Version November 1, 2018

This policy covers the privacy practices that OraCloud Plus LLC (“OraCloud+” or “we”) employ when providing support, consulting, Cloud or other services (the “services”) to its customers (“you” or “your”).

Services Data
Services Data is data that resides on OraCloud+, customer or third-party systems to which OraCloud+ is provided access to perform services (including Cloud environments as well as test, development and production environments that may be accessed to perform OraCloud+consulting and support services). OraCloud+ treats services data according to the terms of this policy, and treats services data as confidential in accordance with the terms of your order for services.In contrast, having contracted with OraCloud+ for Cloud or other services, the customer provides OraCloud+ access to its production, development or test environment, which may include personal information about its employees, customers, partners or suppliers (collectively “end users”).

How OraCloud+ Collects and Uses Services Data
Below are the conditions under which OraCloud+ may access, collect and/or use services data.

To Provide Services and to Fix Issues. Services data may be accessed and used to perform services under your order for support, consulting, Cloud or other services and to confirm your compliance with the terms of your order. This may include testing and applying new product or system versions, patches, updates and upgrades; monitoring and testing system use and performance; and resolving bugs and other issues you have reported to OraCloud+. Any copies of services data created for these purposes are only maintained for time periods relevant to those purposes.

As a Result of Legal Requirements. OraCloud+ may be required to retain or provide access to services data to comply with legally mandated reporting, disclosure or other legal process requirements.

OraCloud+ may transfer and access services data as required for the purposes specified above. If OraCloud+ hires subcontractors to assist in providing services, their access to services data will be consistent with the terms of your order for services and this services privacy policy. OraCloud+ is responsible for its subcontractors’ compliance with the terms of this policy and your order.

OraCloud+ does not use services data except as stated above or in your order. OraCloud+ may process services data, but does not control your collection or use practices for services data. If you provide any services data to OraCloud+ , you are responsible for providing any notices and/or obtaining any consents necessary for OraCloud+ to access, use, retain and transfer services data as specified in this policy and your order.

Access Controls
OraCloud+‘s access to services data is based on job role/responsibility. Services data residing in OraCloud+ hosted or managed systems is controlled via an access control list (ACL) mechanism, as well as the use of an account management framework. You control access to services data by your end users; end users should direct any requests related to their personal information to you.

Security and Breach Notification
OraCloud+ is committed to the security of your services data, and has in place physical, administrative and technical measures designed to prevent unauthorized access to that information. OraCloud+’s security policies cover the management of security for both its internal operations as well as the services.

OraCloud+‘s security policies and procedures are reviewed and overseen by OraCloud+’s Security Officer. OraCloud+’s Security Officer is responsible for security oversight, compliance and enforcement, and for conducting information security assessments and leading the development of information security policy and strategy.

OraCloud+ is also committed to reducing risks of human error, theft, fraud, and misuse of OraCloud+ facilities. OraCloud+‘s efforts include making personnel aware of security policies and training employees to implement security policies. OraCloud+ employees are required to maintain the confidentiality of services data. Employees’ obligations include written confidentiality agreements, regular training on information protection, and compliance with company policies concerning protection of confidential information.

OraCloud+ promptly evaluates and responds to incidents that create suspicions of unauthorized handling of services data. OraCloud+’s Security Officer and Legal are informed of such incidents and, depending on the nature of the activity, define escalation paths and response teams to address the incidents. If OraCloud+determines that your services data has been misappropriated (including by a OraCloud+ employee) or otherwise wrongly acquired by a third party, OraCloud+ will promptly report such misappropriation or acquisition to you.

Dispute Resolution
If you have any complaints regarding our compliance with this privacy policy, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this privacy policy.