Cloudshift21 Legal

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Cloudshift21 Terms Of Service

Last updated: September 4th, 2023


These Terms of Service (“Terms”) govern the relationship between you and Cloudshift21 (Cloudtura Oy), a Finnish company (business ID 3234585-5) having its registered office at Lapinlahdenkatu 16, 00180 Helsinki, Finland (hereinafter “Cloudshift21” or “us” or “we” or “our”) and your use of our Capsulized Cloud™ service, a secure, self-sufficient cloud platform that runs on any infrastructure and works right out of the box (“Service”).

By accessing or using the Service, you agree to be bound by these Terms. If you use our Services on behalf of an entity or organization, you are binding that organization to these Terms, and you represent that you have the authority to do so.

Our Service

  • Our cloud-based platform hosts and administers a number of Cloudshift21 Services. It connects to your resources through connectors on any cloud or infrastructure you choose (on-premises, public cloud, private cloud, or hybrid cloud). It allows you to create, manage, secure, and deploy workspaces with apps and data to your end users from a single console. You are solely responsible for complying with all applicable laws and regulations and the protection of personal information.

Beta Terms

Beta Features: Are services, functionalities, or features that We label as beta, preview, early access, or similar descriptors. You may have the option to try these Beta Features, which we offer “as-is” and might be available for a limited duration, possibly subject to additional terms. We provide these features without any warranties, representations, or guarantees, and they may contain errors or not operate as intended. When you use them, you do so at your own risk. If you provide feedback on Beta Features, you grant us the right to use, modify, and incorporate your feedback without any obligations to you. We also reserve the right to change or discontinue Beta Features at any time without notice. We advise you to maintain backup copies of any content or data you share or store while using these features. By using Beta Features, you agree to these conditions in addition to the general terms of use for our Cloud Platform.

Your Use of the Service

Subject to the payment of applicable fees and subject to these Terms, you are granted a non-exclusive, non-transferable, non-assignable, revocable limited right to use the Service as specified in these Terms for the time period separately agreed upon between you and Cloudshift21 in our webpage (

You agree to use our Service in compliance with these Terms and all applicable laws and regulations. You are responsible for ensuring that your use of the Service does not violate any third-party rights or any applicable laws or regulations.


Subscription Fees: By subscribing to the Service, You agree to pay Us a recurring Subscription Fee. The exact amount, billing cycle, and other pertinent details of this Subscription Fee are outlined at the time of subscription or in our platform’s designated pricing section. Subscription Fees are non-cancellable and non-refundable.

Storage, vCPU and Memory Usage and Data Traffic: Your Subscription Fee covers a specified amount of data, cores, and data traffic which we refer to as the “Allowance”. We reserve the right to modify the Allowance, and any changes will be communicated via your subscription details. Allowances are as follows:

  • Storage: 128 gigabytes for development license, and 512 gigabytes for production license;
  • vCPU Usage: 4 vCPU’s for development license, and 10 vCPU’s for production license;
  • Memory Allocation: 8 GB for development license, and 32 GB for production license; and
  • Data Traffic (egress/month): 10 GB for development license, and 100 GB for production license.

Additional capacity:
Should You exceed your Allowance, You have possibility to acquire additional capacity or traffic. The details of additional capacity and traffic fees will be available on our Services pricing section or will be provided to You before any charges are applied.

Payment Terms: All fees, inclusive of the Subscription Fee and any additional capacity or traffic, will be settled as specified on the invoice or within our platform. Should You fail to settle any fees promptly, We reserve the right to suspend or terminate Your access to the Platform.

Changes to Pricing: We hold the right to adjust the fees when necessary. We will communicate any such changes to You in advance, and they will come into effect from Your next billing cycle.

Prohibited Content

You will not record, or transmit any harmful, offensive, unlawful, or otherwise objectionable content to the Service, including content that:

  • (a) is threatening, abusive, harassing, defamatory, vulgar, obscene, discriminatory, or hateful;
  • (b) infringes any patent, trademark, trade secret, copyright or other intellectual property right or violates the rights of others in any way;
  • (c) is harmful to minors; or
  • (d) promotes or provides instructional information about illegal activities or promotes physical harm or injury to any group or individual.

Ownership and Use of Data and Data Protection

You retain ownership of all data you provide or upload to our Service. By using our service, you grant us a non-exclusive, worldwide, royalty-free license to use, copy, transmit, and display such data as necessary to provide the service to you and to analyze usage to develop the Service.

We will only process and use your data:

  1. to provide, protect, and update the Services,
  2. to enforce these Terms and exercise our rights hereunder,
  3. as required by law, and
  4. as otherwise instructed by you. We may collect and use your data on an aggregated and/or anonymized basis for our internal business purposes; provided that we will not use or share this data in a way that identifies any individual or Customer as the source of the data.

The processing of your personal data is governed in our Privacy Policy. In addition to that, the processing of personal data for enterprise customers shall be agreed upon in the agreement between us and the company you represent or from which your employer is buying services.

We will maintain an industry-standard information security program that consists of technical and organizational safeguards designed to protect your data. Notwithstanding the foregoing, you are responsible for maintaining the security and confidentiality of your user accounts, including account credentials such as usernames and passwords. If you want to hear more, please be in contact with us at [email protected].

We may use subcontractors to assist in providing the Services, provided that:

  1. subcontractors who receive your data will be subject to confidentiality obligations no less protective than those that we generally apply with our customers;
  2. we will remain responsible for our obligations under these Terms and for subcontractors’ use of your data, and
  3. the agreement between us and the company you represent or from which your employer is buying services from will govern any sub-processing of personal data.

Service Levels, Support Services, Maintenance, and Backups

We may suspend access to the Service if it is necessary to perform installation, change, or maintenance work, and such work cannot be performed without suspending the software service. We will attempt to inform members of the suspension and the duration of the suspension in advance. We will strive to minimize any inconvenience resulting from the suspension.

We aim to provide the highest possible uptime for the Service. While we endeavor to maintain continuous and uninterrupted Service, due to the inherent nature of SaaS services and dependencies on various factors, we cannot guarantee 100% service uptime. We commit to using our best efforts to ensure that Service is available to you as consistently and uninterruptedly as possible.

There may be occasions when Service will be interrupted for maintenance, upgrades, or emergency repairs, or due to the failure of telecommunications links and equipment beyond our control. We will take all reasonable steps to minimize such disruption and to restore the service as soon as practicable.

In the event of any issues or service interruptions, we commit to using our best efforts to respond for all the problems being reported, depending on the severity of the issue.

We will provide a support channel for you to report issues or seek assistance. Our support team will endeavor to provide timely and constructive assistance on a best-effort basis.

We commit to regular data backups on a best-effort basis to ensure data integrity and availability.

Third-Party Apps

Possible Third-party apps are subject to their own terms and privacy policies. You are responsible for reviewing those terms and policies before using third-party apps. Cloudshift21 is not responsible for third-party apps.


Title, ownership rights, and intellectual property rights in the Service remain with Cloudshift21 and/or its licensors. We reserve any and all rights not expressly granted to you.

If you provide feedback to us, we may use it without restriction or obligation.


We will treat all data you provide or upload to our Service as confidential and will use reasonable measures to protect it from unauthorized access, use, disclosure, or destruction. We will not disclose your data to any third party unless required by law or as necessary to provide the service to you.


You will not and will ensure your users do not:

  1. reproduce, modify, adapt, or create derivative works of the Services;
  2. rent, lease, distribute, sell, transfer, or sublicense the Services to a third party except as permitted in these Terms;
  3. interfere with, disrupt, or circumvent any security measures or mechanisms designed to protect the Services;
  4. reverse engineer, disassemble, decompile, or seek to obtain or derive the source code, underlying ideas, algorithms, file formats, or non-public APIs of Services;
  5. remove or obscure any proprietary or other notices contained in the Services;
  6. harass, threaten, or cause distress, unwanted attention, or discomfort to a person or entity;
  7. impersonate or falsely state or misrepresent an affiliation with anyone;
  8. use the Services to transmit any viruses, worms, trojan horses, or other harmful or malicious code or programs;
  9. use the Services to build competitive products; or
  10. misuse the Services in any way, including in violation of these Terms or applicable law.


Any use of data mining, robots, or similar data gathering and extraction tools or framing all or any portion of the Services without our permission is strictly prohibited.

Export Control

You are obligated to adhere to all applicable import and export control laws, regulations, and orders, including but not limited to relevant economic sanctions laws, regulations, and orders of any jurisdiction in which you operate or do business. You shall not access or use the Service from any country that is subject to comprehensive territorial embargoes or other significant export controls. Additionally, You must ensure that the data you store, transmit, or process through our Service does not infringe upon, or is not prohibited by, any export control regulations.

Any violations of these obligations may result in immediate suspension or termination of your access to the Service at our discretion.

Limited Warranty and Disclaimer



Some jurisdictions do not allow the limitation or exclusion of express or implied warranties, so the above exclusion may not apply to you, and you may have other rights, which may vary according to your jurisdiction.

Limitation of Liability



You acknowledge that some of the data and other content may have been collected from other customers or public sources. We do not claim ownership of such data. Such data are provided “as is” and we make no representations or warranties regarding the accuracy, completeness, or appropriateness of the data. You agree to use the data at your own risk and to comply with all applicable laws and regulations regarding the use of public domain content. We are not liable for any harm, loss, or damage that may arise from the use of public domain content and data provided within the Service. We disclaim any responsibility whatsoever for any data within the Service regardless of who originated that content.

These Terms shall not affect the statutory rights of a customer or exclude or restrict liability resulting from gross negligence or wilful misconduct of Cloudshift21.


You agree to defend, indemnify, and hold harmless Cloudshift21, (and its officers, directors, employees, agents, and affiliates) from and against any claims, actions or demands, including without limitation reasonable legal and accounting fees, alleging or resulting from your use of the Service or breach of these Terms.

Term and Termination

Subscription Term: Your subscription to the Service begins on the date You activate your subscription and will continue for a period of one month (“Subscription Term”) or as separately agreed in writing, unless terminated earlier in accordance with the provisions of this section.

Service Launch: Upon receipt of your payment, We commit to launching the service for You without undue delay. However, specific commencement times may vary based on technical, operational, or other factors.

Automatic Renewal: Unless You notify Us of your decision to not renew before the end of the Subscription Term, your subscription will automatically renew for an additional one-month term under the then-current terms and conditions. You will be informed of any changes to these Terms 7 days before any automatic renewal.

Termination by You: You may terminate your subscription at any time by providing Us with notice. If you choose to terminate before the end of the Subscription Term, You will be liable for any fees or charges incurred up to the end of the Subscription Term, and no partial refunds will be provided for any unused portion of the Subscription Term.

Termination by Us: We may terminate or suspend your subscription without notice if (i) You breach any terms of this agreement and fail to remedy such breach within 7 days of receiving notice from Us; or (ii) You fail to pay the Subscription Fee or any other fees owed to Us; or (iii) We determine that your use of the service poses a risk to Us or our other users.

Effects of Termination: Upon termination of your subscription, all rights granted to You under this agreement will cease immediately. You must promptly discontinue all use of our Services and pay any outstanding amounts owed to Us. We will store your data for thirty (30) days after the termination during which time You have a possibility to download Your data from the Service. We are not obligated to store or retain any data or information that You have uploaded or added to the Service beyond the 30 days period after the termination.

Survival: Any clauses in this Terms that by their nature should survive termination, including but not limited to indemnification, limitations of liability, and dispute resolution, shall survive the termination of this agreement.

Changes to the Service, and these Terms

We reserve the right to modify, update, or otherwise change the Service at our sole discretion. We will provide you with notice of any significant changes. Your continued use of our Service after such notice constitutes your acceptance of these changes.

We may update these Terms from time to time by posting a new amended version on our website. Your continued use of our Service after any such changes will constitute your acceptance of the amended version. In the event you do not agree to any part of the then-current version, your right to use the Service shall terminate, and your use of the Service must stop immediately.

Governing Law and Jurisdiction

These Terms will be governed by and construed in accordance with the laws of Finland. Any dispute, controversy or claim arising out of or relating to these Terms, or the breach, termination or validity thereof shall be attempted to be settled by negotiation. Should the negotiations fail, any disputes arising out of these Terms shall be finally settled by arbitration in accordance with the Arbitration Rules of the Finland Chamber of Commerce. The number of arbitrators shall be one, the seat of arbitration shall be Helsinki, Finland, and the language of the arbitration shall be Finnish.

Contact Us

The contact details of the company:

Cloudshift21 (Cloudtura Oy), (Business ID 3234585-5), Lapinlahdenkatu 16, 00180 Helsinki.

If you have any questions about these Terms or our Service, please contact us at [email protected].

Cloudshift21 Service Description

Last updated: September 4th, 2023

Note: This service description applies to all active releases of the Cloudshift21 platform
These Service Descriptions provide important details for specific Cloudshift21 Services and supplement and form a part of the End User Services Agreement (“EUA”). Capitalized terms used in these Service Descriptions and not otherwise defined here have the meanings set forth in the EUA.

A. Cloudshift21 Cloud Services

Cloudshift21 Cloud is a cloud-based platform that hosts and administers a number of Cloudshift21 Services. It connects to your resources through connectors on any cloud or infrastructure you choose (on-premises, public cloud, private cloud, or hybrid cloud). It allows you to create, manage, secure, and deploy workspaces with apps and data to your end users from a single console. The following Cloudshift21 Services are all provisioned through Cloudshift21 Cloud.


WorkspaceThe Workspace is the central entity that isolates workloads, users, and data. Each user can create as many workspaces as the allocated resources allow. All traffic inside the workspace is guaranteed to be limited to that workspace alone i.e., there is no risk for involuntary leaks between workspaces or to/from the outside. A user can choose to open routes in the CaaS service that can expose user-created containers to the outside world, the user is expected to protect the exposed container from breaches. But the workspace-level isolation still protects all the layers below that.
Container as a service (CaaS)This service makes it possible for users to launch their own containers inside the workspace. There is no other limit on the number of containers inside the specific instance than available HW resources. Containers can pass workload between themselves or be single-purpose ones. Users have full control over how existing user-level resources are shared between containers/functions. What was said above about workspace-level security holds but it is the responsibility of the user/developer to make sure that their developed code follows best practices with regard to security and data protection. Cloudshift21 cannot be held responsible for any shortcomings in the user’s own code.
Notebook managerThe notebook manager is implemented on top of Jupyter, which is an industry standard for data analytics, data science, AI, and ML development and experimentation. Apache Spark is available to use through it, ensuring the best possible scaling and performance capabilities. Several programming languages are available, the platform currently supports Python and SQL. Pandas’ data frames are built in as default. Each notebook instance is protected by and own password/token to enable teams to share a single workspace for different requirements.
Database as a service (DBaaS)The DBaaS is a generic service that initially only provides PostgreSQL but which will be expanded to other databases in the future. A user can of course add an own database handler either via the virtual Kubernetes function or by wrapping one into a container and launch it. But the generic service provides a more robust and better scaling alternative.
Virtual KubernetesThe Virtual Kubernetes function provides a way to get full Kubernetes functionality without having to build and maintain discreet Kubernetes clusters. By running it inside a workspace it provides multi-tenancy in a simple way and also achieves much better scaling than separate physical clusters. It supports running the same Helm charts for deployments that are used on discreet clusters which makes it simple to port any functionality either into or out from the platform. The overhead is very small providing near to identical performance compared to a discreet cluster. This service is currently in beta i.e., not fully tested.
User MonitoringThe platform is collecting all types of logs, traces and metric data. Users will in the future be able to select what data to collect and how to retain any of those types of data for their own applications. Currently the collection and reporting is only available to the platform’s own administrators but relevant user interfaces will be added in the near future.

B. Other Services

Local deployment The platform can essentially be deployed anywhere where a Kubernetes cluster can be built. This makes it possible to for example build and test a function on a central cloud-based instance and then port it (=copy it) to any other instance like a small scale on-premise or even Edge installation. Scaling is in these cases is dependent on the available HW resources. The actual installation process (deployment) is always automated why setting up additional instances after the first one has been tested and validated will be very rapid.
Training Online manual will be provided. More in-depth training to be added at a later stage.
Support Basic support is over email. No other support is provided for the initial beta testing period.

C. General Terms

  1. Availability and Monitoring

    Platform is continuously monitored by platform support team. Infrastructure layer is monitored by actual service provider which is reporting on a continuous basis to the platform team. The actual platform availability is monitored continuously and the actual uptime and availability will in the future be reported per instance on the performance pages of the website.

  2. Performance

    There are several factors influencing the actual performance a user’s application is experiencing. The Cloudshift21 team can only influence directly how the platform itself is performing. A user application’s performance will be influenced by how much resources have been allocated to the account and/or application, how well the application itself is optimized, how much overall load the instance is getting for all logged-in users etc. It is not possible to state a fixed KPI on performance level in general. Performance targets can be set and measured in the monitoring function for each user. SLO (Service Level Objective) at platform level is expected to be 99,95% which means that a well-designed end user application (with failovers, auto scaling) will reach over 99,999% availability. 

  3. Platform support

    Platform support is currently being done at Finnish working hours only in an 8/5 setup. Any issues will be solved in a first-in, first-out cycle.

  4. Maintenance

    There is no need for maintenance breaks for the platform itself as it is a fully continuous deployment structure. Maintenance breaks or outages caused by infrastructure provider will be communicated by the platform team to all users of a specific instance by email. 

  5. Security

    All care has been taken to ensure that the security and isolation of the workspace entity is fully reliable. As the platform builds upon open-source components no guarantee can be given that there couldn’t be an inherent vulnerability in some of them. The overall architecture is such that none of those components are directly exposed to the outside world or logged-in users but as the platform is a microservices based construct there may be situations that cannot be controlled. All components are continuously scanned for vulnerabilities.

  6. Application Security and User Management

    User management builds upon the OAuth2 and OpenID Connect industry standards. User authentication is the main level to which all workspaces created by a user is connected. Users are maintained in a central platform repository where all data is encrypted and to which only the platform instance super user(s) have access. Currently only one user level is supported, groups and organizations as well as connectivity to external user management systems will be added in the future. Authorization is enforced to all levels of direct access and API calls meaning that the originator to a call chain is always maintained and access rights are enforced through all levels.

  7. Data Center Security

    The main deployment model is to run the platform at a commercial cloud provider. Ensuring data center security is handled by these providers by default and is part of the setup. On-premise and Edge data center locations will be analyzed and agreed upon between customer and Cloudshift21 on a case-by-case basis.

  8. Data Management

    Data is kept in whatever storage system the actual cloud provider is offering. But all data is kept by the platform as encrypted both at rest and in motion. In the case that data is stored outside the actual platform deployment premises the storage security lies with the owner of the data location premises. Full encryption cannot be enforced on those why the protection only extends to the time data is read or written to/from that external site.

  9. Service Backup and Restore

    Data is backed up as part of the service provider’s standard policies for each location. The platform’s internal data is backed up based on Cloudshift21’s internal practices and can be restored either to the original location or if that is completely inaccessible to some other similar location. In the case of a completely new location there will be an additional delay due to setting up relevant connectivity and load balancing parameters but full recovery should be possible in hours at most.

  10. Disaster Recovery and Business Continuity

    Most of this is already covered in the previous point. In the case of on-premise or Edge locations it may not be possible to find an alternative location as easily as with a mainstream cloud provider. All the actions and processes needed to cover these will be handled separately in the contractual terms agreed between customer and Cloudshift21.

Privacy policy of Cloudshift21 service

This Privacy Policy has been updated on 4th of September, 2023.


  • At Cloudshift21, we’re committed to your privacy. We know that earning your trust is utmost important to us when you use our services. Our users’ privacy is of high priority to us at Cloudshift21 and underscores our technology and business decisions.
  • We provide you with Capsulized Cloud™ service, a secure, self-sufficient cloud platform that runs on any infrastructure and works right out of the box. We go to the best possible extent to protect your data and keep it private and secure. Data we may collect when providing you with our cloud-based platform are with the purpose of providing best results and personalized experience and to improve our services.
  • This privacy policy applies to the collection, use, and disclosure of personal data for marketing and sales of services, customer agreements and visit the Website, or communicate or interact with us via the website e.g., download material, subscribe to our newsletters, take part in a promotion campaign, or give us feedback.


What Information Do We Collect?

We collect personal data from You when you use our services, visit our website or otherwise interact with us:

  • basic information, such as name, title, and your relation to a company you represent and contact details (email address);
  • login Information, such as username, password, and any security questions or authentication data you provide to ensure the security of your account.
  • information relating to our relationship, such as services and order details, contract information, payment details, billing information;
  • marketing and communication data e.g., your interests and preferences, selections, marketing permissions and prohibitions;
  • your interaction and related records such as correspondence, your comments, or responses to our surveys;
  • personal data generated while visiting our website through cookies or otherwise, and how you use the website;
  • technical data on browsing the website e.g., language, device ID and type, operating system, application settings as well as other data collected by means of cookies and similar technologies; and
  • other data, which is based on your consent and defined in detail on a case by case basis.
  • We also collect personal data when you fill out a form on our website to request more information. We may collect personal information such as your name, email address, phone number, and company name.

We may collect and use for any purpose aggregated data, where individual person is not identified from e.g., statistical data collected in connection with the provision of services usage of the resources within the Service.

Processing of Personal Data

We only collect and process personal data, which is needed for managing our relationship with you and for other relevant operational or commercial purposes, including the processing of personal data for anonymizing it.

Provision of Service

We process your personal data for the performance of an agreement to provide our services to you, improve our services, and comply with legal obligations or our processing is based on legitimate interest in providing quality services to our customers. The purposes for which we process your data are:

  • Marketing and Sales of services to contact regarding your interest in our services
  • Keeping Cloudshift21 services running – Providing services to you and ensuring the functioning and maintenance of services;
  • Verifying your identity for the purposes of signing into services; 
  • Managing the customer relationship with you, including customer communication, user account management and processing payments;
  • Improving Cloudshift21 services; 
  • Interacting with You for feedback on our services;
  •  Improving and personalizing services and to develop new services and providing notifications on new features, changes, and improvements;
  • Customer Support, corresponding with users, solving issues, and providing customer support through phone or email; and
  • Informing you of new services, features, and content we may offer.

Website admin, and Information Security

  • We process personal data to administer and maintain our website, including hosting and delivering of content therein and for preventing faults and repairing thereof. Your personal data may be used to ensure the information security of the website, including prevention of possible frauds and relevant investigations. In these cases, the processing is based on our legitimate interest to operate business effectively and to ensure that the website is appropriately protected. Our legitimate interest collection and analyzing of the necessary information to develop our operations e.g., functionality of the website.
  • We may process personal data for measurement and reporting including statistical information about the use of our website based on your consent.

Marketing and Analytics

  • We may market and inform you about Cloudshift21 services. We may combine the data collected about you from publicly available sources, and from our different interactions with you. Further, your personal data may also be used for market research and customer surveys. Processing of personal data is based on our legitimate interest to collect and analyze relevant information to better understand our customers and develop relevant services.
  • Based on your consent we may store and access information, including personal data, on your device in order to create personalized ads profiles and deliver relevant content at the website as well as to measure the effectiveness of the advertising. Respectively, your personal data may also be processed to develop and improve the website, or for developing our own or our partners’ services.

Compliance with the law

We process your personal data in order to meet our statutory obligations e.g., to fulfill authorities’ requests based on the law.

Other purposes you have consented to

We may process your personal data also for specific purposes if you have consented to such processing. Processing of data on browsing the website and your preferences related thereto as well as sharing such data with nominated third parties is primarily based on your consent.

Use of Cookies

When you visit our website, Cookies, and other similar technologies (“Cookies”) are used to automatically collect information about your visit. Collected information is e.g., browser type and IP-address. It is possible for you to accept or refuse the use of the cookies in our Cookie-banner. 

  • Cookies remain on your device until they are expired, or you delete them. Retention time for each cookie is available through cookie banner in our website.
  • You can accept or refuse cookies or change your earlier choices through cookie banner at our website. 
  • You can always disable cookies or clear your cookie history for all visited websites from your browser settings. 
  • Accepting cookies will enable you to get the best from our website. If you refuse cookies, some aspects of the website may not work on your device, and you may not be able to access all areas thereof.

Communication of the Marketing Activities

  • We send commercial e-mails that may include technologies (web beacons, cookies or similar) that allow us to know what you do with the message (open, read etc.) and links you may click. When you click a link in our marketing e-mail, we will also use a cookie to log what pages you view and what content you download from our website.
  • You may control the use of your personal data for direct marketing purposes. You can ask us to stop sending you marketing messages by following the opt-out links on any marketing message sent to you at any time. In such case, we will retain minimum amount of personal data to respect your choice in order to avoid contacting you again.
  • Please note that even though you opt-out of direct marketing, we may need to contact and communicate with you in connection with the other purposes your personal data is processed for.

Data Sharing and Disclosures of Personal Data

  • We may use subprocessors to assist in providing the Services, provided that:
    (i) subprocessors who receive your data will be subject to confidentiality obligations no less protective than those that we generally apply with our customers;
    (ii) we will remain responsible for our obligations under this Privacy Policy and for subprocessors’ use of your data; and
    (iii) agreement between us and the company you represent or from which your employer is buying services from will govern any sub-processing of personal data.
  • We may also disclose your personal data to comply with legal obligations or protect our legal interests.

Transfer of Personal Data Outside of the EU or EEA

  • The data we collect is processed by us within the European Union (EU)/European Economic Area (EEA) and in third party data processing facilities within the EU/EEA.
  • Some of our service providers may have access or are located outside the EU/ EEA and their processing of your personal data will involve a transfer of data outside of EU/EEA. We will take necessary steps to provide appropriate safeguards for international data transfers and to the extent necessary implement supplementary measures for protection of personal data as required by applicable laws. Personal data is transferred only to countries that have been deemed to provide an adequate level of protection of personal data, and where not we will implement the standard contractual clauses and implement necessary technical, organisational, or contractual supplementary measures to ensure that personal data has the same protection as in EU/EEA.

Retention of Personal Data

  • We will retain your personal data only for as long as necessary to communicate with you for sales, marketing and other purposes, provide access to our website, and as required by law (different data categories have different retention periods). After that, we will securely dispose of your personal data.
  • Your personal data processed based on a customer relationship with you, or a company you represent, are stored, as a rule, for the duration of the customer relationship or as long as the provision of the services requires. After our relationship or service provision has ended, we store personal data that are necessary to protect our legitimate interests e.g., enabling response on requests or claims under applicable provisions concerning statute of limitations, or we may store your personal data, to the extent necessary, in order to respect your request not to receive direct marketing from us.
  • Personal data processed based on legitimate interests are processed as long as there are grounds for their processing. If you object such processing, data will be erased after your request has been validated. An example of this kind of processing falling within the scope of legitimate interest is direct marketing.
  • If personal data is processed based on legal obligations, it is retained as long as required by law. 
  • The storage time of personal data processed with your consent is determined according to the purposes of processing.

Your Rights

You have certain rights regarding your personal data:

  • Right to Access: You have the right to access your personal data that we hold.
  • Right to Rectify Personal Data: You have the right to request that we correct any inaccurate or incomplete personal data that we hold.
  • The Right to Object to the Processing: You have the right to object to the processing of your personal data for certain purposes.
  • The Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
  • The Right to Be Forgotten: You have the right to request that we erase your personal data under certain circumstances.
  • The Right to Restriction of the Processing: You have the right to request that we restrict the processing of your personal data under certain circumstances.
  • The Right to Give and Withdraw Your Consent: You have the right to give or withdraw your consent for the processing of your personal data.

Data Security

  • We take appropriate technical and organizational measures to protect your personal data from loss, destruction, unauthorized access, disclosure, or other misuse. These measures include physical, electronic, and procedural safeguards that comply with applicable legal requirements. We limit access to personal data to those authorized employees and service providers who need to know the information in the course of their duties. They will only process your personal data based on our instructions and are subject to a confidentiality obligation.
  • Personal Data is stored in an encrypted database within our platform. We adhere to best practices for persisting and encrypting data, and to that end, data is always encrypted in transit and at rest. 
  • Although our good faith efforts to store your data in a secure operating environment that is not available to the public, please remember that unfortunately no data transmission or storage is 100% risk free. You provide your personal data at your own risk and we cannot guarantee the absolute security of your data. In the unfortunate case of a security breach that that endangers your privsubnacy or data we will inform you as well as the relevant authorities, as required by law. We may also temporarily shut down services to protect the personal data.

Changes to the Privacy Policy

We may update this privacy policy from time to time. We will notify you of any significant changes by posting a notice on our website or by sending you an email.

Contact Us

The contact details of the company: Cloudshift21 (Cloudtura Oy), (Business ID 3234585-5), Lapinlahdenkatu 16, 00180 Helsinki. 

If you have any questions or concerns about this privacy policy or our use of your personal data, please contact Cloudshift21 Data Protection Officer, at [email protected].

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