This Data and Privacy Policy seeks to complement and reinforce the trusted relationship between City on the Cloud and its customers. As a result, our Data and Privacy Policy is guided by four simple principles:

• Customer data is the property of the customer.
• City on the Cloud only uses customer data to support the customer or as authorized by the customer.
• City on the Cloud only shares customer data as requested or authorized by the customer.
• City on the Cloud does not analyze, aggregate, or data mine customer data unless requested or authorized by the customer.

To service customers, City on the Cloud maintains customer-provided personal information, such as the customer/entity name and address, company ID, contact information (for example, telephone number(s) and e-mail addresses), and log-in/password to City on the Cloud’s software tools. Customers may also provide data relating to ownership, brokerage, or investment in real property. For some service offerings, either from City on the Cloud or from third parties having market-specific data for customers, customers may also elect to provide additional data like ownership information, expenses, or rent rolls.

All of this data is owned and controlled by the customer, subject to the limited license rights granted to City on the Cloud to provide its services as described in this Policy.

In providing services to customers , and to ensure the integrity of its systems, City on the Cloud utilizes tools to track and monitor user interaction and use of the City on the Cloud software, as well as customer support phone calls and on-line technical support.

To enhance the user experience, City on the Cloud may from time to time give limited, controlled access to the database and the data to authorized third-party providers of system support and revisions who have executed appropriate data protection agreements. This form of access will be only for upgrades and enhancement of the database for the customer’s use. These third-party providers will be contractually bound not to share any data nor acquire any ownership in the data that may be accessed in making the enhancements to the system.

City on the Cloud maintains customer personal information, building data, and market data to provide data storage services, either directly to customers, or indirectly to customer through third parties having specific marketing programs for customers. City on the Cloud may access such data to provide customer service assistance relating to its services (for example, if a customer needs assistance with marketing or improving commercial real estate). If specifically requested or authorized by the customer, City on the Cloud may also provide analysis, aggregation, and data mining for a customer, but will not do so without such request or authorization. City on the Cloud may also use customer information to communicate with its customers (for example to provide information regarding SmartTag Analytics™ tools, updates, transactions, and product announcements). 

City on the Cloud has built its reputation as a valued partner of customers through its protection of data and improved customer value. As such, City on the Cloud allows customers to decide what information is shared and City on the Cloud will not disclose customer data outside of City on the Cloud except as authorized by the customer or its designee. Such authorization may be provided in a written request from the customer to City on the Cloud to provide customer data to a third party, by the customer using data export functionality in the City on the Cloud software tools, or as provided in a separate customer contractual agreement or partnership. Once customer data is shared with authorized third parties, City on the Cloud is not responsible for the third party's use or further disclosure of such data. For example, some customers may authorize third party companies having commercial real estate brokerage or marketing improvement programs for customers to receive customer data as a part of offers or programs of the third party, and allow unlimited use of such data. Additionally, some customers may authorize third parties to receive property data for aggregation, analysis, and/or processing (for example, as part of a property foot traffic analysis program). In either case, City on the Cloud will provide such third parties with the customer data only as authorized by the customer.

City on the Cloud implements a number of security features and processes to protect customer data from unauthorized access, use, and disclosure. City on the Cloud stores customer data on secure servers, with controlled access both to the facilities and the data. Access to customer data, on the user side, is further protected by use of controlled access via user log in and password. In the event of any confirmed unauthorized access, disclosure, or breach of customer data that is likely to result in a high risk to the rights and freedoms of customers, City on the Cloud will notify affected customers without undue delay after becoming aware of the incident and will take appropriate steps to investigate, contain, and remediate the incident. Using customer-specific log-ins and passwords, customers also have the ability to access and edit their information through software tools made available to the customer.

We strive to maintain a high level of transparency about the data we process. With regard to our processing of your personal information described in this Data and Privacy Policy, depending upon applicable law, you may have the following rights: 

• To confirm City on the Cloud is processing your personal information, to get access to or receive a copy of the personal information we may have about you;
• To require us to rectify or update any inaccurate personal information, or complete any incomplete personal information;
• To require us to delete or erase your personal information;
• To restrict our processing of your personal information;
• To require us to transmit certain of your personal information to you or to transfer or have the information transferred to another data controller (data portability);
• To require that we stop processing your personal information for direct marketing purposes. Subject to other legitimate interests which we may be able to rely on (e.g. in the context of legal claims pending or threatened against us), we will then no longer be allowed to process your personal information
• If you wish to exercise any of your above rights, you can contact us at no cost by contacting us at https://www.cityonthecloud.com/contact

We will respond to your request as quickly as possible after validating the request.

We will without undue delay modify your personal information if we agree that it is either inaccurate, out of date, incomplete, irrelevant or misleading, after taking into account the purposes for which it was collected. If we correct it and had previously disclosed it to a third party, we will also notify that third party if required to by law.

If we disagree with your request, subject to applicable law, we will explain the reason for refusal and the ways you can complain.