References to "you," and/or "User" mean a general user of the Website and/or the Learning Platform, whether as a registered member, email list subscriber, subscriber to our private Facebook group, or general Web site user.

The following Privacy Policy governs CloudWolf’s collection and use of its Users’ private information. By accessing the Website or the Learning Platform you represent that you have read and understood the Privacy Policy and that you agree to be bound by thereby.

This Privacy Policy may be additionally subject to our Website Terms and Conditions and any other agreement entered into between us. This Privacy Policy is provided pursuant to the APPs described in the Privacy Act.

The parties acknowledge that in relation to the processing of Personal Information or Personal Data in connection with the provision of the Services under this Agreement, you shall be the Data Controller for the purposes of the Data Protection Laws and CloudWolf the Data Processor.

We and you will both comply with our obligations under the Data Protection Laws, including the Privacy Act, and to the extent each is an APP Entity, comply with the Notifiable Data Breach provisions in the event of a data breach affecting Personal Information of the other party. CloudWolf shall, unless prevented by law, promptly inform you upon receiving any notice or communication from any Data Subject, supervisory or government body, including the United Kingdom Information Commissioner’s Office, or any other regulatory authority under GDPR which relates to the processing of Personal Information or Personal Data under this Privacy Policy.

CloudWolf warrants that it shall implement and maintain appropriate administrative, technical, physical and organizational measures to protect Personal Information against personal data breaches, and any applicable Notifiable Data Breach, having regard to the state of technological development and the cost of implementing such measures, to ensure a level of security appropriate to:

CloudWolf shall, at your expense and taking into account the nature of the processing, assist you by providing appropriate technical and organizational measures, insofar as this is possible, in the fulfilment of your obligations under Data Protection Laws and in particular to respond to requests for exercising the rights of Data Subjects, and any applicable Notifiable Data Breach. In the event of a claim, each party will pay all fines for which it is liable as imposed by a regulatory authority.

You agree to furnish us without demand, with any privacy policy which you may have in effect from time to time.

We may modify, add to, suspend, or delete the Privacy Policy, in whole or in part, at our sole discretion at any time, with such modifications, additions or deletions being effective thirty (30) days following their posting to the Website and emailing of a notice to our registered Members. Your continued use and/or access of the Website or Learning Platform after modification, addition or deletion of the Privacy Policy shall be deemed to constitute acceptance by you of the modification, addition, or deletion.

We do not collect any Sensitive Information. We ask that no User reveal such information in an Interactive Area as defined in our Website Terms and Conditions.

We collect both Personal Information and information which does not constitute Personal Information from our Users by lawful and fair means within the requirements of the legislation.

We only collect such Personal Information as is reasonably necessary for one or more of our functions or activities. In the event such Personal Information is provided by someone other than the User whom it identifies, we will notify the User as is reasonable in the circumstances and otherwise ensure that the User is aware of any such matters. For legal and practical reasons, CloudWolf may not be able to provide its services or access to the Learning Platform without the provision of such Personal Information by our Users to us.

We also collect information which does not constitute Personal Information , such as your IP address, browser/software used to access the Website or the Learning Platform, the Web sites you visit before/after visiting the Website or Learning Platform, type of device used to access the Website or the Learning Platform, and the date and time of your visit to the Website or Learning Platform.

In the event unsolicited Personal Information regarding a User is provided to or otherwise received by us and where the same was not solicited by us or otherwise not information we may have solicited under this Privacy Policy or is not contained in a public record, we will destroy any such information as soon as reasonably possible, but only if it is lawful and reasonable to do so, or otherwise deo-identify such information as per APP 4.

Given the nature of the services provided by CloudWolf and our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 it is impracticable for our Members to remain unidentified or use pseudonyms as detailed in APP 2.1. General enquiries about products and services can be handled anonymously if requested, however failure to provide the personal information required may mean that we cannot provide the services requested or we may be forced to withdraw our services

We may use your Personal Information only for the particular purpose for which it was collected and will not use the information for a secondary purpose unless the User has consented to the use or disclosure of the information or as set forth more fully in Section 11. Specifically, we may use your Personal Information to personalize your User experience; to improve customer service: to process transactions; to administer a contest, promotion, survey or other feature; to contact registered Users via email in order to send them information and updates pertaining to their orders or subscriptions; to respond to inquiries, to send company news, updates and other related information; and to comply with regulatory or legal requirements.

If we receive or otherwise hold Personal Information about an individual, we will not use or disclose the information for the purpose of direct marketing as per the rules and regulations of APP 7.1.

Notwithstanding the forgoing, Users who provide us their email addresses are automatically added to our newsletter and other mailings. Members who register for our services, if they have not opted-in to our newsletter prior to the time of registration, are automatically added. All Users may opt out to receiving marketing information and our newsletter via the unsubscribe link contained at the bottom of certain emails or by emailing us as support@cloudwolf.com. Users should note that opting-out does not prevent us from contacting you regarding your account or any transactions.

Email marketing campaigns published by us may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but shall not be limited to: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.

This information is used to refine future email campaigns and supply the User with more relevant content based around their activity.

This principle does not apply to the extent that a solicitation act preempts the APP regulations, including but not limited to the Do Not Call Register Act 2006, the Spam Act 2003; or any other Act of the Commonwealth, or a Norfolk Island enactment, prescribed by the regulations or any other federal, state, provincial or local rule or regulation which may apply, including but not limited to the U.S. CAN-SPAM Act of 2003, the E.U. Directive on Privacy and Electronic Communications, and the U.K. Privacy and Electronic Communications (EC Directive) Regulations of 2003.

Please note that while you may have the opportunity to opt-out of targeted advertising as discussed in the “How to Opt-Out” section above, and you may be able to control the use of cookies through your Web browser as described in the “Use of Cookies” section below, some Web browsers may also give you the ability to enable a “do not track” setting. This setting sends a special signal to the Web sites you encounter while Web browsing. This “do not track” signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. We do not respond to Web browser “do not track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Policy. For more information about “do not track,” visit www.allaboutdnt.org.

Your Personal Information may be used by us for the purposes provided for in this Privacy Policy or as consented to by you. We may disclose your Personal Information to the extent you would reasonably expect us to use or disclose the information for the purpose of providing our services, the Web site and/or the Learning Platform to you; if the use or disclosure of the information is required or authorized by or under the law or a court/tribunal order; if a permitted general situation exists in relation to the use or disclosure of the information; if we reasonably believe that the use or disclosure of the information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

We may also disclose your Personal Information to external parties who provide services to CloudWolf including (but not limited to): our payment processor in order to facilitate transactions; organizations that assist us with fund registry, archival, research, mail and delivery, auditing, recruitment, payroll, superannuation, insurance, management consulting, financial and legal advisory, banking, security and technology services in their capacity as service providers to CloudWolf; or if we, or our assets, are acquired by a third party, in which case personal data held on the Web site will be part of the transferred assets.

By accessing the Website or otherwise utilizing the Learning Platform, you consent to your Personal Information being shared with such third-parties and are encouraged to review the privacy policies of such third-parties as they may differ from the CloudWolf Privacy Policy.

In addition to the forgoing disclosures contained in Section 11, we reserve the right to disclose your Personal Information as required by law and when believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms or policies or another agreement into which we have entered with you, or as otherwise required by law. If a disclosure is made pursuant to this Section, we will provide the affected User written notice of the use or disclosure.

In the event CloudWolf is or becomes a body corporate and collects Personal Information from a related body corporate, we may disclose Personal Information to a related body corporate for the primary purpose for which the related body corporate collected the information. This principle shall not apply to the use or disclosure by us of Personal Information for the purpose of direct marketing or government related identifiers.

Our Website and Learning Platform may contain links to other Web sites or software, which are outside our control and are not covered by this Privacy Policy. If you access other Web sites and/or software using the links provided, the operators of these Web sites and/or software may collect information from you, which will be used by them in accordance with their own privacy protection procedures, which may differ from ours.

To enhance your online experience, we may use “cookies” or similar technologies, such as Web beacons, activity tracking, app performance tracking, UTM codes, and personalized advertising. Cookies are text files placed in your computer's browser to store your preferences. Cookies do not contain Personal Information; however, once you choose to furnish a Web site or mobile software application with Personal Information, this information may be linked to the data stored in the cookie.

We use cookies to understand Web site, Learning Platform and Internet usage and to improve or customize the content, offerings or advertisements on our Web site and Learning Platform. For example, we may use cookies to enable us to detect and report security issues affecting our Web site and Users; personalize your experience at our Website or Learning Platform (e.g., to recognize you by name when you return); save your password in password-protected areas; and enable you to use shopping carts on our site (if available.) We also may use cookies to help us offer you products, programs, or services that may be of interest to you and to deliver relevant advertising.

We, our third-party service providers, advertisers or our partners also may use cookies to manage and measure the performance of advertisements displayed on or delivered by us and/or other networks or sites. This also helps us, our service providers and partners provide more relevant advertising.

We, our third-party service providers, advertisers and/or our partners may also use “Web beacons,” activity trackers, or clear .gifs, or similar technologies, which are small pieces of code placed on a Web page, to monitor the behavior and collect data about the visitors viewing a Web page. For example, web beacons may be used to count the users who visit a Web page or to deliver a cookie to the browser of a visitor viewing that page.

You can change your privacy preferences regarding the use of cookies and similar technologies through your browser. You may set your browser to accept all cookies, block certain cookies, require your consent before a cookie is placed in your browser, or block all cookies. Blocking all cookies will affect your online experience and may prevent you from enjoying the full features offered by us. Please consult the “Help” section of your browser for more information or follow the links below.

If you access the Web site or Learning Platform and volunteer Personal Information, you may request access to your Personal Information by sending us an email at support@cloudwolf.com. We will endeavor to respond in writing to such requests as is reasonable under the circumstances and within thirty (30) calendar days and give access to the information in the manner requested by the individual, if it is reasonable and practicable to do so. In certain circumstances, we may not be required by law to provide you with access to your Personal Information as well as circumstances where giving access would pose serious threat to life, health or safety of any individual or public, where the request is frivolous or vexatious, where giving access would be unlawful or where denying access is required by law. If access is denied, then we will give you written reasons for that decision and details available to complain about the refusal. An access fee may be charged where permitted by law.

If you access the Web site or Learning Platform and volunteer Personal Information, you may request modification of your Personal Information by sending us an email at support@cloudwolf.com. We will endeavor to respond in writing to such requests as is reasonable under the circumstances and within thirty (30) calendar days and make such modification to the information in the manner requested by the individual, if it is reasonable and practicable to do so. If we refuse or are unable to correct the Personal Information as requested we will give a written notice that sets out the reasons for the refusal (except to the extent that it would be unreasonable to do so) and the mechanisms available to complain about the refusal. You should be aware that it is not always possible to completely remove or modify information in our databases.

In order to monitor compliance with this Privacy Policy and subject to this Privacy Policy, CloudWolf shall:

You shall reimburse us for the time expended during any such audit. Before the commencement of any such audit, we shall mutually agree upon the scope, timing and duration of the audit in addition to the reimbursement rate for which you shall be solely responsible.

You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us. Upon request, CloudWolf will provide you with information about whether we hold any of your personal information. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format. If you need further assistance, you can contact CloudWolf through one of the channels listed below under “How to Contact Us.” We will respond to your request within a reasonable timeframe or as required by law.

If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications.

Protecting children's privacy is important to us. For that reason, we do not collect or maintain information of those persons we actually know are under the age of thirteen (13) nor is any part of the Web site or the Learning Platform targeted to attract anyone under the age of thirteen (13). We request that all users of the Web site and the Learning Platform who are under the age of thirteen (13) not disclose or provide any Personal Information. If we discover that a child under thirteen (13) has provided us with Personal Information, we will delete that child's Personal Information from our records.

In addition to protecting the privacy of children under age (13) we are committed to protect the privacy of minors. Though neither the Web site nor the Learning Platform is targeted to minors nor is it intended to be used by minors, if, for any reason a minor has shared Personal Information via our Web site or Learning Platform said minor may request and obtain removal of such information by contacting us at support@cloudwolf.com. Although we offer deletion capability for our Web site and Learning Platform, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the Web site.

We take reasonable steps in the circumstances to ensure that the Personal Information that we collect is accurate, up-to-date and complete. We also take reasonable steps in the circumstances to ensure that the Personal Information we use or disclose is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.

We take reasonable steps to maintain the security of the Personal Information that we collect against misuse, interference and loss as well as unauthorized access, modification and disclosure, including utilizing SSL technologies and management-only access; however, no data transmission over the Internet can be guaranteed to be completely secure. Thus, we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk. Please note that non-encrypted communication using email is not secure. Thus, we cannot guarantee data security in email communication and, therefore, recommend using physical mail for confidential information.

In the event we hold Personal Information that we no longer need for any purpose for which the information may be used or disclosed by us pursuant to this Privacy Policy; the information is not contained in a public record; and we are not required by or under an Australian Federal or state law, or a court/tribunal order, to retain the information we will take such steps as are reasonable in the circumstances to destroy the information or to ensure that the information is de-identified.

We shall ensure that only such of our employees and contractors who may be required by it to assist it in meeting its obligations under this Privacy Policy shall have access to Personal Information.

We shall promptly notify you of any actual or suspected personal data breach, and any Notifiable Data Breach having regard to the likelihood and severity of harm to the interests of you or the Data Subject(s) that may result.

We operate globally so it is necessary to transfer your Personal Information internationally, outside of Australia or an external Territory, to entities and persons who are not the disclosing parties of such information. In particular, your information will likely be transferred to and processed in the United States where our server is located. Please be assured that we will take reasonable steps in all the circumstances to ensure that your privacy is protected and an overseas recipient does not breach the APPs, other than APP1; however, the data protection and other laws of other countries may not be as comprehensive as those in Australia. Therefore, by accessing our Website or the Learning Platform you confirm that having considered the cross-border transfer of your Personal Information to the overseas recipients described in this Privacy Policy you expressly consent to your Personal Information being collected, used and the cross-border transfer of your Personal Information out of Australia as set forth in this Privacy Policy.

CloudWolf will not use or disclose an identifier that has been assigned to an individual by a Government Agency such as a Tax File Number, Social Security Number, or Medicare Number unless required by law. Personal Information on Expiry of Agreement.

On expiry or termination of your Agreement with us; in respect of the Personal Information processed pursuant to that Agreement, we shall cease to use such Personal Information and will promptly arrange for its deletion, except where we may be required to retain Customer records (that could contain certain Personal Information) for the purposes of producing final invoices or for legal and regulatory compliance, in which case, we shall comply with (a) the applicable provisions in such relevant Agreement, and (b) Data Protection Laws regarding the deletion and retention of Personal Information.

If you have any questions or concerns or claims in respect of our Privacy Policy or its implementation you may contact us by email at support@cloudwolf.com or by postal mail to CloudWolf Pty Ltd, an Australian limited company, with a principal place of business located at 15 Macleay Crescent, Pacific Paradise, QLD 4564.

All notices under this Privacy Policy must be given by e-mail.

For information about privacy generally, or if your concerns are not resolved to your satisfaction, you can contact the Office of the Australian Information Commissioner (OAIC) on 1300 363 992 or via www.oaic.gov.au or your local governing authorities.

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