PRIVACY POLICY

New Privacy Policy as of July 24th, 2018

1. INTRODUCTION

Cien is serious about protecting the privacy of our users. This privacy policy sets out the basis on which any personal data we collect from users, or that users provide to us, will be processed by us.

Please read the following carefully to understand our views and practices regarding personal data and how we will treat it. By visiting Cien.ai or otherwise communicating with us, users are accepting and consenting to the practices described in this policy.

2. CONTROLLER

Unless stated otherwise, Cien is the controller of the personal data collected by means of this Website.

For any query, request, claim or clarification regarding the processing of your personal data, you may contact us via the email: dataprotection@cien.ai.

3. INFORMATION COLLECTION

We may collect and process the following data about you:

a) Users may give us information about themselves by filling in forms on Cien.ai or by corresponding with us by phone, e-mail address or otherwise. This includes information you provide when you register for a Customer Account. This information includes but is not limited to name, email address, postal address, billing address, telephone number, username and password.

b) Users may also give us information about the properties that they advertise using our Services, including the property address.

c) Upon each of the User's visits to Cien.ai, we may automatically collect technical information, including the Internet Protocol (IP) address used to connect users' computers to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

d) We may also collect information about users' visit to Cien.ai, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

e) We do not collect payment card details of our users. In order to pay for the fees related to our Services we use third party payment processors that will collect and process the payment card details of our users.

f) We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers) and may receive information about you from them. If you wish to request access, to limit use, or to limit disclosure, or want to opt out of Cien's information collection process, contact legal@cien.ai.

Cien complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Cien has certified to the Department of Commerce that it is in adherence with the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. The Federal Trade Commission has jurisdiction over Cien’s compliance with the Privacy Shield. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, Cien commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Cien at dataprotection@cien.ai.

Cien has further committed to refer unresolved Privacy Shield complaints to JAMS (Judicial Arbitration and Mediation Services, Inc), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from Cien, or if we have not resolved your complaint, please contact JAMS or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint.  The services of JAMS are provided at no cost to you. Finally, as a last resort and in limited situations, EU and Swiss individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

4. INFORMATION USAGE

Cien processes personal data lawfully, fairly and in a transparent manner in relation to the data subject. Only the personal data necessary for each of the specific processing purposes is processed.

We use information held about our users in order to:

- provide users with the Services, and other information, products and services our users request;

- provide users with information about other services we offer that are similar to those that users have already purchased or enquired about;

- to provide users with information about dissimilar and unrelated goods or services we feel may interest them (only if users have consented to this);

- customize the Services to the individual needs of our users;

- understand and optimize how our Services are used, and improve the Services including by ensuring content is presented in the most effective manner for users and their computers;

- support and assist our users in using the Services; and

- measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

- notify users about changes to our Services.

5. INFORMATION SHARING AND DISCLOSURE

a) We may share our users' information with selected third parties for limited and specific purposes including:

- our business partners and service providers, such as our channel managers, payment providers and third party applications which integrate with the Services, for the performance of any contract we enter with them or our users;

- advertisers that require the information to select and serve relevant adverts to our users and others; and

- analytics providers that assist us in the improvement and optimization of Cien.ai and the Services.

Cien maintains contracts with these third parties restricting their access, use and disclosure of personal data.

b) In certain circumstances we may need to disclose the personal information of our users as required by law, or when we believe in good faith that disclosure is necessary to protect our rights, protect the safety of our users or the safety of others, investigate fraud, or respond to a government request. Cien takes reasonable and appropriate steps to ensure that these third parties effectively process any personal information transferred in a manner consistent with Cien’s obligations under the Privacy Shield Principles. Third parties are required to notify Cien if they are no longer able to meet their obligation to provide the same level of protection as is required by the Privacy Shield Principles. At that time, Cien will take reasonable and appropriate steps to stop and remediate unauthorized processing. Cien will provide a summary or a representative copy of the relevant privacy provisions of its contract with this third party to the U.S. Department of Commerce upon request.

Other than as set out above or otherwise consented to by the user, we will not share the personal data of our users with third parties.

In no event will we sell users' personal information to third parties.

6. STORAGE AND TRANSFER OF DATA

Information collected from our users may be stored in or transferred to a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or one of our business partners or service providers. By using the Services, our users acknowledge and agree that we may be transferring, storing and processing their personal data outside of the country in which they reside. We will take all steps reasonable necessary to ensure that our users' data is treated securely and in accordance with this privacy policy.

7. NEWSLETTER

Users will only receive a newsletter containing marketing content from us if we have their consent pursuant to clause 3 of this Privacy Policy. Users may choose to stop receiving our newsletter or marketing emails anytime by following the unsubscribe instructions included in these emails, or unsubscribing within the Customer Account or contacting us at support@Cien.ai.

8. SECURITY

The security of our users' personal information is important to us. When our users enter sensitive information on our site, we encrypt the transmission of that information using secure socket layer technology (SSL). We take reasonable steps to protect our users' information.

Nevertheless, please note that no data transmission over the Internet or information storage technology can be guaranteed to be totally secure. As a result, whilst we strive to protect our users' information, we cannot ensure or warrant the security of any information which users send to us, and the users do so at their own risk.

9. COOKIES

We may use cookies to distinguish one user from another.

10. LINKS TO THIRD PARTY WEBSITES

Cien.ai includes links to third party websites whose privacy practices may differ from ours. If users submit personal information to any of those sites, the site operators' use of this user information will be governed by their privacy statements. Please check these policies before you submit any personal data to these websites.

11. INFORMATION ACCESS AND USER RIGHTS

The General Data Protection Regulation (GDPR) gives users the right to access information held about them (Right of Access). Users' right of access can be exercised in accordance with this Regulation. Any access request may be subject to a fee of $20 to meet our costs in providing users with details of the information we hold about users.

Additionally, the GDPR gives users the ability to request data deletion (Right to be Forgotten) based on certain conditions, including contract termination. Upon contract termination, we will delete all data stored in our database unless written permission is given stating we can continue to use your data to develop our Service.

With our Privacy Shield self-certification, Cien has committed to respect the rights of EU and Swiss individuals to access personal data about them, and to limit use and disclosure of their personal data. This commitment extends to data submitted by our customers to our services. Cien acts as a processor of the data our customers send our system and, as a result, our personnel have limited ability to access this data. If you wish to request access, to limit use, or to limit disclosure, please provide the name of the Cien customer who submitted your data to our services and contact us at dataprotection@cien.ai. We will refer your request to that customer, and will support them as needed in responding to your request.

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this policy from time to time. Where appropriate, we will notify you in advance of changes via email. To keep up-to-date with our policies, please check this page frequently.

13. QUESTIONS

If you have any questions regarding this Privacy Policy, please contact us at support@cien.ai. We will endeavor to respond to you promptly.