Privacy Policy

Concerto Cloud Services, LLC (“Concerto”) takes our customers’ personal privacy seriously. Please read the following to learn more about our privacy policy.

What this Privacy Policy Covers

This privacy policy covers Concerto’s treatment of personally identifiable information it collects or receives when you are on a Concerto website and when you use our cloud services. This policy also covers Concerto’s treatment of any personally identifiable information Concerto’s subsidiaries, affiliates and business partners share with us or we may collect on a related entity’s or business partner’s website. This privacy policy does not apply to the practices of companies Concerto does not own or control or to people Concerto does not employ or manage.

Information Collection

Concerto provides cloud services to our customers and does not control or determine the purposes and means of processing personal data for our customers.  Our customers determine the purposes and means of processing for personal data they collect, process or store within their applications and databases.   Concerto and its customers have agreements related to their roles and responsibilities, and each customer is responsible for its customer data.

As you browse Concerto’s website(s), personal information such as your name, address, phone number or email address is not automatically collected. Concerto does, however, use "cookies" to collect information about how our website is used. Information, such as the server your computer is logged onto, your browser type (for example, Netscape or Internet Explorer) and the pages you view/request are automatically collected and tracked in aggregate. In order to provide you with e-news, contact us, event and training registration, and other online services, we may request you voluntarily supply us with personal information including your name, email address and contact information.

Privacy Shield

Concerto 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 (“EU”) or Switzerland to the United States (the “Privacy Shield”).  Concerto has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (the “Principles”).  If there is any conflict between the terms in this privacy policy and the Principles, the Principles shall govern.  To learn more about the Privacy Shield program and to view our certification, please visit https://www.privacyshield.gov/.

Concerto has committed to subject to the Principles all personal data received from the EU and Switzerland in reliance on the Privacy Shield. Notwithstanding that, many Concerto practices exceed Privacy Shield policies to help ensure our European customers’ data stays as secure and private as possible.

Information Use

Concerto may use information you have given us to fulfill requests such as provide a service, measure guest interest in certain new products and inform you about products and services. If you provided your email address to us or to one of our business partners or affiliates to make their products and services available to you, we may send you email offers. We may also send you email offers if you provided your email address to a third party and actively chose or requested, on an opt-in basis, to receive email offers from other parties. We allow opt-out on these emailed offers. Please note while we do not provide your email address to our business partners, we may send you offers on behalf of our business partners. When we send emails to you, we may be able to identify information about your email address, such as whether you can read graphic-rich HTML emails. If your email address is html-enabled, we may choose to send you graphic-rich HTML emails.

Information Sharing and Disclosure

Concerto will not sell or rent your personally identifiable information to anyone. Concerto may send personally identifiable information about you to other companies or people when:

  • We have your consent to share the information
  • We need to share your information to provide the product or service you have requested
  • We need to send the information to companies who work on behalf of Concerto to provide a product or service to you. Unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us, or to respond to subpoenas, court orders or legal process.
  • We are required to disclose personal information we handle in response to lawful requests by public authorities, including to      meet national security or law enforcement requirements.

Choices About Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising.  Concerto does not disclose personal information with unaffiliated or non-agent third parties for promotional purposes.
  • Promotional Offers from Concerto. Concerto collects your contact information only if you enter the information in a form on Concerto’s website.  When you receive any promotional email communication from Concerto, the email will include an option for you to opt-out or unsubscribe from receiving future emails. 
  • Targeted Advertising. Concerto does not perform targeted advertising.

Third party vendors may use cookies to serve ads based on prior visits to this website. No personally identifiable information is collected by these cookies. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website at http://www.networkadvertising.org/managing/opt_out.asp.

Onward Transfers

Concerto has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Concerto shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless Concerto proves it is not responsible for the event giving rise to the damage.

Inquiries and Complaints

In compliance with the Principles, Concerto commits to resolve complaints about our collection or use of your personal information.  Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Concerto at privacyshield@concertocloud.com.

Concerto  has further committed to refer unresolved Privacy Shield complaints to the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by the panel and/or Commissioner with regard to data transferred from the EU and/or Switzerland, as applicable.    If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact the panel (http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm) and/or Commissioner (https://www.edoeb.admin.ch/org/00926/index.html?lang=en), as applicable, for more information or to file a complaint.  This service is provided at no cost to you.

Concerto commits to cooperate with the panel and/or the Commissioner, as applicable, and comply with the advice given by the panel and/or the Commissioner, as applicable, with regard to data transferred from the EU and/or Switzerland, as applicable.

You may invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms.   For more information on when binding arbitration may be invoked, refer to Section C of Annex I to the Principles (https://www.privacyshield.gov/article?id=ANNEX-I-introduction).

Rights of Individuals to Access Personal Data

Individuals have a right to access their personal data. For inquiries related to an individual’s right to access their personal data, please contact Concerto at privacyshield@concertocloud.com.

Jurisdiction

Concerto’s compliance with the Privacy Shield is subject to the investigatory and enforcement powers of the Federal Trade Commission or any other then-applicable United States-authorized statutory body.

Changes to this Privacy Policy

Concerto may amend this privacy policy from time to time. If we make any substantial changes in the way we use your personal information, we will notify you by posting a prominent announcement on our website.