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Legal Terms & Privacy

Last Updated: March 6, 2016.

Introduction

This policy applies to the ModusLink Corporation (“we”, “ModusLink”) website accessible through ModusLink’s home page located at  www.moduslink.com and ModusLink’s blog located at www.moduslink.com/blog.

If you have questions or complaints regarding our privacy policy or practices, please contact us at info@moduslink.com.

ModusLink understands the importance of providing you with information concerning the collection and use of data collected from you during your visit to our website or blog. 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 be used 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.

EU-U.S. Privacy Shield

Moduslink (and its parent/subsidiary company(ies)) participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework.  Moduslink is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]

Moduslink is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Moduslink complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Moduslink is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Moduslink may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

ModusLink Corporation has further committed with EU data authorities (DPAS) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

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.

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.

In compliance with the Privacy Shield Principles, ModusLink Corporation commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ModusLink Corporation at:

ModusLink
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 a reasonable timeframe of the request.

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.

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.

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.

Use of Cookies and Other Technologies

Technologies such as: cookies, beacons, tags and scripts are used by ModusLink and our partners, affiliates, analytics or service providers we may hire to provide online customer support. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

As is true of most web sites, we gather certain information automatically and store it in log files.  This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do link this automatically collected data to other information we collect about you.

Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

We may partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, please contact us at info@moduslink.com or opt out of interest-based advertising click here or if located in the European Union click here. Please note you will continue to receive generic ads.

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 Personal 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 measures to help prevent unauthorized access to your Personal Information. In addition, ModusLink uses standard security protocols and mechanisms to exchange the transmission of sensitive data.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. In the event that your Personal Information 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. If you have any questions about the security of your personal information, you can contact us at info@moduslink.com.

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.

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 Personal Information by such third parties, and we cannot guarantee that they will adhere to the same privacy practices as ModusLink. 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.

Public Forums

Our Web site offers publicly accessible 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 the Access/Contact section of this policy. 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.

Social Media Features

Our Web site includes Social Media Features, such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

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 policy 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 prior to the change becoming effective. We encourage you to review this policy whenever you visit our site.

Access /Contact

Upon request Moduslink will provide you with information about whether we hold any of your personal information. 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
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 a reasonable timeframe 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.

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