PRIVACY POLICY

Anchor 1

Ciellos, Inc.

1509 Johnson Ferry Road, Suite 150
Marietta, GA 30062
USA

Hereinafter referred to as “Ciellos” or “Company”

hereinafter referred to as "Privacy policy" or "POLICY"

Last updated March 2025

Steen Fabricius Dahl, Group General Counsel, Master at Laws (LL.M)

1. About Ciellos

Ciellos, Inc. and Ciellos subsidiaries thereof, are Microsoft technology providers founded to provide Business Systems Consulting and Microsoft Business Support to Partners & Customers in the Microsoft Channel being ISV’s, VAR’s & Corporations (end users). Our purpose is to guide and advise our customers and partners in business systems change and the infrastructure that it supports, including systems/technology road mapping, systems selection, process definition and re-engineering, systems implementations, customization and integration, Cloud infrastructure and migrations, and upgrading and managing ongoing support.

2. Introduction

As a company, we process personally identifiable information, to some known as personal data, as a natural part of our business. This means that we are data controllers of information about employees, business partners, website visitors, and visitors to our company page on social media. This also applies in connection with our daily customer facing activities in providing Business Systems Consulting and Microsoft Business Support to Partners & Customers in the Microsoft Channel.

We are held accountable by various legal and industry standards, but also by your expectations as a data subject. This means that we are sensitive to your privacy wishes, and we are obliged to inform you about what information we process.

To ensure compliance with relevant privacy laws and regulations (i.e., CCPA, SOC 2, UK DPA & EU GDPR) Ciellos has drawn up this privacy policy which generally describes how, and in what way, Ciellos is responsible for the processing of your personal data, and otherwise treats your data as independent data controllers.

Ciellos Privacy Policy

General

Ciellos respects the confidentiality of the personal data of our customers, business partners, website visitors, and visitors to our company page on social media. This also applies in connection with our daily customer facing activities in providing Business Systems Consulting and Microsoft Business Support to Partners & Customers in the Microsoft Channel.

This information relates to the processing of the personal data that you yourself provide to us as an applicant or contractor (online or paper-based), information that we obtain as part of the application process or personal identifiable information that is needed and/or requested by Ciellos to complete the terms of employment.

Data Controller

Ciellos is responsible for the processing of your personal data.

1. Collection & Processing of Personally Identifiable Information

VISIT TO OUR WEBSITE

All information related to our use of cookies can be found in our Cookie Policy.

In addition, you can contact us via our contact form.

When you send us an enquiry through our contact form, we process the following information in order to respond to you:

Name

E-mail

Telephone number

Message

In all aspects of collecting and processing personal data Ciellos is committed to the principle of balancing of interests and based on a legitimate interest, where your interests are not overridden because we only process what is absolutely necessary to respond to your request.

If you wish to become a customer or are already a customer of ours, our processing basis will be GDPR Article 6(1)(b) or equivalent regulations for processing necessary for the performance of a contract, including pre-contractual correspondence, which takes place at your request.

We keep the data and correspondence for as long as we have an ongoing business relationship with you, and will ask you to renew your consent upon end of the business relationship. Where required by law, we may retain your data for legal obligations or compliance requirements, or in cases where retention is necessary to protect Ciellos’ legal position, such as for regulatory purposes or in case of legal claims.

NEWSLETTER

We will use your email to send you marketing materials if you have signed up to our newsletter.

CUSTOMER INFORMATION

You may create a profile ("Profile") with us by providing your name, address, email, and business affiliation.

To create a Profile, you must agree to our Terms and this Privacy Policy, after which our processing of your personal data will take place as part of an agreement between you and us.

Our legal basis for processing your personal data is relevant privacy laws and regulations applicable in the countries in which Ciellos are incorporated, including the CCPA, SOC 2, UK Data Protection Act 2018 & Regulation (EU) 2016/679 of the European Parliament and of the Council. For reasons of example this includes GDPR Article 6(1)(b), or equivalent regulations, on processing necessary for the performance of a contract, including correspondence prior to the conclusion of a contract, which takes place at your request.

Your Profile Information is kept until 3 months after you have chosen to close your Profile or have been inactive for 3 years and have not responded to our requests to delete your Profile due to inactivity.

FEEDBACK

We will occasionally, with your consent, collect relevant feedback to ensure that the services we offer meet your requirements. We will do this through surveys, customer satisfaction analysis or market research. Any feedback you give us will be used solely for the purpose of improving our services and will not be made public.

Our legal basis for processing your personal data in the context of feedback is relevant privacy laws and regulations applicable in the countries in which Ciellos are incorporated, including the CCPA, SOC 2, UK Data Protection Act 2018 & Regulation (EU) 2016/679 of the European Parliament and of the Council. For reasons of example this includes GDPR Article 6(1)(a), or equivalent regulations, on consent.

Information on feedback is kept for up to 5 years after receipt. Where possible, we store your feedback anonymously and have a long retention period to measure our own performance over time.

SOCIAL MEDIA

We use social media to promote our business.

You should be aware that social media also processes information about you. You can read about how they process your information in their privacy policies. This is also where you can read about where your data is stored and whether it is transferred outside the USA, EU, Facebook, Instagram, LinkedIn.

In addition, we process social media information to interact with you when you ask questions or otherwise give us reason to respond to your posts. We do not use information about you from social media for direct marketing or statistical purposes. Remember that comments on our social media posts can be seen by other users. Therefore, you should never share information that you do not wish to be made public.

Our legal basis for processing your personal data is relevant privacy laws and regulations applicable in the countries in which Ciellos are incorporated, including the CCPA, SOC 2, UK Data Protection Act 2018 & Regulation (EU) 2016/679 of the European Parliament and of the Council. For reasons of example this includes GDPR Article 6(1)(f), or equivalent regulations, on the basis of a legitimate interest, which does not override your interests, because we only process what is strictly necessary to respond to your request and because your participation on social media is voluntary for you on the terms and conditions applicable on social media.

We reserve the right to delete and retain comments and inquiries with offensive or illegal content if the information is to be used in connection with a legal dispute. The information will be deleted at the latest at the end of the case.

We will keep your data until it is no longer necessary for us to process. As a rule, we delete postings and enquiries after 1 year.

You can always edit or delete listings you have made on our company page. To the extent that you wish to access, delete, or exercise any other right relating to your information on our Company Page, please use the deletion and editing options provided by the social media in the first instance. If this does not satisfy your request, please contact us at dpo@ciellos.com.

2. With Whom we may Share your Personal Data

Your personal data may be processed by our data processors, including hosting partners, external consultants and suppliers of our online CRM, ERP and testing systems. These data processors only process your personal data in accordance with the agreement with and instructions from Ciellos.

Your personal data will generally be stored on secure servers located within the USA/EU/EEA.

Specifically for customers domiciled within the UK & EU be advised that your personal data may also be stored with external parties outside the EU. In that case, Ciellos aims to use the EU Commission's standard contracts for the transfer of information to data controllers and data processors outside the EU/EEA to ensure an adequate level of protection.

Your personal data, except for pictures and video recordings used in marketing and marketing material, will be anonymized or encrypted after “deletion”, and in this anonymized or encrypted form be stored for, among other things, statistical purposes.

3. Use of Digital Signing Tools

Ciellos sends contracts and/or agreements via email links for review and electronically signing.

Each party agrees that any documents to be delivered in connection with any customer facing activity herewith may be electronically signed, and that any electronic signatures appearing on such documents are the same as handwritten signatures for the purposes of validity, enforceability, and admissibility.

4. Your Rights as Registered

You have the right to request Ciellos, Inc. about access to, rectification or deletion of information or restriction of processing of your information and to object to our processing of your information and, depending on the circumstances, a right to data portability.

Ciellos may argue to refuse deletion of such data, to uphold requirements in Government and/or State legislation and/or maintain prerequisites in administering Company’s right to lead for distribution of work, and Company’s obligation to administer Invoicing, VAT, and any other taxes.

If you wish to exercise your rights or to complain about our processing of your personal data, you are welcome to contact us by e-mail at: dpo@ciellos.com

5.Data Protection Officer (DPO)

Ciellos, Inc. has appointed a data protection officer (DPO) who has the following contact details: privacy@ciellos.com, if you have any questions about our processing of your personal data.

Privacy Policy