KlipC Network and its affiliates (“KlipC”) are
committed to protecting the privacy of visitors to KlipC’s public web site at
www.KlipC.com (“Public Website”) and its facilities and Portal, and of customers using
KlipC’s Portal web site, whether through any of our rowsers, mobile apps or otherwise
(“Portal”), and has established this privacy statement (“Statement”) to inform you of
KlipC’s information gathering and dissemination policies and practices regarding use of
the Public Website and/or the Portal.
With respect to Personal Data collected on the
Public Website, KlipC is the controller, and may act as a joint controller with its
affiliates for the Personal Data of European Union customers and prospects as well as
our affiliates and subsidiaries. KlipC is the processor of Personal Data collected in
connection with our offering of the Portal to our customers.
As you navigate the Public Website or
our “Portal”, KlipC may collect information such as your IP Address, Web browser
information and your actions while on the Public Website when browsing. This information
will be collected, if at all, through the use of commonly-used information-gathering
tools, such as imple cookies and web beacons. Standing alone, this information does not
directly identify you personally. When expressing interest in KlipC’s products or
services, you may have the option to provide contact information such as your name
address, e-mail address, phone number, organization information. You may also have the
option of engaging in a “live chat” or other form of interactive communication, during
which KlipC may collect a record of information disclosed by you. Providing this
optional information is voluntary on your part, and in the absence of providing such
information you remain anonymous to KlipC.
Use of Information Collected
We use your information, including your
Personal Data, for the following purposes:
To provide our Public Website and or Portal and
other services to you, to communicate with you about your use of our Public Website and
services, to diagnose technical problems, to respond to your inquiries and for other
customer service purposes.
To tailor the content, data and information
that we may send or display to you, to offer location customization, preferred user
interface and personalized help/instructions, and to otherwise personalize your
experiences while using the Public Website and Portal.
For marketing, research promotional purposes.
For example, we may use your Personal Data, such as your e-mail address and other
optional information you provide, to send you news, updates and newsletters, services,
promotions, partners, events or promotions or to otherwise contact you about products or
information we think may interest you. We only process your Personal Data for such
purposes where you give us your consent when you sign up. For example, consent can be
given by opting-in to receiving direct marketing communications or opting out by
contacing us; in jurisdictions where this is sufficient, consent can be given by not
opting-out of receiving such communications.
To better understand how users and partners
access and use our Public Website or Portal, both on an aggregated and individualized
basis, in order to improve our Public Website or Portal and services and respond to user
preferences and requests, and for other research and analytical purposes.
Automated Decision Making
We may at certain times use automated
decision making to display or send recommendations and personalized offers to you
whether through email or phone, based on your Personal Data and habits, which may
include your browsing history, geographic location, employer, job title, and other
In cases where information has been
limited to a certain area through automated decision making based on your Personal Data,
we will present you with the option at any time to view more general information outside
of that area that has not been limited.
Sharing of Information Collected
KlipC will not share your personal
information, including Personal Data, with third parties, except as follows:
Affiliates. We may disclose the
data/information we collect from you to our network of affiliates or subsidiaries;
however, if we do so, their use and disclosure of your Personal Data will be subject to
Vendors, Service Providers, Contractors and
Agents. We may disclose the information we collect from you to third party vendors,
service providers, contractors or agents who perform functions beneficial on our behalf,
provided they agree to the principles in this Statement.
Business/Company Transfers. If we are
acquired by or merged with another company, if the majority of all of our assets are
transferred to another company, or as part of a bankruptcy proceeding or liquidation, we
may transfer the information we have collected from you to the other company.
In Response to Legal Process. We also may
disclose the data/information we collect from our users in order to comply with the law,
a judicial proceeding, court order, or other legal process, such as in response to a
court order or a subpoena, prosecution or to meet national security or law enforcement
To Protect Us and Other Users/State. We
also may disclose the information we collect from you where we believe it is necessary
to investigate, prevent or take action regarding illegal activities, terrorism, money
laundering, suspected fraud, situations involving potential threats to the safety of any
person, violations of this Statement, or as evidence in litigation in which KlipC is
For Aggregate and De-Identified
Information. Occasionally, we may share aggregate or de-identified information about our
users with third parties for marketing, advertising, research or similar purposes.
Third Party Links
The Public Website of KlipC may contain links
to other web sites or third party applications such as Facebook, Twitter, Wechat,QQ,
Weibo, LinkedIn or YouTube. KlipC is not responsible for the privacy practices or the
content of these other web sites or applications, and we strongly advise you to refer to
the policy statement of these third parties to understand how they collect your
information and how they use this information.
KlipC collects the following Client
Information in connection with the Portal:
Information required to use the Portal,
currently a name and email address，telephone number.
User profile information voluntarily
provided by users, for example a phone number or profile picture, as well as personal
data such as address and description.
KlipC receives financial information
from its customers which may include Personal Data/Information.
Sharing of Information
KlipC will not share Client Information
with third parties without, except as follows:
Affiliates. We may disclose the Client
Information we collect to our affiliates or subsidiaries; however, if we do so, their
use, processing and disclosure of your Personal Data will be subject to this Statement.
Company Transfers. If we are bought by
another or merged with another company, if the majority of our assets are transferred to
another company, or as part of a bankruptcy proceeding, we may transfer the Client
Information we have collected through our services to the other company.
In Response to Legal Process. We also may
disclose Client Information we collect from you in order to comply with local law,
judicial proceedings, court order, or other legal prosecution or processes, such as in
response to a court order or a subpoena or to meet law enforcement, globally.
To Protect Us , other Users. We also may
disclose the Client Information we collect where we believe it is necessary to
investigate, prevent or take action regarding illegal activities, money laundering,
terrorism, suspected fraud, situations involving potential threats to the safety of any
person or state, violations of a Master Agreement or this Statement, or as evidence in
litigation in which KlipC is involved.
Necessary to provide the Portal. We may
disclose Client Information to sub-processors necessary to provide the Portal as
disclosed and consented to you in a data processing agreement or otherwise.
FACILITY VISITOR INFORMATION COLLECTION
If you ever deem necessary to visit our offices
in one of our global locations, you may be required to register as a vistor beforehand
and to provide your name, email address, and company name. We use this information for
security reasons to ensure our working locations are safe and to manage non-disclosure
agreements that visitors may be required to sign, to the extent such processing is
necessary for our legitimate interest in protecting our offices and our confidential
information against unauthorized access.
PROVISIONS APPLICABLE TO ALL CUSTOMERS AND VISITORS
We process your Personal Data on the following legal
Performance of a contract - The use of your
personal information may be necessary to perform the agreement that you have with us
(for example, the portal);
Legitimate interests - We may use your Personal
Information/Data for our legitimate interests to improve our products and services and
the content on our website and portal(for example to manage our network, improve the
service, and better tailor the features, performance and support of the service) and
enhance the user experience.
Consent - We will rely on you as the user’s
consent to use (i) technical information such as cookie data; and (ii) your personal
information for marketing purposes when requested;
Legal obligation - to comply with our legal
Retention and Storage of Information
In accordance with the data
minimization, collection and purpose limitation principles, KlipC will store your
Personal Data as long reasonably necessary and only for as long as required to fulfill
the purposes the relevant purposes of processing your Data. If we process your Data for
various purposes, it will be erased automatically, or saved in a special format which
does not allow any direct conclusions to be drawn as to your identity as soon as the
latest specific purpose has been fulfilled.
How to Exercise your Rights on the Use of Personal
At any time if you desire to access, confirm,
correct, update or delete data you have provided to KlipC via the our website, or to
restrict our use or object to our use of any of your Personal Data and to give
directives on the fate of their Personal Data after death, please contact us by sending
an e-mail to: PrivacyRequest@KlipC.com
If you reside in the jurisdiction of the
European Union, you have the right to withdraw your proper consent of processing of our
Personal Data is based on your consent and to file a complaint with your country’s
national supervisory authority. You also have the right to data portability, at your
request, we will provide your Personal Data to you in a readable format
Please note that we sometimes may be required
(by applicable law or otherwise regulatory reasons) to keep your Personal Data and not
delete it (or to keep your information for a certain time, in which case we will comply
with your deletion request only after we have fulfilled such requirements). In certain
situations, we might be unable to provide you with information on all of your Personal
data accurately due to statutory provisions. Should we be forced to deny your request
for information in such case, we will at the same state the proper reasons for denial.
KlipC will respond to any of your request
within at most thirty (30) business days from the date of your request
KlipC offers its visitors and customers a
decision to choose how we at KlipC may use Personal Data provided. If, at any time after
providing Personal Data, you want to alter how it is about receiving information from us
or about sharing your information with third parties, send an email specifying your new
preferences to: PrivacyRequest@KlipC.com
We will not intentionally collect
,process or keep, and do not want you to provide, any Sensitive Personal Data revealing
your racial or ethnic origin, political opinions, religious or philosophical beliefs, or
trade union membership. We will not process any genetic information, biometric data,
data concerning your medical or health condition and data concerning your sexual
preferences or orientation.
Children’s Online Privacy Protection
KlipC’s Public Website nor Portal are
designed for or directed to children under the age of 13, and we will not intentionally
collect or keep information about anyone under the age of 13.
If we become aware that we have
unknowingly collected Personal Data from a child under the age of 13, or under the age
of 16 without the consent or the authorization of the holder of the parental
responsibility, we will make reasonable efforts to delete such information from our
database and records.
The Public Website and Portal have
security measures in place to help protect against the loss, misuse, and alteration of
information and data under our control. When our Public Website or Portal is accessed
using Internet Explorer 11, or recent versions of Firefox or Chrome Transport Layer
Security (TLS) is employed to encrypt all communications and to help ensure data
confidentiality. Portal uses authentication mechanisms to help ensure that information
and data is safe and secure. KlipC hosts the Public Website and Portal in a secure
environment that uses firewalls, intrusion detection, anti-malware, and other advanced
technology to prevent interference or access from intruders. To ensure an appropriate
level of security, KlipC has implemented technical and organizational measures which are
audited on a regular basis. In addition, KlipC ensures that the recipients of your
Personal Data comply with the above security standards.
KlipC utilizes the self-assessment
approach to assure its compliance with this Statement. KlipC regularly verifies that the
our statement is accurate, comprehensive, clear and prominently displayed, totally
implemented and in conformity with global laws and conducts its self-assessment on an
annual basis to ensure all relevant privacy practices are followed. Appropriate employee
training is in place and internal procedures for periodically conducting objective
reviews of compliance are in place.
Changes to this Privacy Statement
KlipC reserves the right to change this
Privacy Statement at any time deemed necessary or advisable to accommodate changes to
the law , technology or circumstances, and will use reasonable efforts to provide
notification of the material changes at least thirty (60) business days prior to the
changes taking effect.
Questions regarding this Statement or
the practices of the Portal or Public Website should be directed to KlipC’s legal team
KlipC will attempt its best with its team
and lawyers to investigate and promptly resolve any disputes or complaint regarding the
interpretation or compliance with our Privacy Agreement. You can submit a dispute to us
as set forth in the section entitled Contacting KlipC.com above.
Do Not Track Requests
Certain web browsers have incorporated
“Do Not Track” feature. This feature, when turned on, sends a preference to the websites
you visit indicating that you do not wish to be tracked. Those sites (or the third-party
content on those sites) may continue to engage in activities you might view as tracking
even though you have expressed this preference, depending on the sites’ privacy
practices. Because there is not yet a commonly-accepted standard on how to interpret the
Do Not Track requests, KlipC does not currently respond to the browser Do Not Track
requests on its websites or online services.