Privacy Policy

What Type of Personal Data Do We Collect about You?
Links to Other Websites
No Information from Children Under Age 18
How Do We Use the Information We Gather?
Do We Share Your Personal Information with Third Parties, such as Affiliates?
Is Your User Data Secure?
How Long Do We Store Your Data?
Where We Store Your Personal Data
Where We Store Your Personal Data
How Do We Use Cookies
Do We Use Your Information for Advertising Purposes?
How we use data to provide the Services?
Changes to Our Privacy Policy
Contact Us

THIS POLICY CONTAINS INFORMATION REGARDING OUR USE OF COOKIES, THE PROCESSING OF YOUR PERSONAL DATA AND YOUR PRIVACY RIGHTS

Effective date: February 21, 2024

Please note that this Cycleops Privacy Policy applies to personal data that is collected and processed by Stackmasters LLC, a company incorporated under the laws of USA, having its registered office at 315 Montgomery Street, San Francisco, CA 94104, USA (references to Cycleops, us, we or our in this Privacy Policy refer to Stackmasters LLC). Cycleops offers an application deployment platform (“the Services”).

Cycleops understands the importance of protecting your information. We recognize that when you choose to provide us with information about yourself, that you are trusting us to use it in a responsible manner. This Privacy Policy applies to any information provided or collected through our website https://www.cycleops.io (the Website) and outlines how Cycleops as a data controller collects, processes, uses and discloses the information you provide by using the Website. This Privacy Policy also applies to any information provided or generated by you, when ordering and using the Services. In this case, Cycleops processes information collected as a data processor.

By accessing and using this Website, you confirm that you have read and fully understood this Policy, that you agree to the collection and the usage of your own and others’ personal data in accordance with the Policy and that you have the authority to provide Cycleops with all information submitted by you via the Website and the Services, including but not limited to the personal data of third parties.

We will use your personal data only for the purposes and in the manner set forth below, which describes the steps we take to ensure our processing of your personal data is in compliance with applicable data protection law, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA).

Please read the following carefully to understand our use of your personal data. 1

1. What Type of Personal Data Do We Collect about You?

“Personal data” means any information about an individual from which that person can be identified. We only collect personal data about you on our Website which you volunteer by emailing us, by using our online forms or to send you emails or other information. In addition to the information you provide to us, we collect certain information when you visit our Website as explained in our ‘How Do We Use Cookies’ section below. Last, if you decide to purchase or sign in the Services for free, then Cycleops processes Personal Data inputted in the Services by you/the Customer and your Authorized Users (users you permit to access and use the Services) in the way described in our ‘How we process data to provide the Services’ section below.

When you visit or use our Website in any way, we collect and process different types of information about you:

Identity Data includes first name, last name, and title
Contact Data includes email address, telephone numbers, and company information
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this Website
Usage Data includes information about how you use our website
Marketing and Communications Data includes your preferences in receiving marketing from us

Unless you are purchasing our product or signing up to the Services for free (see ‘How we process data to provide the Services’ section below), the provision of your personal data is not a statutory or contractual requirement and you may refuse to disclose same. You can choose not to provide this information; however, you might not be able to enjoy full functionality of the Website.

2. Links to Other Websites

Our Website may, from time to time, contain links to third-party websites. If you follow a link to any of those third-party websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those practices. Please check those policies before you submit any personal data to those websites.

You may also be able to access third party social media services through our Website by using social media plugins on our Website. In that case URL data may be transferred to this third party, based on this party’s privacy policy. Make sure you read the privacy policy of this third party, before you proceed to the plugin.

3. No Information from Children Under Age 18

This Website is not intended for children and we do not knowingly collect data relating to children. If you are under the age of 18, please do not attempt to register with us at this Website or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 18, we will promptly delete that information.

4. How Do We Use the Information We Gather?

We only use your personal data for the purposes and legal bases set out in the table below.

Purpose(s) for Processing Legal Basis for Processing	Legal Basis for Processing
To provide you with information about Cycleops and our products and provide newsletters or email updates to you; To notify you about webinars, events, and news that may be of interest to you. To understand the flow of traffic on our Website and to provide a better website experience and to understand the needs of our customers (see our ‘How we use cookies?’ section below). To allow you to participate in interactive features of the Website, when you choose to do so. To keep our Website and the Services updated and relevant, to develop our business and to inform our marketing strategy and monitoring how you use our Website and Services. To measure your interest in and improve our products, services, and the Website. To ensure that content on the Website and the Services is presented in the most effective manner for you and for your computer or mobile device. To manage and operate our website (see below ‘necessary cookies’) and the Services (see ‘How we use data to provide the Services’ section below). For the prevention and detection of fraud, money laundering or other crimes or for the purpose of responding to a binding request from a public authority or court. To provide the Services	Your consent – which you can withdraw at any time. The processing is necessary to support our legitimate business interests in managing our business provided such interests are not overridden by your interests and rights. We have carried out a balancing test to ensure that your interests do not override this legitimate business interest of ours. Please note that you have a right to object to the processing of your personal data where that processing is carried on for our legitimate interest. You have the right to object at any time. The processing is necessary to comply with legal and regulatory obligations. The processing is based on a contract and a data processing addendum the Customer/you execute Cycleops, in which you provide us with the instructions for the processing

Purpose(s) for Processing Legal Basis for Processing

Legal Basis for Processing

To provide you with information about Cycleops and our products and provide newsletters or email updates to you; To notify you about webinars, events, and news that may be of interest to you. To understand the flow of traffic on our Website and to provide a better website experience and to understand the needs of our customers (see our ‘How we use cookies?’ section below). To allow you to participate in interactive features of the Website, when you choose to do so. To keep our Website and the Services updated and relevant, to develop our business and to inform our marketing strategy and monitoring how you use our Website and Services. To measure your interest in and improve our products, services, and the Website. To ensure that content on the Website and the Services is presented in the most effective manner for you and for your computer or mobile device.
To manage and operate our website (see below ‘necessary cookies’) and the Services (see ‘How we use data to provide the Services’ section below).
For the prevention and detection of fraud, money laundering or other crimes or for the purpose of responding to a binding request from a public authority or court.
To provide the Services

Your consent – which you can withdraw at any time.
The processing is necessary to support our legitimate business interests in managing our business provided such interests are not overridden by your interests and rights. We have carried out a balancing test to ensure that your interests do not override this legitimate business interest of ours. Please note that you have a right to object to the processing of your personal data where that processing is carried on for our legitimate interest.
You have the right to object at any time.
The processing is necessary to comply with legal and regulatory obligations.
The processing is based on a contract and a data processing addendum the Customer/you execute Cycleops, in which you provide us with the instructions for the processing

We may disclose your personal data to any member of our group from time to time to provide you with the services or products requested.

We may disclose your personal data to third parties who provide a service to us, including:

Providers of online marketing efforts;
Providers of cloud-based CRM software;
Providers of cloud-based marketing software in relation to prospective customer information management;
Providers who collect information on our behalf, including as necessary to operate features of the Website, such as surveys
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or court order, or in order to enforce, establish, exercise or defend legal rights, the rights, property, or safety of you, us, our group, or employees;
To detect, prevent, or otherwise address fraud, security, or technical issues; and
To protect against harm to the rights, property or safety of Cycleops, our employees, our users, customers, or the public as required or permitted by law

6. Is Your User Data Secure?

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organization. We will continue to revise policies and implement additional security features as new technologies become available. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorized access or disclosure.

7. How Long Do We Store Your Data?

We store your personal data during the time that you are a customer or end user of Cycleops for purposes of providing you the services, and for as long as it is necessary to comply with legal obligations and for the establishment and defense of legal claims, after you cease to be a customer or end-user. If you have never been a customer or registered end-user of Cycleops, but have consented to receive marketing inquiries or other information from Cycleops, we may store your data for up to two years, after you unsubscribe, to prove that we have respected your consent withdrawal. Upon unsubscribing, you will immediately cease to receive marketing material from us.

8. Where We Store Your Personal Data

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA), for the purposes described above, including to countries such as the United States of America. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and applicable data protection law, including the GDPR, the UK GDPR and the CCPA.

Data transfers outside the EEA or the UK are subject to Adequacy Decisions or to the latest versions of the Standard Contractual Clauses approved by the European Commission from time to time, as published in the Official Journal of the European Union, as well as by the UK Information Commissioner, based on the GDPR and the UK GDPR.

9. Your Rights

Cycleops is committed to ensuring that you have control and visibility to your personal data. Below is a summary of your rights and additional commitments from Cycleops. You may exercise your rights by contacting us at privacy@stackmasters.eu

It is your responsibility to ensure that any information you have provided to us is accurate and up-to-date. If any of the information that you have provided to us changes, please send us an email entitled ‘CHANGE OF DETAILS’ to privacy@stackmasters.eu

Bear in mind that we are entitled to answer to your requests as a data subject, when acting as data controllers. When we are acting as data processors, then data controller, our Customer/you are responsible to address data subjects requests. However, we shall provide any reasonable assistance to the data controller for the satisfaction of data subjects’ rights.

Right of Access

You can request a copy of the personal data we hold about you.

Right to Erasure (‘Right to be Forgotten’)

You have the right to request that your personal data be deleted in certain circumstances including:

The personal data are no longer needed for the purpose for which they were collected;
You withdraw your consent (where the processing was based on consent);
You object to the processing and there are no overriding legitimate grounds justifying us processing the personal data (see Right to Object below);
The personal data have been unlawfully processed; or
To comply with a legal obligation

However, this right does not apply where, for example, the processing is necessary:

To comply with a legal obligation; or
For the establishment, exercise or defense of legal claims

Right to Restriction of Processing

You can ask that we restrict your personal data (i.e., keep but not use) where:

The accuracy of the personal data is contested;
The processing is unlawful but you do not want it erased;
We no longer need the personal data but you require it for the establishment, exercise or defense of legal claims; or
You have objected to the processing and verification as to our overriding legitimate grounds is pending
We can continue to use your personal data:
Where we have your consent to do so;
For the establishment, exercise or defense of legal claims;
To protect the rights of another; or
For reasons of important public interest

Right to Data Portability

Where you have provided personal data to us, you have a right to receive such personal data back in a structured, commonly-used and machine-readable format, and to have those data transmitted to a third-party data controller without hindrance but in each case only where:

The processing is carried out by automated means; and
The processing is based on your consent or on the performance of a contract with you

Right to Object

You have a right to object to the processing of your personal data in those cases where we are processing your personal data in reliance on our legitimate interests. In such a case we will stop processing your personal data unless we can demonstrate compelling legitimate interests which override your interests and you have a right to request information on the balancing test we have carried out. You also have the right to object where we are processing your personal data for direct marketing purposes.

If you do not want to receive newsletters, announcements, or other communications and/or services from the Cycleops, please do not opt-in for those communications or services at the time of registration. If you have opted-in and, later, wish to opt-out, you may be removed from the mailing list, easily and without cost, by selecting the “unsubscribe” link within the e-mail content. You can also send an entitled “UNSUBSCRIBE” to Cycleops at privacy@stackmasters.eu

Right to Complain

We will respond to any request regarding the processing of your data in writing, or orally if requested, as soon as practicable and in any event not more than one month after receipt of your request. That period may be extended by two further months where necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. All requests should be addressed to privacy@stackmasters.eu

You have the right to lodge a complaint with the Data Protection Authority, in the State of your residence, place of work or place of an alleged infringement, if you are unhappy with how we are processing your personal data.

California Residents

Right to opt out and right to Non-Discrimination: If you are a California resident, you should be specifically aware that you have the right to direct a business that sells (or may in the future sell) your Personal Information to stop selling your Personal Information and to refrain from doing so in the future. We do not sell your Personal Information to any other party.

If you are a California resident, you should be specifically aware that we will not discriminate against California residents or against any person, if they exercise any of the rights provided in the CCPA, or any applicable privacy law provision. In particular, we will not deny goods or services; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services; or suggest that anybody (including California residents) will receive a different price or rate for goods or services or a different level or quality of goods or services.

10. How Do We Use Cookies?

Cookies are small data files that are stored in your web browser on your computer, tablet or smartphone (each a “Device”) when you visit a website. Cookies serve many purposes like letting you navigate between pages efficiently, remembering your preferences, interests or log in details, and generally improving your experience.

Cycleops uses cookies to gather information on website usage. This information is gathered to improve the content, usability, and functionality of the website. This helps us better understand our customers and improve their experience with us.

Some cookies are “first party cookies”, which means that they are set by the owner of a website, in our case Cycleops. Cookies set by parties other than the owner of a website are called “third party cookies”.

The following table provides additional information about cookies we use on our Website:

Categories of	Use Description
Necessary	There are the necessary cookies, which are required for technical reasons in order for a website to operate.
Preference	Some cookies are used to enhance the performance and functionality of a website, but are non-essential to their use. However, if you decide not to accept such cookies, certain functionality may become unavailable. Such cookies are called preferences cookies. Cookies can tell us which language you prefer and what your communication preferences are. They can help you fill out forms on cycleops.io more easily. The information is only visible to our domain and analyzed by our in-house team.
Advertising Analytics and Research	We use cookies to show you advertising both on and off the cycleops.io. We use advertising networks to show you targeted ad relevant to your visit to cycleops.io and track your interaction with said ads. These networks may also be able to track your browsing across different sites. These cookies help us learn how well our Website performs in different locations, on different devices, and at different times of the day. Along with what pages you are going to on our Website and how long you stay there.

WEBSITE COOKIES

Further Details on our specific use of cookies are contained in the following table:

Type	Purpose	Who Provides the Cookie?	Duration
Necessary	Provision of the Website	First Party	1 year
Optional	Preferences	First Party	1 year
Optional	Advertising	Google Ads	1 year 1 month 4 days
Optional	Advertising and Social Media	Facebook	3 months
Optional	Analytics	Google Analytics	1 year 1 month 4 days

MANAGING AND DISABLING COOKIES

You can control the cookies placed and retained on your Device. The Privacy ~~and Cookies~~ Policy are provided to be transparent about our practices regarding the use of cookies and to allow you the opportunity to make an informed choice.

When you visit our Website, you are asked to consent to the use of cookies. You may choose to consent to none, one or more of the above cookies, except for the necessary ones. You may withdraw your consent to the use of cookies any time during your visit to our Website freely and easily by clicking on the Cookies Manager button and setting your preferences.

Additionally, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

For instructions on blocking and deleting cookies on your browser, see the privacy and help documentation of your specific browser’s website. If you use more Devices and/or browsers you will need to disable cookies on each Device and on each browser separately. Here are the locations of the cookie settings for all major web browsers:

Internet Explorer – Tools > Internet Options > Privacy tab
Mozilla Firefox – Tools > Options > Privacy menu
Safari Users – Edit > Preferences > Privacy menu
Chrome Users – Settings > Content Settings > Privacy > Cookies

If you limit the ability of our websites to set cookies, this may prevent you from using certain features of our Website properly and your user experience – which will no longer be personalized for you – may deteriorate. You may also be able to opt-out from certain cookies through third-party cookie management sites. Disabling cookies may prevent you from using certain parts of our Website. If you delete your cookies from the browser, you may need to remember to re-install opt-out cookies.

11. Do We Use Your Information for Advertising Purposes?

We may place cookies on partner websites to advertise our brands and/or services. These cookies are mainly used to display content tailored to your interests and to evaluate our content (including advertising). Partner websites must enable you to consent to the activation of advertising cookies. Our cookies are also used by third party sites to provide advertising that is relevant (advertising cookies on our Website). This relevance is based on a profile-built form your previous visits to our Website, including the pages you have visited.

We belong to ad networks that may use your browsing history across participating websites to show you interest-based advertisements on those websites. For example, cookies can be used in the selection of the advertisements that appear on a Google search results page, or at a website in the Google Display Network (that is, ad content might be based on which pages you viewed during past visits to the Cycleops website). You can set preferences for how Google advertises to you on their Ads Settings page. You can opt out of interest-based advertising by changing cookie settings in your browser or by using a browser plugin. We do not control cookies used by these advertising networks.

12. How we use data to provide the Services?

Cycleops is the “data processor” for all personal data processed in relation to the provision of the Services. This means that such Personal Data is collected on the Customer’s/your behalf for your own purposes, that Customer/you are solely responsible i) for the legality, reliability, accuracy and quality of Personal Data processed in relation to the provision of the Services ii) for the legality of the processing purposes and iii) for the necessity of the processing to serve these purposes, and that the Customer/you are the data controller of Personal Data processed, while using the Services. Therefore, the Customer/you are responsible to satisfy the requests of the data subjects, whose Personal Data is processed through the Services. Additionally, the Customer you are responsible to inform the data subjects (any person whose personal data is processed by usage of the Services) about the scope, the purpose, the duration and the means of the processing, and to acquire the consent of the data subjects, whose Personal Data is being processed through the Services, where required. Cycleops executes a Data Processing Addendum with the Customer/you, which is available at https://cyleops.io/dpa.

We share personal data with our associates (sub-contractors and sub-processors), solely for the provision of the Services. We have made sure, by means of a written contract or assignment, that our sub-processors comply with the DPA, and

provide at least the same level of data protection as we do, for example that they follow reliable technical and organizational security measures.

Our full list of sub-processors, their tasks, locations, and contact details, is available at https://cycleops.io/subprocessors.

13. Changes to Our Privacy Policy

We reserve the right to change this Privacy Policy from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last revised” date at the top of this Privacy Policy. You are expected to check our website from time to time to take notice of any changes in this Policy. If we consider the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

14. Contact Us

If you have any questions, comments, requests, and complaints regarding this Privacy and Cookies Policy and the information we hold, please contact us at privacy@stackmasters.eu