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Privacy Policy


Effective Date: January 2025 
Last Updated: January 2026 

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CWX (“CWX”, “we”, “our”, or “us”) is committed to protecting the privacy, confidentiality, and security of personal information entrusted to us. This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when individuals interact with us through our websites, platforms, services, events, communications, or business operations. 
This Privacy Policy applies to all external interactions with CWX unless a separate written agreement or a supplemental privacy notice applies to a specific interaction. 


1. Scope and Applicability 


This Privacy Policy applies to personal information collected by CWX in the course of its external-facing activities, including interactions through: 

 

  • CWX websites and digital platforms 

  • Event registrations, webinars, and marketing activities 

  • Sales, business development, and partner engagements 

  • Communications conducted via email, forms, or other channels 

  • Any other interaction where CWX collects personal information directly from individuals 


This Privacy Policy applies solely to personal information collected by CWX acting as a data controller, and is subject to applicable privacy and data protection laws based on the nature of the interaction and the individual’s jurisdiction. 


Where CWX processes personal information on behalf of customers or partners as part of service delivery, such processing is governed by applicable contractual agreements, including data processing agreements, and not by this Privacy Policy. Furthermore, when CWX processes personal information on behalf of a customer, CWX acts as a Service Provider or Contractor as defined under the California Privacy Rights Act and processes such information solely for the business purposes specified in its agreements. 


CWX does not use or disclose Sensitive Personal Information for purposes other than providing services, ensuring security, or complying with legal obligations, and does not use such information to infer characteristics about individuals.

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2. Definitions 


For the purposes of this Privacy Policy, the following terms shall have the meanings set out below: 

 

  • “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual. 

  • “Sensitive Personal Information” means Personal Information that, if compromised, could result in significant harm, discrimination, or risk to an individual, including but not limited to government identifiers, financial information, authentication credentials, precise location data, or health-related information, where applicable. 

  • “Processing” means any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, transmission, restriction, or deletion. 

  • “Data Subject” means an individual to whom Personal Information relates. ● “Controller” means the entity that determines the purposes and means of Processing Personal Information. For the purposes of this Privacy Policy, CWX acts as a Controller unless otherwise specified. 

  • “Processor” means an entity that Processes Personal Information on behalf of a Controller pursuant to contractual obligations. 

  • “Service Provider” means a third party that processes Personal Information on behalf of CWX for a business purpose and is contractually restricted from using such information for any other purpose. 

  • “Third Party” means any entity other than CWX, a Data Subject, or a Processor or Service Provider acting on behalf of CWX. 

  • “Business Purpose” means the use of Personal Information for operational, administrative, security, compliance, or service-related activities consistent with this Privacy Policy. 

  • “Consent” means any freely given, specific, informed, and unambiguous indication of an individual’s agreement to the Processing of their Personal Information, where required by applicable law. 

  • “Data Breach” means a confirmed or reasonably suspected incident involving the unauthorized access, acquisition, disclosure, alteration, or destruction of Personal Information or systems containing Personal Information. 

  • “Information Security Incident” means an event that compromises, or has the potential to compromise, the confidentiality, integrity, or availability of information assets, including Personal Information. 

  • “Anonymization” means the irreversible process of transforming Personal Information such that it can no longer be used to identify an individual.

  • “Pseudonymization” means the processing of Personal Information in such a manner that it can no longer be attributed to a specific individual without the use of additional information kept separately and subject to safeguards. 

  • “Sell” or “Sale” means transferring, disclosing, or otherwise making Personal Information available to a third party for monetary or other valuable consideration, as defined under applicable privacy laws, including the California Consumer Privacy Act (“CCPA”). 

  • “Share” means disclosing Personal Information for cross-context behavioral advertising or similar purposes, where defined under applicable law. 

  • “Applicable Law” means all laws, regulations, and regulatory requirements relating to privacy, data protection, and information security that apply to CWX’s processing activities. 


3. Categories of Personal Information Collected 


CWX collects personal information only to the extent necessary to support legitimate business, operational, and legal purposes. The categories of personal information that may be collected include the following: 


3.1 Identifiers and Contact Information 

 

  • Full name 

  • Business email address 

  • Telephone number 

  • Company name and professional role or title 


3.2 Professional and Business Information 

 

  • Employer or organization details 

  • Business contact information 

  • Industry or professional affiliations 

  • Information provided during sales, partner, or customer interactions 


3.3 Account, Registration, and Interaction Information 

 

  • Event, webinar, or program registration details 

  • User-submitted form responses 

  • Communication preferences 

  • Records of communications with CWX

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3.4 Technical, Device, and Usage Information 

 

  • IP address 

  • Browser type and version 

  • Device and operating system information 

  • Log files, access timestamps, and interaction metadata 

  • Website usage and analytics data 


3.5 Marketing and Communications Data 

 

  • Subscription and opt-in status 

  • Marketing preferences 

  • Engagement data related to communications sent by CWX 


3.6 Sensitive Personal Information 


CWX does not intentionally collect Sensitive Personal Information unless required for a specific, lawful purpose and subject to appropriate safeguards. 


In limited circumstances, and only where legally permitted and contractually required, Sensitive Personal Information may include: 

 

  • Government-issued identifiers (where required for verification or compliance) ● Authentication credentials (processed in protected or hashed form) 

  • Health-related information, including Protected Health Information (PHI), only where CWX is legally authorized and contractually obligated to process such information 

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3.7 Information Collected from Third Parties 

  • CWX may receive limited personal information from: 

  • Business partners or event co-sponsors 

  • Service providers supporting CWX operations 

  • Publicly available or professional sources 


Such information is processed in accordance with this Privacy Policy and applicable legal requirements. 


3.8 Use of Artificial Intelligence 


CWX deploys artificial intelligence systems solely to support customer-directed use cases.  CWX does not use customer personal information to train, retrain, or improve general purpose or proprietary AI models unless expressly authorized in writing by the customer. CWX does not

engage in automated decision making that produces legal or similarly significant effects concerning individuals without appropriate human oversight.  
4. Purposes of Processing 


CWX processes personal information solely for specified, explicit, and legitimate purposes, and does not process such information in a manner that is incompatible with those purposes. 


Personal information may be processed by CWX for the following purposes: 


4.1 Service Delivery and Business Operations 

 

  • To provide, operate, administer, and improve CWX services and offerings 

  • To manage business relationships with customers, partners, vendors, and prospects ● To process registrations, inquiries, requests, and transactions 


4.2 Communications 

 

  • To respond to inquiries and requests 

  • To deliver service-related, operational, or administrative communications 

  • To provide information about CWX offerings, events, or updates where permitted by law


4.3 Marketing and Promotional Activities 

  • To send marketing or promotional communications where consent has been obtained or where otherwise permitted by applicable law 

  • To manage communication preferences and opt-out requests 

 

4.4 Analytics and Improvement 

  • To monitor, analyze, and improve the performance, functionality, and security of CWX websites, services, and communications 

  • To conduct internal research, reporting, and service optimization 

 

4.5 Security, Risk Management, and Compliance 

  • To protect CWX systems, information assets, and users 

  • To detect, prevent, investigate, and respond to security incidents, fraud, or misuse ● To maintain compliance with applicable laws, regulations, contractual obligations, and industry standards

 

4.6 Legal and Regulatory Obligations 

 

  • To comply with legal, regulatory, and law enforcement requirements 

  • To establish, exercise, or defend legal claims 

 

CWX does not use personal information for materially different, unrelated, or incompatible purposes without providing notice or obtaining consent where required by applicable law. 

 

5. Legal Basis for Processing 
CWX processes personal information in accordance with applicable privacy and data protection laws. The specific legal basis applicable to a given processing activity depends on the context in which personal information is collected and used. Depending on the nature of the interaction and 
the jurisdiction involved, CWX relies on one or more of the following legal bases to process personal information: 

 

5.1 Consent 
Where required by applicable law, CWX processes personal information based on the individual’s freely given, specific, informed, and unambiguous consent. 

 

Consent may be withdrawn at any time, without affecting the lawfulness of processing carried out prior to withdrawal. 

 

5.2 Performance of a Contract 
CWX may process personal information where such processing is necessary for:

  • The performance of a contract to which the individual is a party, or 

  • Taking steps at the request of the individual prior to entering into a contract 

 

5.3 Legal Obligations 
CWX may process personal information where required to comply with applicable legal, regulatory, or statutory obligations. 

 

5.4 Legitimate Interests 
CWX may process personal information where necessary for its legitimate business interests, provided that such interests do not override the rights and freedoms of individuals. These legitimate interests may include: 

  • Operating and improving CWX services 

  • Ensuring network and information security

  • Preventing fraud, misuse, or unlawful activity

  • Managing business relationships and communications 


5.5 Public Interest and Legal Claims 
Where applicable, CWX may process personal information where necessary for:

  • Compliance with obligations carried out in the public interest 

  • Establishment, exercise, or defense of legal claims 


6. Marketing and Communications 
CWX may send marketing or promotional communications relating to its services, events, and offerings in accordance with applicable laws and individual communication preferences. 


Marketing communications are sent only: 

  • Where an individual has provided consent, or 

  • Where otherwise permitted by applicable law based on an existing business relationship or legitimate interest 

 

Individuals may manage their communication preferences or withdraw consent at any time by:

  • Using the unsubscribe mechanism included in CWX communications, or

  • Contacting CWX directly using the details provided in this Privacy Policy 

 

Withdrawing consent or opting out of marketing communications will not affect the receipt of:

  • Service-related or transactional communications 

  • Administrative, security, or legal notices 

 

CWX does not engage in the sale of personal information for marketing purposes and does not knowingly send unsolicited marketing communications in violation of applicable law. 

 

7. Cookies and Tracking Technologies 
CWX uses cookies and similar tracking technologies to support the operation, security, and performance of its websites and digital platforms. 

 

7.1 Types of Technologies Used 
These technologies may include: 

  • Cookies 

  • Web beacons

  • Pixels 

  • Log files 

  • Similar automated data collection tools 7.2 Purposes of Use 


CWX uses cookies and tracking technologies for the following purposes: 

  • To enable core website functionality and accessibility 

  • To maintain website performance and reliability 

  • To understand how users interact with CWX websites and content 

  • To support analytics, reporting, and service improvement 

  • To support marketing and communications activities where permitted by applicable law 


7.3 Managing Cookie Preferences 
Where applicable, individuals may also manage cookie preferences through any cookie consent or preference management tools provided on CWX websites. Please note that disabling certain cookies may impact website functionality or availability of features. 
Where required by applicable law, CWX will provide appropriate notice and obtain consent before placing non-essential cookies. 

 

7.4 Third-Party Technologies 
CWX may permit third-party service providers to place cookies or tracking technologies on its websites for analytics, performance, or marketing support. Such third parties process information in accordance with their own privacy policies and contractual obligations with CWX. 

 

7.5 Automated Data Collection and Scraping 
The use of automated tools, including bots, scrapers, crawlers, spiders, or similar technologies, to access, collect, extract, copy, or reuse personal information or content from CWX websites or digital platforms without prior written authorization is strictly prohibited. 
Personal information made available through CWX websites or communications is provided solely for legitimate business interactions and may not be harvested, aggregated, or used for purposes such as data mining, marketing databases, profiling, or training artificial intelligence or machine learning models without CWX’s express written consent. 


CWX reserves the right to take appropriate technical and legal measures to prevent and respond to unauthorized scraping or automated data collection activities.

 

8. Disclosure of Personal Information 
CWX does not sell or share personal information, including for cross context behavioral advertising, as those terms are defined under the CPRA. 
CWX may disclose personal information only where necessary and in accordance with applicable law for the purposes described in this Privacy Policy, including the following circumstances: 

 

8.1 Internal Access 
Personal information may be accessed by authorized CWX employees, contractors, or representatives who have a legitimate business need to know such information and are subject to confidentiality and data protection obligations. 

 

8.2 Service Providers and Vendors 
CWX may disclose personal information to third-party service providers and vendors that perform services on behalf of CWX, including but not limited to: 

  • Information technology and cloud service providers 

  • Customer relationship management and marketing platforms 

  • Analytics, security, and monitoring providers 

  • Professional services providers (legal, audit, compliance) 

 

Such service providers are contractually required to: 

  • Process personal information only for authorized purposes 

  • Maintain appropriate confidentiality and security safeguards 

  • Comply with applicable data protection laws 

 

8.3 Legal and Regulatory Requirements 
CWX may disclose personal information where required to comply with applicable laws, regulations, legal processes, or lawful requests from public authorities, including law enforcement or regulatory agencies. 

 

8.4 Corporate Transactions 
Personal information may be disclosed in connection with a merger, acquisition, restructuring, financing, or sale of all or a portion of CWX’s business or assets, subject to appropriate confidentiality and data protection safeguards.

 

8.5 Protection of Rights and Interests 
CWX may disclose personal information where necessary to:

  • Enforce applicable terms and agreements 

  • Protect the rights, property, or safety of CWX, its customers, or others

  • Detect, prevent, or respond to fraud, security incidents, or unlawful activity 

 

CWX does not disclose personal information for cross-context behavioral advertising or similar purposes unless permitted by applicable law. 

 

9. Data Retention 
CWX retains personal information only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, and to comply with applicable legal, regulatory, contractual, and operational requirements. 

 

Retention periods are determined based on factors including: 

  • The nature and sensitivity of the personal information 

  • The purposes for which the information is processed 

  • Applicable legal, regulatory, and contractual obligations 

  • The need to establish, exercise, or defend legal claims


When personal information is no longer required for these purposes, CWX securely deletes, anonymizes, or otherwise disposes of such information in accordance with its data retention and information security practices. 


10. Data Security 
CWX implements appropriate administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. 


These safeguards may include, as appropriate: 

  • Access controls and authentication mechanisms 

  • Encryption and secure configuration practices 

  • Monitoring, logging, and incident detection controls 

  • Employee training and confidentiality obligations 

  • Vendor risk management and contractual security requirements

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CWX regularly reviews and enhances its security measures to address evolving threats and risks. 


While CWX strives to protect personal information, no system, transmission method, or storage solution can be guaranteed to be completely secure. Individuals are encouraged to take reasonable steps to protect their own information when interacting with CWX. 


11. International Data Transfers 
Personal information processed by CWX may be transferred to, stored in, or accessed from jurisdictions outside an individual’s country of residence, including jurisdictions that may have data protection laws different from those in the individual’s home country. 


Where required by applicable law, CWX implements appropriate safeguards to ensure that international transfers of personal information are conducted in accordance with applicable data protection and privacy regulations. These may include, as applicable: 

  • The EU General Data Protection Regulation (GDPR) and related cross-border transfer requirements 

  • The UK GDPR and UK data protection laws 

  • The California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA)

  • The Health Insurance Portability and Accountability Act (HIPAA), where CWX is contractually and legally obligated to process Protected Health Information 

  • Other applicable national or regional data protection laws based on the nature of the processing and jurisdiction involved 


Safeguards implemented by CWX may include contractual protections, technical and organizational security measures, and other lawful transfer mechanisms recognized under applicable law. Where personal information is transferred internationally, CWX relies on contractual safeguards and vendor due diligence designed to ensure continued protection consistent with applicable law. 


CWX processes personal information in a manner consistent with this Privacy Policy regardless of where the information is processed and takes reasonable steps to ensure that personal information remains protected during international transfers. 


12. Individual Rights 
Subject to applicable law and depending on an individual’s jurisdiction, individuals may have certain rights with respect to their personal information processed by CWX. 


These rights may include, where applicable:

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12.1 Right to Access 
The right to request confirmation of whether CWX processes personal information about them and to obtain access to such information. 


12.2 Right to Correction 
The right to request correction of inaccurate or incomplete personal information. 


12.3 Right to Deletion 
The right to request deletion of personal information, subject to applicable legal, regulatory, or contractual retention requirements. 


12.4 Right to Restriction of Processing 
The right to request that CWX restrict the processing of personal information in certain circumstances, where permitted by law. 


12.5 Right to Data Portability 
The right to receive certain personal information in a structured, commonly used, and machine-readable format, where required by applicable law. 


12.6 Right to Object 
The right to object to the processing of personal information, including processing based on legitimate interests or for direct marketing purposes, where applicable. 


12.7 Right to Withdraw Consent 
Where processing is based on consent, the right to withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal. 


12.8 Rights Under Specific Laws 
Depending on jurisdiction, individuals may also have rights under specific privacy laws, including the right to: 

  • Opt out of the sale or sharing of personal information (where applicable)

  • Limit the use or disclosure of sensitive personal information 

  • Not be subject to unlawful discrimination for exercising privacy rights

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12.9 Exercising Your Rights 
Requests to exercise privacy rights may be submitted by contacting CWX using the contact details provided in this Privacy Policy. CWX may take reasonable steps to verify the identity of the individual making the request before responding. 
CWX will respond to valid requests within the timeframes required by applicable law. 


12.10 California Residents 
California residents may submit requests by email or through any web form provided by CWX.  CWX will verify requests using commercially reasonable methods and respond within 45 days, subject to permitted extensions. 


13. Third-Party Websites 
CWX websites and communications may contain links to third-party websites or services that are not operated or controlled by CWX. 
CWX is not responsible for the privacy practices, content, or security of third-party websites or services. Individuals are encouraged to review the privacy policies of any third-party websites they visit. 


14. Children’s Privacy 
CWX does not knowingly collect or process personal information from individuals under the age of 16. 


If CWX becomes aware that personal information from an individual under the age of 16 has been collected without appropriate authorization, CWX will take reasonable steps to delete such information in accordance with applicable law. 


CWX’s services, websites, and communications are not directed toward children, and CWX does not intentionally solicit personal information from children. 


15. Changes to This Privacy Policy 
CWX may update this Privacy Policy from time to time to reflect changes in legal requirements, business practices, or operational needs.

Any updates will be posted with a revised “Last Updated” date. The updated Privacy Policy will apply from the date it is posted, unless otherwise stated. 


Individuals are encouraged to review this Privacy Policy periodically to stay informed about how CWX protects personal information. 


16. Contact Information 
For questions, concerns, or privacy-related requests, please contact: 


CWX 
legal@cloudwerx.tech 
grc@cloudwerx.tech 


Additional contact details may be provided where required by applicable law or contractual obligations.
 

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