Privacy Policy
Snapshot as of 25 August 2026, served while CloakShell is paused. Account data is retained, not deleted, while paused; see the notice on the home page for export and deletion requests.
Privacy Policy of CloakShell
Welcome to the privacy policy of CloakShell. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
Summary
Data we collect automatically
We automatically collect data from you for example when you visit CloakShell.
- Usage Data
- IP address
- page views
- browsing history
- +6
Trusted third parties help us to process it
How we use them
- Analytics
- Traffic optimization and distribution
- Handling payments
- Displaying content from external platforms
- Spam and bots protection
- Collection of privacy-related preferences
Data you give to us
We collect the data you give to us while using our service
- country
- city
- first name
- last name
- +2
Trusted third parties help us to process it
How we use them
- Analytics
- Handling payments
Owner and Data Controller
CloakShell LLC4021 West Walnut Street #1037
Rogers, AR 72756
United States
Owner contact email: legal@cloakshell.com
Type of Data we collect
Among the types of Personal Data that CloakShell collects, by itself or through third parties, there are:
- Usage Data
- IP address
- page views
- browsing history
- browser information
- device information
- country
- geography/region
- city
- Trackers
- first name
- last name
- email address
- Universally unique identifier (UUID)
- browser fingerprint
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using CloakShell.
Unless specified otherwise, all Data requested by CloakShell is mandatory and failure to provide this Data may make it impossible for CloakShell to provide its services. In cases where CloakShell specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by CloakShell or by the owners of third-party services used by CloakShell serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through CloakShell.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of CloakShell (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
- Analytics
- Traffic optimization and distribution
- Handling payments
- Managing contacts and sending messages
- Infrastructure monitoring
- Hosting and backend infrastructure
- Registration and authentication
- Displaying content from external platforms
- Spam and bots protection
- Collection of privacy-related preferences
Detailed information on the processing of Personal Data
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Plausible
Plausible is an analytics service provided by Plausible Insights OÜ.
Personal Data processed:
- browser information
- browsing history
- city
- country
- device information
- geography/region
- IP address
- page views
- Usage Data
Service provided by:
- Plausible Insights OÜ (Estonia) – Privacy Policy
Category of Personal Information collected according to the CCPA
- identifiers
- internet or other electronic network activity information
- geolocation data
Collection of privacy-related preferences
This type of service allows CloakShell to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Privacy Controls and Cookie Solution
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on CloakShell.
Personal Data processed:
- IP address
- Trackers
Service provided by:
- iubenda srl (Italy) – Privacy Policy
Category of Personal Information collected according to the CCPA
- internet or other electronic network activity information
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of CloakShell and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube Video Widget (Privacy Enhanced Mode)
YouTube is a video content visualization service provided by Google Ireland Limited that allows CloakShell to incorporate content of this kind on its pages. This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on CloakShell unless they play the video.
Personal Data processed:
- Trackers
- Universally unique identifier (UUID)
- Usage Data
Service provided by:
- Google Ireland Limited (Ireland) – Privacy Policy
Category of Personal Information collected according to the CCPA
- identifiers
- internet or other electronic network activity information
Spotify Widgets
Spotify is an audio content delivery service provided by Spotify AB that allows CloakShell to incorporate content of this kind on its pages.
Personal Data processed:
- Trackers
- Usage Data
Service provided by:
- Spotify AB (Sweden) – Privacy Policy
Category of Personal Information collected according to the CCPA
- internet or other electronic network activity information
Instagram Widget
Instagram is an image visualization service provided by Meta Platforms, Inc. that allows CloakShell to incorporate content of this kind on its pages.
Personal Data processed:
- Trackers
- Usage Data
Service provided by:
- Meta Platforms, Inc. (United States) – Privacy Policy
Category of Personal Information collected according to the CCPA
- internet or other electronic network activity information
TikTok Widget
TikTok video embed widget. CloakShell renders click-to-load TikTok embeds inside messages and forum posts. No data is sent to TikTok until the user explicitly clicks play. Once activated, the embedded iframe loads from tiktok.com and TikTok receives browser fingerprint, IP address, and play telemetry, which TikTok may use for their own purposes (advertising, recommendations) under their own privacy policy. CloakShell does not have a data processing agreement with TikTok; embedded play is treated as a user-initiated visit to TikTok.
Personal Data processed:
- Trackers
Service provided by:
- CloakShell
Category of Personal Information collected according to the CCPA
- internet or other electronic network activity information
Handling payments
Unless otherwise specified, CloakShell processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. CloakShell isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe
Stripe is a payment service provided by Stripe, Inc.
Personal Data processed:
- email address
- first name
- last name
- Trackers
- Usage Data
Service provided by:
- Stripe, Inc. (United States) – Privacy Policy
Category of Personal Information collected according to the CCPA
- identifiers
- internet or other electronic network activity information
RevenueCat
RevenueCat is a payment service provided by RevenueCat, Inc. The service allows the Owner to monitor and analyze the User and their purchase history and can be used to keep track of User behavior.
Personal Data processed:
- Trackers
- Usage Data
Service provided by:
- RevenueCat, Inc. (United States) – Privacy Policy – Opt Out
Category of Personal Information collected according to the CCPA
- internet or other electronic network activity information
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable CloakShell to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of CloakShell.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Upstash
Upstash provides managed Redis services used by CloakShell for real-time message delivery, rate limiting, and presence tracking. Rate limiting data uses irreversible one-way hashed IP addresses that auto-expire in under 60 seconds. No message content, email addresses, or personal information is permanently stored in Upstash.
Fly.io
Fly.io is the application hosting and managed database provider for CloakShell. All platform data including the PostgreSQL database is hosted on Fly.io infrastructure in the United States (ORD region). Fly.io acts as the infrastructure provider and does not independently access or process user data.
Cloudflare R2
Cloudflare R2 is an S3-compatible object-storage service. CloakShell uses R2 to store user-uploaded media (avatars, banners, message attachments, profile/community icons, video uploads). File content is stored at rest. No PII (email, date of birth, username) is included in object keys, paths, or metadata. Data location: Cloudflare's distributed. storage network.
Cloudflare Workers AI
Cloudflare Workers AI provides on-demand AI inference. CloakShell uses it to classify uploaded images (and frames extracted from uploaded videos) for NSFW content via the Llama 3.2 11B Vision model. Images are sent over HTTPS, classified, and the verdict returned. No PII, no metadata, no filenames are sent. Cloudflare maintains a documented no-retention, no-training policy on Workers AI inputs. Images flagged NSFW are rejected at the upload gate and never written to storage.
Infrastructure monitoring
This type of service allows CloakShell to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of CloakShell.
Better Stack
Better Stack provides log management, uptime monitoring, and status page services. CloakShell sends operational logs to Better Stack for infrastructure monitoring. These logs contain no personal data such as email addresses, message content, or IP addresses. Log data is stored in EU data centers with 30-day retention
Sentry
Sentry is a monitoring service provided by Functional Software, Inc. .
Personal Data processed:
- various types of Data as specified in the privacy policy of the service
Service provided by:
- Functional Software, Inc. (United States) – Privacy Policy
Category of Personal Information collected according to the CCPA
- identifiers
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Resend
Resend is a transactional email delivery service. CloakShell uses Resend to send account-related emails such as password resets, email verification, and security alerts. Only the recipient's email address is shared with Resend. No message content, usernames, or other personal data is included in these communications.
Apple Push Notification service (APNs)
Notification payloads (with @usernames and message previews) route through Apple's servers to iOS devices
Firebase Cloud Messaging (FCM)
Chrome web push notifications route through Google's FCM servers with the same notification payloads.
Registration and authentication
By registering or authenticating, Users allow CloakShell to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, CloakShell will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Have I Been Pwned
HaveIBeenPwned is used during registration and password changes to check if a password has appeared in known data breaches. Only a partial password hash prefix (k-anonymity model) is sent. The full password is never transmitted. No personal data such as email addresses or usernames is shared with this service.
Supabase
Supabase provides authentication services for CloakShell, handling user registration, login, password resets, and session management. Supabase processes the user's email address and hashed password. No other personal data is stored in or processed by Supabase's authentication layer. Supabase is hosted in the United States (Americas region).
Spam and bots protection
This type of service analyzes the traffic of CloakShell, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognized as spam or protecting it from malicious bots activities.
Cloudflare Turnstile
Cloudflare Turnstile is a spam protection service provided by Cloudflare, Inc.
Personal Data processed:
- browser fingerprint
- browser information
- IP address
- Trackers
- Usage Data
Service provided by:
- Cloudflare, Inc. (United States) – Privacy Policy
Category of Personal Information collected according to the CCPA
- internet or other electronic network activity information
Traffic optimization and distribution
This type of service allows CloakShell to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between CloakShell and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through CloakShell, i.e., communication between CloakShell and the User's browser, while also allowing analytical data from CloakShell to be collected.
Personal Data processed:
- Trackers
- various types of Data as specified in the privacy policy of the service
Service provided by:
- Cloudflare, Inc. (United States) – Privacy Policy
Category of Personal Information collected according to the CCPA
- identifiers
- internet or other electronic network activity information
Bunny CDN
Bunny CDN is a traffic optimization and distribution service provided by BunnyWay d.o.o.
Personal Data processed:
- Usage Data
Service provided by:
- BunnyWay d.o.o. (Slovenia) – Privacy Policy
Category of Personal Information collected according to the CCPA
- internet or other electronic network activity information
Further information about the processing of Personal Data
Specific legitimate interests pursued by the Owner
The Owner relies on legitimate interests under GDPR Art. 6(1)(f) for the following
specific processing activities:
1. Error monitoring via Sentry (Functional Software, Inc., United States). Personal Data
sent to Sentry is scrubbed before transmission: sendDefaultPii is disabled, Session
Replay is disabled, and explicit redaction hooks remove user identifiers and sensitive
content from breadcrumbs and event payloads. The legitimate interest is maintaining
service reliability by diagnosing application errors and security incidents. Reasoning:
EDPB Opinion 03/2013 § II.3 documents error monitoring as a recognized legitimate
interest use case.
2. Network and infrastructure security via Cloudflare. The legitimate interest is
preventing fraud, abuse, automated attacks, and unauthorized access to the service and
its Users. Reasoning: GDPR Recital 49 explicitly recognizes network and information
security as a legitimate interest.
Users may object to processing based on legitimate interests at any time by contacting
legal@cloakshell.com. See the "Rights of Users" section for the full list of GDPR
rights.
The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use CloakShell only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use CloakShell.
Cookie Policy
CloakShell uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
- right of access to Personal Data;
- right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
- right to receive their Personal Data and have it transferred to another controller (data portability);
- right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running CloakShell and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymized personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
- credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests.
In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.
In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorized by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for Users in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running CloakShell and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana. For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term Personal Information.
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information. While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
Identifiers
Personal Information collected or disclosed:
- Usage Data
- IP address
- page views
- browsing history
- browser information
- device information
- country
- geography/region
- city
- various types of Data as specified in the privacy policy of the service
- Trackers
- first name
- last name
- email address
- Universally unique identifier (UUID)
Purposes:
- Analytics
- Traffic optimization and distribution
- Handling payments
- Displaying content from external platforms
- Further information about Personal Data
- Infrastructure monitoring
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Third-parties:
Plausible Insights OÜ, Stripe, Inc., Google Ireland Limited
Service providers or contractors:
Cloudflare, Inc., Functional Software, Inc.
Internet or other electronic network activity information
Personal Information collected or disclosed:
- Usage Data
- IP address
- page views
- browsing history
- browser information
- device information
- country
- geography/region
- city
- various types of Data as specified in the privacy policy of the service
- Trackers
- first name
- last name
- email address
- Universally unique identifier (UUID)
- browser fingerprint
Purposes:
- Analytics
- Traffic optimization and distribution
- Handling payments
- Displaying content from external platforms
- Spam and bots protection
- Collection of privacy-related preferences
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Third-parties:
Plausible Insights OÜ, Stripe, Inc., BunnyWay d.o.o., Google Ireland Limited, Spotify AB, Meta Platforms, Inc., CloakShell
Service providers or contractors:
Cloudflare, Inc., RevenueCat, Inc., iubenda srl
Geolocation data
Personal Information collected or disclosed:
- Usage Data
- IP address
- page views
- browsing history
- browser information
- device information
- country
- geography/region
- city
Purposes:
- Analytics
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Third-parties:
Plausible Insights OÜ
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use CloakShell.
For example, you directly provide your Personal Information when you submit requests via any forms on CloakShell. You also provide Personal Information indirectly when you navigate CloakShell, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of CloakShell and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
- The right to question the results of the profiling;
- The right to be informed of the reason that the profiling resulted in the decision; if feasible
- The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
- The right to review personal data used in the profiling;
- If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on CloakShell.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of CloakShell or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, CloakShell may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, CloakShell and any third-party services may collect files that record interaction with CloakShell (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within CloakShell and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data) / Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through CloakShell (or third-party services employed in CloakShell), which can include: the IP addresses or domain names of the computers utilized by the Users who use CloakShell, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using CloakShell who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of CloakShell. The Data Controller, unless otherwise specified, is the Owner of CloakShell.
CloakShell (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by CloakShell as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy has been prepared based on provisions of multiple legislations.
This policy relates solely to CloakShell, if not stated otherwise within this document.
How can we help?
What you can do
Your data
- Ask us to know and access the information we hold on you
- Ask us to correct information we hold on you
- Ask us to be forgotten (delete the information we hold on you)
- Ask to port your data to another service
- Manage your privacy preferences
In case of issues
While we strive to create a positive user experience, we understand that issues may occasionally arise between us and our users.
If this is the case, please feel free to contact us.
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CloakShell
CloakShell LLC4021 West Walnut Street #1037
Rogers, AR 72756
United States
Owner contact email: legal@cloakshell.com
iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.