Accio Privacy Policy
Effective Date: January 27, 2025
1.
Introduction
Accio is an intelligent business to business (“B2B”) sourcing mentor which aims to facilitates users with product discovery and supplier negotiations.
We at Alibaba.com Global E-Commerce Pte. Ltd. (together with our affiliates, “Alibaba.com”, “we”, “our” or “us”) recognize the importance of your privacy and the confidentiality of your personal information. This Accio Privacy Policy (“Privacy Policy”) describes how we handle your personal information when you interact with and use the services of Accio (collectively, “Services”).
If you are from the United States of America (“U.S.”), specific disclosures can be found in section 11 “Additional U.S. State Disclosure”. If you are from European Union or the United Kingdom, specific disclosures can be found in section 12 “Additional European Union or the United Kingdom Disclosure”. If you are from Brazil, specific disclosures can be found in section 13 “Additional Brazil Disclosure”. If you are from South Korea, specific disclosures can be found in section 14 “Additional South Korea Disclosure”.
This Privacy Policy does not apply to the extent we process personal information in the role of a processor or service provider on behalf of other companies.
2.
Collection of Personal Information
We collect the following categories of personal information (“Personal Information”):
2.1.
PersonalInformation you provide to us directly
We collect the following Personal Information from you when you create an account to use our Services or communicate with us:
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Identity and Account Information: When you create an account with us, we collect identifiers, such as your username, contact information and account credentials (collectively, “Account Information”).
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Inputs: When you use our Services, we collect Personal Information that is included in the input, files and documents, photos and images, feedback, and other materials that you provide to our Services (“Inputs”).
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Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send. (“Communication Information”).
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Payment Information: We may collect your payment information if you choose to purchase any products and services from us (“Payment Information”).
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Other Information You Provide: We collect other information that you may provide to us, such as when you participate in our events or surveys.
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In order to facilitate your use of our Services, we may request access to, and you may provide us with, contents stored in your devices including but not limited to photos, videos and/or other files. If you are using voice recording function, we may require access to your microphone.
2.2.
PersonalInformation we receive automatically from your use of the Services
When you visit, use, or interact with the Services, we automatically receive the following information about your visit, use, or interactions (“Technical Information”):
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Device and Connection Information: We receive device and browser information which includes name of the device information, operating system, identifiers, browser information, Internet Protocol (IP) address. Information collected may vary depending on the types of devices and browsers you use and their settings.
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Log Information: When you use our Services, we collect log information from your browser or device when you use our Services. Log data includes the date and time of your request, the feature being used, and how you interact with our Services.
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Online Activity Information: We automatically collect information about your use of the Services, such as page views and searches, content views, information about your activity on a page or screen, access times and duration of access, and other details of how you have interacted.
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Cookies: We and our service providers may collect some information from you using cookies and/or similar tracking technologies (collectively, “Cookies”). These technologies enable us to recognize you, analyze the use of our Services to improve their qualities and to enhance your experience, customize and/or personalize your experience, market additional products or services to you. For more information about the types of Cookies we use, why, and how you can control them, please read Accio Cookies Policy.
2.3.
Personal Information we receive from third parties
We may receive your Personal Information from third parties if the services and/or products provided by the third parties are involved in the course of your use of our Services:
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Third-party Account Information: We may receive your account login details and other contact details in accordance with your permissions from third-party companies when you create an account with us or log into our Services using third-party accounts, or interact with social media pages. In addition, the social media companies that host our social media pages may provide us with aggregate information and analytics about our social media activity (collectively, “Third-party Account Information”).
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Verification Information: We may receive your contact details from third-party verification service providers if and when we are required to conduct due diligence, verification and/or “Know Your Customer” checks on you (“Verification Information”).
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Rating Information: In the event where you choose to participate in reviews or ratings conducted by third parties about our Services, we may receive Personal Information about you from them (“Rating Information”).
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Communication Information: We may receive your chat information from third-parties with your consent, or chat information between you and other users via instant messaging services provided by DingTalk (“Communication Information”).
Our instant messaging service is provided by our partner DingTalk (data controllers: Dingding Technology Co., Ltd. and DingTalk (China) Information Technology Co., Ltd.). DingTalk will collect your chat information, and share a copy of your chat information with us. We process this information based on legal requirements and for analytical and service-related purposes. For more details on how DingTalk processes your data, please refer to the applicable privacy policy of DingTalk.
3.
Uses of Personal Information
We use your Personal Information for the following purposes:
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To create and administer your account;
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To provide, administer, maintain and/or analyze the Services;
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To facilitate payments (if any) for products and services offered by us;
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To conduct research and improve our Services;
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To communicate with you, including to send you information about our Services and events via emails, push notifications and other messages;
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To develop new programs and services;
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To recommend features, products and services that may interest you, identify your preferences and personalize your experience;
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To deliver marketing and advertising that may interest you;
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To debug and to identify and repair errors that impair any functionality;
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To prevent and investigate any fraud, criminal activity, or misuses of our Services, and to protect the security of ourinformation technology (IT)systems, architecture and networks; and
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To comply with legal obligations and legal processes, and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
Aggregated or De-Identified Information. We may use the information collected from the provision of the Services to conduct analysis on the effectiveness of our Services, to improve our Services (for example to train the models that power Accio) and for some other similar purposes. In such event, to the extend where it involves the Personal Information, we will aggregate or de-identify the Personal Information prior to using them for the aforementioned purposes. We will not attempt to reidentify the Personal Information, unless otherwise required by laws.
4.
Disclosure or Sharing of Personal Information
We may disclose (or provide access to) your Personal Information to the following categories of recipients without further notice to you, unless otherwise required by applicable laws:
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Service Providers and Business Partners: We may disclose (or provide access to) your Personal Information to certain service providers engaged by us to provide basic processing services such as software, tools and systems, and to other business partners whom we work with, for purposes described in this Privacy Policy. Some of these service providers or business partners include due diligence and verification service providers, risk control service providers, IT service providers, cloud computing service providers, instant messaging service providers and/or social media platforms.
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External Professional Advisers, Law Enforcement Agencies, Government and Regulators: To the extent where we have a good faith belief that disclosure of your Personal Information is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or to protect your vital interests or those of others, we may share your Personal Information with external professional advisers (such as law firms), law enforcement agencies, government and regulators, and other relevant organizations.
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Actual or Potential Business Acquirers (and its agent and advisers): We may disclose your Personal Information in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we will inform the acquirer (or potential acquirer) that it must use your Personal Information only for the purposes disclosed in this Privacy Policy.
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Affiliates: We may disclose Personal Information to our affiliates and related entities in a manner consistent with this Privacy Policy. An affiliate means an entity that controls, is controlled by, or is under common control with Alibaba.com.
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Other Users and Third Parties You Share Information With: You may consent to share or display information generated using the Services with other users or other third parties. In such case, you are doing so at your own choice, and you are advised to exercise due care and diligence.
5.
Security and Retention
We implement commercially reasonable technical, administrative, and organizational measures to protect our systems and your Personal Information from unauthorized access, alteration, disclosure, or destruction. However, no data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. Therefore, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.
For registered users of Accio, some of your information can be viewed and edited through your account, which is protected by a password. It is your responsibility to keep your password secure and confidential. You must not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not save your log-in information (such as username and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.
We retain your Personal Information as long as we have an ongoing legitimate business need to do so. Examples of legitimate needs are to provide services to you, to resolve any disputes, safety and security reasons, or to comply with requirements pursuant to applicable laws (such as tax and accounting laws). When we have no ongoing legitimate business needs to process your Personal Information, we will either delete or anonymize it.
6.
International Transfer of Personal Information
We will process and store your Personal Information in the United States ,Germany, Mainland China, and/or Singapore. For the proper operation of the Services, we may transfer your Personal Information to our affiliates, service providers and business partners who are based in other jurisdictions. Those jurisdictions may be subject to data protection laws that may have different provisions to those of your jurisdiction. We ensure that, unless otherwise permitted by applicable laws, any such international transfers will only be conducted to achieve legitimate purposes and with legal basis. We will put in place a legally valid transfer mechanism and implement appropriate technical and organizational measures to ensure your Personal Information will remain protected in accordance with this Privacy Policy. A copy of those clauses can be requested from dataprotection@accio.com.
7.
Minors
Our Services are intended for adults. Our Services are not directed to, and we do not intend to, or knowingly, collect, or solicit Personal Information from, anyone under the age of 18 (“Minors”). If a Minor has provided us with Personal Information without parental or guardian consent, the parent or guardian should contact dataprotection@accio.com to remove the information.
8.
Your Rights
Depending on location, you may have certain statutory rights in relation to your Personal Information in accordance with the applicable laws and subject to any exceptions provided thereunder. For example, you may have the right to:
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Access your Personal Information and information about how it is processed. In certain cases, you may request portability of your Personal Information.
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Correct and update any inaccurate Personal Information we retain about you. Please note that we cannot guarantee the factual accuracy of the outputs from our Services. If the outputs contain factually inaccurate Personal Information about you, you can submit a correction request and we will make a reasonable effort to correct this information. However, due to the technical complexity of large language models, it may not always be possible for us to do so.
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Delete your Personal Information.
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Object to processing of your Personal Information when it is based on our legitimate interests, and separately the right to object to direct marketing.
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Request us, in some situations, to restrict processing of your Personal Information.
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Opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, or by contacting us.
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If we have collected and process your Personal Information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
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Lodge a complaint with your local data protection authority.
You can exercise these rights at any time by contacting us, or if you live in a jurisdiction that provides for a right to appeal a denial of your request to exercise such rights, you may submit your appeal, using the contact details provided under section 16 “How to Contact Us” below.
9.
Links to Other Websites
The Service may contain links to other websites not operated or controlled by Alibaba.com, including third party e-commerce sites (“Third Party Sites”). The information that you share with Third Party Sites will be governed by policies and rules of the Third Party Sites but not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
10.
Legal Basis for Processing
We will only use your Personal Information in accordance with applicable laws. We rely on the following grounds where available under and in accordance with data protection laws:
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Contract Performance: We process Account Information, Inputs, Payment Information and/or Technical Information to perform our contract with you and to provide our Services to you. If you do not provide us with this information, we may not be able to perform the contract and to provide our Services to you.
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Legitimate Interests: We rely on legitimate interests for the following purposes provided always that your interests and rights do not override our interests: (a) providing, maintaining and improving our products and services; (b) research and development; (c) promoting our products and services; (d) detecting, preventing and enforcing violations of our terms including misuse of services, fraud, abuse and other trust and safety protocols; (e) protecting our rights and the rights of others. This may include the processing of Account Information, Inputs, Third-party Account Information, Verification Information, Rating Information and Technical Information.
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Your Consent: We ask for your consent to process Personal Information for a specific purpose that we communicate with you. You have the right to withdraw your consent at any time.
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Legal Obligations: We use your Personal Information to comply with our legal obligations under applicable laws.
11.
Additional U.S. State Disclosure
This section supplements the description of our Personal Information processing activities elsewhere in the Privacy Policy and provides additional details for U.S. residents including rights that such residents may have with respect to their Personal Information.
11.1.
Notice at Collection
At or before the time of collection, you have a right to receive notice of our practices, including the categories of Personal Information to be collected and the purposes for which such information is collected or used (see section 2 “Collection of Personal Information” and section 3 “Uses of Personal Information” above), whether such information is sold or shared (see the following paragraph 11.2), and how long such information is retained (see section 5 “Security and Retention” above). You can find those details in this Privacy Policy by reviewing the related sections.
11.2.
Disclosure of Personal Information
We disclose or make available Personal Information to third parties in the ways described above in section 4 “Disclosure and Sharing of Personal Information” above. When using third-party Cookies for analytics and advertising purposes, we may be regarded as disclosing your Personal Information to our service providers. This may be considered as a “sale” or “share” of Personal Information under certain applicable laws given how broadly those terms are defined pursuant thereto. Please see the following paragraph 11.3 for more details and information on how to opt-out from the sale or share of your Personal Information.
11.3.
Your Additional Rights
In addition to the rights as set forth in section 8 “Your Rights” above, as a U.S. resident, you can exercise the following data protection rights subject to the applicable local laws and applicable exceptions by using the contact details provided under section 16 “How to Contact Us” below:
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Right to request a copy of the specific pieces of Personal Information that we have collected about you;
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Right to request additional information about our collection, use, disclosure of your Personal Information;
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Right to request that we correct inaccurate Personal Information;
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Right to delete your Personal Information;
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Right to limit our use of sensitive personal information (if any) for any purposes other than to provide the Services, unless otherwise permitted by the applicable laws;
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Right not to be subject to discrimination relating to the exercise of any of your data protection rights; and
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Right to opt-out from future “sales” or “sharing” of your Personal Information. We do not disclose or make available your Personal Information in ways that are considered as a “sale” or “share” for cross-contextual behavioral advertising (as those terms are defined under applicable state laws).
Do Not Track (“DNT”). Some browsers include a DNT setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC, there is not a common understanding of how to interpret the DNT signal. Therefore, we do not respond to browser DNT signals.
Authorized Agent. You may also designate, in writing or through a power of attorney, an authorized agent to exercise your data protection rights on your behalf. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Verification. To provide, correct, or delete specific pieces of personal information, we will need to verify your identity to the degree of certainty required by law. We may verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.
12.
Additional European Union or United Kingdom Disclosure
If you are from European Union or the United Kingdom, below you will find an overview of what kind of Personal Information we process about you, for which purposes, on which legal basis we collect this Personal Information.
If you need us to provide you with our Services or fulfil a contract with you, or because we are required to do so by law, but do not provide us with your Personal Information, we may be unable to provide our Services or fulfil our contractual obligations to you.
Purpose | Categories | Legal basis (where applicable) |
Account administration. To create and administer your account. | Account Information Third-party Account Information | Contract Performance Legitimate Interests |
Purchase and delivery of our Services. To provide, administer, maintain and/or analyze the Services; to enforce our Terms of Use and similar terms and agreement; and to facilitate payments (if any) for products and services offered by us. | Account Information Third-party Account Information Inputs Communication Information Payment Information Technical Information | Contract Performance |
Communicate with you. To communicate with you, including to send you information about our Services and events via emails, push notifications and other messages. | Account Information Third-party Account Information Communication Information | Contract Performance |
Recommendations and personalization. To recommend features, products and services that may interest you, identify your preferences and personalize your experience. | Account Information Third-party Account Information Inputs Communication Information Technical Information | Your Consent Legitimate Interests |
Marketing and advertising. To deliver marketing and advertising that may interest you. | Account Information Third-party Account Information Inputs Communication Information Technical Information | Your Consent |
Research and development. To conduct research and improve our Services; to develop new programs and services; to debug and to identify and repair errors that impair any functionality; and to protect the security of our information technology (IT) systems, architecture and networks. | Account Information Third-party Account Information Inputs Communication Information Technical Information | Legitimate Interests |
Fraud prevention and credit risks. To prevent and investigate any fraud, criminal activity, or misuses of our Services. | Account Information Third-party Account Information Communication Information Payment Information Verification Information Technical Information | Legitimate Interests |
Comply with legal obligations. To comply with legal obligations and legal processes, and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties. | Account Information Third-party Account Information Inputs Communication Information Payment Information Verification Information Technical Information | Legal Obligations |
13.
Additional Brazil Disclosure
This section applies if you are based in Brazil.
13.1.
Additional Legal Basis for Data Processing
If you are from Brazil, our legitimacy for the processing of Personal Information may include the following bases:
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necessary for the regular exercise of rights on legal, administrative or arbitral action; and/or
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necessary for credit protection.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under section 16 “How to Contact Us” below.
13.2.
Your Additional Rights
If you are a registered user from Brazil, in addition to the aforementioned privacy rights under section 8 “Your Rights”, you can exercise the following data protection rights under the Brazilian General Data Protection Law:
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The right to request a review of decisions based solely on automated processing, which may affect your interests, under certain circumstances.
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The right to request information about with whom your Personal Information has been shared.
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The right to request anonymisation of Personal Information, under certain circumstances.
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The right to receive clear and complete information about the possibility and consequences of not providing consent when applicable for the processing of Personal Information.
14.
Additional South Korea Disclosure
This section applies if you are based in South Korea.
14.1.
Delegation of Processing of Personal Information
In order to offer you with better services and user experience, we may work with certain local and foreign third-party service providers which possess the relevant skills and knowledge. A list of the relevant third-party service providers is set out below (each a “Delegatee” and collectively, “Delegatees”). The Delegatees may require your Personal Information in the course of providing their services, and therefore, subject to your consent, we will transfer your personal information to the Delegatees for their processing.
We implement certain technical and organizational measures to ensure your Personal Information are securely processed in this context. Amongst others, we enter into Personal Information delegation agreement with each Delegatee to ensure that it will amongst others: (a) comply with all relevant laws and regulations; (b) strictly limit the use of your Personal Information to the purposes for which you have consented; (c) take appropriate measures to ensure secure processing of your Personal Information; and (d) destroy your Personal Information when the purposes have been achieved or the retention and use period has expired (whichever comes first).
You may object to delegation of processing of your Personal Information or withdraw your consent by contacting us with the contact information provided under the Section 16. “How to Contact Us”. Please however note that, in the event where you exercised the aforementioned right, the scope of services we can provide to you may be limited and it may negatively affect your use of our Services.
Cross-border Delegation of Processing of Personal Information to Overseas Third Parties
Delegatees | Country/Region to which Personal Information is Transferred | Timing and Method of Transfer | Personal Information to be Transferred | Purpose of Use | Retention and Use Period |
Alibaba Cloud | Singapore U.S. | When necessary/ transmission through API | All Personal Information | Data Hosting Services | Until withdrawal of our Services |
14.2.
Provision of Personal Information to Third Parties
Cross-border Provision of Personal Information to Overseas Third Parties
We may transfer your personal information overseas (1) based on your prior consent, or (2) if processing and storage are necessary to conclude and perform the contract regarding your use of Our Services. You have the right to object to international transfer of your personal information or to withdraw your consent by contacting us with the contact information under the Section 16. “How to Contact Us”. Please however note that, in the event where you exercised the aforementioned right, the scope of services we can provide to you may be limited and it may negatively affect your use of Our Services.
We implement various technical and organizational measure to ensure that any transfer of your personal information complies with this Privacy Policy and the applicable laws. We also take appropriate actions to ensure that the following third parties comply with their confidentiality obligations and adopt appropriate measures for the secure processing of your personal information.
Recipients | Country/Region to which Personal Information is Transferred | Timing and Method of Transfer | Personal Information to be Transferred | Purpose of Use | Retention and Use Period |
Dingding Technology Co., Ltd., DingTalk (China) Information Technology Co., Ltd | Mainland China | When necessary/ transmission through API | Account Information Contact Information Technical Information | Instant messaging services | Until withdrawal of membership or the end of the service |
14.3.
Additional Use or Provision of Personal Information
We use and provide Personal Information solely within the scope with your consent. Pursuant to Articles 15(3) and 17(4) of the Personal Information Protection Act (“PIPA”), we may use or provide Personal Information within a scope reasonably related to the initial purpose of the collection without your consent, taking into the following considerations:
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Whether the additional use/provision is related to the initial purpose of the collection;
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Whether the additional use/provision is foreseeable in light of the circumstances under which Personal Information was collected and practices regarding processing;
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Whether the additional use/provision unfairly infringe on your interests; and
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Whether the necessary security measures such as pseudonymization or encryption were taken.
In determining whether to additionally use or provide the Personal Information, we will carefully and comprehensively consider various factors, including the applicable laws and regulations such as the PIPA, the purpose of use and provision of the Personal Information, the method of use and provision of the Personal Information, items of the Personal Information to be used and provided, details of consent provided by you or matters notified to or disclosed to you, impact of use and provision of the Personal Information on you, and measures taken to protect the Personal Information.
14.4.
Minors
Our Services are intended for adults. Our Services are not directed to, and we do not intend to, or knowingly, collect, or solicit the Personal Information from, anyone under the age of 14 (“Minors”). If a Minor has provided us with the Personal Information without parental or guardian consent, the parent or guardian should contact dataprotection@accio.com to remove the relevant Personal Information.
14.5.
Additional Personal Information Protection Measures
In addition to the security measures as stated under section 5. “Security and Retention”, we implement the following specific measures to ensure the proper and secure use of your Personal Information:
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Organizational measures: Establishment and implementation of internal management plan, setting up of a dedicated data protection department, organizing regular employee trainings.
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Technical measures: Develop and maintain access controls to the Personal Information processing system, encryption of the Personal Information, and implementation of security programs (such as firewalls).
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Physical measures: Implementation of access control to data infrastructure (including but not limited to the servers, data storage rooms).
14.6.
Retention Period and Deletion
We will retain your Personal Information for as long as we have an ongoing legitimate interest to do so, to continue providing you the Services, or as required by the applicable laws. Your Personal Information may exist in the following business records, and the main applicable laws and the relevant retention periods are set forth below:
Business Records | Applicable laws | Retention Periods |
Website and app visit history | Protection of Communications Secrets Act | Three (3) months |
Books and evidentiary documents related to transactions | Framework Act on National Taxes | Five (5) years |
Documents proving expenditure of expenses from commercial income or other income | Income Tax Act | Five (5) years |
Books and tax invoices or receipts | Value-Added Tax Act | Five (5) years |
Records on electronic financial transactions | Electronic Financial Transaction Act | At most five (5) years |
In the event where: (a) it is not necessary for us to retain your Personal Information (for example, the purposes for collecting your Personal Information have been achieved); or (b) if you have requested us to delete your Personal Information and provided that there is no obligation for us to retain the Personal Information (whichever comes first), we will either delete or anonymize the Personal Information.
The procedures and methods for deleting your Personal Information are as follows:
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Deletion procedure: When you request to cancel or delete your account, we will promptly take action according to your request within ten (10) days. If there is a dispute, we will not proceed with the deletion process until the relevant process is completed or terminated. Once the purpose of collecting your Personal Information has been achieved and subject to the applicable retention periods, we will delete the Personal Information.
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Deletion method: Personal Information in electronic form is destroyed or anonymized in a way that it cannot be restored. Personal Information stored in a hard copy is to be shredded or incinerated.
14.7.
Your Additional Rights
In addition to the aforementioned privacy rights under section 8. “Your Rights”, you can exercise the following data protection rights under the PIPA:
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Right to confirm whether Personal Information is being processed and to request access to and transfer of Personal Information;
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Right to suspend the processing of Personal Information; and
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Right to appropriate redress for any damage arising out of the processing of such Personal Information through a prompt and fair procedure.
15.
Changes to Privacy Policy
We may update this Privacy Policy from time to time including in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to notify you, consistent with the significance of the changes we make and in accordance with the applicable laws. Once notified, the new Privacy Policy will be effective immediately unless otherwise stated in our notification. We will obtain your consent if and when we materially change this Privacy Policy in a way that reduces the protection of your Personal Information collected in the past.
16.
How to Contact Us
If you are a registered user of Accio, you are contracting with Alibaba.com Global E-Commerce Pte. Ltd.
If you have any requests, questions or concerns about our use of your Personal Information and this Privacy Policy, you can contact our Data Protection Officer at dataprotection@accio.com.
17.
Language
If there is any conflict between the English version and another language version of this Privacy Policy, the English version shall prevail.
