferences of Customers and Guests; 

      To develop, enhance, market and/or provide products and services; 

      To manage and develop SNOW Cloud’s business and operations including transfer of data among affiliated entities in order to optimize the experience; 

      To meet legal and regulatory requirements; 

      To make certain that the Guest is receiving the proper services at Customer’s site and equipment necessary for the activity that the Guest will be participating in; 

      To make certain that the Customer can properly service and accommodate its Guests; 

      To prevent, detect, and investigate risk and fraud; 

      To assist with marketing and other communications; 

      For AI purposes and similar artificial intelligence applications; To provide and improve our products and services; and

      To provide for other legally permissible purposes.

Collection of Personal Information. 

Personal information that we may collect includes:

      Personal contact information such as name, address, telephone number and email address;

      Personal information required to ascertain an individual’s ability to perform certain activities (such as skiing and snowboarding) and to provide appropriate rental equipment for the activity including but not limited to height, weight, age and shoe size;

      Business contact information such as business address, telephone number and email address;

      Transactional information, including bank, credit, or debit card numbers;

      Information necessary to provide services or products;

      Comments and opinions provided when you contact us directly by email, telephone, or mail;

      App usage data;

      Internet or other electronic network activity information (including Internet or other similar activity, browsing history, search history, IP address, and information regarding your interactions with our Website or other services);

      Browser and device information;

      Online information collected through “cookies” and other technologies;

      How you use our sites, search terms, pages you visit on our website and other performance information;

      Demographic information and other information provided by you that does not reveal your specific identity;

      Information that has been aggregated in a manner such that it no longer reveals your specific identity;

      Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;

      Demographic information (e.g., age and date of birth, sex, gender);

      Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data;

      Geolocation data (including that inferred from Internet Protocol (IP) address or mobile device location); and 

      Audiovisual information.

SNOW Cloud uses a third-party processor that collects the credit card information and SNOW Cloud does not have access to this credit card information. 

Personal information excludes certain information such as publicly available information.  

SNOW Cloud’s website and application may collect certain information about your visits, including the name of the internet service provider and the Internet Protocol (“IP”) address through which you accessed the internet; the date and time you accessed our website; the pages that you accessed while on our site; and the internet address of the website from which you linked to our website. 

Use by children.

SNOW Cloud adheres to the United States privacy protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”). SNOW Cloud cares about the safety of children. As a general rule, our websites and mobile services are not directed towards children under the age of 18.  Under no circumstances should anyone under 18 provide SNOW Cloud with any Personally

Identifiable Information unless authorized by a parent or guardian. If a child has inadvertently provided SNOW Cloud with Personally Identifiable information the parent or guardian of that child should immediately contact privacy@snowcloud.io.

Parents should be aware that there are parental control tools available online that can be used to prevent children from submitting information online without parental permission or from accessing material that is harmful to minors.

When do we collect information?

We collect information from you when you register on our Site, when you enter information on our Site, use our Site, or in connection with you purchasing and receiving SNOW Cloud’s service, products, or other related service. 

How do we use your information?

We will use the Information we collect from you for various commercial purposes including but not limited to: 

-          To allow Customers to better personalize the Guest experience; 

-          To allow us to deliver the type of content and product offerings in which you are most interested; 

-          Use of the purchased materials and the time used for those products and services;

-          Fulfilling and processing requests for products, services or information;

-          Communicating with you;

-          Administering accounts;

-          Providing customer service;

-          Offering new products and services;

-          Engaging in marketing and advertising our products and services;

-          Measuring and improve the effectiveness of our Services, marketing, and advertising; -             Administering surveys;

-          Sending marketing communications from us or third parties in which we feel you may be interested in;

-          Protecting against and prevent fraud and unauthorized transactions;

-          Enforcing agreements and legal requirements;

-          Preventing, detecting, and investigate security incidents;

-          Dealing with and preventing malicious, deceptive, fraudulent, or illegal actions directed at us and prosecuting those actions;

-          Ensuring the physical safety of individuals;

-          Verifying and maintain quality and safety of products, and services;

-          Alerting you about issues;

-          To improve our website, platform, and app in order to better serve you; 

-          For AI purposes and similar artificial intelligence applications;

-          To send periodic emails regarding our and other third party’s services; and  -         For other legally permissible purposes.

 

Consent.

By visiting our website, using our application, engaging with us, submitting information, or otherwise interacting with SNOW Cloud, you acknowledge that you consent to and accept the practices and policies outlined in this then-current Privacy Policy. If you do not agree with this Privacy Policy, it is incumbent upon you to neither use our products, services, or other business activities, nor provide us your personal information.  Depending upon the State in which you reside, you may have additional rights and options.  

Disclosure of Personal Information. 

We do not sell your Personal Information to third parties at any time. We may share personal information with our service providers, consultants, vendors, and affiliates for our internal business purposes. Except as described in this Privacy Policy, we will not share Personal Information with a third party. We share information as follows:

                    Service providers, vendors, consultants, and affiliates.  We may share your Personal Information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to process your requests, provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

                    Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy.

                    Other Disclosures without Your Consent. We may disclose Personal Information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or the provision of services by, a third-party intermediary.

                    Public. Some areas of our websites may provide the opportunity to post comments or reviews in a public forum. If you decide to submit information on these pages, that information may be publicly available.

                    Service Providers. We share your personal information with service providers. Among other things, service providers may help us to administer our websites, support our programs, conduct surveys, provide technical support, respond to complaints or other issues, and assist in the provision of services.

Only SNOW Cloud employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about individuals. SNOW Cloud may disclose an individual's Personal Information to a person who in the reasonable judgment of SNOW Cloud is seeking the information as an agent of the individual; a company or individual employed by SNOW Cloud to perform functions on its behalf, such as but not limited to research or data processing; another company or individual for the development, enhancement, marketing or provision of any of SNOW Cloud’s products and services; an agent used by SNOW Cloud to collect the individual's account; a public authority or agent of a public authority, if in the reasonable judgment of SNOW Cloud it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; another entity as part of a merger, a sale of assets or all or part of a business, or any other corporate change or re-organization; a third party or parties, where the individual consents to such disclosure or disclosure is required or permitted by law. 

Retention of Personal Information. 

We attempt to ensure that Personal Information is safeguarded against loss, access, use, modification, disclosure, or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

We will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose(s) remains valid after termination of our relationship with you. The criteria used to determine our retention periods include:

                    The length of time we have an ongoing relationship with you and provide our services to you;

                    Whether there is a legal obligation to which we are subject; or

                    Whether retention is advisable in light of our legal position.

We take all reasonable steps to ensure that your personal information is accurate, up-to-date, complete, relevant, and not misleading.

We may store your Personal Information in databases located in the United States and/or other countries outside of the United States. Additionally, some of our service providers may reside in the United States, Canada, or other countries and they may be subject to the laws of their local jurisdiction. As a result, in certain circumstances, the United States and other foreign governments, courts, law enforcement agencies, or regulatory agencies may be entitled to access the personal information collected and held by us.

Your Rights.

You have the right to “opt-out” of our collection of personal data at any time.  Should you desire to so, please contact our Data Protection Officer at privacy@snowcloud.io to ensure that we do not continue to collect and store your personal information. 

You also have the right to access your personal information.  Should you wish to access your personal data which we have stored, please contact us at the provided contact information and we will respond to your request within seven (7) business days. 

You have the right to be forgotten within SNOW Cloud’s personal information storage system, to the greatest extent permitted by law. If you request to be forgotten, the Company will erase all of your personal data which it currently has. Moving forward, you will need to expressly consent to the collection of information again if you wish to do so in the future. Please note that if you request to be forgotten, your personal needs and preferences will disappear from SNOW Cloud’s records in the future, and the website will not be tailored to best suit your needs. Should you wish to be “forgotten”, please contact us at the provided contact information and we will respond to your request within fourteen (14) business days. 

Depending upon the State in which you reside, you may have additional rights and options, as set forth in the State Specific Privacy Policies attached to this document. 

Use of Cookies.

In addition to the above methods of collecting Personal Information, we may use data collection devices such as “cookies” or tracking pixels on certain web pages to personalize the experience, help analyze our web page processes and use, and measure promotional effectiveness. Cookies are small files that a website transfers to your device through a web browser that enable the systems to recognize your device and capture and remember certain information. Similarly, tracking pixels are graphics embedded on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. 

In general, our website uses cookies and other tracking technologies as follows:

                    Where necessary to run our website, allowing you to log in and engage with new or existing accounts;

                    To increase the function of our websites, including personalizing content for you, prefilling forms, and remembering your preferences;

                    For analytics purposes such as helping us understand how our website is used and to determine how best to market our products to you;

                    To determine if our email messages have been opened and acted upon; and

                    To obtain information about your interactions with our online advertisements.

Cookies vary in how long they last. “Session cookies” terminate shortly after you terminate your internet session. “Persistent cookies” are stored on your device until a set expiration date. We use both session cookies and persistent cookies on our website.

If you set your device to not receive cookies at any time, certain personalized services cannot be provided to you, and accordingly, you may not be able to take full advantage of all of our features. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. Please note that by turning cookies off, you will not have access to many features available on our Website.

Do Not Track

Some browsers have a “do not track” feature that allows you to tell websites that you do not want to have your online activities tracked. At this time, our websites do not respond to browser “do not track” signals.

Security of Data.

We safeguard your personal information on the Internet by using industry-standard practices. Although "guaranteed security" does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with our Privacy Policy and all applicable laws and regulations. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Our Website permits you to create an account. When you do so, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Currently, our Website uses a variety of different security measures designed to protect personal information by users both inside and outside the Company, including the use of encryption mechanisms (e.g., Secure Socket Layers or SSLs), password protection, and other security measures to help prevent unauthorized access to your personally identifiable information.

We have implemented internal policies and technical measures to protect Personal Information from loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:

                    The use of encryption of personal data where appropriate;

                    Procedures and controls to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

                    Procedures for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing; and

                    Procedures to ensure that data is not accessed, except by individuals in the proper performance of their duties.

Subject to Change.

This Privacy Policy may be updated and revised from time to time without notice, and we will post the updated policy with the effective date of the change. Personal Information we collect is subject to the Privacy Policy in effect at the time of collection. You should check this Policy periodically to review any changes.

Contact For Inquiries. 

SNOW Cloud welcomes your comments regarding this Privacy Policy and provides procedures for addressing inquires or challenges from individuals regarding SNOW Cloud’s handling of personal information. You may withdraw your consent for use of personal information at any time, subject to legal or contractual restrictions and reasonable notice.  If you have questions or concerns about our privacy policy or practices, please contact us.

 

By email: privacy@snowcloud.io                      

By phone: (201) 559-1158

By mail: Privacy Officer SNOW Cloud LLC, 112 Main Road, Suite 4, Montville, NJ 07045

 

             

STATE SPECIFIC POLICIES

CALIFORNIA RESIDENTS

If you are a California resident, you may have additional rights under California law. This Privacy

Policy for California Residents supplements the information contained in SNOW Cloud Privacy

Policy and applies solely to all visitors, users, and others who reside in the State of California ("you").This California Privacy Notice is intended to comply with the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 and applicable regulations (collectively, “CCPA”), California Online Privacy Protection Act (“CalOPPA”), and other applicable privacy laws. Terms used in this California Notice have the meaning given those terms in such laws and regulations. In the event of a conflict of defined terms, the definitions in the CCPA control. Note that this CCPA section does not apply to employees or employee candidates. If you have a disability, you may access this California Notice in an alternative format by sending an email to privacy@snowcloud.io.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you ("Personal Information"). Personal information does not include:

       Publicly available information from government records.

       Deidentified or aggregated Client information.

In the last twelve (12) months, we have collected the categories of Personal Information as set forth in the SNOW Cloud Privacy Policy Section above titled “Collection of Personal Information”. Specifically, we have collected:

Category

Examples

Collected

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Yes

B. Personal information categories listed in the California Customer Records statute

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state

identification card number, insurance policy number, education, employment, employment history, bank account number,

Yes

 

 

credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

 

C. Protected classification characteristics under California or federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information

(including familial genetic information).

Yes

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F. Internet or other similar network activity

Browsing history, search history, information on a Client's interaction with a website, application, or advertisement.

Yes

G. Geolocation data

Physical location or movements.

No

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I. Professional or employment-related information.

Current or past job history or performance evaluations.

No

J. Non-public education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student

No

 

schedules, student identification codes, student financial information, or student disciplinary records

 

K. Inferences drawn from other personal information

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

No

 

CATEGORIES OF SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION

We collect the above categories of Personal Information from you, as well as from the sources identified in the SNOW Cloud Privacy Policy Section above titled “When do we collect information.”

BUSINESS OR COMMERCIAL PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION 

We collect Personal Information for the business and commercial purposes set forth in the SNOW Cloud Privacy Policy Section above titled “How do we use your information.” We do not collect or process Sensitive Personal Information (as defined by California law) for the purpose of inferring characteristics about individuals. To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Specifically, and in addition to the above, we may use or disclose the personal information we collect for one or more of the following purposes:

       Fulfilling and processing requests for services or information;

       Communicating with you;

       Administering accounts;

       Providing client service;

       Offering new products and services;

       Engaging in marketing and advertising our services;

       Measuring and improve the effectiveness of our marketing, and advertising;

       Tailoring our offerings to your preferences;

       Administering surveys;

       Sending marketing communications from us or third parties in which we feel you may be interested in;

       Protecting against and prevent fraud and unauthorized transactions;

       Enforcing agreements and legal requirements;

       Preventing, detecting, and investigate security incidents;

       Dealing with and preventing malicious, deceptive, fraudulent, or illegal actions directed at us and prosecuting those actions;

       Ensuring the physical safety of individuals;

       Verifying and maintain quality and safety of products, and services;

       Alerting you about product issues; and 

       For other legally permissible purposes.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

-     CATEGORIES OF PERSONAL INFORMATION SOLD OR SHARED AND THE PURPOSE

We do not sell your Personal Information to other companies for money. We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

In the preceding twelve (12) months, Company has not sold personal information. For more on your personal information sale rights, see your rights further in this document.

Category

Category of Third-Party Recipie

nt

 

Business Purpose Disclosure

Sales

A. Identifiers

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess

creditworthiness, perform auditing and

None

 

 

quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

 

B. Personal information categories listed in the California Customer Records statute

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

None

C. Protected classification characteristics under California or federal law

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and

None

 

 

advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

 

D. Commercial information

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

None

E. Biometric information

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our

None

 

 

behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

 

F. Internet or other similar network activity

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

None

G. Geolocation data

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our

None

 

 

business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

 

H. Sensory data

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

None

I. Professional or employment-related information.

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in

None

 

 

connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).  

 

J. Non-public education information

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

None

K. Inferences drawn from other personal information

We may share your personal information with our corporate affiliates, service providers, vendors and consultants, in order for them to provide their services to us. We may share your personal information to provide customer service, operate and improve our business, website and apps, improve our products and customer service, process payments or assess creditworthiness, perform auditing and quality control, assist with marketing and advertising, to communicate with you on our behalf, and to otherwise operate our business. We may share information with third parties in connection with or during negotiations of any

None

 

reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).

 

 

We do not sell and/or disclose deidentified patient information exempt from the CCPA to third parties. 

RETENTION

We retain each category of Personal Information as set forth above in the SNOW Cloud Privacy

Policy Section above titled “Retention of Personal Information.”

SENSITIVE PERSONAL INFORMATION

We do not use or disclose Sensitive Personal Information, as defined by the CCPA, for reasons other than as necessary and required, as set forth in the SNOW Cloud Privacy Policy Section above titled “How do we use your information.”  

YOUR CALIFORNIA RIGHTS

As a California resident, you have the following rights regarding the Personal Information we collect about you:

RIGHT TO KNOW

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you:

       The categories of personal information we collected about you.

       The categories of sources for the personal information we collected about you.

       Our business or commercial purpose for collecting or selling that personal information.

       The categories of third parties with whom we share that personal information.

       If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o    sales, identifying the personal information categories that each category of recipient purchased; and

o    disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

o    The specific pieces of personal information we collected about you (also called a data portability request).

RIGHT TO CORRECT

You have the right to correct any inaccurate information that we maintain on your personal information.

RIGHT TO DELETE

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

       Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

       Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

       Debug products to identify and repair errors that impair existing intended functionality.

       Exercise free speech, ensure the right of another Client to exercise their free speech rights, or exercise another right provided for by law.

       Comply with the California Electronic Communications Privacy Act.

       Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

       Enable solely internal uses that are reasonably aligned with Client expectations based on your relationship with us.

       Comply with a legal obligation.

       Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

PROCESS

You can exercise the foregoing rights by calling (201) 559-1158 or emailing privacy@snowcloud.io. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To ensure that the request is coming from you and to protect the security of your Personal Information, we may require you to provide us with certain information to verify your identity such as your email address, your telephone number, a description of the product or service you purchased or inquired about, the dollar amount of your last purchase and/or a signed declaration under penalty of perjury from you that you are the person whose Personal Information is subject to the request. The nature of our requirements for verification and authentication may vary based on the sensitivity of your request. You may use an authorized agent to exercise your right to know if the authorized agent has your power of attorney act on your behalf or the authorized agent has your written authorization permitting the authorized agent to request access to your Personal Information.

RIGHT TO NONDISCRIMINATION

You have the right to receive our products and services on equal terms regardless of whether or not you exercise your rights under the CCPA.  We will not discriminate against you because you exercise your rights. For example, we will not deny you goods or services or charge you a different price or rate for goods or services if you make any request under these rights. 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

RIGHT TO OPT-OUT OF SALE/SHARING

As noted above, we do not sell Personal Information for money. However, if you do not want any Personal Information to be sold or shared with third parties as contemplated by California law, you have the right opt-out of sale/sharing of your Personal Information to third parties. You may send your request to privacy@snowcloud.io. Please provide your state of residency, your interaction with us, and any other relevant information to facilitate us identifying data of this nature and honoring your request. Without sufficient information to identify you, we may be unable to implement your request.

DO NOT TRACK SIGNAL

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. As noted above, we do not respond to browser “do not track” requests. For more information, visit https://globalprivacycontrol.org.

RESPONSE TIME

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email privacy@snowcloud.io. We will respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosure will only cover the twelve (12)month period before the date your verifiable request was received. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If we cannot process your request, we will explain the reason why we cannot comply with the request.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

CALIFORNIA SHINE THE LIGHT

If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please email privacy@snowcloud.io. Please allow 30 days for a response.

CALIFORNIA MINORS

If you are a California resident under 18 years old and a registered user, you can request that we remove content or information that you have posted to our website or other online services. To request removal of content or information, please email privacy@snowcloud.io.

             

NEVADA RESIDENTS

We do not sell Personal Information for money. Nonetheless, under Nevada law, if you are a Nevada resident, you have the right to direct us not to sell your Personal Information for monetary payment by emailing us at privacy@snowcloud.io or calling (469) 718-1747. Once we receive a verified request, we are prohibited from selling any covered information and we shall respond to every verified request within 60 days after receipt and may not extend the response by more than 30 days as reasonably necessary. If we seek such an extension, we will notify you.

             

VIRGINIA RESIDENTS

If you are a Virginia resident, you may have additional rights under Virginia law. This Virginia Privacy Notice is intended to comply with Virginia’s Consumer Data Protection Act and applicable regulations (collectively, “VCDPA”). Terms used in this Virginia Notice have the meaning given to those terms in such laws and regulations. In the event of a conflicting of defined terms, the definitions in the VCDPA control.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We collect the categories of Personal Information as set forth in the SNOW Cloud Privacy Policy

Section above titled “Collection of Personal Information.”

PURPOSE FOR COLLECTING PERSONAL INFORMATION

We collect Personal Information for the business and commercial purposes set forth in the SNOW

Cloud Privacy Policy Section above titled “Purposes for Collection of Personal Information.”  

CATEGORIES OF THIRD PARTIES

We have disclosed Personal Information to the categories of third parties as set forth in the

SNOW Cloud Privacy Policy Section above titled “Disclosure of Personal Information.”

YOUR VIRGINIA RIGHTS

As a Virginia resident, you have the following rights regarding the Personal Information we collect about you:

RIGHT TO ACCESS

You have the right to request confirmation whether or not we are processing your Personal Information and to access such Personal Information.

RIGHT TO CORRECT

You have a right to request the correction of inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of such Personal Information.

RIGHT TO DELETE

You have a right to request deletion of Personal Information concerning you.

RIGHT TO DATA PORTABILITY

You have a right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data.

RIGHT TO OPT-OUT

You have a right to opt-out of the processing of the Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling.

PROCESS

You can exercise the foregoing rights by calling (201) 559-1158 or emailing privacy@snowcloud.io. If we are unable to authenticate the request using commercially reasonable efforts, we will not be required to comply with your request to initiate an action of your rights and may request that you provide additional information reasonably necessary to authenticate your request.

RIGHT TO APPEAL

If we reject or deny your request, you have the right to appeal our decision by submitting an appeal to privacy@snowcloud.io. This appeal request must be submitted within a reasonable time following our rejection of your request.

RESPONSE TIME

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosure will only cover the twelve (12)-month period before the date verifiable consumer request was received. If we cannot process your request, we will explain the reason why we cannot comply with the request, along with information on how to appeal our decision.

             

COLORADO RESIDENTS

If you are a Colorado resident, you may have additional rights under Colorado law. This Colorado Privacy Notice is intended to comply with the Colorado Privacy Act and applicable regulations. Terms used in this Colorado Notice have the meaning given to those terms in such laws and regulations. In the event of a conflicting of defined terms, the definitions in the Colorado Privacy Act and associated regulations control.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We collect the categories of Personal Information as set forth in the SNOW Cloud Privacy Policy

Section above titled “Collection of Personal Information.”

PURPOSE FOR COLLECTING PERSONAL INFORMATION

We collect Personal Information for the business and commercial purposes set forth in the SNOW Cloud Privacy Policy Section above titled “Purposes for Collection of Personal Information”.  

CATEGORIES OF THIRD PARTIES

We have disclosed Personal Information to the categories of third parties as set forth in the

SNOW Cloud Privacy Policy Section above titled “Disclosure of Personal Information.”

YOUR COLORADO RIGHTS

As a Colorado resident, you have the following rights regarding the Personal Information we collect about you:

RIGHT TO ACCESS

You have the right to request confirmation whether or not we are processing your Personal Information and to access such Personal Information.

RIGHT TO CORRECT

You have a right to request the correction of inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of such Personal Information.

RIGHT TO DELETE

You have a right to request deletion of Personal Information concerning you.

RIGHT TO DATA PORTABILITY

You have a right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data.

RIGHT TO OPT-OUT

You have a right to opt-out of the processing of the Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling.

PROCESS

You can exercise the foregoing rights by calling (469) 718-1747, emailing privacy@snowcloud.io. If we are unable to authenticate the request using commercially reasonable efforts, we will not be required to comply with your request to initiate an action of your rights and may request that you provide additional information reasonably necessary to authenticate your request.

RIGHT TO APPEAL

If we reject or deny your request, you have the right to appeal our decision by submitting an appeal to privacy@snowcloud.io. This appeal request must be submitted within a reasonable time following our rejection of your request. If you have any concerns about an appeal denial, you may contact the Colorado Attorney General at Office of the Attorney General, Colorado Department of Law, Ralph L. Carr Judicial Building, 1300 Broadway, 10th Floor, Denver, CO 80203, (720) 508-6000.

RESPONSE TIME

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and seek an extension period of an additional 45 days. Any disclosure will only cover the twelve (12)-month period before the date verifiable consumer request was received. If we cannot process your request, we will explain the reason why we cannot comply with the request, along with information on how to appeal our decision.

             

UTAH RESIDENTS

[EFFECTIVE DECEMBER 31, 2023] If you are a Utah resident, you may have additional rights under Utah law. This Utah Privacy Notice is intended to comply with Utah’s Consumer Privacy Act and applicable regulations. Terms used in this Utah Notice have the meaning given to those terms in such laws and regulations. In the event of a conflicting of defined terms, the definitions in the laws and regulations control.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We collect the categories of Personal Information as set forth in the SNOW Cloud Privacy Policy

Section above titled “Collection of Personal Information.”

PURPOSE FOR COLLECTING PERSONAL INFORMATION

We collect Personal Information for the business and commercial purposes set forth in the SNOW

Cloud Privacy Policy Section above titled “Purposes for Collection of Personal Information.”

CATEGORIES OF THIRD PARTIES

We have disclosed Personal Information to the categories of third parties as set forth in the

SNOW Cloud Privacy Policy Section above titled “Disclosure of Personal Information.”

YOUR UTAH RIGHTS

As a Utah resident, you have the following rights regarding the Personal Information we collect about you:

RIGHT TO ACCESS

You have the right to request confirmation whether or not we are processing your Personal Information and to access such Personal Information.

RIGHT TO DELETE

You have a right to request deletion of Personal Information you have provided to us.

RIGHT TO DATA PORTABILITY

You have a right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data.

RIGHT TO OPT-OUT

You have a right to opt-out of the processing of the Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling.

PROCESS

You can exercise the foregoing rights by calling (201) 559-1158 or emailing privacy@snowcloud.io. If we are unable to authenticate the request using commercially reasonable efforts, we will not be required to comply with your request to initiate an action of your rights and may request that you provide additional information reasonably necessary to authenticate your request.

RESPONSE TIME

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will seek an additional 45 days. Any disclosure will only cover the twelve (12)-month period before the date verifiable consumer request was received. If we cannot process your request, we will explain the reason why we cannot comply with the request, along with information on how to appeal our decision.

             

CONNECTICUT RESIDENTS

If you are a Connecticut resident, you may have additional rights under Connecticut law. This Connecticut Privacy Notice is intended to comply with Connecticut‘s Data Privacy Act and applicable regulations. Terms used in this Connecticut Notice have the meaning given to those terms in such laws and regulations. In the event of a conflicting of defined terms, the definitions in the laws and regulations control.

CATEGORIES OF PERSONAL INFORMATION COLLECTED

We collect the categories of Personal Information as set forth in the SNOW Cloud Privacy Policy

Section above titled “Collection of Personal Information.”

PURPOSE FOR COLLECTING PERSONAL INFORMATION

We collect Personal Information for the business and commercial purposes set forth in the SNOW

Cloud Privacy Policy Section above titled “Purpose for Collection of Personal Information.”  

CATEGORIES OF THIRD PARTIES

We have disclosed Personal Information to the categories of third parties as set forth in the

SNOW Cloud Privacy Policy Section above titled “Disclosure of Personal Information.”

YOUR CONNECTICUT RIGHTS

As a Connecticut resident, you have the following rights regarding the Personal Information we collect about you:

RIGHT TO ACCESS

You have the right to request confirmation whether or not we are processing your Personal Information and to access such Personal Information.

RIGHT TO CORRECT

You have a right to request the correction of inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of such Personal Information.

RIGHT TO DELETE

You have a right to request deletion of Personal Information concerning you.

RIGHT TO DATA PORTABILITY

You have a right to obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data.

RIGHT TO OPT-OUT

You have a right to opt-out of the processing of the Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling.

PROCESS

You can exercise the foregoing rights by calling (201) 559-1158 or emailing privacy@snowcloud.io. If we are unable to authenticate the request using commercially reasonable efforts, we will not be required to comply with your request to initiate an action of your rights and may request that you provide additional information reasonably necessary to authenticate your request.

RIGHT TO APPEAL

If we reject or deny your request, you have the right to appeal our decision by submitting an appeal to privacy@snowcloud.io. This appeal request must be submitted within a reasonable time following our rejection of your request.

RESPONSE TIME

We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will notify you of taking an additional 45 days. Any disclosure will only cover the twelve (12)-month period before the date verifiable consumer request was received. If we cannot process your request, we will explain the reason why we cannot comply with the request, along with information on how to appeal our decision.