ModusLink Legal Terms and Privacy
Last Updated: August 30, 2012
1. Introduction
This policy applies to the ModusLink Corporation website accessible through ModusLink Corporation’s home page located at www.moduslink.com.
ModusLink Corporation has been awarded TRUSTe's Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software or our applications. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at info@moduslink.com. If you are not satisfied with our response you can contact TRUSTe here or mail at Watchdog Complaints, TRUSTe, 55 2nd Street, 2nd Floor, San Francisco, CA, USA 94105. If you are faxing or mailing TRUSTe to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. The TRUSTe dispute resolution process shall be conducted in English.
ModusLink Corporation complies with the U.S. – E.U. Safe Harbor framework and the U.S. - Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland. ModusLink Corporation has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view ModusLink Corporation’s certification, please visit http://www.export.gov/safeharbor/.
We (ModusLink Corporation) understand the importance of providing you with information concerning the collection and use of data collected from you during your visit to our website. Our privacy policy is set forth below. This policy may be updated from time to time and we encourage you to check this page periodically for any updates.
Definitions. Some helpful definitions of terms used in this privacy policy are:
Personal Information is information that can beused to uniquely identify you personally. Examples of Personal Information include your name, mailing address, telephone number, email address and credit card number.
Anonymous Information is information that cannot be used to uniquely identify you personally. Examples of Anonymous Information include your IP address, the type of browser software you use when visiting our site, the date and time you visit our site and what pages you viewed when visiting our site collected through the use of log files used by our third party tracking-utility partners.
2. Collection and Use of Anonymous Information
You can visit our website without telling us who you are or revealing any Personal Information to us. During your visit, we may collect certain Anonymous Information. For example, we may track the number of visitors to our website by logging Internet Protocol (IP) addresses. We may keep track of what pages are visited on our website so we can monitor the performance and usage of our website. Also, we may pay attention to what visitors do and do not use on our website in order to assess the effectiveness of our website and modify our content or design appropriately. Anonymous Information may be used individually or aggregated with other Anonymous Information. We may use Anonymous Information for our own benefit and we may share Anonymous Information with other companies.
3. Collection and Use of Personal Information
We collect Personal Information about you only when you elect to provide such information to us, such as when you register to receive products or services, request additional information from us, enter a contest or promotion, or submit an email to us. The information collected might include your name, company name, e-mail address, mailing address, phone numbers, etc. Any Personal Information collected will be used solely for the purpose(s) for which it was collected (for example, to send you additional information about our products or services that you requested) unless you indicate otherwise. The Personal Information you provide to us may be shared with other companies with which we have relationships in order to complete your request or provide you with the products or services which you have requested. We may also enlist a third party to collect, store, process and manage on our behalf any Personal Information you elect provide to us. When we use other companies to perform services on our behalf, we will require that such companies protect your Personal Information consistent with this policy and not for their own promotional purposes.
In addition, from time to time, we may offer you the opportunity to receive information, products or services, such as marketing collateral or whitepapers, directly from a third party. If you elect to receive such items, we may share with such third party any of your Personal Information that was collected when you elected to receive such items.
If you have provided us with Personal Information in order to receive information, products or services directly from a third party and no longer wish to have your Personal Information used for these purposes you may contact us at info@moduslink.com.
4. Choice/Opt-out
If you no longer wish for us to collect your Personal Information or to receive communications from us, you may contact us using the instructions in the Access/Contact section below indicating your wishes or follow the unsubscribe instructions included in each promotional email.
5. Sharing of Your Personal Information
Except as disclosed in this privacy policy, ModusLink Corporation 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 Corporation or this site; (b) protect and defend the rights or property of ModusLink Corporation and our family of Web sites; or (c) act in urgent circumstances to protect the personal safety of ModusLink Corporation’ 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.
6. Use of Cookies and Other Technologies
A cookie is a small amount of data that is sent to your browser software from a web server and is typically stored by your browser on your computer's hard drive.
We may insert cookies on your computer and access those cookies. These cookies may be used to help you navigate through our website, to provide you with customized and personalized features, and to assist us in collecting Anonymous Information concerning usage of our web site.
The use of cookies by our third party service providers is covered by our privacy statement. We do not have access or control over these cookies in all cases. Our third party service providers use session ID cookies in various ways, such as to define user sessions, provide analytics data, and manage the registered users who administer the third party provider sites.
We use third party tracking-utility partners who employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We tie the information gathered by clear gifs to our customers’ personally identifiable information.
We use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
7. Advertising
We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
8. Security
ModusLink Corporation 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 Personal Information from loss, unauthorized access, disclosure, alteration or destruction. ModusLink Corporation 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, ModusLink Corporation 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 Corporation 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 Corporation or law enforcement to determine the scope of the breach and to assure or restore the integrity of the data system. ModusLink Corporation may delay notification if ModusLink Corporation or a law enforcement agency determines that the notification will impede a criminal investigation, unless and until ModusLink Corporation or the agency determines that notification will not compromise the investigation.
9. Children
ModusLink Corporation 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
If you click on a link to a third-party site, including on an advertisement, you will leave our website and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your personally identifiable information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as ModusLink Corporation. We encourage you to review the privacy statements of any other service provider from whom you request services. If you visit a third party website that is linked to our website, you should read that site’s privacy statement before providing any personally identifiable information.
11. Public Forums
Our Web site offers publiclyaccessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us via the information below. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
14. Changes to This Privacy Policy
We reserve the right to change the terms of thisprivacy 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 policy or in how ModusLink Corporation 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 prior to the change becoming effective. We encourage you to review this policy whenever you visit our site.
15. Access /Contact
If you have questions or concerns about this privacy policy, the practices of our website or would like access to your Personal Information in order to correct, update, or delete this information please contact us at:
ModusLink Corporation
1601 Trapelo Road
Suite 170
Waltham, MA 02451
Tel: 781.663.5000
Fax: 781.663.5095
Attn: Legal Department
email: info@moduslink.com
Requests for access will be responded to within 30 days of the request.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.