ModusLink Privacy Policy

ARTICLE 1 - PRIVACY STATEMENT

1. Introduction - T3 Micro, Inc., 228 Main Street, Suite 12, Venice, CA 90291 (hereinafter, the “Operator”) is committed to protect your privacy and has taken appropriate technical and organizational security measures to ensure that information which it holds about you will be secure and confidential.

2. Purposes of the collection and use of information - The information the Operator collects directly (or via its service provider acting as a data processor for the processing of orders), from you when you order a product includes your name, email address, address and payment information (including but not limited to credit card number and expiration date of the credit card). This information enables the Operator to complete and process, via its service provider, your order and/or enables the Operator to keep you updated on the status of your order. If you give your consent, the Operator may also provide your information (excluding the payment information) to T3 Micro in the form of various reports used to monitor usage of the website, viewing and traffic patterns, and other consumer behaviours, in accordance with the Cookies Policy. The legal basis used by the Operator to implement the data processing are the following: (i) consumer consent, (ii) performance of the contract, (iii) compliance with a legal obligation to which the Operator is subject, or (iv) legitimate interests pursued by the Operator (eg. consumer profiling).

3. Protection of information - The Operator strives to ensure that every online communication with you meets the Operator’s high standards of privacy and security by using a secure server with software that encrypts all of your personal and confidential information. In addition, the Operator takes strong measures to protect your data against unauthorized access.

4. Use of “cookies” - The Operator uses cookies which are small bites of information that are stored by the browser on the hard drive of a computer, to which you give your consent. The cookies which the Operator uses, allows the Operator to recognize each returning consumer and their relevant information so that the consumer does not need to input the same information more than once. The Operator does not place any personally identifying confidential information in these cookies. In addition, cookies are not used to access information entered on the secure server. This information can only be accessed when you enters your name and order reference number. For more information on the use of cookies on the website, please see the Cookies Policy.

5. Sharing of your personal information - As noted above under paragraph 2 above, the Operator only shares your information obtained through its websites with T3 Micro in the form of various reports provided that your have given your consent to this processing, and with its service provider in relation to the ordering process. The Operator itself will not trade, sell or rent your personal information (such as name, address, or phone number) to third parties without your express consent. The Operator also protects your privacy by limiting employee access to and use of your data. The Operator may provide statistics to outside companies about the websites, consumer traffic and viewing patterns, including sales and related site information. However, such information is compiled into a statistical aggregate, which does not include any personally identifying (whether directly or indirectly) information.

In certain cases and for [to be completed by the transfer purposes] purposes, the Operator may transfer your personal information [identified in paragraph 2 of this article] to third parties which are located outside of the European Economic Area, in [to be completed by the countries outside the European Economic Area in which consumer's data are transferred], which may not have an adequate level of protection as defined by the General Data Protection Regulation (2016/679).

The Operator entered into contractual measures based on the European Commission model clauses with the data recipients located outside the European Economic Area to ensure that all personal data transferred receive an adequate level of data protection within the meaning of the General Data Protection Regulation (2016/679) and that appropriate technical and organizational security measures are in place to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.

6. Changes to this privacy policy - The Operator reserves the right to change the terms of this privacy policy at any time. When changes are made, the Operator will revise the "last updated" date at the top of the policy. If there are material changes to this policy or in how the Operator will use your personal information, the Operator will notify you by prominently posting a notice of such changes sufficiently in advance to allow you to discontinue using the website or cancel your account (where relevant) if you do not agree with these changes. The Operator encourages you to review this policy whenever they visit the site.

7. Release of information for legal reasons - The Operator may release information concerning your use of the website as required by law and when the Operator believes in good faith that such release is appropriate to protect the Operator’s rights and/or comply with a judicial proceeding, court order or legal process served on the Operator or the website.

8. Your Rights - Right to withdraw consent. If you have given your consent to the Operator's processing of your personal data, you have the right to withdraw your consent at any time free of charge.

Your rights. You have a right of access to your personal data, the right to the correction of personal data, the right to request that the Operator deletes your personal data (“right to be forgotten”), the right to restrict the processing of your personal data, the right to data portability, the right to object to the processing of your personal data and the right to complain to a supervisory authority.

Right of access to your personal data. You have the right to ask the Operator to confirm whether they are processing any of your personal data. You have the right to request a copy of the personal data the Operator is processing about you. For your own privacy and security, at the Operator's discretion the Operator may require you to prove your identity before providing the requested information. The right to information covers information regarding the purposes for which the Operator processes your personal data, the categories of your personal data that the Operator processes and the recipients or categories of recipients to whom your personal data has been or is still being disclosed. Please note that the right to information is not an absolute right and that the legitimate interests of other persons may restrict the right to information.

Right to correction. You have the right to ask the Operator to correct your personal data where it is incomplete or inaccurate. [You have the option of correcting this yourself directly via your account].

Right to request that the Operator deletes your personal data (“right to be forgotten”). You have the right to request that the personal data that the Operator processes about you be deleted, except the Operator is not obliged to do so if it needs to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

Right to restrict processing. You have the right to request that the Operator restricts processing of your personal data where you believe such data to be inaccurate; the Operator' processing is unlawful; or that the Operator no longer needs to process such data for a particular purpose, unless the Operator is not able to delete the personal data due to a legal or other obligation. In this case, the personal data concerned will be marked accordingly and, if necessary, only processed for specific purposes.

Right to data portability. You have the right to data portability with regard to your personal data where this is (a) personal information which you have provided to the Operator; (b) if the Operator is processing that data on the basis of your consent or to perform a contract with you; and (c) where the processing is carried out by automated means. This right extends to the personal data you have provided to the Operator. You have the right to request to receive this data in a structured, common and electronic format and to transmit that data to another controller.

Right to object. Where the legal justification for the processing of your personal data is the Operator's legitimate interest, you have the right to object to such processing of your personal data.

You also have the right to object to the processing of personal data for direct marketing purposes at any time and free of charge. The same applies with regard to processing of personal data, including profiling, if this is in relation to direct marketing.

Complaints to supervisory authorities. Finally, you have the right to file a complaint with the local data protection authority if you believe that the Operator has not complied with applicable data protection laws.

9. Data Retention - Your personal data will be retained for a 5 year period and anytime thereafter for as long as necessary to comply with applicable data retention obligations or in order to fulfill regulatory requirements.

ARTICLE 2 - SECURITY

1. The Operator is concerned with the security of the data which is collected and has implemented appropriate technical and organizational measures to prevent unauthorized access to that information. These measures include policies, procedures and technical elements relating to data access controls. Such measures are reasonably designed to help protect your personal information from loss, unauthorized access, disclosure, alteration or destruction. The Operator may use encryption, secure socket layer, firewalls, physical lock and key, internal restrictions, password protection and other security measures to help prevent unauthorized access to your personal information. In addition, the Operator uses standard security protocols and mechanisms to exchange the transmission of data.

2. In the event that your personal data is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable laws require notification, the Operator will notify the you of the breach. Notice will be given promptly, consistent with the legitimate needs of law enforcement and any measures necessary for the Operator or law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system. The Operator may delay notification if the Operator or a law enforcement agency determines that the notification will obstruct a criminal investigation, unless and until the Operator or the law enforcement agency determines that notification will not compromise the criminal investigation.