PRIVACY POLICY

Last updated: March 20, 2025

This policy provides information about data we collect, use, and share, and our commitment to using the personal data we collect in a respectful fashion.

Scope of our policy

This is the Privacy Policy of CIPO Cloud Software, Inc. (“CIPO”, “we”, “us” and/or “our”) for CIPO customers and their individual users (“Clients”, “you” or “your”). CIPO’s head office is located at 651 N BROAD ST, STE 205 #2347, Middletown, DE 19709.  This Privacy Policy has been created to provide information to our Clients about our company and, our cloud-based integrated and fully customizable business process execution software services and other related services (“Services”). This Privacy Policy sets forth CIPO’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected, used, shared and secured from users of our Services. It also describes your choices regarding use, access and correction of your personal information. The use of information collected through our Services shall be limited to the purpose of providing the Services and as otherwise set forth in this Privacy Policy and our Master Subscription Agreement.

EU-U.S. Data Privacy Framework with UK Extension, and Swiss-U.S. Data Privacy Framework

CIPO complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

CIPO is responsible for the processing of personal data it receives, under the DPF, and subsequently transfers to a third party acting as an agent on its behalf. CIPO complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.

The Federal Trade Commission has jurisdiction over CIPO’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, CIPO may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on EU-U.S. and the UK extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact CIPO at privacy@ciposoftware.com and give us the opportunity to resolve your complaint. We will respond to your complaint promptly.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, CIPO commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to PrivacyTrust, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.privacytrust.com/drs/CIPO for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

Additional Information Regarding Transfers of GDPR Protected Personal Data

Transfers within the CIPO group will be covered by an internal data processing agreement between entities of the CIPO group which contractually obliges each member to ensure that Personal Data receives an adequate and consistent level of protection wherever it is transferred to. When CIPO engages in transfers of GDPR and/or UK GDPR and where applicable, the Act on the Protection of Personal Information (“APPI”) protected Personal Data outside of the EEA, UK or Japan (for example to third party service providers for the purposes listed above), we generally rely on either: (i) Adequacy Decisions adopted by the European Commission under Article 45 of the GDPR; (ii) the Standard Contractual Clauses issued by the European Commission or the United Kingdom (as updated from time to time); or (iii) another lawful transfer mechanism provided for under the GDPR or the APPI e.g. Binding Corporate Rules. CIPO also monitors the circumstances surrounding such transfers to ensure that Personal Data continues to be afforded a level of protection that is essentially equivalent to the one guaranteed by the GDPR, UK GDPR and APPI.

Information We Collect

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data that You Provide Through the Services: We collect Personal Data from you when you or your employer voluntarily provides such information, such as name, email, phone numbers, and title. By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of CIPO and the authorized third parties referred to herein located in the United States (or other location used to provide Services in your local region).

Other Information: When you use our Services, we automatically collect information on the type of device you use and operating system version.

Passive Collection: As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

In operating the Services, we may use technology called “cookies” or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Services may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

Business and Operational Data: In connection with your use of the Services we may collect and process data, analytics and reports of Clients, including textual data, images, and PDFs.

Aggregated Personal Data: In an ongoing effort to better understand and serve the users of the Services, CIPO often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and CIPO may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. CIPO may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Location Information: Our Service may collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Service. If you choose to enable our location features, your location information may be publicly displayed within the Service. You may opt-out of location-based services at any time by editing the setting at the device level or by emailing us at privacy@ciposoftware.com.

Please keep in mind that other users can see this information about you, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your location information may be subject to abuse, misuse, and monitoring by others, so please be careful if you choose to enable location functionality. We may also use your location information in an aggregate way, as described above in the “Aggregated Personal Data”. We may share your geo-location data with third parties for the purpose of them serving you information for local services (such as restaurants, meeting places) in your area. If you do not wish to allow us to share your information in this manner, please opt-out by contacting us at privacy@ciposoftware.com.

Our use of your personal data and other information

CIPO uses the Personal Data you provide in a manner that is consistent and outlined within this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. CIPOand its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services.

Our Disclosure of Your Personal Data and Other Information

CIPO is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies for purposes outlined within this Privacy Policy.

Vendors, consultants and other service providers: CIPO, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Third Party Applications: CIPO provides you with opportunities to connect with third-party applications or services. If you choose to use any such third-party applications or services, we may share information about you including your username and any Content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary. This Privacy Notice does not apply to your use of such third-party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and Content. We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.

Legal Compliance: In certain situations, CIPO may disclose your information to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and Terms of Service, (c) to protect the security or integrity of our Services, (d) to protect CIPO, our Clients or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person or (f) to any other third party with your prior consent. 

Aggregated Data: We may also share aggregated information that no longer identifies individual users and other de-identified information with third parties.

Your choices

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

You may sign-up to receive product updated via email or newsletter or text messages or other communications from us. If you would like to discontinue receiving this information, you may opt out of receiving promotional and newsletter communications from CIPO by following the opt-out instructions provided in those communications. You may also opt-out of receiving promotional emails and other promotional communications from us at any time by emailing privacy@ciposoftware.com with your specific request. If you opt out, we may still send you non-promotional communications, such as security alerts, important updates and notices related to your access to or use of the CIPO Services or those about your online account or our ongoing business relations via email, text messages or other communication modes.

We partner with a third party to manage our advertising on other sites. Our third-party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising, click here or if located in the European Union click here. Please note you will continue to receive generic ads.

Access to information

Upon request CIPO will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at privacy@ciposoftware.com with your request. You may access, correct, or request deletion of your personal information by contacting us at privacy@ciposoftware.com. We will respond to these requests within 30-days.

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by CIPO other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to CIPO through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and CIPO shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children: CIPO does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to CIPO through the Services, please contact us at privacy@ciposoftware.com, and we will endeavor to delete that information from our databases.

Links to other websites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by CIPO (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Services do not imply that CIPO endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Security

CIPO takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. While we take reasonable efforts to guard personal information, we knowingly collect directly from you, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to CIPO via the Internet. If you have any questions about the security of your personal information, you can contact us at privacy@ciposoftware.com.

Information collected on the services

CIPO collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the CIPO’s Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client.

CIPO will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

California residents

Personal Information	Sources of Personal Information	Why We Collect Personal Information?	To Whom May We Disclose Personal Information?
Identifiers such as a name, unique personal identifier, email, phone number	Section 3	Section 4	Section 5
Commercial information such as records of services purchased, obtained, or considered as well as records of surveys, promotions and correspondence	Section 3	Section4	Section 5
Internet or other electronic network activity information, including browsing history and search history	Section 3	Section 4	Section 5
Financial information such as your payment card information	Section 3	Section 4	Section 5
Inferences such as how you interact with our Service	Section 3	Section 4	Section 5

 

Other terms and conditions

Your access to and use of the Services is subject to the Terms of Service at /terms or other written, signed agreement you have with CIPO.

 Changes to CIPO’s Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for CIPO to update our Privacy Policy to reflect changes to our information practices. We encourage you to periodically review our policy for the latest information on our privacy practices, especially before you provide any Personal Data.

If we make any changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Notice and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Notice, we will notify you more directly by email or means of a notice on the homepage prior to the change becoming effective. We encourage you to review our Privacy Notice whenever you access the CIPO Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Contacting CIPO

Email: privacy@ciposoftware.com