Cloud9 Business Analytics Limited (“Cloud9”) is committed to protecting the privacy and security of personal data. This Privacy Policy explains how we process personal data when acting as both a data processor for our customers and a data controller in relation to our own business activities.
- Role and Scope
1.1 Cloud9 as a Data Processor
When providing cloud‑based call recording, speech analytics, and related services, Cloud9 acts as a data processor on behalf of its customers. Cloud9 does not determine the purposes or means of processing customer data and does not claim ownership of any customer data processed through its solutions. All customer data remains the exclusive property of the customer and is processed strictly in accordance with customer instructions and contractual terms.
1.2 Cloud9 as a Data Controller
Cloud9 acts as a data controller in relation to personal data collected through our website, marketing and sales activities, recruitment and employment, business relationships with partners and suppliers, and communications with prospective customers and contacts.
- Information We Collect (Controller Activities)
We may collect and process personal data including, but not limited to:
- Name, job title, company name
- Contact details (email address, telephone number)
- Recruitment and employment‑related information
- Communications with our representatives
- Website usage data and interaction data
- Profiles of Individuals We Hold Data On
- Individuals responsible for, or influencing, decisions to engage Cloud9 services
- Customers, partners, and suppliers
- Website visitors
- Current, former, and prospective employees
- How We Use Your Personal Information
We process personal data only where necessary for legitimate business purposes, including:
- Providing and supporting our services
- Managing business relationships
- Responding to enquiries and requests
- Recruitment and employment administration
- Informing you about services, industry updates, events, and related materials (with opt‑out and unsubscribe options for marketing communications)
- Improving our website and user experience using aggregated analytics data (no personally identifiable attributes are shared with third parties)
- Legal Basis for Processing
Under the UK and EU GDPR, Cloud9 relies on the following lawful bases, as applicable:
- Contractual necessity
- Compliance with legal obligations
- Legitimate interests (where not overridden by your rights and freedoms)
- Consent (where explicitly obtained)
- Data Security
Cloud9 implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. Security controls are proportionate to the risks presented by the processing and are reviewed periodically.
- Data Retention
7.1 Processor Data
Retention and deletion of customer data are governed by customer configuration and contractual terms. Cloud9 does not retain customer data longer than necessary to provide the service.
7.2 Controller Data
We retain personal data while there is an ongoing relationship, where there is a legitimate business interest, and as necessary to meet legal and contractual obligations. We conduct periodic data reviews to ensure accuracy and appropriate retention.
- International Data Transfers
Where we transfer personal data outside the UK or EEA, we rely on appropriate safeguards such as adequacy regulations or Standard Contractual Clauses, together with supplementary measures where required.
- Subprocessors and Third‑Party Services
We may engage carefully selected service providers to support our operations (for example, managed hosting, ticketing, communications, and security monitoring). Where such providers process personal data on our behalf, they do so under written agreements that require equivalent data protection and security obligations. A current list of material subprocessors is available on request.
- Cookies
10.1 Cookies and Similar Technologies
Cloud9 uses cookies and similar technologies on the Cloud9ba.com website to ensure the site functions correctly, to improve user experience, and to analyse website usage. We will only set non‑essential cookies (including analytics) with your consent via our cookie banner or preferences centre. You can withdraw consent at any time.
10.2 Types of Cookies We Use
We may use the following categories of cookies:
- Strictly necessary cookies – essential for the operation of our website and cannot be switched off.
- Analytics cookies – help us understand how visitors interact with our website by collecting information in an aggregated and anonymous form. No personally identifiable information is collected through these cookies.
Cloud9 does not use cookies for behavioural advertising or profiling.
10.3 Managing Cookies
You can control and manage cookies through your browser settings and the cookie banner. Disabling or rejecting certain cookies may affect website functionality.
10.4 Third‑Party Cookies
Where third‑party services are used (for example, website analytics providers), those third parties may set cookies on your device. These cookies are governed by the privacy policies of the relevant third parties.
10.5 Changes to Our Use of Cookies
We may update our use of cookies from time to time. Any material changes will be reflected in this Privacy Policy and, where appropriate, communicated via the website.
- Microsoft Commercial Marketplace (Azure Marketplace/AppSource)
Where customers acquire Cloud9 services through the Microsoft commercial marketplace, Microsoft acts as the transacting platform and reseller for billing purposes. Cloud9 remains the data processor for customer data processed by our services, acting on the customer’s documented instructions. We provide a public privacy policy and support contact for our listing as required by Microsoft’s Marketplace certification policies. For marketplace transactions we may receive limited customer contact and subscription metadata from Microsoft to provision and support your subscription. This metadata is used only to operate your subscription and provide support.
- Your Rights
Where Cloud9 acts as a data controller, you have the following rights subject to limitations and applicable law:
- Right of access
- Right to rectification
- Right to erasure
- Right to object to or restrict processing
To exercise these rights, please contact us using the details in the Contact section. Where we process data on behalf of a customer, we will direct you to the relevant customer (the data controller).
- Children’s Privacy
Our services are intended for business users. We do not knowingly collect personal data from children.
- Changes to This Privacy Policy
This Privacy Policy may be updated from time to time. The latest version will always be available on the Cloud9ba.com website. Where appropriate, material changes will be communicated directly.
- Contact
For questions about this Privacy Policy or to exercise your data protection rights, contact:
Email: compliance@cloud9ba.com
We will acknowledge and respond to rights requests without undue delay and within one month where required by law. You may also lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO).