Software Privacy Policy

This policy was last updated in December of 2022. 

This is our Software Privacy Policy. 

General information 

We, at CNCSimulator.com, are committed to protecting the privacy of our business partners who are licensed to use our software (“the “Software”) on their internal network (“you” or “Client”) and our end users which have access to any of the data resources monitored by our Software (“End Users”). 

We encourage you and the End Users to read this “Software Privacy Policy” (“Privacy Policy”) carefully and use it to make informed decisions. By using our Software, you agree to the terms of this Privacy Policy, and your continued use of the Software constitutes your ongoing agreement to it. 

Client’s obligation 

Without derogating any of the terms and warranties of the License Agreement, Client shall ensure that all End Users have been informed of, and have given their consent to, Company’s use and process of any information, as detailed in this Privacy Policy, to the extent such consent is required by applicable law. 

What information do we collect? 

We collect two types of information when you are using our Software:
The first type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”), which includes the following: 

Client’s Information: We may collect contact information (including Personal Information) from you when you register on our site, subscribe to our software, contact support via email, subscribe to our newsletter, respond to a survey, or fill out a form. 

Feedback: When you allow us (or our trusted third-party service providers) to receive the End Users’ feedback and rating with regard to Software (“Feedback”), we may gather Personal Information which may include the following: email address of the End User, End User’s full name, and End User’s IP address. In addition, we may collect Personal Information that the End User voluntarily shares with us when he sends us Feedback (e.g., identifying content, images; etc.). 

In order to provide some of our Software as a Service (“SaaS”) products, we will collect metadata of our End Users, including IP addresses, MAC addresses, user agent, identifiers issued by Client, path of files, and file names. Under certain privacy regulations, some of this metadata may amount to Personal Information. 

The second type of information is unidentified and non-identifiable information pertaining to our End Users, which may be made available or gathered via the use of the Software (“Non-Personal Information”). We are not aware of the identity of the user from which the Non-Personal Information was collected. 

Non-Personal Information that is being collected may include usernames, directory names, server names, share names, file names, configurations, logs related to Software and Client (e.g. event logs), browsing events, and technical information transmitted by End Users’ devices, including certain software and hardware information (e.g., the type of browser and operating system the device uses, language preference, access time and the domain name from which the End Users are linked to the Software; etc.). 

In addition, when you allow us (or our trusted third-party service providers) to receive the End Users’ Feedback with regard to Software, we may gather Non-Personal Information which may include the following: Feedback rating, Feedback tags, Feedback text, browser type and language, operating system, viewport of the screen, page URL on which the Feedback has been given, and our clients. 

Please note that when the Software is deployed by our Clients, it analyzes unstructured data that is stored on the Clients’ platforms. The Clients maintain sole ownership of this data and determine their own policies regarding the storage, access, deletion, sharing, and retention of this data. This data is hosted and stored only on the Clients’ servers (not on the Company’s servers). 

How we use the information we collect? 

In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for legitimate business purposes only, such as: 

To set up your account and to provide our services to our Users; 

To identify and authenticate End Users’ access to the Software; 

To obtain End Users’ Feedback with regard to the Software; 

To improve our Software; 

To support and troubleshoot our Software and respond to queries; and
To investigate violations and enforce our policies, and as required by law, regulation, or other governmental authority, or to comply with a subpoena or similar legal process or respond to a governmental request. 

We use the Personal Information only to the extent required and while maintaining your right to privacy.

What are the Conditions for Processing of Personal Information? 

We will process your Personal Information for a variety of reasons, each of which is prescribed by relevant data protection laws. 

Performance of a contract, compliance with a legal obligation: It is necessary for us to process your Personal Information where it is necessary for the performance of a contract (such as for our agreement) or in order for us to comply with our various legal and/or regulatory responsibilities. 

Legitimate interests: 

We also process your Personal Information where we deem such processing to be in our (or a third party’s) legitimate interests and provided always that such processing will not prejudice your interests, rights and freedoms. Examples of us processing in accordance with legitimate interests would include: (i) where we disclose your Personal Information to any one or more of our associate companies following a restructure or for internal administrative purposes; (ii) processing for the purposes of ensuring network and information security, including preventing unauthorized access to our electronic communications network. 

With whom we share the information we collect? 

We do not rent, sell or share your Personal Information with third parties except as described in this Privacy Policy. 

We may transfer or disclose Personal Information to our affiliated companies. In addition, User’s Personal Information may be disclosed to other trusted third-party service providers or partners for the purpose of: (i) storing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations and Software and improving it (e.g., processing and analyzing End Users’ Feedback); and (iii) performing research, technical diagnostics and analytics with regard to the Software. 

We may disclose Personal Information, or any information you submitted via the Software if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including this Privacy Policy), including investigations of potential violations thereof; (iii) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights. 

Since we operate globally, it may be necessary to transfer Personal Information to countries outside the US or the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union or in the US − in these instances, we will take steps to ensure that a similar level of protection is given to Personal Information. You hereby consent to the transfer of your Personal Information to countries outside the European Union or the US.

Third party collection of information 

Our policy only addresses our use and disclosure of personal information from you and from your End Users through the Software (as described under the “With whom we share the information we collect” section herein). To the extent that you or your End Users disclose your information to other parties through the Software, different rules may apply to their use or disclosure of the information disclosed to them. 

How long do we retain the information we collect? 

At any time, you may request to view, change and update your Personal Information by emailing us at staff@cncsimulator.com. You can also request that we will cease processing or that we will erase Personal Information by emailing us at same email address. 

Please note that we retain the information we collect for as long as needed to provide our services (including marketing and communication, as described in our website and marketing privacy policy available on our website) and to comply with our legal obligations, resolve disputes and enforce our agreements (including exercising any of our rights under our agreements, such as audit and record-keeping). 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. 

How do we safeguard and transfer your information? 

We are committed to making reasonable efforts, in accordance with market best practices, to ensure the security, confidentially and integrity of the Personal Information. We take great care in implementing and maintaining the security of the Software and the Personal Information. Access to the Personal Information is based on the ‘least to know’ concept together with role based access control systems, ensuring only authorized access to the Personal Information. We employ market best practice security measures to ensure the safety of your End Users’ Personal Information and prevent unauthorized use of any such information. Although we take steps to safeguard such information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Software, and we make no warranty, express, implied or otherwise, that we will prevent such access. If a password is used to help protect your accounts and Personal Information, it is your responsibility to keep your password confidential. 

We use best efforts to ensure that your Personal Information is protected in accordance with our Privacy Policy, through contractual means (such as by using the standard contractual clauses approved by the European Commission for data transfers) or other means (such as by transferring data only to recipients located in jurisdictions which were granted an “adequacy decision” with regard to their level of protection of personal data by the European Commission and the US). 

What are your rights? 

You may contact us at staff@cncsimulator.com any time and request: 

To delete, change or update any personal data relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected); 

That we will cease any further use of your Personal Information or delete your information (for example, you may ask that we stop using or sharing your Personal Information with third parties). 

If you wish to raise a complaint on how we have handled your Personal Information, you may contact us at the addresses indicated below. 

Minors 

The Software is not designated to End Users under the age of 16. In the event that we become aware that End Users under the age of 16 have shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at staff@cncsimulator.com. 

Updates or amendments to the Privacy Policy 

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on the website. We encourage you to review this Privacy Policy regularly for any changes. 

Your continued use of the Software, following the notification of such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments. 

Deletion Requests 

You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies. 

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.