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Last Updated: September 11, 2007
1. Introduction
ModusLink Corporation and its affiliated companies (“ModusLink”) are committed to protecting your privacy and adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States of America. ModusLink follows the Safe Harbor Principles published by the U.S. Department of Commerce ("Principles") with respect to the collection, use, and retention of data from the EU. If there is any conflict between the policies in this statement and the Principles, the Principles will govern.
ModusLink is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, non-profit organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the Web site www.moduslink.com. Because ModusLink wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.
If you have questions or concerns regarding this statement, you should first contact ModusLink. Please see “Access/Contact” section below. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php. TRUSTe will then serve as a liaison with us to resolve your concerns.
This statement outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use that information and the choices that affected individuals have regarding our use of, and their ability to correct, that information. This statement applies to all personal information we handle, including on-line, off-line, and manually processed data. The terms of this policy applies to www.moduslink.com only.
By using this site, you understand and agree to the terms of this policy. This site is owned by ModusLink and may be accessed in the United States and abroad. For data protection purposes, ModusLink is the controller and, unless otherwise noted, is also the processor of data. Information collected may be retained indefinitely, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.
2. Collection of Your Personal Information
ModusLink collects and uses information you provide to us or that we learn from your use of this site. ModusLink does not share your personal information with third parties for their direct marketing purposes, except that (with your permission) we may share such information with our service providers and their partners. We may share your personal information where it is necessary for us to complete a transaction or do something that you have asked us to do. This will include sharing your information with the companies whose products you order through our website. You should familiarize yourself with the privacy policy of any such company. We will ask you when we need information that personally identifies you or allows us to contact you. The personal information we collect may include name, e-mail address, phone, postal address, demographic information and credit card information. This site may collect certain information about your visit, such as the name of the Internet service provider and the Internet Protocol (IP) address through which you access the Internet; the date and time you access the site; the pages that you access while at the Site and the Internet address of the Web site from which you linked directly to our site. This information is used for the operation and improvement of the site.
3. Use of Your Personal Information
The personal information collected on this site will be used to operate the site and to provide the service(s) or carry out the transaction(s) you have requested or authorized. In support of these uses, ModusLink may use the personal information to provide you with more effective customer service, to improve the site, and to make the site easier to use by eliminating the need for you to repeatedly enter the same information or by customizing the site to your particular preference or interests.
Personal information collected by ModusLink may be stored indefinitely, and may be processed in the United States or any other country in which ModusLink or its affiliates, subsidiaries or agents maintain facilities, and by using our site or services, you consent to any such transfer of information outside of your country. If you would like to exercise any of your data protection rights (including the right to have your personal information deleted), see “Access/Contact” instructions below
4. Communications from the Site
Newsletters. If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the "Choice/Opt-out" section.
Customer Service. Based upon the personally identifiable you provide us, we will send you a welcoming email to verify your ursername and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will also communicate with you by email or telephone, in accordance with your wishes. Generally, you may not opt-out of receiving these service related communications.
5. Choice/Opt-out
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at moduslink_marketing@moduslink.comor you may contact us using the instructions in the Access/Contact section below.
6. Sharing of Your Personal Information
Except as disclosed in this privacy policy, ModusLink does not share your personal information with any outside parties. We may share your personal information with service providers who perform services on our behalf. For example, we may hire other companies to handle the processing of payments, to provide data storage, to host our website, to assist in direct marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. This will include sharing your information with the companies whose products you order through our website. You should familiarize yourself with the privacy policy of any such company.
Information about our customers, including personal information, may be disclosed as part of any merger, acquisition, or sale of the company and/or its assets, as well as in the unlikely event of insolvency, bankruptcy, or receivership. We will notify you of such an occurrence as described in the "Changes to This Privacy Policy" section below.
We reserve the right to disclose personal information if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on ModusLink or this site; (b) protect and defend the rights or property of ModusLink and our family of Web sites; or (c) act in urgent circumstances to protect the personal safety of ModusLink’s employees or agents, users of our services, or members of the public. Personal information collected on this site may be stored and processed in the United States, Europe and Asia, and by using the Site, you consent to any such transfer of information outside of your country.
7. Use of Cookies and Other Technologies
ModusLink uses "cookies" to enable you to sign in to our services and to help personalize your online experience. A cookie is a small text file that is placed on your hard drive. Cookies contain information, including personal information, which can later be read by a web server in the domain that issued the cookie to you. The information that cookies collect includes the date and time of your visit, your registration information, and your navigational and purchase history.
Cookies offer you many conveniences. They allow us to identify registered users when they return to the site so that they can retrieve previous image search results, access lightboxes and clipbins and view their previous invoices. Cookies also save you time by eliminating the need to repeatedly enter the same information.
In some cases, our third-party service providers may use cookies on our sites. We have no access to or control over these cookies. This privacy statement covers the use of cookies by ModusLink only, and does not cover the use of cookies by third parties.
You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, you may not be able to sign in or use other interactive features of our sites and services that depend on cookies.
In addition to cookies, we may use other technologies, including single-pixel gifs (also known as web beacons) on our website and in promotional e-mail messages or newsletters. These tiny electronic images assist us in determining how many users have visited certain pages or opened messages or newsletters. We do not use these images to collect personal information.
8. Security
ModusLink is concerned with the security of the data we have collected and has in place reasonable 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 personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. ModusLink may use encryption, secure socket layer, firewalls, physical lock and key, internal restrictions, password protection and other security meansures to help prevent unauthorized acces to your personally identifiable information. In addition, ModusLink uses standard security protocols and mechanisms to exchange the transmission of sensitive data.
In the event that your personal data is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, ModusLink will notify you of the breach. Notice will be given promptly, consistent with the legitimate needs of law enforcement and any measures necessary for ModusLink or law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system. ModusLink may delay notification if ModusLink or a law enforcement agency determines that the notification will impede a criminal investigation, unless and until ModusLink or the agency determines that notification will not compromise the investigation.
9. Children
ModusLink recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. We do not intend to solicit or collect personal information from anyone under the age of 13. If you are under 13, you should not use or enter information on this site, including without limitation any interactive areas of the site.
10. Links
Our website may contain links to other websites that have different privacy policies and practices from those disclosed here. The inclusion of any link does not imply our endorsement of the external site company, its web site, or the products and services it promotes and sells. Please be aware that ModusLink is not responsible for the privacy practices of other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects personally identifiable information. This privacy statement applies solely to information collected by ModusLink.
11. Changes to This Privacy Policy
We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the "last updated" date at the top of the policy. If there are material changes to this statement or in how ModusLink will use your personal information, we will notify you by prominently posting a notice of such changes here. We will then notify you via a prominent notice on our home page, and/or by sending you an email. We encourage you to review this policy whenever you visit our site.
12. Access /Contact
If you have questions or concerns about this statement or would like access to your personally identifiable information in order to correct, update, or delete this information please contact us at:
ModusLink Corporation
1100 Winter Street
Suite 4600
Waltham, MA 02451
Tel: 781.663.5000
Requests for access will be responded to within 30 days of the request.
