KlipC PRIVACY STATEMENT

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.

PUBLIC WEBSITE INFORMATION COLLECTION

Information Collected

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 non-sensitive data.

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 this Statement.

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 requirements.

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 involved.

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.

Portal INFORMATION COLLECTION

Information Collected

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.

COOKIES

Regarding our use of Cookies, please refer to our privacy cookie policy.

GENERAL PROVISIONS APPLICABLE TO ALL CUSTOMERS AND VISITORS

We process your Personal Data on the following legal bases:

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 obligations.

Retention and Storage of Information Collected

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 Data

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

Sensitive Information

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.

Security

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.

Verification

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.

Contacting KlipC

Questions regarding this Statement or the practices of the Portal or Public Website should be directed to KlipC’s legal team at legal@KlipC.com

Disputes/Arbitration

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.